Privacy Policy
Privacy Policy as of November 17th, 2022
I. INTRODUCTION
We take particular care to safeguard your privacy so that your personal data is processed in accordance with applicable legislation and is protected against loss, destruction, disclosure, unauthorized access, or improper use.
In view of the above, we have prepared a document called Privacy Policy, which fulfills the obligation referred to in Article 13 and Article 14 of 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), hereinafter: 'GDPR'.
The Privacy Policy outlines how we look after your personal data and what your rights are.
The Privacy policy has been drawn up in two language versions: Polish and English. In the event of any discrepancies between the language versions, the Polish language version is binding.
II. DEFINITIONS
Below you will find explanations of the basic terms used in this Privacy Policy:
- Controller / ExecMind / we, our - ExecMind Karolina Jarosińska headquartered in Kraków, ul. Michała Bobrzyńskiego 14, 30-348 Kraków, VAT: PL8411466945, REGON: 147201167
- Personal data - any information that relates to an identified or identifiable person. For example: name, email address, education, and employment history, professional qualifications, resume, image, voice recording,
location data, information contained in correspondence, information collected through recording equipment or other similar technology. - Portal - the website available on the domain https://biotechvibes.com.
- Employer - means a natural person, a legal person or an organisational unit not being a legal person conducting business activity, who wishes to employ an employee, creates an account, and submits a job advertisement on the Platform, as well as an entity acting on behalf of the Employer.
- Logged-in User - a natural person of full age who has an Account and uses the services offered by the Platform.
- Non-logged-in User - a natural person of full age who makes use of the services offered by the Platform which do not require the creation of an Account.
- Account - the Employer's Panel or Candidate's Panel, respectively, constituting a collection of resources and settings created for the Employer or Candidate to manage the services provided by the Platform.
- Regulations - the Regulations for the provision of electronic services on the Platform belonging to ExecMind
In addition to the above, in this Policy, we may use the names of the services and functionalities of the Platform, which are defined and described in detail in the Terms and Conditions.
III. CONTACT WITH THE CONTROLLER
You can contact us as follows:
- by letter to: ExecMind, ul. Michała Bobrzyńskiego 14, 30-348 Kraków
- by e-mail: iodo@execmind.com
- by phone: + 48 12 340 24 43, + 48 606 226 528
IV. PURPOSES, LEGAL BASIS FOR PROCESSING AND SCOPE
As the Controller provides various services including to Employers, logged-in Users and non-logged-in Users, personal data is processed for different purposes, in different scopes and on different legal bases as defined in the GPDR.
Depending on the purpose, the Controller may process the following information about you:
- name and surname,
- contact details (telephone number, e-mail address),
- educational information,
- information about your professional qualifications,
- previous employment history,
- information contained in your CV,
- generic preferences for job advertisements,
- image (photograph),
- company name
- business address
- VAT numer
In addition, we may collect data about your activity on the Platform, i.e., among other things: identifiers and information collected through cookies, session data, device data, operating system data, location data, data about jobs viewed.
The scope of the data processed is described by the Controller more precisely for each processing purpose. In addition, information about the processing of personal data is grouped below according to their purposes.
A. Use of the Platform by Non-logged-in User
We may process some information of non-logged-in Users who use Platform services that do not require the creation of an Account. In this connection, the following table shows for what purposes some information may be processed.
PURPOSE | LEGAL BASIS |
for the purposes of providing electronic services by making available the content collected on the Platform, among others, the job search engine | the legal basis for the processing is the necessity of the processing for the performance of the contract (Article 6(1)(b) GPDR) |
for statistical and analytical purposes | the legal basis for the processing is the legitimate interest of the Controller (Article 6(1)(f) GPDR) in relation to testing the functionality of the Platform and measuring its effectiveness |
to determine and settle claims or defend against claims which may arise | the legal basis of the processing is the legitimate interest of the Controller (Article 6(1)(f) GPDR) |
The scope of the data processed includes personal data relating to activity on the Platform, i.e., among other things: identifiers and information collected via cookies, session data, device data, operating system data, location data, data relating to jobs viewed.
B. Use of the Platform by logged-in Users
We may process personal data if you create an account on the Platform, in which case we process the personal data of logged-in Users. In this connection, the following table shows for what purposes some information may be processed.
