Privacy Policy

Last updated: 25 August 2022


PRIVACY POLICY OF THE POCKETSQUARE.PL SERVICE

General Information

We attach great importance to the protection of your personal data and handling it in accordance with applicable law, in particular in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council 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) of 27 April 2016 ("GDPR"). Our goal is to ensure that you have control over the processing of your personal data by us and to provide tools that allow you to exercise your rights.

Below we present information on how we process your personal data, how we care for its security and to whom we disclose it. If you have any additional questions about how we use your personal data, please do not hesitate to write to us at pomoc@pocketsquare.pl.

These rules apply to:

  1. The Pocketsquare.pl Service ("Service"),
  2. The Client Zone – a dedicated Pocketsquare.pl module enabling the purchase and online use of Service services (publication of job offers, publication of training offers, use of the CV Database).

The types and scope of services provided electronically by Pocketsquare sp. z o.o. and the rules for collecting and processing personal data are regulated in detail:

  1. In the case of User personal data, in the Terms of Service for provision of services via the Pocketsquare.pl Service
  2. In the case of Service Clients, in the Client Zone Terms of Service for the Pocketsquare.pl service.

How do we obtain your data?

We use your personal data because you decided to register in our Service as a User, submitted an application for a specific job offer, or registered in the Client Zone of the Service. Creating an account in the Service is possible directly on the Service's pages (for Users also via external authentication services – Facebook.com and Google.com). In all cases, we will require you to accept the Terms of Service, which you can read on the Service's pages.

About the company: Who is the controller of your personal data?

The controller of your personal data is Pocketsquare Spółka z ograniczoną odpowiedzialnością with its registered office in Warsaw at: ul. Indiry Gandhi 15/4, 02-776 Warsaw, whose registration files are maintained by the District Court for the capital city of Warsaw in Warsaw, XII Commercial Division of the National Court Register, under KRS number: 0000911168, NIP: 7011035170, REGON: 388890697, with a share capital of PLN 250,000. We will refer to this company as the "Controller" or "Pocketsquare sp. z o.o."

You can contact the Controller regarding the processing of your personal data:

  1. by sending an email to: pomoc@pocketsquare.pl,
  2. by traditional mail: Pocketsquare sp. z o.o., ul. Indiry Gandhi 15/4, 02-776 Warsaw.

In the case of the Client Zone, when making online payments, the payment order is transferred to the Stripe system. The Client will be informed about the entity acting as the controller of their personal data during the payment process.

What data do we process?

In the case of Users: first name, last name, email address, phone number, residential address, education and professional experience, and other data included by the User in their CV.

In the case of Clients: company name, registered office address, addresses of other offices, contact person's name and surname, email address(es) for contact, number of employees, year of establishment, description of business activities, company logo, and marketing materials published on the www.pocketsquare.pl service.

How do we process your personal data?

Service Users

We process your personal data provided to us in the form of a CV or otherwise for the following purposes:

  1. provision of electronic services, based on a contract concluded with Pocketsquare sp. z o.o. through the User's acceptance of the Service's terms, namely: (i) maintaining an account in the Service; (ii) creating a professional profile; (iii) enabling applications for selected job offers in the Service; (iv) participation in future recruitments – the legal basis for data processing will be the contract concluded between the User and Pocketsquare sp. z o.o. under the terms set out in the Service's regulations (Art. 6(1)(b) GDPR),
  2. assessing the provided data and creating the User's professional profile and matching job offers registered in the Service to the User's experience and qualifications, and sending recommended job offers – the legal basis for processing the User's data will be the legitimate interest of Pocketsquare sp. z o.o. consisting in conducting recruitment processes on behalf of employers (Art. 6(1)(f) GDPR), as well as the provisions of the contract concluded between the User and Pocketsquare sp. z o.o. (Art. 6(1)(b) GDPR),
  3. transferring the User's personal data, processed in their professional profile created in the Service, to potential employers or entities acting on their behalf, including recruiting entities whose job offers match the User's professional qualifications and experience – the legal basis for data processing will be the legitimate interest of Pocketsquare sp. z o.o. (Art. 6(1)(f) GDPR), as well as the provisions of the contract concluded between the User and Pocketsquare sp. z o.o. (Art. 6(1)(b) GDPR).
  4. reminding the User from time to time to update their data in the Service – the legal basis for processing will be the legitimate interest of the Controller in conducting recruitment processes based on current User data (Art. 6(1)(f) GDPR),
  5. statistical purposes for the internal archival needs of Pocketsquare sp. z o.o. – the legal basis will be the legitimate interest of Pocketsquare sp. z o.o., and statistical data resulting from processing the User's data for this purpose may be shared with other entities (Art. 6(1)(f) GDPR),
  6. marketing purposes, i.e. if the User gives separate consent, the provided email address will also be processed for the purpose of sending commercial information about the Controller's marketing activities related to services provided by Pocketsquare sp. z o.o. – the legal basis is the User's consent, which can be withdrawn at any time (Art. 6(1)(a) GDPR),
  7. marketing purposes, i.e. if the User gives separate consent, the provided email address will also be processed for the purpose of sending commercial information about the marketing activities of the Controller's partners (including potential employers), particularly regarding work in finance and education – the legal basis is the User's consent, which can be withdrawn at any time (Art. 6(1)(a) GDPR),
  8. archiving completed recruitment processes, confirming the fulfillment of Pocketsquare sp. z o.o.'s obligations under personal data protection regulations, and pursuing or defending against claims – the legal basis is the legitimate interest of Pocketsquare sp. z o.o. in protecting rights and claims (Art. 6(1)(f) GDPR),
  9. ensuring the correct functioning of the Service, analyzing traffic of Users and visitors, as described in detail in the section: Information about the use of cookies – the legal basis is the legitimate interest of Pocketsquare sp. z o.o. in ensuring the functioning of the Service (Art. 6(1)(f) GDPR), and in certain cases also the User's consent (Art. 6(1)(a) GDPR)
  10. marketing and service delivery purposes, i.e. through maintaining pages on social media platforms such as LinkedIn and Facebook – the legal basis is the legitimate interest of Pocketsquare sp. z o.o. in marketing its own services (Art. 6(1)(f) GDPR).

Service Clients (Client Zone module)

We process your personal data for the following purposes (regarding the processing of personal data of potential clients who are employers, their representatives and attorneys):

  1. provision of electronic services based on a contract with Pocketsquare sp. z o.o. through the Client's acceptance of the Service's terms, namely: (i) maintaining an account in the Service; (ii) enabling orders for specific services; (iii) making payments and settling for services; (iv) using the Service's services – the legal basis is the contract concluded between the Client and Pocketsquare sp. z o.o. (Art. 6(1)(b) GDPR) or the legitimate interest of Pocketsquare sp. z o.o. (Art. 6(1)(f) GDPR),
  2. submitting service proposals and pre-contract contact – the legal basis is the legitimate interest of Pocketsquare sp. z o.o. in presenting service proposals (Art. 6(1)(f) GDPR),
  3. reminding the Client from time to time to update their data in the Service – the legal basis is the legitimate interest of the Controller in conducting recruitment processes based on current Client data (Art. 6(1)(f) GDPR),
  4. statistical purposes for the internal archival needs of Pocketsquare sp. z o.o. – the legal basis is the legitimate interest of Pocketsquare sp. z o.o., and statistical data from processing the Client's data will not be shared with other entities (Art. 6(1)(f) GDPR),
  5. marketing purposes, i.e. if the Client gives separate consent, the provided email address will also be processed for sending commercial information about the Controller's marketing activities – the legal basis is the Client's consent, which can be withdrawn at any time (Art. 6(1)(a) GDPR),
  6. archiving completed recruitment processes, confirming the fulfillment of Pocketsquare sp. z o.o.'s obligations and pursuing or defending against claims – the legal basis is the legitimate interest of Pocketsquare sp. z o.o. in protecting rights and claims (Art. 6(1)(f) GDPR),
  7. ensuring the correct functioning of the Service, analyzing traffic, as described in the cookies section – the legal basis is the legitimate interest of Pocketsquare sp. z o.o. (Art. 6(1)(f) GDPR), and in certain cases also the Client's consent (Art. 6(1)(a) GDPR),
  8. marketing and service delivery purposes through maintaining social media pages such as LinkedIn and Facebook – the legal basis is the legitimate interest of Pocketsquare sp. z o.o. in marketing its own services (Art. 6(1)(f) GDPR).

