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Privacy Policy

Effective Date: 12/11/2024

This Privacy Policy explains how Apptivity sp. z o.o. with its registered office at ul. Podole 60, 30-394 Krakow (apptivity.pl), processes your personal data within the hexjobs.com website.

Before using the Website, please read the following information.

1. DEFINITIONS

  • Apptivity / Administrator – Apptivity Spółka z ograniczoną odpowiedzialnością with its registered office in Krakow (apptivity.pl) entered into the Register of Entrepreneurs of the National Court Register by the District Court for Krakow-Śródmieście in Krakow, 11th Commercial Division of the National Court Register under KRS number: 0001168563, NIP: 6762692212, REGON: 541513315, with a share capital of PLN 5,000;
  • User – a natural person not holding an Account, visiting the Website or using services or functionalities available on the Website;
  • GDPR – 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;
  • Personal Data – any information relating to an identified or identifiable natural person ("data subject");
  • Account – a collection of resources and functionalities created for an Employer or User, used to manage services provided by the Website;
  • Processor – a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller;
  • Cookies – IT data, in particular text files, stored in the Service User's terminal equipment and intended for using the Website's pages;

2. WHO IS THE ADMINISTRATOR OF YOUR PERSONAL DATA?

The administrator of your personal data, i.e., the entity that independently or jointly with others determines the purposes and means of processing personal data, is Apptivity Spółka z ograniczoną odpowiedzialnością with its registered office in Krakow (apptivity.pl) entered into the Register of Entrepreneurs of the National Court Register by the District Court for Krakow-Śródmieście in Krakow, 11th Commercial Division of the National Court Register under KRS number: 0001168563, NIP: 6762692212, REGON: 541513315, with a share capital of PLN 5,000.

3. HOW CAN YOU CONTACT THE ADMINISTRATOR?

In matters related to the processing of your personal data by hexjobs.com, in particular to exercise your rights, you can contact the Administrator:

  • in writing, by sending a letter to the address of Apptivity's registered office indicated above;
  • via e-mail to the address: [email protected]

4. WHAT ARE THE PURPOSES AND LEGAL BASES FOR PROCESSING YOUR DATA?

4.1 Using the Website without creating an Account

Apptivity processes data of persons using the Website who are not registered Users (i.e. do not have an Account on the Website):

  1. To provide services electronically in terms of making content collected on the Website available to Users – the legal basis is the necessity of processing for the performance of the contract (Art. 6(1)(b) GDPR);
  2. For analytical and statistical purposes – the legal basis is the Administrator's legitimate interest (Art. 6(1)(f) GDPR), consisting in measuring the effectiveness of the Website and improving its functionality;
  3. To diagnose problems related to the operation of the Website, ensure its proper configuration and IT security – the legal basis is the Administrator's legitimate interest (Art. 6(1)(f) GDPR), consisting in ensuring the proper functioning of the Website.

For the above purposes, Apptivity processes data concerning activity on the Website, such as: viewed content, session data, device, operating system, browser, location, and the User's IP address.

4.2 Using the Website requiring an Account

Registering an Account on the hexjobs.com Website is possible only via OAuth2 through LinkedIn or Google social networks. The Website retrieves from the social network account the data necessary to register an Account on the Website. Information on the scope and purposes of data processing by these portals can be found in their privacy policies.

Personal data is processed:

  1. To provide services electronically related to maintaining and servicing the Account and making its functionalities available – the legal basis is the necessity of processing for the performance of the contract (Art. 6(1)(b) GDPR);
  2. For analytical and statistical purposes – the legal basis is the Administrator's legitimate interest (Art. 6(1)(f) GDPR), consisting in measuring the effectiveness of the Website and improving its functionality;
  3. To diagnose problems related to the operation of the Website, ensure its proper configuration and IT security – the legal basis is the Administrator's legitimate interest (Art. 6(1)(f) GDPR), consisting in ensuring the proper functioning of the Website;
  4. For direct marketing of own services and products – the legal basis is the Administrator's legitimate interest (Art. 6(1)(f) GDPR).

For the above purposes, Apptivity processes personal data obtained from social networks during Account registration and data concerning activity on the Website.

4.3 Processing candidate's personal data in connection with applying for job offers via the Website

If you apply as a Candidate for job offers posted on our Website, Apptivity processes your personal data as a Processor, acting on behalf of and in accordance with the instructions of the Employer who published the given job offer. This means that the Administrator of your personal data contained in the application is the Employer to whom you directed your application. The hexjobs.com Website processes data solely for the purpose of technically enabling the transmission of your application to the selected Employer.

