Privacy Policy_

Privacy Policy

at the Łucznik Arms Factory - Radom sp. z o.o.

About Us

Łucznik Arms Factory - Radom sp. z o.o., located in Radom, A. Grobickiego Street 23, 26-17 Radom, entered in the National Court Register kept by the Lublin - East District Court in Lublin with its registered office in Świdnik – VI Economic Department of the National Court Register under the number KRS 0000031426, NIP 9482182612, REGON 672021450, share capital of PLN 89,618,500.00, hereinafter referred to as the Company, in order to properly secure its interests, has appointed a Data Protection Officer, who can be contacted via email:

Personal data is collected and processed in accordance with the provisions of this Privacy Policy.

General provisions

We attach great importance to the privacy protection of our customers, contractors, and employees. One of its key aspects is the protection of the rights and freedoms of individuals in connection with the processing of their personal data.

We ensure that the processing of your data is in compliance with the General Data Protection Regulation 2016/679/EU (hereinafter "GDPR"), the Personal Data Protection Act, and specific regulations (including labor law or accounting law).

The Company is the data controller within the meaning of Article 4(7) of the GDPR and also uses the services of data processors, as mentioned in Article 4(8) of the GDPR – entities that process personal data on behalf of the controller (such as IT companies, security, occupational health clinics, etc.).

The Company implements appropriate technical and organizational measures to ensure a level of security appropriate to the risk of infringement of the rights or freedoms of natural persons of varying likelihood and severity. We also develop policies and procedures, as well as organize regular training to enhance the knowledge and skills of our employees in this area.

How we use your personal data

As an employer, we process the data of employees and individuals who cooperate with us on a basis other than an employment relationship. Contact details obtained from contractors (e.g., their employees) are used for concluding and efficiently implementing contracts. We also engage in marketing activities, aiming to reach a wider audience to provide them with current information about our products and services.

We disclose your data to third parties with your consent or when required by law.

On what principles and on what basis we process your data

We take due care to protect the interests of the individuals whose data we process, ensuring that such data is:

  • processed lawfully, fairly, and transparently for the data subject;
  • collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
  • adequate, relevant, and limited to what is necessary for the purposes for which they are processed;
  • accurate and, where necessary, kept up to date; we take steps to ensure that personal data that is inaccurate in light of the purposes for which it is processed is erased or rectified without delay;
  • kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed;
  • processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction.

We typically process your data based on your consent, which can be withdrawn at any time. Another situation is when the processing of your data is necessary for the performance of a contract of which you are a party or for taking pre-contractual steps at your request.

In some situations, processing is necessary to fulfill a legal obligation that applies to us as the Data Controller. Such obligations arise, for example, from labor law or accounting regulations.

Processing may also be necessary for purposes arising from our legitimate interests, such as pursuing claims from our business activities.

Your rights

We take appropriate measures to provide you with concise, transparent, understandable, and easily accessible information in a clear and plain language concerning your right to:

  • information provided when personal data is obtained;
  • information provided upon request - whether data is processed and other matters specified in Article 15 of the GDPR, including the right to a copy of the data;
  • rectification of data;
  • erasure;
  • restriction of processing;
  • data portability;
  • objection;
  • not to be subject to a decision based solely on automated processing (including profiling);
  • information about a personal data breach.

To contact us regarding the exercise of your rights, send a message to

How we will contact you

We provide information in writing or by other means, including, where appropriate, electronically. If you request, we may provide information orally, provided we confirm your identity by other means. If you submit your request electronically, to the extent possible, information will also be provided electronically, unless you indicate another preferred form of communication.

When we will fulfill your request

We strive to provide information without undue delay – generally within one month of receiving the request. If necessary, we may extend this period by an additional two months due to the complex nature of the request or the number of requests. However, in any case, within one month of receiving the request, we will inform you of the actions taken and (where applicable) the extension of the deadline, stating the reason for such delay.

Subcontractors/data processors

If we cooperate with entities that process personal data on our behalf, we only use the services of such data processors that provide sufficient guarantees to implement appropriate technical and organizational measures to meet the GDPR requirements and protect the rights of the individuals whose data is processed. We carefully examine the entities to which we entrust the processing of your data. We conclude detailed agreements with them and periodically verify compliance with the content of such agreements and legal regulations.

How we ensure the processing of your data

To meet the requirements of the law, we have developed detailed procedures covering issues such as:

  • data protection by design and by default;
  • data protection impact assessment;
  • notification of breaches;
  • keeping a record of processing activities;
  • data retention;
  • exercising the rights of the individuals whose data is processed.

We regularly check and update our documentation to demonstrate compliance with legal requirements in accordance with the accountability principle defined in the GDPR. Additionally, we strive to incorporate the best market practices into our documentation, also for the benefit of the individuals whose data is processed.

Data retention

We store personal data in a form that allows the identification of the data subject for no longer than necessary for the purposes for which such data is processed. After this period, we anonymize the data (remove features allowing the identification of a specific person) or delete it. The deletion of personal data is complete and permanent. In the retention procedure, we ensure:

  • limiting the retention period of personal data to the strict minimum;
  • determining the period for deleting personal data and criteria for determining this period or for periodic review.

The period of data processing is determined primarily based on legal regulations (e.g., the retention period for employee documentation, accounting documents), as well as the legitimate interests of the controller (e.g., marketing activities). The retention policy covers both data processed in paper and electronic form.


We ensure that each person acting on our behalf and having access to your personal data processes it only on our instructions, unless other requirements arise from Union law or the law of a Member State.

Changes to this Privacy Policy are possible

We commit to regularly review this Privacy Policy and make changes when necessary or desirable due to new legal regulations, new guidelines from authorities responsible for supervising personal data protection processes, or best practices in the field of personal data protection. We also reserve the right to change this Privacy Policy in the event of changes in the technologies used to process personal data (if such changes affect the wording of this document) and in the case of changes in the methods, purposes, or legal bases for processing personal data by us.

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