- The purpose of the Privacy and cookies Policy is, among others, implementation of the information obligation referred to in Article 13 and 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”.
- This Privacy and cookies Policy applies to our:
- Candidates – natural persons participating in recruitment processes carried out by us;
- Employees or associates of our clients and contractors – natural persons with whom we contact in connection with ongoing or potential business cooperation;
- Contacting persons – natural persons contacting us (e.g. by phone, via e-mail, post, contact form, chat) or with whom we may contact;
- Website users – natural persons using our website https://closeurope.com;
- Please note that we may make some changes to this Privacy and cookies Policy from time to time. Please visit this webpage if you want to stay up to date, as all our changes and updated versions will be posted here.
What kind of personal data do we collect?
The controller of your personal data is Vladyslav Muzhylivskyi operating under the business name Vladyslav Muzhylivskyi Close Europe with its registered office in Kraków, Francesco Nullo 13/15, 31 – 543 Kraków, Tax ID: 6751522794, REGON: 380162082 (hereinafter referred to as “Controller” or “us”).
You can contact us in the following ways:
- via post: ul. Francesco Nullo 13/15, 31 – 543 Kraków;
- via e-mail: email@example.com;
- by phone: + 48 531 381 201.
What kind of personal data do we collect?
Candidate data: In order to provide the best-tailored employment opportunities for you, we need to process certain information about you. We only ask for details that will help us to assist you, such as your full name, age, contact details, education details, employment history, current status, immigration status, financial information (regarding your expectations). You can choose to share other relevant information with us. Where appropriate and in accordance with local laws and requirements, we may also collect information related to your health or details of any criminal convictions.
Employees or associates of our clients and contractors: we will process your personal data because you are the contact person for us at our client or contractor (or potential client or contractor); we need to collect and use information about you in order to provide our clients with excellent services such as 1) finding candidate which is a good fit for the company, or 2) providing our clients with recruitment process outsourcing services, or 3) providing our clients with dedicated recruitment market informational services or in order to properly use services offered by our contractors. We only ask for details that will help us to establish proper communication such as your full name, contact details and job position, as well as the type of matters entrusted to you as a person contacting us or representing our client or contractor.
Contacting persons: if you contact us in any matter (and you are neither our client nor contractor, employee or associate of our client and contractor) or if we contact you in any matter (e.g. because one of our candidates or clients recommended you or informed us that you might be interested in cooperation with us) we will only process your personal data in order to establish and maintain contact with you. We may process your personal data such as your full name, contact details and details concerning the subject of your inquiry or other information received from our candidates or clients.
Website users: We collect a limited amount of data of our website users, which is used to help us improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, and the time periods when our website is the most popular.
How do we collect your personal data?
There are several ways, in which we can collect your personal data:
- directly from you – e.g. as a result of sending us a CV, e-mails, phone calls or messages via LinkedIn, as well as your activity on our website, including use of our contact form or chat;
- from third parties – e.g. your employer, colleagues or our current candidate or client
- through publicly available internet portals such as LinkedIn, or your personal websites;
How do we use your personal data – what is the aim and legal basis?
Candidate data: Your personal data will be processed in order to carry out the recruitment process for the position specified in the job offer, including for the purpose of assessing your qualifications for work in this position. If you give us additional consent, your personal data will also be processed for the purposes of future recruitment processes (expressing this consent is voluntary and does not affect the recruitment process in which you participate.)
The legal basis for the processing of your personal data is:
- in terms of conducting the recruitment process for the position specified in the job offer – your voluntary consent (Article 6 (1) (a) of the GDPR);
- in the scope of personal data collected during the interview – processing is necessary for the purposes of our legitimate interests (Article 6 (1) (f) of the GDPR) consisting in the possibility of verifying your skills and qualifications;
- in the scope of data processing for the purposes of future recruitment processes – your voluntary consent (Article 6 (1) (a) of the GDPR) to the processing of data for the purposes of future recruitment processes.
Employees or associates of our clients and contractors: Your personal data will be processed in order to contact you in regard with current affairs concerning the performance of contracts (potential or concluded) between us and our client or contractor that you represent, presenting offers, negotiations, receiving orders, answering questions. The legal basis for the processing of your personal data is our legitimate interests (Article 6 (1) (f) of the GDPR) consisting in the possibility of maintaining ongoing contact with our clients and contractors (i.e. their employees or associates) and maintaining relationships as part of our business activity.
