Privacy Policy of INTECA sp. z o.o.

1. INTRODUCTION

This document is a description of the privacy policy of Inteca sp. z o.o. with registered office at ul. Kościuszki 29, 50-011 Wrocław, Poland, entered into the Register of Businesses of the National Court Register by the District Court for Wrocław-Fabryczna in Wrocław, 6th Commercial Division of the National Court Register, under the KRS number 0000387005, having statistical (REGON) number 021498966 and taxpayer identification (NIP) number 8951993080, with share capital in the amount of PLN 20,000, hereinafter referred to as Inteca. The privacy policy of Inteca, hereinafter referred to as Policy, defines the principles and the method of processing and use of data and information coming from candidates, customers, and users of all Inteca’s websites, including: www.inteca.pl and www.apilogic.pro.

Please read the Policy carefully. By accessing or using an Inteca’s website and sending us any Personal Information in connection with job applications, referring a friend for work, sending a request for an offer/cooperation, etc., the User accepts the terms and conditions of this Policy and confirms that he or she has read it.

2. TERMS USED IN THE POLICY

Personal Data means personal data as defined in the GDPR regulation, i.e. any information about an identified or identifiable individual. These data identify the individual directly or indirectly by reference to his or her name, e-mail address, or telephone number, as well as other data.

GRPR means 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, OJ UE L of 2016.119.1), in compliance with which Inteca processes Users’ Personal Data.

Specialist – a job candidate offered by Inteca to its customers.

User – a job candidate, a newsletter subscriber, a person asking a question, a person recommending a friend for work, or a person visiting Inteca’s sites.

Services should be understood as services provided by Inteca by electronic means, by means of a website, i.e.: subscription to a newsletter, sending an inquiry through a contact form, or sending documents necessary in the recruitment process.

3. SUBMISSION OF PERSONAL DATA

By submitting your Personal Data on the www.inteca.pl website and other Inteca websites, you acknowledge that you have the necessary permissions to submit your personal data, which will be used by Inteca in the manner described in this Policy. Submission of Personal Data is voluntary, but is necessary for Inteca to provide the Service.

4. PERSONAL DATA CONTROLLER

4.1. Inteca is the controller of Users’ Personal Data provided in connection with the use of Inteca websites, in particular in connection with recruitment processes, sending marketing information (including newsletters), and the use of other services contained on the website (data indicated above).

5. OBJECTIVES AD LEGAL BASIS OF PERSONAL DATA PROCESSING

Inteca processes Personal Data for the following purposes:

5.1. To send commercial and marketing information (including the Inteca newsletter) to Users to the e-mail addresses provided by them, provided that the Users have agreed to receive it. For more detailed information on the processing of Personal Data in connection with marketing, please see section 9 of this Policy.

5.2. To send answers to the questions previously sent via the contact form to Users to the e-mail addresses or telephone numbers provided by them.

In the event of contact with the User in order to provide an answer, the legal basis of the processing of Personal Data is the User’s consent (Article 6.1.a) of the GDPR). Without processing of Personal Data, in particular contact details, we will not be able to provide answers and, consequently, to help resolve the issue indicated in the inquiry.

Importantly, in the context of consent to the sending of commercial information to Users as a part of the implementation of a legitimate interest of the data controller, if the User asks Inteca for a specific commercial offer, e.g. implementation of software, sending a form is tantamount to a consent to receive the commercial offer the User has asked for, by means of a clear affirmative action.

5.3. To consideration of a job application sent by the User and possibly to conduct a recruitment process by Inteca, after prior consent of the User to process the data contained in the resume or form.

In the event that Personal Data is processed for the purpose of processing job applications, the legal basis is the consent of each User to the processing of personal data (Art. 6.1.a) of the GDPR) For more detailed information on the processing of Personal Data in connection with recruitment processes, please see section 8 of this Policy.

5.4. To conduct and settle the “Refer a friend for work in Inteca” Program.

6. MAKING PERSONAL DATA AVAILABLE

6.1. Inteca is entitled to make data available to entities authorized under the relevant legislation.

6.2. Inteca may make Users’ Personal Data available to entities supporting Inteca in the fulfillment of individual orders within the framework of cooperation with them, including:

6.2.1. marketing service providers (advertising agencies, mass-mailing companies, etc.);

6.2.2. providers of support services in the organization and conduct of training and examinations;

6.3. Personal Data is made available by way of outsourcing of its processing. To this end, Inteca has concluded appropriate outsourcing contracts with the above-mentioned entities, pursuant to Article 28 of the GDPR.

6.4. Inteca also provides Users’ Personal Information to its customers in connection with recruitment processes conducted for them for the purpose of employment and subsequent secondment of Specialists or entire teams to provide services. Inteca has concluded appropriate agreements and contracts specifying the principles of provision of access to Personal Data.

