Privacy policy and cookies notice

Purpose of this notice

This privacy policy and cookies notice sets out how we use and protect any information that you give when you use our website: polcode.com (Site) and services available on our Site.

Who are we?

This website is owned and operated by Polcode sp. z o. o., company listed in the Register of Entrepreneurs of the National Court Register maintained by the District Court of Warsaw, XII Commercial Division under the number 525949.

Polcode sp. z o. o. is the controller of the personal data collected when you access and use our Site and its resources ( “Controller”, “we” or “our”).

When we will be referring to You as a natural person using the Site we will use phrase “User” or we will refer directly to “you”.

Definitions

Personal Data – any information relating to an identified or identifiable natural person who can be identified by reference to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, including the IP of a device, location data, Internet identifier and information collected through cookies and other similar forms of technology.

GDPR – 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.

User – each natural person visiting Site or using one or several of the services or functionalities described in this notice.

Rules of using the Website

Using Site is free of charge.

The User is obliged to use Site in accordance with the law and good practice, taking into account intellectual property rights. It is prohibited to post unlawful content on Site.

Site, including its content and structure, is copyrighted and is subject to protection, thus, it is prohibited to use the content published on Site for commercial purposes.

The User is obliged not to undertake any actions that would affect the correct operation of our Site.

Your data will not be used for automated decision making.

How you can contact us?

You can contact as at the address: Polcode sp. z o. o. with its registered office in Warsaw, Al. Jerozolimskie 94, 00-807 Warsaw or via email at info@polcode.com

Purposes and legal basis of data processing

Use of our Site

We process personal data of Users of our Site and our Services, such as contact data, IP addresses and other identifiers and information collected through cookies, for the purposes set out herein.

Providing electronic services

·   for providing Users with the content of our Site - the legal basis of processing data is article 6(1)(b) GDPR.

·   for the establishment, if any, and pursuit of claims or defence against claims - the legal basis for the processing your data is article 6(1)(f) GDPR (Controller’s legitimate interests to protect its rights).

Contact Form and email correspondence

With regard to processing data that you use and submit to contact us via our contact forms or via email – we process provided data for the purpose of communication and addressing the matter to which such correspondence relates – the legal basis of processing your data is article 6(1)(f) GDPR (Controller’s legitimate interests).

The provision of personal data by the User is voluntary, although necessary to respond to the message received.

Chatbot PolBuddy

With regard to processing data that you use and submit to contact us via chatbot called PolBuddy – we process provided data for the purpose of communication and addressing the matter to which such correspondence relates as well as marketing and sales purposes. As the case may be – the legal basis of processing your data is:

·   for the establishment, if any, and pursuit of claims or defence against claims - the legal basis for the processing data is article 6(1)(f) GDPR (Controller’s legitimate interests to protect its rights).

·   with regard to processing your data for communication, marketing and sales purposes - the legal basis for the processing data is article 6(1)(a) GDPR (your consent)

You can withdraw your consent at any time by contacting us at: info@polcode.com

Your withdrawal will not affect the lawfulness of the processing of your data conducted prior to such withdrawal.

The provision of personal data by the User is voluntary, although necessary to respond to the message received.

Job applications

When applying to open vacancies via our electronic form, we will process your personal data submitted during the process. We will process your data for the recruitment process that you applied to.

If you agree to the processing of your personal data for future recruitment purposes, we will process your data also in such a case.

Collected data may include your name, last name, contact details, work experience, IP address and other data that you will submit to us along with your resume. As the case may be – the legal basis of processing your data is:

·       article 22(1)(1) of the Labour Code, in conjunction with article 6(1)(b) GDPR with regard to first name(s) and surname, date of birth, contact details, educational background, professional qualifications, history of previous employment history.

·       article 6(1)(b) GDPR - to act upon your request prior to concluding a contract (e.g. information about your expected salary and your availability to start work, information about recruitment meetings, our assessment of your suitability for a certain position).

·       article 6(1)(a) GDPR, with regard to other data than required by the Labour Law submitted by you in your application i.e. processing on the basis of your consent, e.g. your interests, soft skills, your image.

·       article 6(1)(f) GDPR, with regard to Controller’s legitimate interest to protect its rights - in this case - for the establishment, if any, and pursuit of claims or defence against claims.