Contacting persons: Your personal data will be processed in order to establish and maintain contact with you, including for the purpose of answering your questions addressed to us, presenting you offers of cooperation and exchanging current correspondence. The legal basis for the processing of your personal data is our legitimate interests (Article 6 (1) (f) of the GDPR) consisting in the possibility of maintaining ongoing contact with you as part of our business activities.
Website users: Your personal data will be processed in order to ensure the safety of using the website, its proper functioning as well as to adapt its content and operation to the needs of users by conducting analytical and statistical activities. The legal basis for the processing of your personal data is our legitimate interests (Article 6 (1) (f) of the GDPR) consisting in the possibility of ensuring security and proper functioning of the website as well as adapting its content and operation to the needs of its users by conducting analytical and statistical activities.
Defence of legal claims: Additionally, we may process personal data of all the above-mentioned data subject categories in order to establish, exercise or defend any possible legal claims. The legal basis for the processing of personal data in this regard is our legitimate interests (Article 6 (1) (f) of the GDPR) consisting in the possibility of establishing, exercising or defending any possible legal claims.
Who do we share your personal data with?
Candidate data: The recipients of your personal data are authorized persons who carry out the recruitment process, as well as entities providing advisory services (eg. legal, tax, accounting) and IT services to us. Your personal data may also be transferred to our clients for whom we conduct the recruitment process (potential employers). The basis for the transfer of data in such case will be your voluntary consent (Article 6 (1) (a) of the GDPR) to provide personal data to our Client for whom we conduct the recruitment process.
Employees or associates of our clients and contractors / Contacting persons / Website users: We may transfer your personal data to entities providing advisory services (eg. legal, tax, accounting) and IT services to us. Personal data may be disclosed to other entities only in cases where such an obligation results from applicable law and each time in accordance with relevant provisions.
Transfer of your personal data to third countries or international organisations
Your personal data may be transferred to entities processing them in countries that are not members of the European Economic Area (so called “third countries”), however, only to the extent necessary, related to the provision of services by these entities to us, especially IT services, and based on appropriate legal safeguards ensuring an adequate level of protection of these data in third countries (for example standard contractual clauses approved by the European Commission).
In order to obtain additional information on the data transfer security measures applied by us, including obtaining a copy of such additional security measures, please contact us at the address provided in the section “Who is controller of your personal data?”.
How do we protect your personal data?
We really care about protecting your information. That’s why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your personal data. We have in place a range of appropriate technical and organisational measures. For instance, we are using SSL certificates on our website, and several steps authorizing procedures.
How do we protect your personal data?
Your personal data will be kept by us for the period necessary to achieve the processing purposes, i.e.:
- in terms of conducting the recruitment process for the position specified in the job offer – for a period not longer than 12 months from the end of the recruitment process for this position
- in the scope of data processing for the purposes of future recruitment processes – for a period not longer than 2 years from the receipt of your recruitment application or until your consent is withdrawn, if it occurs earlier.
Employees or associates of our clients and contractors: until the end of cooperation with our client or contractor that you represent.
Contacting persons: for the period of correspondence, and after that time for the period and to the extent necessary to possibly renew contact or maintain current relations (up to 2 years).
Website users: for the period of validity of cookies or other similar technologies used on our website (as indicated below) or until you delete these cookie files.
To the extent that personal data are processed by us for the purposes necessary to establish, exercise or defend legal claims, we may process personal data for the period of limitation of such claims.
What are your rights as a data subject?
In case we already hold your personal data, you still have various rights in relation to it, described below. In order to exercise any of these rights, please contact us at the address provided in the section “Who is controller of your personal data?”. We will work with your request without undue delay, and in any event in accordance with the requirements of applicable law. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
In connection with the processing of your personal data, as a data subject you may have the following rights (the scope of rights in a specific case depends on the legal basis for the processing of the data):
Right of access: the right to obtain confirmation from us as to whether your personal data is being processed and to obtain access to them and information, in accordance with Articles 13 and 14 GDPR.
Right to rectification: the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you; taking into account the purposes of the processing, you may have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Right to erasure: in certain situations (for example, where the personal data are no longer necessary in relation to the purposes for which they were collected or we have processed your data unlawfully), you have the right to request us to erase your personal data and we are obliged to delete the personal data without undue delay (also known as “right to be forgotten”); nevertheless, there are some exceptions to this right, as set out in Article 17 sec. 3 GDPR (e.g. further processing of personal data is necessary to establish, exercise or defend legal claims).
