1. INTRODUCTION

This document is a description of the privacy policy of Commoditech sp. z oo, with its registered office at ul. Mokotowska 1, 00-640 Warsaw (hereinafter: Commoditech). The Commoditech privacy policy (hereinafter: the Policy) defines the rules, method of processing and using data and information from candidates, clients and users of websites belonging to Commoditech: i.e. www.commoditech.pl .

Please read the Policy carefully. By accessing or using the website belonging to Commoditech and sending us any personal data in connection with applications for a conference, contest, recruitment or training, etc. and reading this Policy, the User accepts the terms of this Policy and confirms that he has read it content.

  1. TERMS USED IN POLITICS

Personal Data – means Personal Data within the meaning of the GDPR, i.e. any information about an identified or identifiable natural person that identifies a natural person directly or indirectly, in particular such as the name, e-mail address or telephone number of a natural person and other data that in combination with the above, may identify the User.

GDPR – 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 Regulation on data protection), according to which Commoditech processes Users’ Personal Data.

Specialist – a job candidate offered by Commoditech to its clients.

User – job candidate, newsletter subscriber, competition participant, person asking a question, training participant, person recommending a friend to work, person visiting websites belonging to Commoditech.

Services – should be understood as services provided by Commoditech electronically, via the website, i.e.: subscribing to the Newsletter, sending inquiries via the contact form, sending documents necessary in the recruitment process, applying for participation in competitions, applying for participation in training, setting up an account on the candidate’s portal .

III. PROVISION OF PERSONAL DATA

By providing their Personal Data on the website www.commoditech.pl and other websites belonging to Commoditech, the User confirms that they have the necessary permissions to disclose personal data that will be used by Commoditech in the manner described in this Policy.

  1. PERSONAL DATA ADMINISTRATOR

The administrator of Users’ Personal Data provided in connection with the use of Commoditech websites, in particular in connection with conducting recruitment processes using them, conducting training, sending marketing information, including newsletters, accepting subscriptions for conferences, events, using other services contained on website is Commoditech Sp. z o. o. ul. Mokotowska 1, 02-640 Warsaw, tel. 791 662 241. The recipients of the data are OVH Sp z o. o. with its registered office in Wrocław 54-402.

  1. DATA PROTECTION OFFICER

A Data Protection Officer has been appointed at Commoditech. Contact details for the Data Protection Officer: personaldata@commoditech.pl

  1. PURPOSES OF PERSONAL DATA PROCESSING AND LEGAL BASIS FOR THEIR PROCESSING

The Administrator processes Personal Data in order to:

  1. sending Users, to the e-mail addresses provided by them, commercial and marketing information, including the Commoditech newsletter, provided that the User has agreed to receive them.
    In the case of sending newsletters, the legal basis is the User’s consent to the processing of Personal Data (Article 6(1)(a) of the GDPR)Consent to sending unsolicited commercial information to Users in accordance with Art. 10 of the Act on the provision of electronic services is expressed by Users independently and separately.
  2. sending Users, to the e-mail addresses provided by them, the telephone number of answers to previously asked inquiries sent via the contact form.
    In the event of contacting the User in order to provide an answer, the legal basis for the processing of Personal Data is the consent of each User to the processing of personal data (Article 6(1)(a) of the GDPR).
  3. consideration of the job application sent by the User and possible recruitment process, after the User’s prior consent to the processing of data contained in the CV or form by Commoditech.
    In the case of processing Personal Data in order to consider a job application, the legal basis is the consent of each User to the processing of personal data (Article 6(1)(a) of the GDPR).
  4. organizing and conducting competitions by Commoditech.
    In the case of competitions, the legal basis for the processing of Personal Data is the User’s consent (Article 6(1)(a) of the GDPR).
  5. Organizing and conducting open and dedicated trainings.
    In the case of training, the legal basis for the processing of Personal Data is the contract for the provision of training services concluded with Commoditech by sending an order form (Article 6(1)(b) of the GDPR).

VII. USER RIGHTS

Pursuant to Chapter III, Art. 15-21 of the GDPR, the User has the following rights in connection with the processing of his Personal Data by Commoditech:

  1. the right to access your Personal Data,
  2. the right to rectify the processed data,
  3. the right to delete data (“the right to be forgotten”),
  4. the right to limit data processing,
  5. the right to transfer data,
  6. the right to object to further data processing,
  7. the right not to be subject to decisions based solely on automated processing, including profiling.

Each of the above rights is exercised at the User’s request. Commoditech considers the submitted application and sends a response within 1 month from the date of receipt of the application.

As part of the rights, the User may at any time withdraw consent to further processing of Personal Data for purposes that require consent, with the proviso that the withdrawal of consent does not affect the legal use of personal data in activities performed on the basis of consent before its withdrawal.

Under the right of access, the User is entitled to obtain the following information in the form of a copy:

  1. the purposes of processing Personal Data;
  2. categories of Personal Data – what data we process, e.g. name, surname, telephone number;
  3. information about the recipients or categories of data recipients – to whom (person, company, institution) the data may be transferred;
  4. information on the right to request from Commoditech rectification, deletion or limitation of their processing and to object to specific data processing;
  5. information on the possibility of lodging a complaint to the Office for Personal Data Protection;
  6. information about the data source, if the data was not obtained directly from the User – an indication of the person, company or institution that provided the Personal Data;
  7. on the use of profiling: on what terms is it undertaken, what may be the consequences of profiling for the User.

