GDPR Information Clause

Pursuant to Article 13(1) and (2) 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, “GDPR”), I hereby inform you that:

1. Data Controller
   The controller of your personal data is NAJ International Sp. z o.o., Rondo ONZ 1, 00-124 Warsaw, Poland, Tax Identification Number (NIP): 5210090012 (the “Controller”).
2. Purpose and Legal Basis of Processing
   Your personal data will be processed for the purpose of conducting recruitment processes carried out by the Controller for positions offered by the Controller’s clients, as well as for presenting anonymised candidate profiles to potential employers. Your data may also be processed for the purpose of securing and, if necessary, establishing, pursuing or defending against claims related to the recruitment process.

The legal basis for the processing of your personal data is Article 6(1)(a) of the GDPR, i.e. your freely given, specific, informed and unambiguous consent expressed by submitting your application to participate in a recruitment process conducted by the Controller. Providing personal data is voluntary; however, it is necessary in order to participate in the recruitment process conducted by the Controller.

1. Confidential (Hidden) Recruitment Process
   The Controller conducts recruitment processes in the form of so-called confidential (hidden) recruitment, in which, at the initial stage, the identity of the potential employer is not disclosed. Information about candidates is shared with the potential employer in anonymised form, preventing both direct and indirect identification of candidates.

Personal data enabling your identification will not be disclosed to a potential employer without your separate and explicit consent. If a potential employer expresses interest in your profile, you will be informed of the employer’s identity and asked to provide separate consent to disclose your personal data. Upon granting such consent, the potential employer will become an independent controller of your personal data and will fulfil its information obligations towards you in accordance with Article 14 of the GDPR.

1. Future Recruitment and Marketing Purposes
   If you provide separate voluntary consent in the application form, your personal data may also be processed:
   • for the purposes of future recruitment processes;
   • for marketing purposes (legal basis: Article 6(1)(a) GDPR).
2. Recipients of Personal Data
   Recipients of your personal data will be entities with whom the Controller has concluded recruitment agreements, solely upon obtaining your written consent.

Your personal data may also be processed by entities providing the Controller with IT system support, recruitment tools, and legal services, exclusively on the basis of appropriate data processing agreements and in compliance with applicable data protection laws.

Your personal data will not be transferred to third countries outside the European Economic Area unless you are informed separately thereof.

1. Data Retention Period
   Your personal data will be retained until the completion of the specific recruitment process or until you withdraw your consent. After completion of the recruitment process, your data will be retained for the period resulting from your consent to participate in future recruitment processes or, irrespective of the withdrawal of consent, for the period necessary to establish, pursue or defend against potential claims related to participation in the recruitment process, but no longer than until the expiry of the applicable statutory limitation periods under generally binding law.
2. Your Rights
   You have the right to access your personal data and to request rectification, erasure, restriction of processing, and data portability, as well as the right to object to processing and the right to withdraw your consent at any time, without affecting the lawfulness of processing carried out on the basis of consent before its withdrawal.
3. Right to Lodge a Complaint
   You have the right to lodge a complaint with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych) if you believe that the processing of your personal data violates data protection laws.
4. Voluntary Participation and Withdrawal of Consent
   Participation in the recruitment process and provision of personal data are voluntary and equivalent to granting consent for their processing. Such consent may be withdrawn at any time. In the event of withdrawal, the personal data will be deleted without undue delay. Withdrawal of consent should be sent to: out@naj.com.pl.
5. Updating Personal Data
   Changes to personal data may be made by submitting a relevant request to: RODO@naj.com.pl. In response, you will receive an activation link enabling you to update your personal data in the Controller’s system.

This website www.naj.com.pl is owned by NAJ International Sp. z o.o. with its registered office in Warsaw (NAJ). Users of this website are requested to carefully read the information provided below. This website can be used without the need to provide any personal data. If you voluntarily decide to provide them, NAJ will use them in compliance with the personal data protection rules presented below and with the applicable regulations. If you do not accept how personal data are processed as presented in this Privacy Policy, please do not send personal data or documents containing such data to us.

