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PRIVACY POLICY OF THE STRIX WEBSITE





This Privacy Policy (hereinafter: "Policy") contains information on the processing of your personal data in connection with the use of the website operating at: www.strix.net (hereinafter: "Website").



Administrator of your personal data



The administrator of your personal data is Strix Poland spółka z ograniczoną odpowiedzialnością with its registered office in Kraków (address: ul. Zygmunta Miłkowskiego 5 lok. 3U, 30-349 Kraków), entered into the Register of Entrepreneurs of the National Court Register kept by the District Court for Kraków-Śródmieście in Kraków, XI Economic Division of the National Court Register under KRS no.: 0000291014, holding NIP: 6762358772, REGON no.: 120553861, holding share capital of PLN 154,000.00 (one hundred fifty-four thousand zlotys) (hereinafter: "Administrator").



Contact with the Administrator



In all matters related to the processing of personal data, you can contact the Administrator by e-mail at: kontakt@strix.net.



Data Protection Officer



You can contact the Data Protection Supervisor appointed by the Administrator - Ms. Ewelina Suchodolska - by e-mail, at: ewelina.suchodolska@strix.net.



Personal data protection measures



The Administrator uses modern organisational and technical safeguards to ensure the best possible protection of your personal data and ensures that it is processed in accordance with the provisions 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: "RODO"), the Act of 10 May 2018 on the protection of personal data and other data protection legislation.



Information about the personal data processed



The use of the Website requires the processing of your personal data. Below you will find detailed information about the purposes and legal grounds for the processing, as well as the duration of the processing and the obligation or voluntariness to provide it.











Purpose of processing:



To carry out the recruitment of candidates for employment on the basis of an employment contract



Personal data processed:



first name(s) and surname



date of birth



contact details you have provided (e.g. home address, e-mail address, telephone number)



education



professional qualifications



previous employment history (career history, training, courses, certificates)



optionally - additional data you choose to provide, e.g. your photograph and data stored on your LinkedIn profile



Legal basis:



as regards the data indicated in points 1-6:



Article 6(1)(c) RODO (the processing is necessary for the fulfilment of a legal obligation incumbent on the Administrator, in this case the obligation arising from Article 22(1) § 1 of the Labour Code)



with regard to the data indicated in point 7 and data processed for future recruitment:



Art. 6(1)(a) RODO



(processing takes place on the basis of the consent you have given).



The provision of the personal data indicated in points 1-6 is mandatory, pursuant to Article 22(1) § 1 of the Labour Code. The provision of other personal data is voluntary.



When the Administrator contacts you via LinkedIn, this service is the source of the Administrator's acquisition of your personal data, which you have recorded on your profile on this service.



The Administrator will process the above personal data:



in relation to data processed for the purposes of the currently ongoing recruitment - until the currently ongoing recruitment has ended;



with regard to the data processed for the purposes of future recruitment - until the expiry of the period of validity of your consent to the processing of personal data or its withdrawal (depending on which of the aforementioned events occurs first).











Purpose of processing:



To recruit candidates for employment under a civil law contract (including but not limited to service contracts, contracts for specific work).



Personal data processed:



date of birth



contact details you have provided (e.g. home address, e-mail address, telephone number)



education



professional qualifications



previous employment history (career history, training, courses, certificates)



optionally - additional data you choose to provide, e.g. your photograph and data stored on your LinkedIn profile



Legal basis:



Article 6(1)(a) RODO (processing takes place on the basis of your consent).



The provision of the aforementioned personal data is voluntary but necessary in order to take part in the recruitment conducted by the Administrator (the consequence of failing to do so will be the inability to take part in the recruitment).



The Administrator will process the above personal data:



in relation to data processed for the purposes of the currently conducted recruitment - until the end of the currently conducted recruitment;



with regard to data processed for future recruitment - until the expiry of the period of your consent to the processing of personal data or its withdrawal (whichever occurs first).











Purpose of processing:



Sending commercial information (newsletter).



Personal data processed:



e-mail address



Legal basis:



Article 6(1)(f) RODO



(processing is necessary in order to pursue the legitimate interest of the Administrator, in this case to carry out direct marketing).



The provision of an e-mail address is voluntary but necessary in order to receive the newsletter (the consequence of not providing it will be the inability to receive the newsletter).



In the event that the Administrator contacts you via LinkedIn, this service is the source of the Administrator's acquisition of your personal data that you have saved on your profile on this service.



The Administrator will process your email address until you successfully object or the purpose of the processing is achieved (whichever comes first).









Purpose of processing:



To operate the chat form.



Personal data processed:



data contained in the message sent via the chat form



Legal basis:



Article 6(1)(f) RODO



(processing is necessary in order to pursue the legitimate interest of the Administrator, in this case to respond to an enquiry received).



The provision of the aforementioned personal data is voluntary, but necessary in order to receive a response to an enquiry (the consequence of failing to do so will be the inability to receive a response).





The Administrator will process the above personal data until an effective objection is lodged or the purpose of the processing is achieved (whichever comes first).











Purpose of processing:



Provision of free content (including but not limited to ebooks).



