PRIVACY POLICY - personal data of job applicants -

1. Who we are and how to find us

The controller of your personal data is INUITS spółka z ograniczoną odpowiedzialnością with its registered seat in Kraków (address: ul. Krupnicza 5/1, 31-123 Kraków), entered into the registry of entrepreneurs of the National Court Register by the District Court for Kraków-Śródmieście in Kraków, XI Commercial Department of the National Court Register, under the number: 0000792510, having Tax Identification Number: 6762567702 and Statistical Number: 383659794 (hereinafter referred to as: „Inuits” or “We” or “Controller”).

You can contact us by e-mail to the address: hello@inuits.it

2. Why do we process your personal data

As we consider you a suitable candidate, we process your personal data in order to ensure your participation in the recruitment process.

We may process your data in order to:

  1. contact you and conduct the recruitment process,

  2. evaluate your qualifications for work at the position you are applying for,

  3. evaluate your abilities and skills necessary to work at the position you are applying for,

  4. match characteristics of a specific person with a potential employer and choose the right person to work at a given position,

  5. ensure your participation in future recruitment processes.

Please mind, that we may also store and process your personal data for the purposes of future recruitment processes to similar positions at Inuits.

3. What personal data do we process

We process the following data of job applicants:

a) name(s) and surname;

b) date of birth;

c) contact details indicated by such a person (e.g. correspondence address, e-mail address, telephone number);

d) education;

e) professional experience;

f) employment history;

g) other personal data contained in your application documents such as CV, motivation letter, letter of reference or other (e.g. your image);

h) personal data made publicly available on business or professional social media (LinkedIn);

i) other personal data acquired during an interview to the extent permitted by law.

Personal data of job applicants indicated in points d) – f) above may be asked for only when required to perform work of a specific type or in a specific position. At Inuits, we need to analyze your education, professional qualifications and employment history to understand if you will be able to perform your future responsibilities successfully.

We may ask for other data than those mentioned in points a) – f) above only if it is necessary to exercise rights or to fulfil an obligation arising from the law provision. However, they still can be processed under your consent.

The legal basis for the processing of your personal data is:

  1. in relation to personal data mentioned under points from a) to f) above – a provision of law (Article 221 of the Polish Labour Law) and the necessity of processing to take steps at the request of the data subject prior to entering into a contract (Article 6 section 1 letter b) of the GDPR);

  2. in relation to personal data mentioned under point g) above – your consent (Article 6 section 1 letter a) of the GDPR). You can withdraw your consent at any time by contacting us via email (without affecting the lawfulness of processing based on consent before its withdrawal);

  3. in relation to personal data mentioned under point h) above – the necessity of processing for the purposes of pursuing our legitimate interests (Article 6 section 1 letter f) of the GDPR). We have a legitimate interest in actively searching for potential job candidates by looking through their publicly available profiles on business or professional social media because otherwise we would not be able to judge whether you might be interested in a given position.

We hope that you do not consider our activities as violating your rights and freedoms. We make every effort to ensure that our activities do not include unnecessary data and do not surprise you. After all, creating a profile in social media of a business or professional nature, taking part in events of this type and engaging in online discussions on topics related to us, you can expect that potential employers will contact you!

  1. in relation to personal data mentioned under point i) above – the necessity of processing for the purposes of pursuing our legitimate interests (Article 6 section 1 letter f) of the GDPR). We have a legitimate interest in verifying your skills and abilities – it is necessary to assess whether you are the right person for the position we are recruiting for.

If the data you provide to us includes sensitive data, we may process it only on the basis of your express and separate consent. The consent may be revoked at any time by contacting us at via email (without affecting the lawfulness of processing based on consent before its withdrawal). In the absence of the consent data will be deleted immediately.

We may also process your personal data for the purposes of future recruitment processes. You can give your consent to participate in future recruitment processes both when sending your application for a specific position and later already during the recruitment process or other interviews with Inuits. You can withdraw your consent at any time by contacting us by email (without affecting the lawfulness of processing based on consent before its withdrawal).

4. To whom we disclose your personal data

The recipients of your personal data may be our clients to whom we provide recruitment services. Since it is our clients who make the final decisions whether to present you a job or not, we may provide them with information such as your application documents or your contact details in order to verify your candidature or conduct a telephone interview. These entities act as independent controllers and the transfer of data is based on your consent (Article 6 section 1 letter a) of the GDPR). We will always ask for your consent before we send any of your data to our client. You can withdraw your consent at any time by contacting us by email (without affecting the lawfulness of processing based on consent before its withdrawal).

