PRIVACY POLICY 

– regarding personal data of applicants –

 

1. Who we are and how to find us

We are DOTLINKERS, and we process your personal data as described in this Privacy Policy. 

We operate as a group of companies. The details of these companies are as follows: 

• DOTLINKERS Limited Liability Company based in Kraków (address: ul. Przemysłowa 12, 30-701 Kraków, Poland), 

• DOTLINKERS Limited Liability Company – Limited Partnership based in Kraków (address: ul. Przemysłowa 12, 30-701 Kraków, Poland). 

Both of our companies are co-controllers of your personal data, which means that: 

• when one of the companies obtains your personal data, the other will also have access to it, 

• both companies jointly decide how and why they process your personal data, 

• this Privacy Policy applies to both companies, 

• you can contact either of them to obtain information or exercise any of your rights under the GDPR. We have established a joint contact point for this purpose—an email address at rodo@dotlinkers.pl and a phone number at +48 505 184 303. 

We have decided not to appoint a Data Protection Officer as it is not mandatory in our situation. For any matters related to personal data protection, you can contact us using the contact details provided above.

2. Why we process your personal data

If we consider you a good candidate for a position with our client or with us, we process your personal data to facilitate your participation in the recruitment process. 

We will process your personal data to: 

• contact you for the recruitment process, 

• assess your qualifications for the position, 

• evaluate your abilities and skills necessary for the role, 

• select the appropriate person for a job with us or our client. 

RECRUITMENT INITIATED BY DOTLINKERS 

This recruitment process is divided into two stages, which are important for the protection of your personal data. Initially, we search for you (for example, on LinkedIn). At this point, you may not be aware that we are processing your data, but we must do so—otherwise, we would not be able to assess whether you might be interested in the position, nor could we contact you. Our work involves connecting candidates and employers. Therefore, this processing is necessary for the purposes arising from the legitimate interests pursued by the data controller, which is us (Article 6(1)(f) of the General Data Protection Regulation (EU) 2016/679 of April 27, 2016, on the protection of individuals with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC, hereinafter referred to as “GDPR”). We hope you do not consider our actions to violate your rights and freedoms. We make every effort to ensure that this first stage of our work lasts as short as possible, does not involve unnecessary data, and does not come as a surprise to you. By creating a profile on professional or business social media, attending such events, and participating in online discussions on topics relevant to us, you can reasonably expect that you may attract the attention of more than one headhunter interested in your expertise! 

In the next stage of the recruitment process, you will be fully aware of your participation. We will contact you, send you an email, and invite you for an interview. Along with our initial contact, we will provide you with all the information contained in this Privacy Policy (for example, by sending you a link via email). 

RECRUITMENT INITIATED BY THE JOB CANDIDATE 

Sometimes, however, it is you who applies for the job offers we publish regarding positions with us or our clients (for example, through the application form on our website). We process your personal data solely for the purpose of conducting the recruitment specified in the job offer and for future recruitment purposes, if you have provided the relevant consent in your application. The legal basis for processing your personal data, which you provide to us when applying for the published job offers, is Article 6(1)(a) of the GDPR (the data subject has given consent to the processing of their personal data for one or more specific purposes). 

You should also know that even in such cases, we supplement the personal data you send us by reviewing your publicly available profiles on business or professional social media. Hiring a programmer requires a meticulous assessment of a candidate’s suitability for specific tasks, which often demand a very narrow specialization. The personal data contained in standard CVs is usually not sufficient for this purpose. Based on Article 6(1)(f) of the GDPR (processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party), we therefore have a legitimate interest in independently supplementing this information from publicly available sources. 

If any of the data you provide to us includes sensitive data, we may process it only based on your explicit and separate consent. This consent can be revoked at any time. In the absence of such consent, we will promptly delete this data. 

RECRUITMENT INITIATED BY YOUR FRIEND THROUGH THE DOTLINKERS REFERRAL PROGRAM 

We may also receive your application from another third party who has referred you as a candidate for employment through our referral program. In this case, your data will be processed for the purpose of conducting the recruitment process based on Article 6(1)(a) of the GDPR (the data subject has given consent to the processing of their personal data for one or more specific purposes). More details about our referral program can be found in the regulations available here: https://dotlinkers-itrecruitment.com/candidate-referral-program/ 

QUALIFICATION TESTS 

As part of the recruitment process, we may conduct so-called qualification tests. These tests are designed to verify whether you have the skills needed for the specific position. The legal basis for processing your personal data in this case is Article 6(1)(f) of the GDPR (processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party). We have a legitimate interest in assessing your skills and abilities, as this is necessary for us to determine whether you are the right person for the position we are recruiting for. 