Personal data processed:



e-mail address



company name.



Legal basis:



Article 6(1)(f) RODO



(processing is necessary for the purposes of the Administrator's legitimate interest, in this case the provision of free content in connection with direct marketing).



The provision of the aforementioned personal data in order to receive free content is voluntary. If you wish to receive free content without providing your personal data, you can request your personal data from the Administrator by email.







The Administrator will process the aforementioned personal data until you successfully object or the purpose of the processing is achieved (whichever comes first).











Purpose of processing:



Fulfilment of tax obligations (e.g. issuing VAT invoices, keeping accounting records)



Personal data processed:



name/company



address of residence/site



NIP



Legal basis:



Article 6(1)(c) RODO



(processing is necessary to fulfil a legal obligation incumbent on the Administrator, in this case obligations under tax law).



The provision of the above personal data is mandatory in order for the Administrator to comply with its tax obligations.



The Administrator will process the above personal data for a period of 5 years from the end of the year in which the deadline for payment of tax for the previous year expired.











Purpose of processing:



To comply with data protection obligations



Personal data processed:



name/company



contact details you have provided (e-mail address; mailing address; telephone number)



Legal basis:



Article 6(1)(c) RODO



(processing is necessary for the fulfilment of a legal obligation incumbent on the Administrator, in this case obligations under data protection legislation).



The provision of the aforementioned personal data is voluntary, but necessary for the Administrator to properly perform its duties under the data protection legislation, including the exercise of the rights granted to you by the RODO (the consequence of failing to provide the aforementioned data will be the inability to properly exercise the aforementioned rights).



The Administrator will process the aforementioned personal data until the expiry of the statute of limitations for claims for breach of data protection legislation.









Purpose of processing:



Establishing, investigating or defending against claims



Personal data processed:



first name



surname



company



e-mail address



residential/residential address



PESEL/KRS number



NIP



Legal basis:



Article 6(1)(f) RODO





(processing is necessary for the purposes of the Administrator's legitimate interest, in this case to establish, investigate or defend against claims that may arise in connection with the performance of contracts concluded with the Administrator).



Provision of the aforementioned personal data is voluntary, but necessary in order to establish, assert or defend against claims that may arise in connection with the performance of contracts concluded with the Administrator (the consequence of failing to provide the aforementioned data will be the Administrator's inability to take the aforementioned actions)





The Administrator will process the aforementioned personal data until the expiry of the limitation periods for claims that may arise in connection with the performance of contracts concluded with the Administrator.











Purpose of processing:



Analysis of your activity on the Website



Personal data processed:



date and time of visit



IP number of the device



type of operating system of the device



approximate location



type of Internet browser



time spent on the Website



subpages visited and other actions taken on the Website



Legal basis:



Article 6(1)(f) RODO



(processing is necessary in order to pursue the legitimate interest of the Administrator, in this case to obtain information about your activity on the Website).



The provision of the aforementioned personal data is voluntary but necessary in order for the Administrator to obtain information about your activity on the Website (the consequence of failing to do so will be the Administrator's inability to obtain the aforementioned information).





The Administrator will process the above personal data until you successfully lodge an objection or the purpose of the processing is achieved (whichever comes first).











Purpose of processing:



Administration of the Website



Personal data processed:



IP address;



server date and time;



web browser information;



information about the operating system.



The above-mentioned data are recorded automatically in so-called server logs every time the Website is used (administration of the Website without the use of server logs and automatic recording would not be possible).



Legal basis:



Article 6(1)(f) RODO





(processing is necessary for the Administrator's legitimate interest, in this case to ensure the proper operation of the Website).



The provision of the aforementioned personal data is voluntary, but necessary in order to ensure the proper operation of the Website (the consequence of failing to provide such data will be the inability to ensure the proper operation of the Website).





The Administrator will process the aforementioned personal data until an objection is successfully raised or the purpose of the processing is achieved (whichever comes first).











Profiling



In order to create your profile for marketing purposes and to target you with direct marketing tailored to your preferences, the Administrator will process your personal data by automated means, including profiling - but this will not have any legal effect on you or similarly significantly affect you.



The extent of the personal data profiled corresponds to that indicated above in relation to the analysis of your activity on the Website.



The legal basis for the processing of personal data for the above purpose is Article 6(1)(f) of the RODO, according to which the Administrator may process personal data in order to pursue its legitimate interests, in this case to carry out marketing activities tailored to the preferences of the recipients. The provision of the aforementioned personal data is voluntary but necessary for the fulfilment of the aforementioned purpose (the consequence of failing to provide such data will be the Administrator's inability to conduct marketing activities tailored to the recipients' preferences).



The Administrator will process personal data for the purpose of profiling until an effective objection is lodged or the purpose of the processing is achieved (whichever comes first).







Recipients of personal data



The recipients of the personal data will be the following external entities working with the Administrator:



domain provider;



email service provider;



provider of the chat form;



newsletter sign-up form provider;



provider of the application used to manage recruitment activities;



data hosting service providers;



Companies providing tools to analyse activity on the Website and direct marketing to visitors (including Google Analytics);



IT service provider;



accounting firm;



law firm.

