Date of issue: 23/September/2019
We carefully safeguard the information we hold about our partners, clients and employees. We endeavor to comply with the General Data Protection Regulation and the local laws applicable in the countries in which we operate.
If you are visiting our website as a job seeker, please look at the section that applies to our job applicants.
Our website and services are not intended for children, and we do not collect personal data relating to children.
We collect personal data when you provide your contact details to us when applying for a job or requesting information about our products or services, either via e-mail, telephone or face-to-face.
"Personal data" is any information that relates to you and that identifies you either directly from that information or indirectly, by reference to other information that we have access to. The personal data that we collect, and how we collect it, depends upon how you interact with us.
If you are a job applicant, we process information included in your CV or cover letter, such as your contact data, employment history, academic background, history, qualifications & skills, languages spoken, if you provide such information to us. In addition, if you send us application documents containing your personal data to a wider extent than required by provisions of the applicable labor law, you consent for the data to be processed by us for the purposes of the ongoing recruitment.
Other categories of personal data that we collect through our contact data forms available on our webpage include:
We also routinely collect data relating to our website/apps: IP address, cookies and other collected data during your visit at our website (for more details, please see also our Cookies Policy.
We do not collect any special categories of personal data, as defined under the General Data Protection Regulation.
Providing your personal data is voluntary, however if you do not provide us with the necessary information, we will not be allowed to get in touch with you and consider your job application.
|Purpose||Lawful basis for processing|
|To fulfil a query, to respond to your inquiries and fulfil your requests for services and/or to administer our services.||Article 6 paragraph 1 point b or Article 6 paragraph 1 point f of the GDPR - our legitimate interest here is to identify the sender of the query and handle the query, including queries transmitted through electronic means.|
|To maintain records of prospective, current and past clients and partners.||Article 6 paragraph 1 point f of the GDPR - our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest.|
|To track your use of our websites and interaction with our services. For example, to understand which website content is most popular with our visitors.||Article 6 paragraph 1 point f of the GDPR - our legitimate interest in enhancing, facilitating and improving our website content and our services that you may use or are using – for more details please see our Cookies Policy.|
|To provide our subscribers with KCR’s online newsletter (KCR’s Insights) and commercial information (direct marketing) through electronic means.||Article 6 paragraph 1 point a of the GDPR (subscriber’s consent). Article 10 of the Polish Act on the Provision of Electronic Services and Article 172 of the Polish Telecommunications Law.|
If you are a job applicant, your personal data provided in the application documents will be processed for the following purposes:
|Purpose||Lawful basis for processing|
|To conduct the ongoing recruitment and take action before concluding an employment agreement with you (if applicable).||Article 6 paragraph 1 point a & Article 6 paragraph 1 point c of the GDPR in connection with relevant local labour laws.|
|To carry out future recruitment, if you grant us such consent.||Article 6 paragraph 1 point a of the GDPR – your consent that you can provide us with voluntarily.|
|To establish or pursue claims that may arise in connection with recruitment process, until the end of the period of limitation in the event you are not employed in the position for which you applied.||Article 6 paragraph 1 point f of the GDPR (legitimate interest of the data controller - the right to defense against the claims of a person who has not been employed).|
We take appropriate steps to ensure your personal data is stored in a secure environment to prevent any unauthorized access. We will not share your personal information with any third parties for them to use for their own marketing purposes. We may disclose your personal data if required to do so by law.
If this is compliant with applicable law, we will share your personal data with other entities, such us our clients (your prospective employers to offer you a job that you are or may be interested in), our service providers, subcontractors and companies from our company’s capital group, provided that you give us your consent or there is another legal basis to provide these data to those entities. In case of data transfer to the companies from our capital group, we may have a legitimate interest in sending personal data for internal administrative purposes.
We may process your personal information abroad, including outside the European Economic Area (EEA), provided we comply with the applicable laws and regulations. In cases where we are sharing your personal data with organizations outside the EEA, we will ensure they agree to apply equivalent levels of protection as we do, and the transfer of your personal data is compliant with applicable law.
You have a number of rights under data protection law, which have been strengthened under the General Data Protection Regulation (GDPR):
You have the right to request access to and rectification or erasure of your personal data, as well as restriction of processing, data portability, the right not to be subject to a decision based solely on automated processing, including profiling, and the right to object to your personal data processing.
You have the right to object the personal data processing where the processing is carried out based on legitimate interests and/or for statistical purposes and your objection is justified by your particular situation.
You have the right to withdraw your consent to personal data processing at any time to the extent to which your consent applies. Withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.
If you are unhappy with the way in which we have handled your personal data, you have the right to file a complaint with the supervisory body dealing with the protection of personal data in particular in the EU Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal data infringes provisions of the General Data Protection Regulation.
We encourage you to contact us first, as we aim to promptly, efficiently and satisfactorily resolve any concerns or complaints you may have in relation to the processing of your personal data.
To fulfill your request, we will require you to provide satisfactory proof of your identity to ensure that your rights are respected and protected. This is to ensure that your personal data is disclosed only to you.
We will only retain personal data for as long as is necessary for the purposes we are using it for – the retention period will vary depending on the purposes it is used for.
For the recruitment process purposes, we may process your personal data in the scope covered by the labor law until the recruitment process is completed, and the data provided by you voluntarily in a wider scope than required by the law, until your consent to the processing of personal data is revoked.
Upon completion of the recruitment process, we may process your personal data to defend against potential claims that may occur in connection with recruitment until the end of the period of limitation of these claims.
If you give us consent to use your personal data for the purpose of future recruitment, your data will be used for up to 3 years.