You can withdraw your consent at any time by contacting us at: info@polcode.com

Your withdrawal will not affect the lawfulness of the processing of your data conducted prior to such withdrawal.

We use the external tool to collect data within open recruitment processes, for more information about the processing of your data please see the dedicated informational clause.

The provision of the personal data indicated in the Labour Code or other legislation (as required by the notice about open positions) is mandatory to take part in the recruitment process. Likewise, the provision of the data indicated above necessary to take action at your request prior to the conclusion of the contract and necessary in our legitimate interest. The provision of other data is voluntary.

Polcode’s Talent Pool

If there are no open vacancies and you are interested in jobs at Polcode you can share your contact details and your profile with us.

Collected data may include your name, last name, contact details, professional interests, individual preferences, IP address and other data that you will submit to us along with your resume – the legal basis of processing your data is article 6(1)(a) GDPR (your consent).

You can withdraw your consent at any time by contacting us at: info@polcode.com

Your withdrawal will not affect the lawfulness of the processing of your data conducted prior to such withdrawal.

We use the external tool to collect data within talent pool, for more information about the processing of your data please see the dedicated informational clause.

The provision of personal data by the User is voluntary, although necessary to take part in Controller’s talent pool.

Newsletter (Polcode’s blog)

If you choose to opt-in, we will process your contact details for the purpose of providing you with newsletters to your email address on the basis of your consent – the legal basis of processing your data is article 6(1)(a) GDPR.

You can withdraw your consent at any time by contacting us at: info@polcode.com

Your withdrawal will not affect the lawfulness of the processing of your data conducted prior to such withdrawal.

The provision of personal data by the User is voluntary, although necessary to send information about current blog entries as well as other product marketing information, at the User's request.

Information about processing personal data for people associated with our Clients (Client’s personnel)

In the event of a business cooperation between us and the entity on whose behalf you are acting (our Client) – we will process data received from such an entity such as your name, last name, phone number and email address to enable the provision of services to our Client - the legal basis for the processing your data is article 6(1)(f) GDPR (Controller’s legitimate interests).

The provision of personal data of our Client’s personnel is voluntary, although necessary to establish and perform cooperation with the Controller.

The represented entity (our Client) is a source of your personal data.

LINK application demo version

If you are interested in using a demo licence of our LINK tool and would like to sign a demo licence agreement with us we will process your contact details and data necessary to provide you with access data – the legal basis of processing your data is article 6(1)(b) GDPR - for the performance of a contract to which the data subject is party.  The provision of a demo version of LINK is a service provided electronically.

The provision of personal data by the User is voluntary, although necessary to conclude and perform demo licence agreement.

Terms and conditions of use of LINK are regulated by a separate document.

Cookies, Site traffic data and information about your computer

Cookies are small text files stored on the User's terminal device. Cookies contain basic information such as the URL of the originating website, the scheduled time of storage on the User's device, a unique number and name. Cookies have a number of different functions and are used primarily to provide the User with electronic services and to improve the quality of these services. Cookies can be distinguished by their attributes, e.g. there are required cookies (used by the website to function properly, without which the site would not work), functional cookies (used to enhance the performance of a website) analytical cookies (a type of cookies that track how Users navigate and interact with a website) and marketing cookies (used to track your online activity for marketing and advertising purposes); session cookies (they last for a session) and permanent cookies (they are stored on Users' hard drive until it expires or until the User deletes the cookie).

When you browse our Site, we use following cookies:

·       necessary cookies: These cookies are necessary for Site to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms.

·       functional cookies: We use a set of these cookies that are optional for Site to function. They are usually only set in response to information provided to Site to personalize and optimize your experience as well as remember your chat history.

·   analytical cookies: These cookies help us to understand how Users engage with our Site. We may use a set of cookies to collect information and report site usage statistics. In addition to reporting site usage statistics, data collected may also be used, together with some of the advertising cookies described, to help show more relevant ads across the web and to measure interactions with the ads we show.

