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Privacy policy

PRIVACY POLICY

  1. Who we are and how to find us

My name is Alessandro Lombardi (I use the IT brand Selecta in my business) and I am the administrator of your personal data. Our office is located in Krakow (Poland) at ul Rynek Kleparski 4/19a ,31-150 Krakow . You may also contact me via e-mail to info@itselecta.com or by calling +48/517484382.

 

  1. Why do I proces your personal data

If I consider you a good job candidate for my client, I process your personal information in order to ensure your participation in recruitment

Such recruitment is divided into two stages, important from the point of view of protection of your personal data. At the beginning, sometimes it is us who search for you (for example on LinkedIn). At this point you are not aware yet that we are processing your data, but this is something we have to do – otherwise we would not be able to assess if you might be interested in the position, nor could we contact you. Our work consists in matching employers with candidates. Processing is therefore necessary for purposes arising from legitimate interests pursued by the controller of personal data, that is ourselves (Article 6(1)(f) of GDPR). I hope that you will not regard our actions as violating your rights and freedoms. We make every effort to ensure that this first stage of our work lasts as short as possible, does not include unnecessary data, nor does it surprise you. By creating a profile in social media of a business or professional nature, taking part in similar events, and getting involved in online discussions on the topics of importance to us – you can expect that more than one head-hunter will surely be interested in you (as a good specialist)!

You are fully aware when taking part in the next stage of recruitment. We contact you, write an e-mail, and invite you for an interview. At the first contact we provide you with all information contained in this Privacy Policy (e.g. by sending you a link via email) and ask for your consent to the processing of your data for specific purposes. If you agree – we base further data processing on your consent (Article 6(1)(a) of GDPR). If you do not agree – we remove your data from our database.

After obtaining a separate consent, we may process your personal data also for marketing purposes (e.g. to invite you to events organized by ourselves or to send you a newsletter).

You may withdraw the consent at any time (without affecting the lawfulness of the processing which was made on the basis of the consent prior to its withdrawal) by sending an e-mail to the address from which we contacted you or to the address info@itselecta.com. You may also withdraw your consent by calling +48-517484382, in which case please keep in mind that we handle phones on our office opening days and hours (from Monday to Friday, 9.00-17.00 CET) and we will need to verify if this is you who is calling us, in order to avoid the situation of withdrawing the consent of a different person than the one actually contacting us… 

If you are my client, I process your personal data in order to perform the contract concluded with you and for tax purposes.

The legal basis for processing of your personal data is therefore Art. 6(1)(b) of GDPR (processing is necessary for performance of the contract to which the data subject is a party, or to take action at the request of the data subject before concluding the contract), and Art. 6(1)(c) of GDPR (processing is necessary to fulfill the legal obligation of the administrator).

 

In addition, the legal basis for processing of your personal data by myself is Article 6(1)(f) of GDPR (processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child). Such legitimate aim is providing myself with the opportunity to prove in the event of a dispute with you the contents of the contract entered by yourself and us, and that I have performed it in a diligent manner.

If you are an employee of our client, I process your personal data; otherwise, I would not be able to perform a contract between myself and your employer (hence, the goal is only to cooperate with your company).

Such processing is necessary for purposes arising from legitimate interests pursued by the administrator (Art. 6(1)(f) of GDPR). I hope that you will not regard our actions as violating your rights and freedoms. I use my best endeavours to process only the personal data which is necessary to us, preferably provided directly by yourself. If your employer has sent us more of your data than you think is appropriate – please advise us (see item 6).

 

  1. What personal data do I process

I process the following personal data of candidates:

1)            name and surname;

2)            address for correspondence;

3)            email address;

4)            telephone number;

5)            education;

6)            course of previous employment (including type of contract, type and amount of remuneration, availability);

7)            data contained in profiles on social media of a business or professional nature (e.g. LinkedIn, GitHub, or Facebook thematic groups).

I process the following personal data of clients:

1)            names and surnames;

2)            e-mail address;

3)            telephone number;

4)            address of business activity;

5)            Tax Identification Number /NIP/;

6)            company name;

7)            Business Identification /REGON/ number;

I process the following personal data of employees and representatives of the clients:

1)            name and surname;

2)            e-mail address

  1. To whom I disclose your personal information

If I consider you a suitable job candidate for my client, I will disclose your personal information to the employer at the last stage of recruitment. I am not able to determine in advance in this Privacy Policy what type of entity it may be. Of course, before disclosing your data to any employer, I will ask for your consent.

Your personal data is processed in the IT system, located in part in the so-called cloud computing. All programmes which we use for this purpose are provided by renowned manufacturers, and personal data is secured to the highest standards. Currently, IT Selecta uses MS Office 365 software. Technical support of the IT system is provided by a local (Krakow based) IT service provider. When you provide these services, you may have access to your personal information.

In addition, your personal data will be disclosed to a third party providing myself with accounting and tax services.

If you are our client, I disclose your personal data to the extent required by state administration bodies authorized to do so by law (such as tax authorities).

I may also disclose your data to candidates who I have sourced for you.

Your personal data is processed in the IT system, located in part in the so-called cloud computing. All programmes which we use for this purpose are provided by renowned manufacturers, and personal data is secured to the highest standards. Currently, IT Selecta uses MS Office 365 software. Technical support of the IT system is provided by a local (Krakow based) IT service provider. When you provide these services, you may have access to your personal information.

