Information on the Processing of Personal Data – TSL Services

Protecting personal data is very important to us.

Therefore, in this notice, we would like to explain what information we collect about you, who is responsible for protecting your data, with whom we share your data, and what rights you have.

TSL Services is a company that coordinates and supports processes related to the performance of transport orders by freight forwarding companies, including the helpline, contact forms, and the carrier portal available at: https://www.tslservices.pl/


1. What terms do we use in this notice?

TSL Means TSL Services sp. z o.o., with its registered office in Warsaw. The company provides services to freight forwarding companies, including customer communications, helpline services, and operation of the carrier portal.
Freight forwarding company Means the freight forwarding company handling your transport order. Information identifying this company can be found, for example, in the transport order document.

Example:
If the order about which you are contacting us is handled by Ligural sp. z o.o. (the freight forwarding company), TSL provides services to Ligural sp. z o.o., including customer communications via the helpline or email.
We Means TSL or the freight forwarding company.
You Means a customer of the freight forwarding company, a carrier, their representatives, or any other person who contacts us and whose personal data we collect.


2. Who is the controller of your personal data?

A data controller is an entity responsible for your personal data and its security.

The separate controllers of your data are:

  • The freight forwarding company to the extent that your data is used to handle and perform the transport order, including enquiries from carriers handling the order;
  • TSL to the extent that it uses your personal data to analyse or improve the quality of its services and ensure their security.

Explanation:
The freight forwarding company uses TSL’s services, including in the area of communications with customers and carriers. TSL therefore processes personal data on behalf of the freight forwarding company. TSL also acts on its own behalf and processes personal data for its own purposes, for example by using call recordings to improve the quality of the services provided by TSL.


3. How can you contact us?

If you have any questions or requests concerning your personal data, you can contact us:

  • by email at: [email protected];
  • by sending correspondence by post to: ul. Franciszka Bohomolca 21, 01-613 Warsaw, Poland.


4. What personal data do we process and from what sources?

We receive your personal data directly from you when you provide it to us, including during a telephone conversation or in a message. This data may include, in particular: your first name, surname, contact details such as your email address and telephone number, workplace, job title and, depending on the method of communication, a recording of your voice, including the content of the conversation or correspondence, as well as invoice and transport order details.

If we contact you regarding an order, we obtained your personal data during the conclusion and performance of that order, for example from your employer or directly from you.


5. Is providing personal data mandatory or voluntary?

  • Mandatory data: To handle your enquiry, you must provide the tax identification number (NIP) of the company on whose behalf you are contacting us and the transport order number. We may also require your first name, surname, and job title.

  • Voluntary data: You can decide whether you consent to us recording your helpline call. If you do not consent, please contact us by email at: [email protected].


6. For what purposes and on what legal grounds do we process your personal data?

The freight forwarding company and TSL, as separate controllers of your personal data, have different purposes and legal grounds for processing your data. These purposes and legal grounds are explained below.

Data controller Purposes and legal grounds
Freight forwarding company

A. Purpose: handling an enquiry concerning a transport order

Legal grounds:

  • performance of an order concluded directly with you (Article 6(1)(b) of the GDPR). If you represent an entity for which the freight forwarding company is performing the order or contact us regarding the order in another capacity, the legal basis for processing your personal data is the legitimate interests pursued by the freight forwarding company, consisting in properly handling your enquiry and correctly performing the order (Article 6(1)(f) of the GDPR);
  • if the communication concerns actions arising from legal provisions, for example a complaint, the legal basis for processing your personal data may be the necessity to comply with legal obligations imposed on the freight forwarding company (Article 6(1)(c) of the GDPR);
  • if you contact us via the helpline, your call is recorded on the basis of your voluntary consent to the recording (Article 6(1)(a) of the GDPR).

B. Purpose: establishing, pursuing, or defending legal claims

Legal grounds:

  • the legitimate interest of the freight forwarding company or a third party, consisting in the ability to establish, pursue, or defend claims concerning the order or the course of communication (Article 6(1)(f) of the GDPR).
TSL

A. Purpose: analysing and improving the quality of services and ensuring the security of communications

Legal grounds:

  • TSL’s legitimate interest, consisting in analysing the services provided to freight forwarding companies, improving the quality of the services provided by TSL, and ensuring the security of communications by monitoring their course (Article 6(1)(f) of the GDPR);
  • if you contact us via the helpline, your call is recorded on the basis of your voluntary consent to the recording (Article 6(1)(a) of the GDPR).

B. Purpose: establishing, pursuing, or defending legal claims

Legal grounds:

  • the legitimate interest of TSL or a third party, consisting in the ability to establish, pursue, or defend claims concerning the course of communication (Article 6(1)(f) of the GDPR).


7. To whom may we disclose your personal data?

We may disclose your personal data to:

  • entities providing various services to us, in particular providers of helpline and email communication systems, IT service providers, and providers of outsourced accounting services;
  • legal or tax advisers;
  • postal operators and courier companies;
  • entities authorised under applicable law, in particular institutions authorised to inspect the activities of the freight forwarding company or TSL;
  • the freight forwarding company may also disclose personal data to its subcontractors, for example companies within the corporate group to which it belongs, if they are involved in the performance of the relevant order.


8. How long do we retain your personal data?

We retain recordings of telephone calls for three full calendar months from the date on which the recording was made.

Information obtained during recorded telephone calls, for example in the form of written notes, as well as the contents of transport documents, email correspondence, and other enquiries, are retained for the duration of the order to which the communication relates and subsequently for the applicable limitation period for potential claims.

The periods indicated above may be extended if proceedings concerning claims related to the communication or order are ongoing, until such proceedings have been finally concluded.


9. What rights do you have?

You have the following rights concerning the protection of your personal data:

  • the right to access your data, including obtaining a copy of it;
  • the right to rectify your data, except for the voice recording itself;
  • the right to erase your data;
  • the right to restrict the processing of your data;
  • the right to data portability, which applies to data processed on the basis of your consent or data necessary for the conclusion and performance of an order;
  • the right to object to the processing of your data if we process it on the basis of our legitimate interests. We will uphold your objection if it is justified after balancing our interests and rights against yours;
  • the right to withdraw your consent to the processing of your voice recording at any time. We will then delete the recording, although we may continue to process personal data provided by you during the telephone conversation on another legal basis indicated above. Withdrawal of consent does not affect the lawfulness of processing carried out before the consent was withdrawn. You can withdraw your consent by contacting us at: [email protected];
  • the right to lodge a complaint with the President of the Personal Data Protection Office: more information is available here.

If you submit a request concerning your personal data, we may ask you to answer questions that will allow us to verify your identity.


10. Do we transfer your personal data outside the EEA?

We process your personal data within the EEA. The EEA is the European Economic Area, comprising the European Union (EU) and countries such as Iceland, Norway, and Liechtenstein.

We use service providers that operate within the EEA and do not transfer your data outside the EEA. However, due to the global nature of such services, some of our IT providers may process your personal data outside the EEA. In such cases, we safeguard transfers of data outside the EEA in accordance with personal data protection laws. We generally use the European Commission’s Standard Contractual Clauses and assess the security of such data transfers in accordance with legal requirements.

If you would like to learn more about the safeguards we use for transfers of data outside the EEA, including obtaining a copy of those safeguards, please contact us using the contact details provided in section 3 of this notice.


11. Do we use profiling or automated decision-making?

We do not make automated decisions based on your personal data or profile you.