We are committed to transparency in processing your personal data. If you have any questions about the processing process or our service policies, please contact us.

We process the personal data you provide to us solely for the purposes for which it was collected and will not process it for other purposes unless you give separate, informed consent.

We process your data in accordance with the law, ensuring it remains up-to-date and accurate. From time to time we will remind you of the need to update your data by leaving a notification on your profile or sending a message to the email address you provided.

Is providing data mandatory?

You determine what data you provide to Pocketsquare sp. z o.o. when registering in the Service or submitting an application in a specific recruitment process.

However, when creating an account in the Service (both as a User and as a Client), it is necessary to provide data required for Pocketsquare sp. z o.o. to perform the services specified in the relevant Terms of Service.

When creating a User account in the Service, failure to provide the required data will prevent account creation and result in the inability to submit applications for selected job offers.

When registering in the Client Zone, failure to provide the required data will prevent the creation of a Client account and the purchase and online use of the Service's services.

To whom will we disclose your personal data?

In addition to disclosing your data to the Controller's clients, i.e. entities searching for employees through us (potential employers or entities acting on their behalf), we will also share your data with entities acting on our behalf, such as IT support companies, hosting service providers, software providers, and IT support services. Data disclosure will be based on a data processing agreement specifying the purpose and scope of processing.

The Service also has active buttons redirecting to our pages on social media platforms such as Facebook and LinkedIn. Data is transferred to these providers only when a User or Client uses the relevant icon. Further processing within those platforms is governed by the platform provider's terms of service.

Will we transfer your data outside the European Union?

We will not transfer your personal data to third countries, i.e. countries outside the European Economic Area, unless a potential employer or recruitment entity is located outside the EU. In such cases, Pocketsquare sp. z o.o. may transfer your data to a country outside the EU and, if the European Commission has not previously issued an adequacy decision for that country, will sign a contract with the recipient in accordance with the standard data protection clauses adopted by the European Commission or the Polish supervisory authority. Please note that all our IT service providers declare that server space is located within the European Economic Area, although some do not completely exclude the possibility of data access by entities outside the EEA. Questions regarding the processing of your personal data in a third country should be directed to: pomoc@pocketsquare.pl.

How long will we process your personal data?

If you register in our Service, we will process your data for the following period:

  1. if you create an Account in the Service, until the profile is deleted from the Service or for a period of 2 years from the last login,
  2. after account deletion – for the period of limitation of claims under applicable law, i.e. Pocketsquare sp. z o.o. may process your data for archival, statistical purposes, confirmation of obligations, and pursuing or defending against claims,
  3. in the case of processing based on consent – we will delete your data after the process ends.

How do we protect your data?

We apply a range of IT and physical security measures to minimize the risk of data leakage, destruction or disintegration, such as firewall systems, antivirus security systems, and internal data access and processing procedures. Please remember, however, that using the Internet always carries the risk of certain security incidents. We assure you that we do a lot to minimize this risk as much as possible.

What rights do you have regarding the processing of your data?