·   advertising cookies: We use these cookies to make our ads more engaging and valuable to Site Users. Some common applications of cookies are to select advertising based on what’s relevant to a User; to improve reporting on ad campaign performance; and to avoid showing ads the User has already seen

Social Media

Our Site uses social plugins provided by the social networks such as LinkedIn, Facebook, Dribbble and Instagram. By setting up a company profile on a social network, the Controller receives statistical data about the profile. The use of these functions may involve the use of cookies from the social network providers. By viewing our Site, the User's browser establishes a direct connection with the servers of the social network providers. The content of the plugin is sent directly to the User's browser by the relevant provider and integrated into the Site. Thanks to this integration, the social network provider receives information that the User's browser has visited our Site. This information (together with the User's IP address) is sent directly from the User's browser to the social network providers' server and stored there. If the User is logged into one of the social networks, the provider of that social network may associate the User's visit to the Website with the User's profile on that social network. If the User does not want the social networks to associate the data collected during a visit to our Site directly with the User's profile on the social network concerned, the User must log out of the social network concerned before visiting the Site. The User must also completely prevent the loading of plug-ins on the Site by using the appropriate extensions for his browser, such as script blocking.

Each social network provider sets the rules for the use of cookies and processing personal data in its privacy policy, and we therefore have no control over the privacy policies and use of cookies of these providers. For security reasons, we recommend that each User reads the privacy and cookie policy document before using resources offered by other websites or services.

Your rights

You have the following rights:

·       the right to access your personal data and demand its rectification, erasure and restriction of processing, the rights to data portability and to object to the processing of the data.

·       the right to object to the processing of data for marketing purposes if the processing is carried out in connection with the Controller pursuing its legitimate interests, and – for reasons related to the User’s particular situation – in other cases where the legal basis for the processing is the Controller pursuing its legitimate interests (e.g. in connection with analytical and statistical purposes).

·       to the extent that the User’s data is processed on the basis of consent, such consent may be withdrawn at any time by contacting the Controller by email at info@polcode.com

·       the right to submit a complaint to the supervisory authority responsible for the protection of personal data (PUODO).

Data processing duration

Data processed for the purpose of performing services electronically, as a rule, will be processed for the duration of the provision of that service. However, data collected through contact form will be processed for the period of one year after its collection.[ak5] 

Data processed on the basis of your consent will be processed until you withdraw your consent.

We process data processed on the basis of our legitimate interest until the purpose for which they are processed is fulfilled or until you raise an effective objection against such processing.

With regard to data obtained via the newsletter service we will store such data until the User opts out of this service.

Data processed for the purpose of recruitment process will be retained for a term of the recruitment process and for the additional period of:

3 years - in the case of persons applying for employment based on an employment contract
or
period resulting from applicable laws (other than the Labor Code or justified by the interests of the Controller as long as the applicant's rights and freedoms are not violated) - in the case of applicants for employment under a civil law contract
or
if you provide us consent for further recruitment processes your personal data will be retained until you withdraw the consent.

The aforementioned periods may be extended if the processing of personal data is necessary for the purposes of a legitimate defense or for establishing and assertion of potential claims.

Transmission of data outside the EEA

Your data will be transferred outside the European Economic Area or to international organizations only if necessary and only if the European Commission determines that the third country, or a territory or specific sector within a third country, or the international organization in question ensures an adequate level of protection or if other adequate or appropriate safeguards are put in place, in particular the standard contractual clauses adopted by the European Commission.

The Controller informs you of its intention to transfer personal data to third countries or to international organizations at the stage of their collection.

Data recipients

We may share your personal data with the following categories of recipients:

• entities servicing and managing our IT systems, communication service providers.

• hosting companies.

• entities supporting the Controller's activity, recruitment system’s providers, law firms.

• state authorities or other entities authorized by law.

Security

We take precautions to protect your information. When you submit any personal data via our Site, your information is protected both online and offline.

Wherever we collect personal information, that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed padlock icon in your web browser, or looking for “https” at the beginning of the address of the web page.

While we use encryption to protect personal and sensitive information during transfer and at rest (in computer storage), we also protect your information offline. Only personnel who need the information to perform a specific job (for example, customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment.

Updates

This Privacy policy and cookies notice may change from time to time and all updates will be posted on this page.

If you feel that we are not abiding by this privacy policy and cookies notice, you should contact us immediately via email: info@polcode.com