What personal data are gathered, and how are they used?
The data provided to NAJ on a voluntary basis by means of this website, such as the name, surname, e-mail address or any information provided on the application form, included in the CV provided or correspondence sent to NAJ as well as data received thanks to business contacts or from public sources of information, such as LinkedIn, GoldenLine etc.
are gathered and processed by NAJ for the following purposes:

1. Entering them in the NAJ candidate database,
2. Using them for the current and future recruitment processes conducted by NAJ;
3. Making them available to potential employers;
4. Direct marketing of NAJ services;
5. Entrusting NAJ by employers with their projects connected with employee recruitment;
6. Adapting this website’s image and functionality to its users’ needs.

Access to personal data
Users of this website have, at any time, the right to get access to their personal data, as well as correct or delete them. Data can be corrected or deleted by getting in touch with NAJ at the following e-mail address:RODO@naj.com.pl or out@naj.com.pl
You also have the right to lodge a complaint with the supervisory body, from May 25, 2018, PUODO (President of the Office for Personal Data Protection, 2 Stawki St., 00-986 Warsaw).

Processing of personal data
Personal data gathered through the NAJInternational website are processed to the extent necessary to achieve the above-mentioned purposes. By providing their personal data, candidates agree to have them processed for the above-mentioned purposes in compliance with this Privacy Policy and the Regulation of the European Parliament and the Council of Europe (EU) 2016/679 of 27 April 2016. on the protection of individuals in relation to data processing and the repeal of Directive 95/46 / EC (referred to as “RODO”, “ORODO”, “GDPR”, or “General Data Protection Regulation”).

Protection of personal data
Data provided to NAJ are stored in compliance with the applicable regulations. Due to the fact that no online data transfer is fully secure, NAJ cannot ensure the full security of personal data sent to NAJ. However, we do our best to ensure the highest possible level of security by available technical and organisational means. We use a number of IT and physical security measures to minimise the risk of data leakage, destruction or disintegration, such as anti-virus security systems, internal procedures of access and data processing.

Making personal data available
The administrator of the personal data provided by means of this website is NAJ International Sp. z o.o. with its registered office in Warsaw, Rondo ONZ 1, 00-124 Warsaw. Authorised employees and authorised persons of NAJ have access to personal data. Furthermore, the data may be made available to our clients who look for candidates for the positions they offer. The data may also be made available to third parties which provide services to NAJ, but only to the extent it is necessary to provide these services by these parties to NAJ. At the same time, we inform you that before the personal data are provided to clients in connection with the recruitment process conducted on behalf of such clients, we get in touch with the candidate to obtain their consent for providing the data. Furthermore, personal data may be made available to bodies authorised by regulations in situations specified by the applicable law. At the same time, in the case of an acquisition, merger, takeover, liquidation or bankruptcy of NAJ, and in the case of the sale of all or almost all assets, NAJ reserves the right to transfer the data, including the personal data, to third parties. Candidates will be immediately informed about such a situation and will have an opportunity to delete their data.

Gathering statistical data about visitors and cookies
Furthermore, the website gathers data on the ways in which the visitors use it. These are not, however, data which enable users’ identification. Their aim is only to make the website’s operation smoother and adapt it to the users’ needs. This website also uses cookie files https://naj.com.pl/kandydat/cookie-policy/ .

Other websites
On www.naj.com.pl, links to other websites may appear. Clicking such a link will take you to another website. NAJ is not responsible for the manner in which other websites operate and process personal data. One should become acquainted with the privacy policy of each website before using it.

Changes to the Privacy Policy
This Privacy Policy may be changed at any time by NAJ. In such a case, it will be immediately posted on our website so that people who use it can become acquainted. Should you have any questions related to it, please get in touch with us at administration@naj.com.pl

Equal treatment
NAJ ensures equal opportunities to everybody. For this reason, all candidates are treated by NAJ in the same way, irrespective of their ethnic origin, religion, gender, sexual orientation, marital status, nationality, disability or age.

Copyright
NAJ is the owner of the copyright to this website, texts published here, NAJ logotypes and other graphic and sound elements featured on the website. The owner of the trademarks which can be noticed on the sites part of the website are NAJ or our trade partners. It is forbidden to download data, copy or print any content and materials posted on the website, except for using them by the user only for their own purposes, and on condition that the form given to them by their authors and legally reserved remarks remain unchanged. It is forbidden to copy and distribute this content for any use without the prior consent of NAJ. Furthermore, it is forbidden to make any attempts at decoding, disassembling or modifying the software, coding the information posted on the website, and posting content which breaches intellectual property rights or other rights of NAJ.