OTHER RECRUITMENTS 

If you wish for your CV (and other data contained in your recruitment application collected in connection with your participation in the recruitment process for the specific job position) to be used for future recruitments or for other currently ongoing recruitments, your data will be processed based on your voluntary consent, i.e., pursuant to Article 6(1)(a) of the GDPR (the data subject has given consent to the processing of their personal data for one or more specific purposes). 

CONTACT 

By contacting us (via the contact form or using any of our other contact details), you provide us with your personal data, including the data contained in the correspondence, particularly: email address, phone number, and first and last name. Providing this data is voluntary but necessary to establish contact with us. The legal basis for processing your personal data that you provide when contacting us is Article 6(1)(f) of the GDPR (processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party). This legitimate interest is the desire to communicate with individuals interested in our services. 

CLAIMING RIGHTS 

Additionally, the content of our correspondence with you may be subject to archiving, and we cannot definitively determine when it will be deleted. You have the right to request a history of the correspondence you have had with us (if it has been archived) and to demand its deletion unless its archiving is justified by our overriding interests. The legal basis for processing your personal data after the termination of contact with us is also our legitimate interest in archiving correspondence for the purpose of ensuring that we can demonstrate specific facts in the future. Therefore, we may process your personal data for the purpose of pursuing and defending against claims based on Article 6(1)(f) of the GDPR (processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party). 

DIRECT MARKETING 

In accordance with applicable regulations, we may use the information you provide for the purpose of conducting direct marketing using electronic communication methods (sending targeted advertisements to specific users via social media platforms or third-party websites). Thus, we may direct advertisements (including marketing materials, suggestions, and recommendations regarding our services and products) to you through communication channels such as Facebook, LinkedIn, and Google Ads. In this case, your data will be processed based on Article 6(1)(f) of the GDPR (processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party). This legitimate interest is direct marketing and advertising of DOTLINKERS’ own services (according to Recital 47 of the GDPR: processing personal data for the purposes of direct marketing may be considered a legitimate interest). 

Detailed information regarding the transmission of personalized advertisements can be found on the respective external social media websites listed below: 

• Facebook: https://www.facebook.com/privacy/explanation 

• Google: https://policies.google.com/ 

• LinkedIn: https://www.linkedin.com/legal/privacy-policy 

In cases where we obtained your data from a third party providing databases, we first ensure that such a party collected it for the purpose of direct marketing and with your consent. Therefore, we are not obliged to determine whether processing for another purpose is compatible with the purpose for which the personal data was originally collected, pursuant to Article 6(4) of the GDPR.

3. What Personal Data We Process

We process the following personal data of candidates: 

• First and last name 

• Mailing address 

• Email address 

• Phone number 

• Image (photo included in the CV) 

• Educational background 

• Employment history 

• Professional specialization 

• Publicly available information on professional or business social media (LinkedIn, GitHub, Facebook groups, etc.) 

• Financial expectations regarding salary with a new employer 

• Level of English language proficiency 
• Notice period for the current employment contract

4. Who we share Your personal data with

If we consider you a suitable candidate for a position with our client, we will disclose your personal data to them at the final stage of the recruitment process. We cannot specify in advance, within this Privacy Policy, which entity this will be. However, we can assure you that most of our clients are reputable companies in the IT sector, and we will ask for your consent every time we wish to disclose your personal data to any employer. 

External service providers involved in processing your personal data include: 

• The hosting provider that stores data on the server 

• The email system provider where your data is stored 

Your personal data is processed in an IT system that is partially located in the so-called cloud, provided to us by bitebyte.pl (Maciej Kupiec conducting business under the name “bitebyte.pl – Maciej Kupiec,” address: ul. Henryka Dąbrowskiego 34/7, 41-300 Dąbrowa Górnicza, REGON number: 243229800, NIP: 6292368157). This same entity also handles our company’s IT services, which may provide access to some of your personal data. This does not involve the transfer of your personal data to third countries. 