6.5. Each User has the right to obtain access to information to which Inteca customer his or her Personal Data has been made available, in accordance with the rules defined in section 7 of this Policy.

6.6. Your personal data will not be transferred outside the European Economic Area.

7. USER’S RIGHTS

7.1. In accordance with Chapter III, Articles 15-22 of the GDPR, the User has the following rights in connection with the processing of his or her Personal Data by Inteca:

A. The right to access his or her Personal Data;

B. The right to rectify the data being processed;

C. The right to erase data (“right to be forgotten”), subject to the limitations specified in Article 17 of the GDPR;

D. The right to restrict data processing;

E. The right to transfer data;

F. Right to object to further processing based on Article 6(1)(e) or (f) of the GDPR;

G. The right not to be subject to decisions based solely on automated processing, including profiling;

H. The right to withdraw consent for further processing of Personal Data, in cases where the basis for the processing of the Personal Data was the consent given by the User.

7.2. Each of the above rights shall be exercised upon request of the User sent to the e-mail address office@inteca.pl. Inteca examines the request sent and sends a reply within 1 month of the receipt of the request, indicating the outcome of the examination: which specific actions have been taken with information on the estimated time for implementation of the entire application, if the specific actions require a longer implementation period.

7.3. Within the framework of the law referred to in section 7.2.1, the User may at any time withdraw his or her consent for further processing of his or her Personal Data for purposes that require consent (which applies to content sent in electronic form), provided that withdrawal of consent does not affect the legal use of Personal Data in actions performed on the basis of the consent before its withdrawal.

7.4. Within the scope of the right of access, the User has the right to obtain the following information in the form of a copy:

· The purposes of processing of the Personal Data;

· The categories of the Personal Data: what data we process, e.g. first name, last name, telephone number;

· Information about the recipients or categories of recipients of the data: to whom (person, company, institution) the data may be transferred;

· The planned period in which the Personal Data is to be retained and, where this is not possible, the criteria for determination of this period;

· Information on the right to request Inteca to rectify, erase, or limit the processing of the data, and to object to certain data processing;

· Information about the possibility to lodge a complaint with the Data Protection Office;

· Information about the source of the data, if the data was not obtained directly from the User: indication of the person, company, or institution that provided the Personal Data;

· Concerning the use of profiling: on what principles it is undertaken and what the consequences of profiling for the User may be.

7.5. At the same time, Inteca informs that each subsequent copy of the Personal Data is subject to a fee resulting from the costs incurred in creating the subsequent copy of the Personal Data. Inteca notifies the User of the costs after evaluating the scope of the information indicated in the application.

7.6. Inteca reserves the right to respond to a request for the exercise of any right later than by the above-mentioned time limit (up to two months) due to the number of inquiries or the complexity of the inquiry submitted. Complexity should be understood as the need to compile data from multiple IT systems or the need to consult more than one person from a department or departments in order to obtain the requested information. In any event, Inteca undertakes to inform the User of this fact, giving the reasons.

7.7. Inteca informs that it may refuse to exercise any of the rights set out in Articles 15 – 22 of the GDPR when the User makes continuous, excessive requests without any justification. Each time, Inteca will justify its refusal to the exercise of the right indicated in the application. Continuous and excessive should be understood as sending subsequent applications with a similar request to the first one, despite the fact that it has been examined and the User has been informed about its implementation, e.g. the User submits a request for access to information, Inteca implements it by sending a summary of the information it has, and the User submits a second and subsequent requests without explaining the reason for submitting a renewed request for information.

8. PROCESSING OF PERSONAL DATA FOR THE PURPOSE OF RECRUITMENT AND AS A PART OF THE CANDIDATE REFERRAL SYSTEM

8.1. Inteca conducts recruitment procedures for its own needs and for the customers to whom it provides services, e.g. the Specialist provision service. Therefore, we hereby inform that the User’s data may also be processed by Inteca’s customers, as mentioned in the job advertisement, which indicates that Inteca is conducting a recruitment procedure for a customer. At the same time, Inteca informs that by expressing its consent to the recruitment processes, the User gives his or her consent both to the recruitment for a specific position specified in the job advertisement and to future recruitment processes. This means that Inteca will store the User’s Personal Data in its database in order to send information about job offers that match the User’s profile and work experience. The User may at any time withdraw his or her consent to further processing in accordance with section 7 of this Policy, which does not affect the lawful use of the Personal Data in activities carried out on the basis of his or her consent before its withdrawal.