Right to restriction of processing: the right to obtain from us restriction of processing where one of the cases specified in Article 18 sec. 1 GDPR applies (e.g. in the event the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data); however in cases where processing has been restricted, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.
Right to data portability: when the processing is carried out in an automated manner or on the basis of consent or on the basis of a contract you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transmit those data to another controller without hindrance from us; we will help you with this – either by directly transferring your data for you or by providing you with a copy in a commonly used machine-readable format.
Right to object: to the extent that personal data is processed for purposes resulting from our legitimate interests, you have the right to object to such processing on grounds relating to your particular situation.
Right to withdraw consent: where we have obtained your consent to process your personal data, you may withdraw your consent at any time; however withdrawal of consent does not affect the legality of the processing carried out on its basis prior to its withdrawal.
Complaint to the supervisory authority
If you believe that the processing of your personal data by us violates the applicable regulations, you have the right to lodge a complaint with the supervisory authority for the protection of personal data, which in Poland is the President of the Personal Data Protection Office (address: ul. Stawki 2, 00-193 Warszawa).
Automated decision making
Your personal data is not subject to automated decision making, including profiling.
Consequences of not providing personal data
Candidate data: Providing your personal data in the recruitment application is voluntary, but in the following scope: name and surname, contact details, education, professional qualifications, the course of previous employment, it is necessary for us to carry out the recruitment process. Failure to provide this data may prevent us from considering your recruitment application.
Employees or associates of our clients and contractors: Providing your personal data is voluntary, however, failure to do so my prevent us from maintaining ongoing contact with our clients and contractors and maintaining relationships as part of our business activity.
Contacting persons: Providing personal data is voluntary, however, failure to do so may prevent us from contacting you.
Website users: Providing personal data is voluntary, however, failure to do so may hinder or prevent us from ensuring security and proper functioning of the website as well as adapting its content and operation to the needs of its users.
In connection with the use of our website, cookies and other similar technologies are collected on users’ end devices. Below we present the rules on which we use such files and technologies.
What are cookies and for what purposes do we use them?
A “cookie” is a bite-sized piece of data that is stored on your device when using the website. In most of cases cookies contain the name of the website they come from, the storage time on the end device and a unique identifier. Cookies may also contain personal data in the form of e.g. an IP address and a unique device identifier saved in the file.
If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings.
What are the types of cookies?
In connection with your use of the website, the following types of cookies may be collected:
- necessary – ensuring proper functioning of the website;
- functional – making it possible to adjust the content of the website to the user’s preferences and to optimize the use of the website;
- analytical – enabling the acquisition of analytical and statistical data related to the use of the website by the user;
- advertising – used to e.g. personalize user targeted advertising;
- security – used to monitor possible abuses related to the use of the website.
In addition to our own cookies, the website may also contain third party cookies. They are placed by external entities, e.g. suppliers of analytical tools.
Moreover, cookies described above used on the website may be permanent or session (temporary). Permanent files are saved on the end device until they are deleted by the user or until the moment indicated in the cookie file parameters. Session files remain on the user’s end device only for the duration of the website use, i.e. until turning off the website or the browser used by the user.
What types of cookies do we use on the website?
We use the following cookies on our website:
|Name of cookie||Type of cookie||Function of cookie||Retention period|
|_ga||analytical||used to distinguish users||2 years|
|_gid||analytical||used to distinguish users||24 hours|
|_gat||analytical||used to persist session state||1 minute|
How to change setting related to cookies?
Most browsers accept all cookies by default, but you may always manage the browser settings, including activating or blocking the saving of all or some cookies on your end device. Please remember, however, that the consequence of blocking cookies may be the difficulty in using certain features offered by the website.
Additional information on browser settings can be found on the websites of their producers, for example:
- Internet Explorer: https://support.microsoft.com/pl-pl/products/windows?os=windows-10
- Mozilla Firefox: https://support.mozilla.org/pl/kb/ciasteczka
- Google Chrome: https://support.google.com/chrome/answer/95647?hl=pl
- Safari browser: https://support.apple.com/pl-pl/HT201265
- Opera browser: http://help.opera.com/Linux/9.22/pl/cookies.html
and in the section “Support” (or similar) contained in the web browser used by the user.
Additional information on cookies
More information on cookies or other similar technologies can be obtained, inter alia, on the website https://www.youronlinechoices.com/ or aboutcookies.org.