5. WHO CAN YOUR PERSONAL DATA BE SHARED WITH?

Your personal data may be shared with or entrusted to entities cooperating with Apptivity in the provision of services, in particular entities providing hosting, mailing services, contact form availability, and consulting and marketing services. Your anonymized data, preventing your identification, may be transferred to third parties providing statistical tools, providers of mailing, analytical, and marketing services. These entities process data on the basis of an agreement concluded with the Administrator and only in accordance with their instructions. Your data may also be, within the limits specified by law, transferred to authorized state bodies at their request, in connection with the tasks they perform. This applies in particular to: organizational units of the prosecutor's office, the Police, the President of the Personal Data Protection Office, the President of the Office of Electronic Communications, and the President of the Office of Competition and Consumer Protection.

6. WILL APPTIVITY TRANSFER YOUR DATA TO THIRD COUNTRIES?

The Administrator alone will not transfer your personal data outside the European Economic Area. However, within the scope of using supporting tools, the Administrator may use the services of entities that will – to a limited extent – transfer your personal data outside the European Economic Area.

In such a situation, personal data will be transferred only to recipients who guarantee the highest protection and security of data, e.g., by:

  1. Using standard contractual clauses issued by the European Commission,
  2. Using binding corporate rules approved by the competent supervisory authority,
  3. Cooperating with entities processing personal data in countries for which a relevant decision of the European Commission regarding the appropriate level of data protection has been issued.

This applies in particular to:

  • Microsoft Ireland Operations Limited with its registered office in Dublin, Ireland, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18 D18 P521 - hosting in the Microsoft Azure cloud and analytical tools.

Hosting in the Microsoft Azure cloud enables secure storage of data and their processing on servers located in Europe, in accordance with personal data protection regulations. Additionally, as part of analytical services, the Microsoft Clarity tool is used, which allows analyzing user interactions with our Website. Microsoft Clarity records anonymous data regarding user behavior, such as clicks, scrolling, or viewed pages, which allows us to improve the functionality of the Website. These data are processed in accordance with applicable regulations and used solely for statistical and analytical purposes. Detailed information regarding Microsoft's privacy policy is available at: https://privacy.microsoft.com/

  • Google Ireland Limited, Gordon House Barrow Street Dublin 4 Ireland EOG - statistical purposes.

Google processes data to generate statistics regarding the use of our Website. For this purpose, we use the Google Analytics tool, which allows analyzing traffic on the Website and its optimization. Google Analytics collects anonymous information, such as the number of visits, time spent on the page, traffic sources, and user interactions. These data help us better understand how our Website is used and adapt its operation to user needs. Google applies data security measures in accordance with applicable regulations, including GDPR regulations, and detailed information on Google's privacy policy is available at: https://policies.google.com/privacy.

  • Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA.

Cloudflare offers a content delivery network with DNS, which is available worldwide. As a result, the transfer of information between your browser and our website is technically routed through the Cloudflare network. Thanks to this, Cloudflare can analyze data transactions between your browser and our website and act as a filter between our servers and potentially malicious data traffic from the Internet. In this context, Cloudflare may also use cookies or other technologies deployed to recognize Internet users, which however will be used solely for the purposes described in this document.

To obtain more information on Cloudflare's precautions and data privacy policy, click this link: https://www.cloudflare.com/privacypolicy/.

7. HOW LONG WILL YOUR DATA BE PROCESSED BY APPTIVITY?

Apptivity guarantees that personal data will be stored only for the time necessary to achieve the purposes for which they were collected. The period of data processing depends on the type of service provided, the purpose of processing, and the legal basis:

  • In the case of processing personal data based on consent, the processing period lasts until the consent is withdrawn.
  • In the case of processing personal data based on the legitimate interest of the data administrator, the processing period lasts until this interest ceases (e.g., the limitation period for civil law claims) or until an effective objection to further processing is made – in situations where such an objection is available under the law.
  • In the case of processing personal data based on a contract in connection with making Account functionality available, data is processed until the Account is deleted. After deleting the Account, data may be stored to a limited extent (company name, business contact details, application history, and information on consents granted) for the purpose of defense against possible claims for a period of 3 years from the deletion of the Account.
  • In the case of processing cookies, personal data will be processed for the period in which cookies are stored on your device.

8. WHAT RIGHTS DO YOU HAVE IN CONNECTION WITH THE PROCESSING OF YOUR DATA BY APPTIVITY?

Within the scope limited by applicable law in connection with the processing of your personal data by Apptivity, you have the following rights:

a) Right of access to data – the right to obtain information about the processing of your personal data, including, among others, the purposes and legal bases for processing, the scope of data held, entities to which personal data is disclosed, and the planned date of their deletion, as well as the right to receive a copy of the processed data (Art. 15 GDPR);

b) Right to rectification of data – the right to request the correction or updating of personal data if they are inaccurate or incomplete (Art. 16 GDPR);

c) Right to deletion of data – the right to request the deletion of data in cases and on principles specified in Art. 17 GDPR;

d) Right to restriction of data processing – the right to request that we temporarily or permanently stop processing all or part of personal data in situations and on principles specified in Art. 18 GDPR;

e) Right to data portability – the right to receive in a structured, commonly used machine-readable format personal data that you have provided to us and the right to request that these personal data be sent to another administrator (Art. 20 GDPR);

f) Right to object – the right to object to the use of your personal data in situations and on principles specified in Art. 21 GDPR;

g) Right to withdraw consent to the processing of personal data at any time without affecting the lawfulness of processing based on consent before its withdrawal;

h) Right to lodge a complaint with a supervisory authority – if you believe that the processing of personal data violates GDPR regulations or other regulations regarding personal data protection, the data subject may lodge a complaint with the President of the Personal Data Protection Office.