We may entrust some of your personal data to our suppliers of services or different tools that are very useful and make our everyday work far easier. Therefore in this case the transfer of data is based on the legitimate interest that we have in optimizing our internal processes in order to provide our services more efficiently. These entities act either as controllers who manage your data independently or as processors who process your data on behalf of and for the purposes set by us on the basis of relevant entrustment agreement of personal data processing.

The operations described above may involve (due to the location of some entities’ headquarters or servers) the transmission of your data to the so-called third countries (outside the European Economic Area), where the GDPR is not applicable. However, this always happens on the basis of legal instruments provided for in the GDPR, guaranteeing adequate protection of your rights and freedoms.

In the case of the transfer of personal data to a third country within the meaning of the GDPR, when the European Commission has not issued a decision on the adequate protection of personal data for those countries (in accordance with Article 45 of the GDPR), we take appropriate measures to ensure an adequate level of data protection in the event of transfer. These include the European Union's standard contractual clauses or binding internal data protection regulations. In cases where this is not possible, we base the transfer of data on the exceptions described in Article 49 of the GDPR, in particular express consent or the necessity of the data transfer to fulfil the terms of the contract or to perform pre-contractual activities. The legal basis for data transfers to third countries is therefore, unless otherwise stated, the consent referred to in Article 6 section 1 letter a) of the GDPR in conjunction with Article 49 section 1 letter a) of the GDPR. At the same time, we would like to inform you that in the case of sending data to a third country for which there is no decision on adequate protection of personal data or adequate guarantees, there is a possibility and risk that authorities in the third country in question (for example, intelligence services) will gain access to the transferred data for the purpose of collection and analysis, and that the possibility of enforcing the rights of data subjects cannot be guaranteed.

5. How long do we process your personal data

Your personal data is processed until the end of the recruitment process related to the position for which you are applying. After this time they are delated, unless you expressed your consent for processing your personal data for the purposes of future recruitment processes (in such case you data will be stored for up to 24 months).

Sensitive data that we have received from you without an explicit and separate consent for its processing will be deleted immediately.

In the event when we obtain your personal data from publicly available sources (social media of a business or professional nature, like LinkedIn), we contact you no later than 30 (thirty) days from obtaining the data (in accordance with Article 14 section 3 of the GDPR).

The processing of your other data based on consent, as a legal premise, continues until you withdraw your consent.

6. What are your rights and how to exercise them

You have many rights that will allow you to influence the way we process your personal information. These rights are:

  1. the right of access by the data subject (regulated in Article 15 of the GDPR)

  2. right to rectification of your data (regulated in Article 16 of the GDPR)

  3. right to erase your data (regulated in Article 17 of the GDPR)

  4. right to restrict of processing of your data (regulated in Article 18 of the GDPR)

  5. right to data portability of your data (regulated in Article 20 of the GDPR)

  6. right to object to the processing of your data (regulated in Article 21 of the GDPR)

To the extent that your data is processed on the basis of consent you have the right to withdraw your consent for data processing at any time (Article 7 section 3) of the GDPR). The withdrawal of consent does not affect the lawfulness of the processing that was carried out on the basis of your consent before the withdrawal.

To use any of the rights described above, please contact us by email.

7. Complaint to the supervisory authority

If you are the person to whom the GDPR applies pursuant to Article 77 of the GDPR you are entitled to submit a complaint to the supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place where the alleged violation is committed, if you believe that the processing of personal data regarding you violates the provisions of the GDPR.

In Poland, the supervisory body is the President of the Office for Personal Data Protection. You can make a complaint, among others by traditional mail to the following address: ul. Stawki 2, 00-913 Warsaw or electronically through portal ePUAP2. You can also get more detailed information on the website: https://uodo.gov.pl/en

To contact another supervisory authority responsible for the protection of personal data, please visit the website of the European Data Protection Board available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en

8. Is the provision of data necessary to work with us

At this point we do not conclude any agreement with you. However, in order to participate in the recruitment process you need to provide your personal data at least within the scope resulting from labour law. Provision of other data is voluntary.

9. How do we find your data

The recruitment process consists of two stages that are important from the perspective of protection of your personal data.

Usually, we actively search for job candidates looking through profiles made publicly available on LinkedIn, and that is where we first obtain your personal data. Another possibility is that you contacted us on your own via e-mail, social media or in a different way. In such case we may still examine your profile on social media of business or professional nature in order to verify your experience, specialization and usefulness for a specific tasks.

If you accept our invitation sent via LinkedIn, we contact you by e-mail and ask for CV. The next stage is that we invite you to a job interview. During the interview we chat with candidates, we do not verify their abilities and skills through tests or grade them with a checklist. In the course of those further steps of the recruitment process we may acquire other personal data.

10. Automated decision-making and profiling

We do not make decisions in an automated manner or subject any personal data to profiling as understood by the GDPR.