PRIVACY POLICY regarding personal data of prospective clients - dotLinkers

dotLinkers

PRIVACY POLICY

– regarding personal data of prospective clients –

1. Who we are and how to contact us

We are called 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 joint controllers of your personal data, meaning:

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 may contact either of them to obtain information or exercise your rights under the GDPR. To facilitate this, we have established a common contact point – you can reach us by email at rodo@dotlinkers.pl or by phone at +48 505 184 303.

2. Why we process your personal data

DIRECT MARKETING

If we believe we can assist you in recruiting employees, we will process your personal data for marketing purposes.

According to applicable regulations, we may use the information you provide to conduct direct marketing using electronic communication (sending targeted advertisements via social media platforms or third-party websites). Therefore, we may deliver advertisements (including marketing materials, suggestions, and recommendations related to our services and products) 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 controller or by a third party). This legitimate interest is direct marketing and advertising of DOTLINKERS’ own services (as stated in Recital 47 of the GDPR, the processing of personal data for direct marketing purposes may be considered a legitimate interest).

Detailed information on personalized advertising can be found on the respective external social media pages listed below:

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

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

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

If we obtained your data from a third-party entity providing databases, we first ensure that the entity collected it for direct marketing purposes and with your consent. Therefore, we are not required to verify whether processing for a different purpose is consistent with the purpose for which personal data was originally collected under Article 6(4) of the GDPR.

CLAIM ENFORCEMENT

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 the history of correspondence we have had with you (if it has been archived), as well as to request its deletion unless its archiving is justified due to our overriding interests. The legal basis for processing your personal data after contact with us has ended is our legitimate interest in archiving correspondence to ensure we can demonstrate certain 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 controller or by a third party).

3. What personal data we process

We process the following personal data of potential clients:

full name;

position;

company name;

email address;

phone number;

publicly available data from your website or professional social media platforms (such as LinkedIn, GitHub, or thematic groups on Facebook, etc.);

history of our correspondence with you (including email exchanges)

4. To whom we disclose your personal data

The external service providers involved in processing your personal data include:

a hosting provider that stores data on a server,

a mailing system provider where your data is stored.

Your personal data is processed within an IT system, which is partially located in a cloud service provided 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: 243229800, NIP: 6292368157). This entity also provides IT support for our company and may have access to some of your personal data in the course of this support. This does not involve transferring your personal data to third countries.

Additionally, we use a cloud service provided by Microsoft through Office 365 tools. We also use Skype, a communication tool provided by Microsoft. This does not involve the transfer of your personal data to third countries.

We also utilize software dedicated to HR firms and tools that support and automate our service sales processes (including communication with you), provided by international entities. Your personal data processed within these systems may be transferred to third countries. This transfer is conducted based on a legal instrument provided by the GDPR and is entirely secure.

To deliver targeted advertisements, your data may also be shared with companies such as Facebook Inc., Google LLC and Google Ireland Limited, as well as LinkedIn Ireland Unlimited Company and LinkedIn Corporation. These companies’ servers are located in various parts of the world, meaning data may be transferred outside the European Economic Area. However, this always occurs based on GDPR-compliant legal instruments that ensure adequate protection of your rights and freedoms. For a better fit of the content shown to you, the above entities may be provided with such data as your name, email address, phone number, the technology you work with, and the company where you currently work (with this data being appropriately anonymized each time). It is also possible that our advertisements were displayed to you based on an analysis of demographic data, interests, and behaviors that indicated you share characteristics with others 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 will contact you within 30 days of obtaining your data. If we are unable to reach you, your personal data will be promptly deleted (although in some cases, your personal data may be retained beyond this period in case of potential claims, in accordance with the limitation periods set by applicable laws). However, if you have knowingly provided your data, for example, by using our service, this time frame does not apply. We always strive to contact you as soon as possible.

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

6. How we enable you to exercise Your rights

We make every effort to ensure that you are satisfied with our cooperation. However, please remember that you have several rights that allow you to influence the way we process your personal data and, in certain cases, to stop this processing altogether. These rights include:

the right to access your personal data (regulated under Article 15 of the GDPR).

Article 15

Right of access by the data subject

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:
a) the purposes of the processing;
b) the categories of personal data concerned;
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;
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;
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;
f) the right to lodge a complaint with a supervisory authority;
g) where the personal data are not collected from the data subject, any available information as to their source;
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.
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.
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.
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”)

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:
a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
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;
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);
d) the personal data have been unlawfully processed;
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;
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:

a) for exercising the right of freedom of expression and information;
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;
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);
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
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

The data subject has the right to obtain from the controller restriction of processing where one of the following applies:
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;
b) the processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
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;
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.
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.
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

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.
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.
If the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
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.
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.
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

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:
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
b) the processing is carried out by automated means.
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.
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.
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 conclude an agreement with us?

We are not concluding any agreement with you at this stage.

9. Source of Your personal data

We obtain publicly available data from the website of the company where you work or that you own, as well as from business-oriented or professional social networking platforms.

10. Automated processing and profiling

We do not process your data in an automated manner or profile it as defined by the GDPR.