You can exercise the rights specified in points a) - g) above in accordance with the principles described in Art. 16 – 21 GDPR by sending a message to the e-mail address: [email protected]

Such an application should, as far as possible, precisely specify what the request concerns, i.e., in particular, it should contain the following information:

a) indication of which of the above rights you want to use;

b) specification of what processing process the request concerns;

c) specification of what processing purposes the request concerns.

If it is necessary to clarify the content of the application, the Administrator will ask you to provide additional information. A response to the application is provided immediately, no later than within one month from the date of receipt of the application to the e-mail address from which the application was sent.

9. COOKIES

The Website uses two types of cookies: "session" and "persistent". "Session" cookies are temporary files that are stored on the User's terminal equipment until logging out, leaving the website, or turning off the software (web browser). "Persistent" cookies are stored on the User's terminal equipment for the time specified in the cookie parameters or until they are deleted by the User. The Website uses cookies in particular to:

  1. adapt the content of the Website to the User's preferences;
  2. provide services requested by you related to logging into the Employer Panel and User Account and navigating the Website;
  3. optimize the use of the Website by the User (including adjusting the appropriate display of the page);
  4. segment users for advertising purposes, personalization, and targeting of ads using advertising partners: Google, LinkedIn, Facebook.
  5. ensure security, e.g., by detecting abuses in the scope of authentication within the Website;
  6. maintain statistics and measure traffic on the Website using Google Analytics cookies;

By using the Website, the User consents to the use of cookies. The User can control and manage cookies at any time using web browser settings by managing their display, deletion, and blocking. Excessive restriction of the use of cookies may make it difficult to use some functionalities of the Website, or even prevent their use. The Website also uses tools for analytical and marketing purposes from third parties, in particular:

  1. Social media plugins (Google, LinkedIn) are used on the Website. Plugins allow logging in via a social network and sharing content published on the Website there. The use of plugins on the Website causes the given social network to receive information about the User's use of the Website and may assign it to the User's profile created on the given social network. Apptivity has no knowledge of the purpose and scope of data collection by social networks.
  2. Google Analytics cookies are files used by Google to analyze the way the User uses the Website, to create statistics and analyses regarding the functioning of the Website. Google does not use the collected data to identify the User. Information on the scope and principles of data collection in connection with this service can be found at the link: https://www.google.com/intl/en/policies/privacy/partners
  3. Cloudflare cookies - Cloudflare offers a content delivery network (CDN) that ensures global data transfer between the User's browser and the Website. Cloudflare cookies support the optimization of page loading time and increase the level of security, protecting against malicious internet traffic. As part of this process, Cloudflare may analyze data regarding network connections and use cookies or other technologies identifying users. More information on Cloudflare's data processing principles can be found at: https://www.cloudflare.com/trust-hub/gdpr/.
  4. Microsoft cookies – Microsoft uses cookies as part of the Microsoft Azure cloud computing and the Microsoft Clarity analytical tool. These files enable the analysis of User interaction with the Website, helping to optimize its operation and adapt to user needs. Detailed information on Microsoft's privacy policy is available at: https://www.microsoft.com/en-us/privacy/privacystatement.

Detailed information on this subject can be found at the following links:

10. SECURITY

Apptivity uses technical and organizational measures to ensure the protection of processed personal data. This protection is adapted to the threats and categories of data covered by it. Personal data is in particular protected against disclosure to unauthorized persons, alteration, loss, damage or destruction, as well as against processing in violation of applicable regulations. The technical and organizational measures referred to in this point include in particular:

access to the account conditioned by providing a login and password in a trusted external service (Google, LinkedIn);

  1. SSL certificate;
  2. connection encryption;
  3. encryption of files containing user CVs and databases;
  4. securing the data set against unauthorized access;
  5. hashing data used for User authorization;

11. FINAL PROVISIONS

Apptivity reserves the right to change this Privacy Policy for important reasons, which may include in particular:

  1. development of functionalities and services offered on the Website, affecting the content of the Privacy Policy;
  2. change of generally applicable law in the scope of, among others, personal data processing.

In the scope not covered by this Privacy Policy, the provisions of the GDPR and generally applicable law in the territory of the Republic of Poland apply. In case of additional questions related to security and personal data processing by the Administrator, we encourage you to contact us at the e-mail address: [email protected]