This Privacy Policy is an integral part of the Terms of Service (Terms and Conditions) located at LINK. Definitions of terms used in this Privacy Policy are provided in the Terms of Service. The provisions of the Terms of Service shall apply accordingly.

1. CONTROLLER AND DATA PROCESSED WITHIN THE SERVICE

1.1. Devire sp. z o.o. with its registered office in Warsaw, 94 Jerozolimskie Avenue, entered in the register of entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, XII Commercial Department of the National Court Register under the number KRS 0000256332, having the tax identification number NIP 5252360806 and REGON 14041789800000 and Devire GmbH, Devire s.r.o., Neumann Executive Sp. z o.o. and Flaire Sp. z o.o. is the administrator of the personal data (hereinafter referred to as ADO) of the Users.

1.2. Contact with the ADO can be made:

1. (a) Devire sp. z o.o., based in Warsaw, Poland. You can contact us as follows:

• by mail to the address: 94 Jerozolimskie Avenue, 00-807 Warsaw
• by phone: (+48) 22 312 4098

1. (b) Devire GmbH, headquartered in Frankfurt am Main. You can contact us as follows:

• By mail to the following address: Taunusanlage 1, 60329 Frankfurt am Main
• By phone: +49 89 206 021 650

1. (c) Devire s.r.o., based in Prague. You can contact us as follows:

• by mail to: Pod vilami 747/10, Nusle, 140 00 Praha 4
• by phone: +420 777 850 015

1. (d) Neumann Executive Sp. z o.o., headquartered in Warsaw, Poland. You may contact us as follows:

• by mail to the address: 94 Jerozolimskie Avenue, 00-807 Warsaw
• by phone: (+48) 22 312 4098

1. (e) Flaire Sp. z o.o., based in Warsaw, Poland. You may contact us as follows:

• by mail to the address: 94 Jerozolimskie Avenue, 00-807 Warsaw
• by phone: (+48) 22 312 4098

1.3 The Data Protection Inspector is Beata Pucyk. Contact with Beata Pucyk can be made by e-mail at: gdpr@devire.pl or by post at the address of Devire sp. z o.o. based in Warsaw.

1.4. The scope of personal data processed is determined by the scope of data completed by Users and subsequently submitted to ADO via the appropriate data form and in the resume file. The processing of Users’ personal data may concern, in particular, e-mail address, first and last name, date of birth, address of residence, PESEL number and telephone number.

1.5. The Service may store http requests in connection with which some information may be stored in the server log files, including the IP address from which the request came, the name of the User’s station

– identification implemented by the http protocol, if possible, the date and system time of registration and arrival of the request, information about errors that occurred in the execution of http transactions. Logs can be collected as material for the proper administration of the Application. Only persons authorized to administer the information system have access to the information. Log files may be analyzed to compile statistics of traffic on the Website and errors that occur. Summary of such information does not identify the User.

1.6. ADO does not transfer personal data to countries outside the European Union

2. PURPOSE AND LEGAL BASIS OF DATA PROCESSING AND PERIOD OF PROCESSING

2.1. Users’ personal data will be processed by ADO in order to: (a) fulfillment of obligations under the law, (b) performance of Contracts, provision of services electronically, (c) recruitment activities including: assessment of candidate’s qualifications for a specific position, assessment of candidate’s abilities and skills needed for a specific position , selection of suitable person(s) for employment, and (d) for email marketing purposes.

2.2. The legal basis for the processing of personal data in the case referred to in para. 2.1. Lit. (a) is the statutory authorization for processing necessary for the performance of obligations under the law, while in the case referred to in paragraph 2.1(b) is the statutory authorization for processing necessary for the performance of a contract where the data subject is a party thereto, in the case referred to in paragraph 2.1(c) and (d) is your consent, including the processing of data provided in the form, resume and cover letter,.

2.3. Provision of personal data is voluntary.

2.4. Your personal data will be processed for the following period of time: data for which the basis of processing is a provision of law – until the fulfillment of the obligation described in the relevant legislation; data for which the basis of processing is the performance of a contract – until its execution, termination or expiration; data for which the basis of processing is consent – until the withdrawal of consent, no longer than 9 years from the date of granting consent.

2.5. Consent to the processing of personal data may be withdrawn at any time, which does not affect the legality of processing carried out before the withdrawal of consent.

3. RECIPIENTS OF PERSONAL DATA

3.1. Users’ personal data may be entrusted for processing to entities for which Devire sp. z o.o., Devire s.r.o., Neumann Executive Sp. z o.o., Flaire Sp. z o.o. or Devire GmbH provide recruitment, outsourcing, temporary work services.

3.2. Users’ personal data may be entrusted for processing to entities that enable the provision of Services and execution of Contracts. Such recipients of personal data are: the company providing hosting services, the company providing maintenance and development services of the Service, the company providing digital marketing services.

3.3. Personal data may also be made available: to relevant state authorities upon their request under relevant laws, or to other persons, based on Users’ prior consents.