Additionally, we utilize cloud services provided by Microsoft as part of Office 365 tools. We also use Skype, provided by Microsoft. This does not involve the transfer of your personal data to third countries. 

We also employ software dedicated to companies in the HR sector and tools that support and automate the sale of our services (including communication processes with you), provided by international entities. Your personal data processed by these tools will be transferred to third countries. This transfer occurs based on a legal instrument provided for by GDPR and is entirely secure. 

For advertising purposes, your data may also be shared with entities such as Facebook Inc., Google LLC, Google Ireland Limited, LinkedIn Ireland Unlimited Company, and LinkedIn Corporation. The servers of these companies are located in various parts of the world, meaning that your data may be transferred outside the European Economic Area. However, this always occurs based on legal instruments provided for by GDPR, ensuring adequate protection of your rights and freedoms. To better tailor the content you see, the aforementioned entities may receive data such as your first and last name, email address, phone number, the technology you work with, and the company you currently work for (these data are anonymized each time). It is also possible that you have seen our ads because, based on demographic data analysis and your interests and behaviors, you were identified as a person similar to others who are interested in our services. 

If you would like to learn more about the principles of targeted advertising, please refer to the information provided at the following addresses: 

• Facebook: 

https://pl-pl.facebook.com/legal/terms 

https://pl-pl.facebook.com/business/gdpr 

https://www.facebook.com/about/ads 

• Google: 

https://support.google.com/google-ads/answer/9028179?hl=pl 

• LinkedIn: 

https://www.linkedin.com/legal/ads-policy 

 5. How long we will process Your personal data

We strive to keep your data up to date. To this end, we will contact you no less than once every 24 months to catch up. If, for any reason, we are unable to reach you during this period, your personal data will be deleted 24 months after its acquisition. 

For personal data processed for the purpose of future recruitment processes based on your consent, your data will be stored for a period of 24 months from the date consent was given. 

Sensitive data we have received from you, for which we have not obtained explicit and separate consent for processing, will be deleted immediately. 

Please remember that we may also retain your personal data for the purpose of establishing, pursuing, or defending against claims related to the recruitment process for a period of 3 years from the conclusion of the recruitment process in which you participated. 

In the case of processing your data for direct marketing purposes, you have the right to object to the processing of your personal data for such marketing, including profiling, at any time, to the extent that the processing is related to such direct marketing. 

 6. How we enable You to exercise Your rights

We make every effort to ensure you are satisfied with our collaboration. However, please remember that you have many rights that allow you to influence how we process your personal data and, in some cases, to stop such processing. These rights include: 

 

• the right of access to personal data (regulated by Article 15 of GDPR) 

 

Article 15 

Right of access by the data subject 

1. The data subject has the right to obtain from the controller confirmation as to whether or not personal data concerning them are being processed, and, where that is the case, access to the personal data and the following information: 
2. a) the purposes of the processing;
3. b) the categories of personal data concerned;
4. c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
5. d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
6. e) the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
7. f) the right to lodge a complaint with a supervisory authority;
8. g) where the personal data are not collected from the data subject, any available information as to their source;
9. h) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4), and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
10. Where personal data are transferred to a third country or an international organization, the data subject has the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.
11. The controller shall provide a copy of the personal data undergoing processing to the data subject. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. If the data subject makes the request by electronic means and unless otherwise requested, the information shall be provided in a commonly used electronic form.
12. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.

 

• right to rectification of data (regulated under Article 16 of the GDPR) 

 

Article 16 

Right to rectification of data 

The data subject has the right to obtain from the controller the rectification of inaccurate personal data concerning them without undue delay. Taking into account the purposes of the processing, the data subject also has the right to have incomplete personal data completed, including by providing a supplementary statement. 

 

• right to erasure of data (regulated under Article 17 of the GDPR) 

 

Article 17 

Right to erasure (“right to be forgotten”) 

1. The data subject has the right to obtain from the controller the erasure of personal data concerning them without undue delay, and the controller has the obligation to erase personal data without undue delay where one of the following grounds applies: 
2. a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
3. b) the data subject withdraws consent on which the processing is based according to Article 6(1)(a) or Article 9(2)(a), and where there is no other legal ground for the processing;
4. c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
5. d) the personal data have been unlawfully processed;
6. e) the personal data must be erased to comply with a legal obligation under Union or Member State law to which the controller is subject;
7. f) the personal data have been collected in connection with the offer of information society services referred to in Article 8(1).

Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copies or replications of, those personal data. 

Paragraphs 1 and 2 do not apply to the extent that processing is necessary:  

1. a) for exercising the right of freedom of expression and information;
2. b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
3. c) for reasons of public interest in the area of public health in accordance with Article 9(2)(h) and (i) and Article 9(3);
4. d) for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) to the extent that the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or 
5. e) for the establishment, exercise, or defense of legal claims.

 

• right to restriction of processing (regulated under Article 18 of the GDPR) 

 

Article 18 

Right to restriction of processing 

1. The data subject has the right to obtain from the controller restriction of processing where one of the following applies: 
2. a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
3. b) the processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
4. c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise, or defense of legal claims;
5. d) the data subject has objected to processing pursuant to Article 21(1) pending the verification of whether the legitimate grounds of the controller override those of the data subject.
6. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the Union or of a Member State.
7. The controller shall inform the data subject who has obtained restriction of processing under paragraph 1 before the restriction is lifted.

 

• right to object to processing (regulated under Article 21 of the GDPR) 

 

Article 21 

Right to object 

1. The data subject shall have the right to object, on grounds relating to their particular situation, at any time to the processing of personal data concerning them which is based on Article 6(1)(e) or (f), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject or for the establishment, exercise, or defense of legal claims.
2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning them for such marketing, which includes profiling to the extent that it is related to such direct marketing.
3. If the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
4. The right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject at the latest at the time of the first communication with the data subject and shall be presented clearly and separately from any other information.
5. In the context of the use of information society services and notwithstanding Directive 2002/58/EC, the data subject may exercise their right to object by automated means using technical specifications.
6. Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to their particular situation, shall have the right to object to processing of personal data concerning them, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

 

• right to data portability (regulated under Article 20 of the GDPR) 

 

Article 20 

Right to data portability 

1. The data subject has the right to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used, and machine-readable format, and has the right to transmit those data to another controller without hindrance from the controller to whom the personal data have been provided, where: 
2. a) the processing is based on consent pursuant to Article 6(1)(a) or Article 9(2)(a) or on a contract pursuant to Article 6(1)(b); and 
3. b) the processing is carried out by automated means.
4. 2. When exercising their right to data portability as referred to in paragraph 1, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible.
5. 3. Exercising the right referred to in paragraph 1 of this Article does not prejudice Article 17. This right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
6. 4. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.

 

7. Right to lodge a complaint with a supervisory authority

Under Article 77 of the GDPR, you have the right to lodge a complaint with a supervisory authority, particularly in the EU Member State of your habitual residence, place of work, or place of the alleged infringement, if you consider that the processing of your personal data infringes the GDPR. In Poland, the supervisory authority is the President of the Personal Data Protection Office (PUODO), and you may file a complaint, among other ways: 

• by traditional mail at: ul. Stawki 2, 00-913 Warsaw (as described here: https://uodo.gov.pl/pl/83/155), 

• electronically using the form via the ePuap2 system (as described here: https://uodo.gov.pl/pl/83/155). 

More detailed information (including current phone numbers and email addresses) is available on the Personal Data Protection Office (UODO) website at: https://uodo.gov.pl. 

8. Is providing data necessary to enter into a contract with us?

At this stage, we are not entering into any contract with you. Providing data is necessary to participate in the recruitment process. 

9. Where do we get Your personal data?

You may have responded to our job posting using the application form on our website, by emailing us, or by contacting us through social media. In that case, the initial set of data was received directly from you. However, we may wish to supplement this information from publicly available sources, such as reviewing your profile on LinkedIn. 

It is also possible that we obtained your data from someone who recommended you as part of our referral program. If you would like to learn more about the rules of the referral program, please visit: https://dotlinkers-itrecruitment.com/candidate-referral-program/. 

Most likely, however, we searched for your publicly available data on business or professional social media platforms ourselves, or someone recommended you to us as a good specialist. 

10. Automated processing and profiling

We do not process your data in an automated manner, nor do we engage in profiling as defined by GDPR.