PRIVACY POLICY OF TALENT47 LIMITED LIABILITY COMPANY

Talent47 Limited Liability Company, located in Warsaw, is committed to protecting the personal data of its candidates, clients, and website users.

On our website www.talent47.com  you can find information about our activities, learn about ongoing recruitment processes, explore collaboration opportunities, and discover offers related to our services.

 I. Personal Data Controller

The personal data controller is TALENT47 Limited Liability Company,  with its registered office in Warsaw, ul. Krucza 50, 00-025 Warsaw, Tax Identification Number (NIP): 5252852030, National Business Registry Number (REGON): 38821979800000, registered in the National Court Register maintained by the District Court for the capital city of Warsaw, XII Economic Department of the National Court Register, under the KRS number 0000883670, represented by Ewa Wysocka,  President of the Management Board, (hereinafter referred to as the „Controller” or „Talent47”).

You can contact the Controller l at the above-mentioned address or by email at [email protected]

II. Data Processing 

In connection with our activities, the Controller collects and processes personal data, making every effort to ensure that the processed personal data are adequately protected. The processing of personal data is carried out in accordance with applicable regulations and with respect for the rights and freedoms of individuals who provide us with their data. The data are collected directly from the individuals to whom the data relate and may also be collected from third parties, from websites (in particular Linkedin, Goldenline) and publicly available registers, subject to applicable legal provisions. The legal basis for processing personal data is the applicable law, in particular 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, „GDPR”).

III. TYPES OF DATA WE PROCESS

FOR CANDIDATES

We collect only the data that are necessary for conducting the recruitment process, such as name, contact details, and address information (including email address). Additionally, we gather data regarding education, employment history, and other additional information voluntarily provided by the candidate, such as that contained in the CV. During our cooperation, we may receive further information about the candidate, both directly from the candidate and from a third party, such as an employer to whom we have submitted the CV and who has contacted the candidate as part of the recruitment process.

We process personal data of candidates when:

1) you enter your data on the Talent47 website via an application or contact form,

2) you apply for recruitment advertisements posted on the Talent47 website, job portals, job search engines,

3) you send your CV to Talent47

4) during direct or telephone contact with Talent47 consultants, you have given consent for further contact.

We also obtain personal data of candidates in the following cases:

1) searching for potential candidates in external sources and websites (particularly LinkedIn, Goldenline),

2) receiving recommendations from our clients or from other individuals, such as colleagues or other candidates.

FOR CLIENTS

We process personal data of clients when:

1) during direct or telephone contact with Talent47 consultants, the client expresses consent for further contact,

2) the client enters their data on the Talent47 website via an application or contact form,

3) we conclude civil law agreements with clients,

4) we obtain data from publicly available sources (e.g., LinkedIn, Goldenline, websites, others).

 IV Purposes and legal grounds for data processing

The legal basis for the processing of personal data is set out in article 6 of the GDPR, which regulates the general principles of compliance with the processing of personal data. In each case, the Controller processes the data relevant to the case and for the purpose for which they were collected, ensuring their adequate protection. The Controller processes personal data for purposes related to business activity, in particular in connection with the provision of services and recruitment.

Your data will be processed in order to:

  1. contacting you when you express your willingness to participate in recruitment conducted by Talent47 or in further recruitment, when you give separate consent to the processing of data for further recruitment for a specified period of time pursuant to art. 6 sec. 1 letter a) GDPR;
  2. assessment of the candidate’s qualifications to work in a specific position with our clients; 
  3. assessing the skills and predispositions of the candidate to work in a specific position for our clients;
  4. recruiting the right candidate/candidates to work for our clients;
  5. contacting you, but only when you want to use our services or ask us a question and you provide Talent47 with your personal data through the contact forms available on our websites pursuant to art. 6 (1) f) of the GDPR, it is the Controller’s legitimate interest, which is to answer a question or send an offer if you are interested in the services provided by Talent47;
  6. promotion and advertising of activities and own services offered by Talent47 by means of electronic communication, including a newsletter to the e-mail address provided in accordance with the provisions of art. 10 (2) of the Act of 18 July 2002 on the provision of electronic services in the case of persons who have given their consent and no longer than until the consent is withdrawn;
  7. Direct marketing of products and services offered by Talent47 – pursuant to art. 6 (1) f) GDPR;
  8. take action to conclude and properly implement the contracts concluded between us – pursuant to art. 6 (1) b) GDPR and no longer than until the claims in connection with these contracts expire;
  9. making automated decisions in relation to you in individual cases, including decisions based on profiling – only if you consent to such action, pursuant to art. 6 (1) a) GDPR and no longer than until the consent is withdrawn;
  10. determining the target groups of advertisements and other activities as a user of the Talent47 website using tools for measuring the effectiveness of online marketing activities – pursuant to art. 6 (1) f) GDPR and no longer than until the objection is raised;
  11. monitoring your activity on the www.talent47.com website and in Talent47 social media and in order to adapt the displayed content to your needs and improve the services we provide (pursuant to Article 6(1) f) of the GDPR), however not longer than to object; for this purpose, in some cases, we use profiling;
  12. fulfillment of legal obligations incumbent on the Controller pursuant to art. 6 (1) c) GDPR; 
  13.  protection against claims and pursuing possible claims pursuant to art. 6 (1) f) GDPR – the Controller’s legitimate interest;
  14.  archival and evidence purposes, for the purpose of securing information that can be used to prove facts – pursuant to art. 6 (1) f) GDPR – the Controller’s legitimate interest;
  15.  managing the Controller’s website – pursuant to art. 6 (1) f) GDPR – the Conroller’s legitimate interest;
  16. in order to create your own databases – pursuant to art. 6 (1) f) GDPR – the Controller’s legitimate interest, no longer than for the time necessary to achieve the indicated purpose or to object to data processing in a situation where the Controller is unable to prove grounds that override the rights and freedoms of the person lodging the objection;