8.2. The User’s Personal Data may also be processed in the event of the User’s referral by another person. In this situation, the person making the referral enters his or her data and the data of the referred person and places the resume under the form with the User’s data. Inteca verifies the referred person’s resume received from the person making the referral in the scope of the referred person’s consent to the processing of Personal Data that meets the requirements of the GDPR within 30 days. If consent is given, Inteca is entitled to use this data for recruitment processes.

9. PROCESSING OF PERSONAL DATA FOR MARKETING PURPOSES

9.1. By submitting an inquiry, the User may consent to the processing of Personal Data for the purpose of sending marketing information about Inteca’s products and services, including newsletters, electronically. The rules for obtaining consent are set out in sections 5.1-5.2 of the Policy. Consent may be withdrawn at any time, subject to the rules set out in section 7.3 of this Policy.

9.2. In the case of sending newsletters, the legal basis is the User’s consent to the processing of Personal Data (Art. 6.1.a of the GDPR).

The User agrees to receive the newsletter by placing his or her e-mail address on the newsletter subscription form or by ticking a checkbox when filling in the contact or recruitment form. The inclusion of an e-mail address in the newsletter subscription form is a clear affirmative action that confirms consent to the processing of Personal Data within the meaning of Article 4 (11) of the GDPR concerning the definition of consent and the related recital 32 of the GDPR which explains what constitutes a clear affirmative action.

According to the above-mentioned recital, a clear affirmative action is provision of information by the User to Inteca that he or she agrees to the use of the e-mail address provided in the form to send Inteca newsletters with information promoting Inteca. This is one of the permitted forms of consent, besides ticking a checkbox, to the use of the e-mail address provided for the aforementioned purpose.

Consent for sending unsolicited commercial information to Users pursuant to Article 10 of the Act on provision of electronic services and Article 172(1) of the Telecommunications Law is given by Users independently and separately, by ticking a dedicated checkbox next to the content of the consent.

9.3. In order to download some of the documents posted on Inteca’s websites, it may be necessary to complete a form and provide personal data. The data provided will be processed on the basis of a consent (Article 6(1)(a) of the GDPR) expressed through a clear affirmative action. On the other hand, if the User wants to receive other marketing information, he or she can choose whether he or she wants to tick or not a dedicated checkbox. If the checkbox is not ticked, Inteca will be informed that the User is not interested in receiving information and therefore the User will not be included in the mailing lists. The User’s withdrawal of consent for processing of personal data means deletion from mailing lists.

10. SECURITY RULES

Inteca has implemented security measures (organizational and technical) to protect Personal Data against loss, misuse, illegal processing, and modification. Inteca is committed to protecting any information disclosed by Users in accordance with security and confidentiality standards.

11. COOKIES

11.1. Inteca declares that it uses cookies on its www.inteca.pl website and other websites owned by Inteca. By using that website, the User agrees to the introduction of cookies on the User’s device, as explained below.

11.2. Cookie files used on the www.inteca.pl website and other websites owned by Inteca may be set by Inteca or by a third-party website.

11.3. Cookie files are used to:

· Adjust the content of websites to the User’s preferences and optimize the use of websites; in particular, these files make it possible to recognize the website User’s device and to properly display the website tailored to the User’s individual needs;

· Create statistics that help understand how website Users use the web pages to improve their structure and content;

· Provide Users with advertising content that is more suited to their interests.

11.4 Types of cookie files used by Inteca:

· “Necessary” cookies, which enable the use of services available on the website, e.g. enable the use of sessions;

· “Functional” cookies, which enable “remembering” the settings selected by the User and personalizing the User’s interface, e.g. in terms of the selected mobile/desktop version, the last phrases entered by the user, the appearance of the website, etc.;

· “Analytical” cookies, which enable monitoring Users’ activity on the website.

11.5. The User has the possibility to block the saving of cookie files by changing the settings of his or her web browser accordingly. Disabling cookies may affect the functioning of the website. Failure to change the browser’s settings means acceptance of the use of cookies.

12. SERVER LOGS

Information about certain user behavior is logged into the server layer. This data is used solely for the purpose of administration of the website and to ensure the most efficient performance of the hosting services provided.

The resources viewed are identified by their URL addresses. In addition, the following may be recorded:

a. inquiry arrival time;

b. answer sending time;

c. customer station’s name – identification performed by the HTTP protocol;

d. information on errors that occurred during the execution of HTTP transactions;

e. the URL address of the page previously visited by the user (referrer link) – in cases where the access to the Website was made via a link;

f. information about the user’s browser;

g. information about the IP address.

The above data is not associated with any particular person viewing the pages.

The above data is used only for the purpose of administration of the server.

13. POLICY CHANGE

Due to the development and progress of technology and changing laws, the rules set out in this Privacy Policy may change. The User will be informed of any change to these rules by posting a new content of this document on the https://inteca.pl/en/service-privacy-policy/ website.