3.4. Each entity to which ADO entrusts Users’ personal data for processing based on a Personal Data Processing Entrustment Agreement (hereinafter referred to as Entrustment Agreement) guarantees an adequate level of security and confidentiality of personal data processing. The processing entities shall act only in accordance with our instructions.

3.5. Sharing of personal data with unauthorized parties according to this Privacy Policy, may only take place with the prior consent of the User to whom the data refers.

4. RIGHTS OF THE PERSONAL DATA SUBJECT

4.1. The user has the right to control the processing of data concerning him/her, and in particular the right to: access to their personal data, to complete and correct their data by submitting such a request from ADO to demand temporary or permanent suspension of their processing or their deletion if they are incomplete, outdated, untrue or have been collected in violation of the law or are already unnecessary for the purpose for which they were collected, to object to the processing of their personal data – in cases provided for by law – and the right to demand their deletion when they become unnecessary for the purpose for which they were collected.

4.2. As of the effective date of RODO, i.e. May 25, 2018, Users gain the right to: to delete personal data collected about them both from the system belonging to ADO and from the databases of entities with which ADO cooperates or has cooperated, to restrict data processing, to transfer personal data collected by ADO about the User, including to receive it in a structured form, to lodge a complaint with a supervisory authority in a situation in which the User considers that his or her data is being processed unlawfully, and to file a remedy in court against the supervisory authority and against the infringer.

4.3. In the event that ADO becomes aware of a User’s use of an electronically provided service in violation of the Regulations or applicable laws (unauthorized use), ADO may process the User’s personal data to the extent necessary to determine the User’s liability.

5. INFORMATION SECURITY

5.1. ADO within the Service applies technical and organizational measures to ensure the protection of the processed personal data appropriate to the risks and categories of protected data, and in particular technically and organizationally protects the data from being made available to unauthorized persons, from being taken by an unauthorized person, from being processed in violation of the Act, and from being altered, lost, damaged or destroyed, among others SSL (Secure Socket Layer) certificates are used. The collection of collected personal data of Users is stored on a secured server and data is also protected by ADO’s internal procedures on personal data processing and information security policy. As of May 25, 2018, ADO will additionally apply all necessary technical measures specified in Articles 25,30, 32-34, 35-39 of the RODO to ensure increased protection and security of the processing of Users’ personal data.

5.2. Communication between the User’s device and the Service, is encrypted using SSL protocol.

5.3. At the same time, ADO points out that the use of the Internet and electronically provided services, especially the use of publicly accessible Wi-Fi networks, may involve specific ICT risks, such as the presence and operation of Internet worms (worms), spyware or malware, including computer viruses, as well as the possibility of being exposed to cracing or phishing (password hunting), and others. In order to acquire detailed and professional information regarding Internet security behavior, ADO recommends seeking it from entities specializing in such IT services.

6. COOKIES

6.1. In order for the Service to function properly, ADO uses cookie technology. Cookies are packages of information stored on the User’s device, through the Service, usually containing information consistent with the purpose of the file, by means of which the User uses the Service – these are usually: the address of the service, the date of posting, the expiration date, a unique number and additional information consistent with the purpose of the file.

6.2. The Website uses two types of Cookies: (a) session cookies, which are deleted permanently when the User’s browser session ends; (b) persistent cookies, which remain after the end of the browser session on the User’s device until they are deleted.

6.3. Based on Cookies, both session and permanent, it is not possible to determine the identity of the User. The Cookies mechanism does not allow the collection of any personal data.

6.4. Cookies of the Service are safe for the User’s device, in particular, they do not allow viruses or other software to enter the device.

6.5. Cookies generated directly by the Service cannot be read by other services. External Cookies (i.e. Cookies placed by entities cooperating with ADO) can be read by an external server.

6.6. Users can independently change the settings for Cookies at any time, specifying the conditions for storing them, through their browser settings or by configuring the service. Users can also independently delete the Cookies stored on his device at any time, according to the instructions of the browser manufacturer.

6.7. You may disable the storage of Cookies on your device, according to the instructions of your browser manufacturer, but this may result in the unavailability of some or all of the features of the Website.

6.8. ADO uses its own Cookies for the following purposes: authentication of the User on the Website and maintaining the User’s session; configuration of the Website and adjusting the content of the pages to the User’s preferences or behavior; analysis and study of the audience, the number of clicks and paths through the website in order to improve the appearance and organization of the content on the website, time spent on the website, number and frequency of visitors to the Website.

6.9. ADO uses external Cookies for the following purposes:

6.10. Detailed information about the handling of Cookies is available in the settings of the Internet browser used by the User.

7. CHANGE IN PRIVACY POLICY

7.1. The amendment of this Privacy Policy shall be made in accordance with the amendment of the Terms and Conditions, provided that the User must accept or refuse to accept the new provisions of the Privacy Policy and terminate the Agreement with immediate effect. If the User fails to accept the new provisions of the Privacy Policy within the specified time, the Agreement shall be terminated with immediate effect and his/her resume shall be removed from the recruitment process.