V Sharing personal data

CANDIDATES

The Candidate’s data is transferred, with his consent, to the Client (potential Employer).

In addition to the entities listed above, candidates’ data may be made available only to bodies authorized to do so under generally applicable law, e.g. law enforcement authorities in the event of a request by the authority on an appropriate legal basis.

CLIENTS

We provide our Clients’ data to Candidates in the event of concluding contracts with the Client

related to the recruitment process for the Client. In connection with the conducted activity, the Controller provides the data of Clients and Candidates to the Controller’s bodies, employees and associates, and in some cases to third parties, in particular providers of legal and accounting services, courier and transport companies, suppliers of IT systems and equipment on the basis of relevant agreements entrusting the processing of personal data and ensured by the above entities with appropriate technical and organizational measures to ensure data protection. mandatory provisions of law.

VI Requirement to provide data

Providing data is voluntary, however, if the processing is necessary to perform the contract or take action at the request of the data subject before concluding the contract or is related to participation in recruitment or future recruitment, providing data is a condition for concluding the contract or participation in recruitment process or future recruitments. If you do not provide personal data, the contract may not be concluded and the recruitment process is not possible. Providing personal data for marketing purposes is voluntary. 

Expressing consent to making automated decisions in relation to you in individual cases, including decisions based on profiling, is voluntary. 

Providing certain information is also a legal obligation, e.g. necessary to issue an invoice, settle remuneration.

VII. Data processing period

Your personal data will be processed for the time necessary to achieve each of the above-mentioned purposes. However, we will store the candidate’s personal data until the recruitment process for the position you are applying for is completed. If you have given separate consent to the processing of your data for the purposes of future recruitment processes, we will store your data for a period of 2 years from the date of their collection. If personal data is collected in order to conclude a contract, personal data is stored from the moment of data collection until termination of the contract or performance of the contract after its termination. In the case of collecting personal data in order to fulfill the obligations arising from legal provisions, the data will be stored for the period of performance of duties and tasks resulting from individual provisions of law. 

In the case of processing personal data for purposes arising from the legitimate interests of the Controller, including direct marketing, including profiling, the data will be processed no longer than it is necessary to achieve these purposes or until a justified objection to processing for these purposes is raised. 

In the case of collecting personal data on the basis of consent until its withdrawal.

 The period of personal data processing may be extended when processing is necessary to establish, pursue or defend against possible claims, and after this period only when required by law and to the extent required by law. 

VIII. Rights of Data Subjects

You have the following rights related to the processing of your personal data:

  1. the right to access your data and obtain confirmation from the Controller whether your personal data is being processed (Article 15 of the GDPR);
  2. the right to receive a copy of the data – obtaining a copy of the data subject to processing, the first copy being free of charge, and the the Controller may charge a reasonable fee for subsequent copies, resulting from administrative costs (Article 15(3) of the GDPR);
  3. the right to rectification – request rectification of your personal data that is incorrect or supplementation of incomplete data (Article 16 of the GDPR);
  4. the right to delete data – request removal of your personal data if the Controller no longer has a legal basis for processing them or the data is no longer necessary for the purposes of processing (Article 17 of the GDPR);
  5. the right to limit processing – request to limit the processing of personal data (Article 18 of the GDPR), when:
  • you question the correctness of personal data – for a period allowing the Controller to check the correctness of this data,
  •  the processing is unlawful and you oppose their removal, requesting the restriction of their use,
  • Talent47 no longer needs these data, but they are needed by the data subject to establish, pursue or defend claims,
  •  you have objected to the processing – until it is determined whether the legitimate grounds on the part of the Controller override the grounds for the objection;
  1. the right to transfer data – to receive in a structured, commonly used machine-readable format personal data concerning you, which you provided to Talent47, and to request that this data be sent to another controller, if the data is processed on the basis of your consent or a concluded contract, and if the data is processed in an automated manner (Article 20 of the GDPR);
  2. the right to object – to object to the processing of personal data for the legitimate purposes of the Controller for reasons related to your particular situation, including profiling. Then Talent47 assesses the existence of important legally justified grounds for processing, overriding the interests, rights and freedoms of data subjects, or grounds for establishing, pursuing or defending claims. If, according to the assessment, your interests are more important than the interests of the Controller, Talent47 will be obliged to stop processing data for these purposes (Article 21(1) of the GDPR);