In addition, your personal data will be disclosed to a third party providing me with accounting and tax services.

If you are an employee of my client, you should know that your personal data is processed by me in the IT system, located in part in the so-called cloud computing. All programmes which we use for this purpose are provided by renowned manufacturers, and personal data is secured to the highest standards. Currently, IT Selecta uses MS Office 365 software. Technical support of the IT system is provided by a local (Krakow based) IT service provider. When providing these services, the provider may have access to your personal information.

 

  1. For how long am I going to proces your personal data?

As you probably remember from item 1, I process personal data of candidates in two stages. The first stage, in which data is processed without your knowledge, lasts only as short as it is necessary (no longer than a month). Next, I process the data only with your consent.

I use my best endeavours to keep your data up-to-date. To this end, we contact you at least once every 24 months for an update. If for some reason we are unable to contact you within this period, your personal data will be deleted after 24 months from obtaining consent for its processing.

As my client, please be aware that we will process your personal data for as long as it is necessary for tax purposes, that is – in accordance with the current provisions of the Polish law – for 5 fiscal years. You probably know that five fiscal years may in fact mean six, and sometimes almost seven calendar years.

If I cooperate with you on a permanent basis, of course, some of your data will be processed throughout the entire period of such cooperation.

If you are an employee of my client, your personal data (especially those contained in e-mail correspondence) may be processed by us for the same period as the data of your employer.

  1. How do I enable you to exercise your rights

I use my best endeavours to ensure you are satisfied working with us. Please bear in mind, however, that you are entitled to a number of privileges which will allow you to influence the manner in which I process your personal information, and in some cases cause cessation of such processing. These rights are:

 

 the right to access personal data (regulated in Article 15 of GDPR)

 the right to rectify data (regulated in Article 16 of GDPR)

 the right to erase data (regulated in Article 17 of GDPR)

 the right to limit processing (regulated in Article 18 of GDPR)

 the right to object to the processing (regulated in Article 21 of GDPR)

 the right to transfer data (regulated in Article 20 of GDPR)

 

In order to exercise any of the indicated rights, please contact us by e-mail to the address we contacted you from, or the address info@itselecta.com. For this purposes, you may also contact us by calling +48/517484382.

 

  1. Lodging a complaint with a supervisory authority
  2. Pursuant to Art. 77 of GDPR you are entitled to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work, or the place where the alleged violation has been committed, if you believe that processing of your personal data violates the provisions of the GDPR. In Poland the supervisory authority is the President of the Office for Personal Data Protection – you may make such complaint, among others, by means of regular mail to the address [_] or by e-mail to the address [_], you may also obtain more detailed information (including valid phone numbers) on the website:[_] .

 

 Do I need to provide my data in order to conclude a contract?

If you are my client, this part of the privacy policy may be of interest to you.

I collect your personal data within the scope necessary to conclude and perform a contract. A part of data is also necessary to fulfill my obligations under the law (tax regulations, accounting regulations). Failure to provide your personal data will, unfortunately, prevent conclusion and execution of a contract.

 

  1. Where do I obtain your personal information from

My job consists in matching employers with candidates. This requires searching and reaching candidates (such as yourself) in many different ways.

Perhaps you have responded to our job advertisement using the application form on the website or by emailing us. In such case you have provided us with the first handful of data. However, we may want to supplement it with the data from publicly available sources, i.e. by browsing your business (professional) profile in social media (e.g. on LinkedIn, GitHub, or even Facebook, if you are involved in thematic groups related to the IT or HR industries).

Perhaps, however, it was us who first have found you before making contact. In this case we could obtain information about you from publicly available sources, i.e. by browsing your business (professional) profile in social media (e.g. on LinkedIn, GitHub, or even Facebook, if you are involved in thematic groups related to the IT or HR industries) or from other people in the IT or HR industries who have recommended you as a great specialist.

I collect personal data of my clients only from the clients themselves.

I collect personal data of employees of my clients only from the clients themselves.

  1. Automated processing and profiling

I do not process your data in an automated way or perform profiling of such data in the sense accepted by GDPR.


CONTENT OF THE NOTICE REQUIRED PURSUANT TO ARTICLE 21(4) OF GDPR

 

Guided by the content of Article 21(4) of GDPR, as well as guidelines of the Article 29 Working Party contained in the Guidelines on Transparency under Regulation 2016/679, IT Selecta, at the latest, upon first communication with the data subject, shall expressly inform such person about the rights referred to in Article 21(1) and (2) of GDPR. The following information is presented clearly and separately from any other information.

 

Alessandro Lombardi using the IT Selecta brand (hereinafter “IT Selecta”) informs that:

  1. You have the right to object at any time – for reasons related to your particular situation – to the processing of your personal data concerning pursuant to Art. 6(1)(e) or (f) of GDPR*, including profiling on the basis of these provisions. In this case IT Selecta may no longer process such personal data unless it demonstrates the existence of important and legitimate grounds for processing which override your interests, rights, and freedoms, or grounds for establishing, investigating or defending claims.

 

  1. If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data concerning for such marketing purposes, including profiling, to the extent to which the processing is related to such direct marketing.

*Content of Art. 6(1)(e) and (f) of GDPR is as follows:

  1. Processing is lawful only in cases where – and to the extent that – at least one of the following conditions is met:

(…)

(e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

(f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.