Under the GDPR, you have a number of rights in connection with providing us with your personal data, such as:

  1. the right to obtain information on how your personal data is processed – if you have questions about whether and how we process your data, please contact us by sending a message to: pomoc@pocketsquare.pl,
  2. the right to access and update data – you always have access to the personal data you provided on your account in the Service (you can edit and update the data provided),
  3. the right to rectification of data if it is incorrect,
  4. the right to request erasure of data – if you want us to stop processing some of your data, you can delete it from your account in the Service. If you want to delete all data from your account, please notify us by sending a message to pomoc@pocketsquare.pl or delete your account yourself.
  5. under the conditions set out in the GDPR, you also have the right to:
    1. request restriction of processing of your data,
    2. object to the processing of your data, although the objection will not affect previously completed operations,
    3. withdraw consent, if data is processed on the basis of your consent,
    4. data portability, if processing is based on a contract or your consent,

    for the above matters, you can contact us by sending a message to pomoc@pocketsquare.pl

  6. the right to lodge a complaint with the supervisory authority – if you believe that the processing of personal data violates the GDPR or other personal data protection regulations, you have the right to lodge a complaint with the supervisory authority, which in Poland is the President of the Personal Data Protection Office.

Within what timeframe will your rights be exercised?

We strive to fulfill your requests and respond to your inquiries about your data as quickly as possible. In any case, you should receive a response from us no later than 30 days from the date of receipt of your request. If due to circumstances beyond our control we are unable to meet this deadline, we will inform you and explain the reasons for the delay. If we have doubts about whether it is you making a particular request, we may ask a few additional questions to verify your identity.

Contact

If you have any questions related to the processing of your personal data by us or wish to submit a request to exercise a specific right under the GDPR, please send a message to: pomoc@pocketsquare.pl.

Information about the use of cookies

Cookies are text files stored on computers and software used to browse the Internet (e.g. web browsers). These files allow the device used by a given User to be recognized, along with information related to the use of websites. A cookie file usually contains the name of the website it comes from, the storage time on the device, and a unique numerical identifier.

The Service places cookies on Users' computers and then uses them during subsequent visits to the Service.

Cookies are used by the Service for the purpose of:

  1. adapting the content and functionality offered in the Service to the individual preferences of the User (e.g. profile, job offer notifications),
  2. conducting statistics on User behavior in the Service, which allows optimizing its content and functionality,
  3. maintaining the User's session after logging in, so that re-logging is not necessary when navigating to subpages or revisiting the Service,
  4. adapting advertising campaigns in the service, e.g. by displaying a given advertisement only once to each User.

Please note that web browsers by default allow cookies to be stored on the computer.

However, you can change the way these files are used at any time, e.g. disable automatic cookie handling. To do this, change the privacy settings in the web browser you use. Please note that restricting the use of cookies may affect some functionalities offered in the Service.

Google Analytics

Please note that the Service also uses the Google Analytics service offered by Google Inc., headquartered in the United States. This service uses cookies stored on the User's computer, and this data is sent and stored on Google's servers. This allows for statistics on the Service and analysis of User behavior. Through these processes, we can optimize the Service and offer increasingly high quality services. Please note that your personal data is not transferred to Google, only cookies with information about the use of the Service. It is not possible to link a User's behavior in the Service to their personal data. Google Analytics is used by us solely for statistical and analytical purposes.

Privacy protection in textual materials

The good name of experts and other persons described and speaking in articles published on the Pocketsquare.pl service is extremely important to us. The editorial team of the service, in order to ensure high quality texts, sends material for authorization where possible and/or necessary. Articles received from third parties and our partners are not authorized by us and in that case we cannot be fully responsible for protecting the good name of the persons quoted. In all situations where it is violated or you wish a statement to be removed from the service, please contact us at: pomoc@pocketsquare.pl.

Personal data security

The Controller exercises due diligence to ensure adequate protection of personal data, in particular applying the organizational and legal measures required by the GDPR.

Contact details

You can contact the Controller via email: pomoc@pocketsquare.pl or by post to: ul. Indiry Gandhi 15/4, 02-776 Warsaw.

This Privacy Policy is regularly reviewed and updated as necessary. The current version of the Policy was adopted and has been in force since 25 August 2022.