In addition, personal data may also be transferred to public or private entities if such an obligation arises from generally applicable legislation, a final court judgment or a valid administrative decision.







Transfer of personal data to a third country



In connection with the Administrator's use of services provided by Google LLC (including Google Analytics and Google Ads), your personal data may be transferred to the following third countries: UK, Canada, USA, Chile, Brazil, Israel, Saudi Arabia, Qatar, India, China, South Korea, Japan, Singapore, Taiwan (Republic of China), Indonesia and Australia. The basis for the transfer of data to the aforementioned third countries is:



in the case of the UK, Canada, Israel and Japan, decisions of the European Commission finding an adequate level of protection for personal data in each of the aforementioned third countries;



in the case of the USA, Chile, Brazil, Saudi Arabia, Qatar, India, China, South Korea, Singapore, Taiwan (Republic of China), Indonesia and Australia - contractual clauses providing an adequate level of protection in accordance with the standard contractual clauses set out in Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries under Regulation (EU) 2016/679 of the European Parliament and of the Council.



You can obtain a copy of data transferred to a third country from the Controller.





Rights



In relation to the processing of your personal data, you have the following rights:



The right to be informed which personal data concerning you are processed by the Controller and to receive a copy of that data (the so-called right of access). The issue of the first copy of the data is free of charge, for subsequent copies the Administrator may charge a fee;



if the data processed becomes outdated or incomplete (or otherwise incorrect) you have the right to request rectification of the data;



in certain situations you may request the Administrator to delete your personal data, e.g. when:



you no longer need the data for the purposes notified to the Administrator;



you have effectively withdrawn your consent to the processing of the data - unless the Administrator is entitled to process the data on another legal basis;



the processing is unlawful;



the need to erase the data arises from a legal obligation on the Administrator;



where your personal data are processed by the Administrator on the basis of your consent to the processing or for the performance of a Contract with the Administrator, you have the right to transfer your data to another controller;



where personal data is processed by the Controller on the basis of your consent to processing, you have the right to withdraw that consent at any time (withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal);



if you consider that the processed personal data is incorrect, its processing is unlawful, or the Administrator no longer needs certain data, you can request that for a certain, necessary period of time (e.g. to verify the correctness of the data or to assert claims) the Administrator does not perform any operations on the data, but only stores them;



you have the right to object to the processing of personal data based on the legitimate interest of the Administrator. If you successfully lodge an objection, the Administrator will stop processing your personal data for the aforementioned purpose;



you have the right to lodge a complaint with the President of the Personal Data Protection Authority if you consider that the processing of your personal data violates the provisions of the RODO.





Cookies



The Administrator informs you that the Website uses "cookies" (cookie files), installed in your terminal device. These are small text files which can be read by the Administrator's system, as well as by systems belonging to other entities whose services are used by the Administrator (e.g. Google).



The Administrator uses cookies for the following purposes:



ensuring proper functioning of the Website - thanks to cookies, it is possible for the Website to function smoothly, to use its functions and to move comfortably between individual sub-pages;



Increasing comfort of browsing the Website - thanks to cookies it is possible to detect errors on some subpages and constantly improve them;



creation of statistics - cookies are used to analyse how users use the Website. This makes it possible to continuously improve the Website and to adapt its operation to the preferences of users;



conducting marketing activities - thanks to cookies, the Administrator can direct advertisements to users tailored to their preferences.



The Administrator may place both permanent and temporary (session) files on your device. Session files are usually deleted when the browser is closed, while closing the browser does not delete permanent files.



Information about the cookies used by the Administrator is displayed in the panel at the bottom of the Website. Depending on your decision, you can enable or disable cookies of particular categories (except for essential cookies) and change these settings at any time.



The data collected through cookies do not allow the Administrator to identify you.





The Administrator uses the following cookies or tools that use them:



TOOL: Essential cookies



SUPPLIER: Administrator



FUNCTIONS AND SCOPE OF DATA COLLECTED:



The operation of these cookies is essential for the proper functioning of the Website, so you cannot disable them. Thanks to these cookies (which collect, among other things, your device's IP number), it is possible, among other things, to inform you of cookies operating on the Website.



PERIOD OF OPERATION: Most of the necessary cookies are of a session nature, but some remain on your terminal device for a period of 12 months or until they are deleted;









TOOL: Google Analytics



PROVIDER: Google



FUNCTIONS AND SCOPE OF DATA COLLECTED:



This tool enables the collection of statistical data about how users use the Website, such as the number of visits, duration of visits, search engine used, location, among others. The data collected helps to improve the Website and make it more user-friendly.



PERIOD OF OPERATION: Up to 2 years or until they are deleted (whichever comes first).







Through most commonly used browsers, you can check whether cookies have been installed on your terminal device, as well as delete installed cookies and block future installation of cookies by the Website. However, disabling or restricting cookies may cause quite serious difficulties in using the Website, e.g. in the form of longer loading times for the Website or restrictions on the use of certain functionalities.







Final provisions



To the extent not regulated by the Policy, generally applicable data protection regulations shall apply.



The Policy is effective as of 12.12.2022.