Personal Data Protection Policy (GDPR) 

INFORMATION CLAUSE - GSA PLATFORM  

Why do we need your personal data? 

Your personal data will be processed by the Gas Transmission System Operator GAZ-SYSTEM S.A.  (hereinafter „GSA Operator”) in order to: 

a) perform the Agreement for the use of the GSA Platform and take action prior to the conclusion thereof including verification of authorisation to perform the Agreement for the use of the GSA Platform, 

b) provide capacity in the Auction procedure in accordance with the GSA Platform Terms and Conditions, 

c) enable capacity booking and performing transactions on the primary and secondary market in accordance with the GSA Platform Rules, 

d) verify the Platform User's authorisation to represent the Transmission System Operator (TSO) or System User by a Platform User, 

e) manage the rights to GSA Operator resources, 

f) ensure the security of GSA Operator resources, 

g) achieve the objectives arising from the legitimate interests of the personal data controller or a third party - i.e. a TSO/System User intending to use the services offered by means of the GSA Platform or an administrative body referred to in the GSA Operator’s regulations, 

h) communicating with GSA Platform Users in the course of pursuing our legitimate interest, including responding to questions addressed to the GSA Operator via the contact form according to the subject category. 

Whom do we share personal data with? 

The recipients of your personal data shall be: 

a) employees of the GSA Operator or persons acting on its behalf, in its interest or under powers vested in them regardless of the legal basis of their relationship with the GSA Operator, who on account of their duties hold relevant authorisation to access the system (their duties justify the need to access the system services and protected information), 

b) ICT service providers as entities processing personal data on the basis of separate data entrustment agreements (for technical purposes, related to the provision of ICT services), 

c) relevant TSO/System User, 

d) competent administrative bodies regulating the functioning of the GSA Platform for capacity booking, based on generally applicable national and EU law. 

Do we transfer the data to third countries or international organizations? 

Your personal data will not be transferred to third countries or international organisations outside the European Economic Area. 

What is the legal basis for data processing? 

The legal basis for the processing of your personal data comprises: 

a) Article 6(1)(b) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), hereinafter referred to as the ‘GDPR’, stipulating that the processing of personal data is necessary for the performance of the Agreement for the use of the GSA Platform or in order to respond to your request prior to entering into such an agreement, 

b) GDPR Article 6(1)(f) prescribing that the processing of personal data is necessary for the purposes of the legitimate interests pursued by the GSA Operator or by third parties referred to in clause Why do we need your personal data item (g) and (h) above. 

The provision of your personal data is a prerequisite for the conclusion of a contract for the supply of electronic services. The provision of personal data is voluntary, but the absence of such data will result in denied access to services supplied electronically on the GSA Platform. 

Providing personal data in the contact form is voluntary, but indispensable to receive responses to the questions submitted that way. 

How long shall we process the data? 

Personal data recorded in the GSA Platform (including those entered to the contact form) will be processed until the Platform User submits a request for cancellation of services supplied electronically on the GSA Platform, in accordance with the ‘Regulations for the provision of electronic services and the processing of personal data on the GSA Platform’ and during the retention period of 5 years following the date of Platform User’s resignation from the electronic services supplied on the GSA Platform. 

Do we make automated decisions including profiling? 

Your personal data are not used for profiling, nor for making automated decisions within the meaning of the GDPR. 

You have the right to: 

a) access your personal data, namely you are authorized to obtain information what data is processed, in what manner and for what purpose, 

b) rectify your data, i.e. demand the data be updated if the collected data prove to be incorrect or no longer up-to-date, 

c) request the erasure of your personal data, i.e. request that all or part of your personal data be deleted from the record; if the request is justified, the deletion will be performed immediately, 

d) restrict processing, i.e. to request the restriction of data processing to storage only - we will unblock the processing once the grounds for restriction have ceased to exist, 

e) transfer your personal data, 

f) object to the processing, i. e. request that we cease to process your personal data for the purpose specified above if you consider that we infringe your rights in connection with the processing of your personal data, 

g) file a complaint against the GSA Operator with the President of the Office for Personal Data Protection (Prezes Urzędu Ochrony Danych Osobowych) if you believe that the processing of your personal data violates the applicable provisions of law. 

Contact - where to exercise your rights or obtain more information? 

Your personal data controller on the GSA Platform shall be Operator Gazociągów 

Przesyłowych GAZ-SYSTEM S.A. with the registered office at ul. Mszczonowska 4, 02-337 Warsaw.  

You may exercise your rights (or obtain more information) by writing to the address: rodo@gaz-system.pl

The ‘Terms and Conditions for the Provision of Electronic Services and the Processing of Personal 

Data on the GSA Platform’ are available on the website www.gsaplatform.eu in a 

downloadable format enabling saving and printing.