PURPOSE | LEGAL BASIS |
for the purposes of providing electronic services relating to the maintenance and operation of the Candidate's Account on the Platform, as well as the use of the Electronic Services and functionalities provided by the Account, including, but not limited to, recommended job offers, job application history and information on the status of applications, the possibility of filling the Account with data, applying for job offers | the legal basis for the processing is the necessity of the processing for the performance of the contract (Article 6(1)(b) GPDR) and as regards data marked as voluntary, the legal basis for the processing is the consent (Article 6(1)(a) GPDR) |
for statistical and analytical purposes | the legal basis for the processing is the legitimate interest of the Controller (Article 6(1)(f) GPDR) in relation to testing the functionality of the Platform and measuring its effectiveness for marketing and commercial communication the legal basis for the processing is the consent given by ticking the relevant checkbox (Article 6(1)(a) RODO) and the legitimate interest (Article 6(1)(f) RODO) related to for the possible defense of claims related to the sending of commercial information, in order to demonstrate the fact that consent to receive commercial information was given and when it was withdrawn. |
to determine and settle claims or defend againstclaims which may arise | the legal basis of the processing is the legitimate interest of the Controller (Article 6(1)(f) GPDR) |
The scope of the processed data includes to the extent necessary to operate the services provided, the so-called personal data provided in the registration form to create an Account, e.g., name and surname, contact data (telephone number, e-mail address). Additionally, to expand the profile: educational information, information on professional qualifications, information on previous employment, information contained in the CV, generic preferences for job advertisements, image (photo).
C. Use of the Platform by Employers
PURPOSE | LEGAL BASIS |
for the purposes of providing electronic services relating to the maintenance and operation of the Employer's account on the Platform | the legal basis for the processing is the necessity of the processing for the performance of the contract (Article 6(1)(b) GPDR) and as regards data marked as voluntary, the legal basis for the processing is the consent (Article 6(1)(a) GPDR) |
to carry out an order placed for a specific paid service, such as the publication of job advertisements | the legal basis for the processing is the necessity of the processing for the performance of the contract (Article 6(1)(b) GPDR); as regards data provided voluntarily, the legal basis for the processing is consent (Article 6(1)(a) GPDR); |
in order to comply with statutory obligations incumbent on the Controller, resulting in particular from tax and accounting regulations, e.g. issuing an invoice | the legal basis for the processing is the fulfilment of a legal obligation incumbent on the Controller (Article 6(1)(c) GPDR); |
For marketing and commercial communication | the legal basis for the processing is the consent given by ticking the relevant checkbox (Article 6(1)(a) RODO) and the legitimate interest (Article 6(1)(f) RODO) related to for the possible defense of claims related to the sending of commercial information, in order to demonstrate the fact that consent to receive commercial information was given and when it was withdrawn. |
for statistical and analytical purposes | the legal basis for the processing is the legitimate interest of the Controller (Article 6(1)(f) GPDR) in relation to testing the functionality of the Platform and measuring its effectiveness |
to determine and settle claims or defend against claims which may arise | the legal basis of the processing is the legitimate interest of the Controller (Article 6(1)(f) GPDR) |
The scope of the data processed includes: to the extent necessary to operate the services provided, i.e.: name, surname, contact details, (telephone number, e-mail address), VAT number, company name, and optionally a description of the business conducted, together with contact and registration data. In addition, we may collect data about your activity on the Platform, i.e., identifiers and information collected through cookies, session data, device, operating system, location, among others.
CORRESPONDENCE:
Each user of the Platform has access to the Administrator's contact details as well as to the contact form offered on the Platform. When contacting the Administrator by e-mail, telephone, letter or contact form, personal data contained in the content of the correspondence is naturally provided. The provision of data is voluntary, but necessary to make contact.
Personal data of persons who contact the Administrator by e-mail, traditional correspondence by telephone or via the contact form will be processed by us to answer any questions, in particular inquiries related to cooperation with us, as well as to present offers of cooperation and services, if the Administrator is requested to do so.
The legal basis for the processing of personal data is the legitimate interest of the Controller (Article 6(1)(f) of the GPDR) in the form of answering questions, establishing a relationship with the person who contacts us, and providing an offer of cooperation and services, if requested. In addition, the Controller is entitled to store the correspondence for the period of limitation of possible claims. The legal basis for this is the Controller's legitimate interest (Article 6(1)(f) GPDR).