At the same time, Commoditech informs that each subsequent copy of Personal Data is associated with a fee resulting from the costs incurred in connection with the creation of another copy of Personal Data.

Commoditech stipulates that it has the option of not responding to the request or responding later than the above-mentioned (up to two months) due to the number of inquiries or the complexity of the inquiry sent. By the complex nature we mean the need to compile Data from many IT systems, the need to consult more than one person from the department or departments in order to obtain information that is the subject of the request.

In both of the above situations, Commoditech undertakes to inform the User about this fact, each time providing justification.

VIII. PROCESSING OF PERSONAL DATA FOR THE PURPOSE OF RECRUITMENT AND UNDER THE CANDIDATE REFERENCE SYSTEM

Commoditech conducts recruitment for its own needs and for clients, to whom it provides e.g. Specialist delivery services. Therefore, we would like to inform you that the User’s data may also be processed by Commoditech’s clients, about which we inform in the content of the job advertisement, indicating that we are recruiting for the client. At the same time, we would like to inform you that by agreeing to recruitment processes, this applies to recruitment for a specific position included in the job advertisement as well as for future recruitment. This means that we will store Personal Data in our database in order to send you information about job offers tailored to your profile and work experience. At any time, the User, in accordance with Chapter VII of this Policy, may withdraw consent to further processing, which does not affect the legal use of personal data in activities performed on the basis of consent before its withdrawal.

The User’s Personal Data may also be processed in the event of the User’s recommendation by the recommending person. In this situation, the recommending person enters his or her data and the recommended person’s data and places a CV under the form with the User’s data. Commoditech verifies the CV of the recommended person received from the recommending person in the scope of the recommended person’s consent to the processing of Personal Data that meets the requirements of the GDPR. If the consent has been concluded, Commoditech has the right to use this data for recruitment processes.

  1. PROCESSING OF PERSONAL DATA FOR MARKETING PURPOSES

By sending an inquiry, applying for a training, conference or other event organized by Commoditech, the User may consent to the processing of Personal Data for the purpose of sending marketing information about Commoditech’s products and services, including newsletters. Consent may be withdrawn at any time, subject to the rules set out in Chapter VII of this Policy.

  1. PROCESSING OF PERSONAL DATA WHEN ORGANIZING AND CONDUCTING TRAINING

One of the areas of Commoditech’s activity is open and dedicated training for Commoditech’s clients and any interested person. Therefore, Commoditech will process the Personal Data of Users reporting participation in training to the extent necessary to carry out matters related to training.

  1. PERSONAL DATA PROCESSING AND PROFILING

Commoditech conducts profiling understood as a form of automated processing of personal data, consisting in the use of certain data about the User. The data obtained include information from social media profiles, location, data provided by Users using forms on the Commoditech website.

This allows us to:

  • a more conscious and better matched selection of job offers, corresponding to the skills and experience of Users (in the case of candidates for a job at Commoditech),
  • matching the marketing and advertising materials sent to the interests and needs of Users.

The User may object to profiling at any time in accordance with Chapter VII of this Policy, but this involves the impossibility of sending marketing and commercial information or receiving new job offers tailored to the profile and professional experience.

XII. SAFETY RULES

Commoditech has implemented appropriate security measures (organizational and technical) to protect Personal Data against loss, misuse, unlawful processing or modification. The Administrator undertakes to protect all information disclosed by Users in accordance with the standards of security protection and confidentiality. Access to Users’ Personal Data has been restricted in a restrictive manner so that this information does not fall into the hands of unauthorized persons. Access to Personal Data is limited by the number of authorized Commoditech employees.

Commoditech is entitled to share data with entities authorized under applicable law.

XIII. COOKIES

Commoditech declares that we use cookies on the website www.commoditech.pl and other websites belonging to Commoditech. By using this website, you consent to cookies being placed on your device as explained below.
Cookies used on the website www.commoditech.pl and other websites belonging to Commoditech may be set by our website or by a third party website.
Cookies are used to:

  1. adapting the content of websites to the User’s preferences and optimizing the use of websites; in particular, these files allow to recognize the device of the website user and properly display the website, tailored to his individual needs,
  2. creating statistics that help to understand how website users use websites, which allows improving their structure and content,
  3. providing users with advertising content more tailored to their interests.

Types of cookies used by Commoditech:

  • “necessary” cookies, enabling the use of services available on the website, e.g. enabling the use of sessions;
  • “functional” cookies, enabling “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, enabling monitoring of Users’ activity on the website.

The user has the option of blocking the saving of cookies by changing the web browser settings accordingly. Disabling cookies may affect the functioning of the website. If you do not change your browser settings, you accept the cookies used.

XIV. CHANGE OF POLICY

Due to the development and progress of technology and changing legal regulations, the rules set out in this Privacy Policy may change. The User will be informed about the change of these rules by posting the new content of this document on the website www.commoditech.pl/RODO/polityka-aktywnosci