If personal data is processed for the purposes of direct marketing, including profiling, on the basis of the Controller’s legitimate interest (Article 6(1)(f) of the GDPR), you have the right to object to the processing of personal data for the purposes of such marketing at any time including profiling, to the extent that the processing is related to such direct marketing and your data will not be processed for these purposes (Article 21(2) of the GDPR). 

In the case of consent to the processing of personal data – you have the right to withdraw it at any time,with the proviso that the withdrawal of consent does not affect the lawfulness of the processing that was made on the basis of consent before its withdrawal. Consent can be revoked at any time by sending an e-mail to the following address: [email protected];

In addition, you have the right to lodge a complaint with a supervisory authority. In Poland, since 25 May 2018, the supervisory authority is the President of the Office for Personal Data Protection.

IX Transfer of your personal data

Talent47 uses services (tools) offered by global providers such as Google LLC (address: 1600 Amphitheatre Parkway Mountain View, CA 94043, USA), Google Ireland Limited ( address: Gordon House Barrow St Dublin 4, Ireland), Meta Platforms Ireland Limited (address: Facebook Ireland (Hanover Reach 5-7 Hanover Quay, Dublin 2, Ireland) Meta Platforms Inc. (address; 1601 Willow Road Menlo Park, CA 94025, USA), ActiveCampaign LLC. (address: 1 North Dearborn St 5th Floor, Chicago, IL 60602, USA) based in the USA. Your personal data may therefore be made available outside the European Economic Area (EEA), in particular to the United States. The above entities warrant that they have implemented an adequate level of protection and appropriate safeguards under the GDPR. An adequate level of protection for the processing of personal data outside the EEA is guaranteed by entering into agreements on data processing based on standard contractual clauses approved by the European Union. If you have any questions about the transfer of data outside the European Economic Area, please contact Us at [email protected] 

If our client from outside the European Economic Area is looking for candidates for work and it is necessary to provide him with personal data in the recruitment process, Talent47 always contacts the candidate individually, and the transfer of personal data outside the EEA takes place in accordance with the GDPR.

X. Form of processing 

Your personal data will be profiled and also profiled automatically. Your data will be processed automatically to evaluate some of your information, in particular, to analyze your personal preferences, behaviors, and interests. In addition, when profiling, we take into account statistical data on the behavior on our websites and social media. Your personal data will be processed automatically, as will the form of its profiling, however, it will not have any legal effect or similar effect on your situation and making decisions. 

XI. The Cookies Policy. 

The cookie policy can be found at https://talent47.com/cookies. We would also like to inform you that the data contained in the cookies do not allow for the direct identification of an individual. They allow only to identify the device you use. If you do not want any cookies to be stored on your device, you can change this in the settings of your web browser. You can also delete all data stored in the form of cookies. 

XII. Contact with Talent47 regarding the processing of personal data 

In matters related to the processing of personal data, including in order to exercise your rights, please contact us at the e-mail address [email protected] or in writing to the address of the Controller’s registered office.

XIII. Final Information

Information about the processing of personal data is regularly updated to align with the business activities conducted by the Controller. This Privacy Policy is continuously reviewed and updated. Any changes to this Privacy Policy will be promptly communicated through announcements on the website www.talent47.com. On our website, there may be links or other references leading to external websites or social media services such as YouTube, Facebook, Instagram, Twitter, LinkedIn, which do not belong to Talent47. Talent47 does not interfere with or take responsibility for the manner in which personal data is processed by entities that own these platforms. Individuals who use redirection will also be subject to the privacy and cookies policies published by the controllers of external websites. You can familiarize yourself with the privacy policies of controllers other than the Controller on their respective websites. The Controller is not responsible for the processing of data, the policies regarding the processing of personal data, their security, or the transmission by other entities, particularly social media service providers such as YouTube, Facebook, Instagram, Twitter, LinkedIn, Goldenline.

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