The scope of the data processed includes: in terms of the contact form, the Controller requires only the first name and contact details. In addition, any other personal data voluntarily provided by the person contacting the Controller in the content of their message may be processed.
V. PERIOD OF PROCESSING OF PERSONAL DATA
The duration of data processing by the Controller depends on the type of service provided and the purpose of the processing. Personal data will only be kept for the time necessary to fulfill the purposes for which the data were collected. The period of data processing may also result from the legislation when it is the basis for processing.
The processing period may be extended if the processing is necessary for the determination or settlement of claims or the defense against claims, and thereafter only if and to the extent required by law. After the expiry of the processing period, the data shall be irreversibly deleted.
We will therefore be able to keep your personal data for the following periods:
- data processed based on consent - until consent is withdrawn.
- data processed to the extent necessary to conclude and perform the contract, e.g., in connection with the functionality of the Account - for the duration of the contract, i.e. having an account on the Platform. After the
termination of the provision of services, the Controller shall store the data until the statute of limitations for claims related to the provision of services. - data processed based on legitimate interest - for a period enabling the fulfillment of that interest or until an effective objection is raised against the processing.
- data processed for tax and accounting purposes to the extent and for the duration compliant with generally applicable laws.
- in the case of processing cookies, we will process your personal data for the period in which cookies will be stored on your device.
VI. VOLUNTARINESS OF PERSONAL DATA
The provision of your Personal Data within the scope of the services provided is voluntary but may be necessary to use the various functionalities of the Platform and the services available therein. Each time, the scope of Personal Data required to perform a particular service is indicated in advance on the Platform and in the Terms and Conditions. We wish to respect your privacy. Therefore, we ask you not to provide more information than is necessary, in particular not to provide sensitive data, e.g. information about your health (unless this is necessary due to special circumstances of the job), information concerning your race or ethnic origin, religion or philosophical beliefs etc. in connection with the services offered by the Administrator. The Administrator does not request or require the transmission of such personal data.
VII. RIGHTS IN RELATION TO THE PROCESSING OF PERSONAL DATA
In connection with the processing of your personal data, you have the following rights:
- The right to object to the processing of your data on the grounds of your particular situation - in cases where we process your data on the basis of our legitimate interest, the right to request access to, to rectify, delete or limit processing of Personal Data,
- the right to withdraw consent to the processing of Personal Data
- the right to transfer Personal Data,
- the right to lodge a complaint with the supervisory authority in charge of personal data protection, i.e., the President of the Office for Personal Data Protection.For more information: https://uodo.gov.pl/pl/p/skargi.
For more information on the rights of data subjects, please refer to the provisions of Articles 12 to 23 of the GPDR.Should you wish to exercise the rights referred to contact us above, please by email, traditional mail or telephone using the details indicated in Part III of this Policy.
VIII. RECIPIENTS OF YOUR PERSONAL DATA
In connection with the provision of particular services, maintenance of the Account and day-to-day operation, the Administrator may disclose your personal data to the following data recipients: IT service providers, entities providing accounting services, postal operators, couriers
The Administrator reserves the right to disclose selected information concerning the Data Subject to the competent public authorities or authorized entities, which will submit a request for such information, on the appropriate legal basis and in accordance with the provisions of the applicable law.
IX. TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES AND INTERNATIONAL ORGANISATIONS
The level of protection of Personal Data outside the European Economic Area ("EEA") differs from that provided by European law.
Due to the nature of the Administrator's business, the Administrator may also cooperate with entities with an international scope, which may involve the transfer of Personal Data outside the EEA. For this reason, the Administrator transfers Personal Data outside of the EEA only when it is necessary to do so, in which case mechanisms and measures
are applied considering the appropriate level of protection, e.g., by:
- cooperating with processors of Personal Data in countries for which a relevant decision of the European Commission has been issued to ensure an adequate level of protection of Personal Data.
- applying the standard contractual clauses issued by the European Commission.
The Controller always gives notice of its intention to transfer Personal Data outside the EEA at the stage of collection.
X. CHANGES TO THE PRIVACY POLICY
- The Policy shall be reviewed on an ongoing basis and updated as necessary.
- If the Privacy Policy is changed, its new content will be announced at the Portal. The new version of the Policy comes into force on the date of its announcement.
- The Portal may contain links to other websites. We recommend that when you go to other websites, you should read the privacy policy established there. This Privacy policy applies only to the Controller's Portal.