PRIVACY POLICY
as of November 2nd, 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 fulfils 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.
• Website - ExecMind's website available under the domain https://www.execmind.com

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 AND LEGAL BASES FOR THE PROCESSING OF PERSONAL DATA

In each case, the purpose, scope, and recipients of the Personal Data processed by ExecMind arise from the relevant legal premise, because of actions taken on the Site or through other communication channels.

Below are the possible purposes and grounds for the processing of personal data by Execmind:

V.   THE SCOPE OF THE DATA TO BE PROCESSED

In our operations, we are guided by the principle of minimising processing and not obtaining excessive Personal Data. As part of our recruitment processes, the Administrator expects to provide Personal Data only to the extent specified in the Labour Law.  This means that, in our job application forms, we expect to receive only the Personal Data that the acquisition of which is in accordance with the applicable legal provisions. Here, we rely on the catalogue of personal data indicated in Article 221 of the Labour Code:

• name( s) and surname;
• contact details as indicated by the person (phone number, e-mail address)
• educational background
• information about professional qualifications
• information on previous employment history.

If the applications sent contain additional data beyond that indicated by the labour legislation, their processing will be based on the candidate's consent (Article 6(1)(a) of the GPDR), expressed through the unambiguous affirmative action of the candidate sending the application documents. If the applications sent will contain information inappropriate for the purpose of recruitment, they will not be used or considered in the recruitment process.

We wish to respect your privacy, therefore we ask you not to provide more information than necessary, in particular not to provide sensitive data, e.g. information about your health (unless this is necessary due to the specific circumstances of your job) information on race or ethnic origin, religion or philosophical beliefs etc. in connection with the services offered by ExecMind.  We do not request or require the transmission of such personal data.

For the Newsletter, we only ask for your email address.

In the case of the Contact Form, which is available on our website, we only ask for your name and your contact details so that we can contact you.  In addition, we process any other personal data that you voluntarily provide in the content of your message.

VI.  PERIOD OF PROCESSING OF PERSONAL DATA

The period of data processing by the Controller depends on the type of service provided and the purpose of the processing. The period of data processing may also result from 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 defence 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 for recruitment purposes - for the duration of the current recruitment process or for a period of 3 years in the case of data processing for future recruitment processes (by consent). These periods are reduced if the person withdraws consent to process data for recruitment purposes.
• data processed based on consent - until consent is withdrawn.
• data processed based on a legitimate interest - for the period that enables that interest to be fulfilled or until you submit an effective objection to the data being processed.
   

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 without affecting the lawfulness of processing carried out prior to its withdrawal.
• 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 performance of the services, the Administrator may disclose your personal data to the following recipients:

• public authorities or legitimate entities that make a request for such information, based on the relevant legal basis and in accordance with the provisions of the applicable law.
• entities providing services to us, including technical, IT and organisational services that enable the Administrator to conduct its business,
• personal data of persons who contact us for the purpose of the recruitment process may be entrusted to ExecMind's employees, as well as made available to Employers with whom ExecMind cooperates based on contracted services in the scope of carrying out the recruitment process and in accordance with concluded contracts.
   

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.  COOKIES

1. The website uses cookies, which are small text files stored on the User's final device (PC, phone, etc.). To obtain information on cookies, we encourage you to visit: https://allaboutcookies.org/.
2. Information collected by means of cookies may include data relating to:
   1. your visit to the Site i.e. date and time of use of the Site (or its sub-sites) by you;
   2. your device and location, i.e. IP address, domain name, browser name and version, name and version of the operating system of the device you are using.
3. We use cookies to ensure the proper functioning of the Website and for statistical purposes, e.g., research into the popularity of individual tabs. As part of the Website, we use:
   1. Necessary cookies - these enable our Website to function correctly
   2. Analytical cookies - these are used to determine how users use our Website and allow us to measure the effectiveness of our activities
   3. Marketing cookies - these are used to determine how users use our website in terms of tailoring the content displayed to your interests via the Site.
4. The implementation of cookies is based on our legitimate interest 6 (1) (f) RODO. (analysis and creation of statistics on the viewing of the Website, adaptation of the content of the Website to your preferences)
5. You can manage your cookie settings within your web browser. Disabling or restricting cookies may prevent you from using some of the features available on our Site and may cause difficulties in using the Site, as well as many other websites that use cookies.
6. In the case of the processing of cookies, we will process the information for the period that the cookies are stored on your device.
7. You may find ways to configure the cookie settings of the various browsers at, among other places, the following addresses:
   1. Google Chrome: http://support.google.com/chrome/bin/answer.py?hl=pl&answer=95647;
   2. Mozilla Firefox: http://support.mozilla.org/pl/kb/usuwanie-ciasteczek;
   3. Microsoft Internet Explorer: http://support.microsoft.com/kb/278835/pl;
   4. Safari: https://support.apple.com/pl-pl/guide/safari/sfri11471/mac
   5. Opera: https://help.opera.com/en/latest/web-preferences/
8. You can also visit http://tools.google.com/dlpage/gaoptout to block being tracked by Google Analytics on all websites.
    

XI.  CHANGES TO THE PRIVACY POLICY

1.  The Policy shall be reviewed on an ongoing basis and updated as necessary.
2. If the Privacy Policy will be changed, its new content will be announced at www.execmind.com. The new version of the Policy comes into force on the date of its announcement.
3. The website 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 Website.