The policy is informative and fulfills the information obligations imposed on the data controller by RODO, i.e. Regulation 2016/679 of April 27, 2016 on the protection of natural persons in relation to the processing of personal data and on the free flow of such data and repealing Directive 95/46/EC (General Data Protection Regulation).
1.PERSONAL DATA CONTROLLER
1.1. The administrator of the personal data is Talent Bridge sp. z o.o. with its registered office in Warsaw (02- 717), Potoki 12A/9 Street, registered in the Register of Entrepreneurs of the National Court Register under KRS: 0000817018, NIP: 5213884362, REGON: 38501570100000, with a capital of share capital of PLN 5,000 (hereinafter referred to as “Talent Bridge”).
1.2 Contact the administrator: kontakt@talentbridge.pl
2. METHOD OF DATA PROCESSING
2.1The scope, purposes and legal basis for processing personal data are presented in the table below.
| Purpose of processing | Scope of data | Legal basis for processing | Period of data processing |
| Provide access to the platform provided by Talent Bridge | name, surname, official position, place of employment (cooperation), number
telephone number, e-mail address |
Article 6(1)(b) RODO – statutory authorization to process data necessary for the performance of the contract | Until the statute of limitations for claims arising from the contract under which Talent Bridge provides the platform to the data subject |
| conducting phone calls | telephone number, other personal data voluntarily provided by the data subject
concerned |
Article 6(1)(f) of the RODO – the legitimate interest of the controller in handling inquiries and correspondence addressed directly by data subjects | Until such time as the discussions are concluded or the data subject objects |
| conducting correspondence in the form of electronic messages | e-mail address, first name, last name, organization name, other personal data voluntarily provided
by the person to whom the data pertains |
Article 6(1)(f) of the RODO – the legitimate interest of the controller in handling inquiries and correspondence addressed directly by data subjects | Until the correspondence is terminated or the data subject objects |
| providing access to the website | IP address | Article 6(1)(b) of the RODO – statutory authorization to process data necessary to perform the contract | Until the expiration of the statute of limitations for claims related to access to the website |
| undertaking marketing activities | email address | Article 6(1)(f) RODO – the administrator’s legitimate interest in providing information about its activities | Until the data is no longer useful or the data subject objects |
| website traffic survey | IP address, cookies like:
– _utma; – _utmb; – _utmc; – _utmz; – – PHPSESSID |
Article 6(1)(a) of the RODO – consent of the data subject | Until the data is no longer useful or the data subject withdraws consent |
| protection from claims, referral of claims | e-mail address, first name, last name, other data voluntarily provided by the data subject | Article 6(1)(f) of the RODO – legitimate interest of the administrator to protect against claims and to direct claims | until the expiration of the statute of limitations for claims related to access to the website and users’ activities on the website, calculated from the last time the user in question visited the website |
2.2. Talent Bridge on this website does not process personal data for the purpose of automated decision-making, including profiling.
2.3. In order to fulfill some of the processing purposes indicated in the table above, Talent Bridge may transfer personal data to third countries. In such case, this will always be done on the basis of standard contractual clauses in accordance with the European Commission’s decision, in which both Talent Bridge and its contractors undertake to ensure an adequate degree of security for the personal data transferred. Before signing the standard contractual clauses, Talent Bridge verifies each of its contractors that will have access to personal data, as well as assesses whether the country to which the personal data goes allows for the enforcement of rights and provides data subjects with effective legal remedies.
2.4.If the European Commission issues a decision on whether the third country in question provides an adequate level of protection for personal data, then the transfer of personal data to that country may also take place on the basis of that decision.
2.5. If it is not possible to apply the standard contractual clauses and there is no decision of the European Commission, then the transfer of personal data will only take place in specific situations, by which is meant the necessity to perform a contract that has been entered into between the data subject and Talent Bridge or the implementation of pre-contractual measures. Also in this situation, Talent Bridge shall thoroughly vet each of its contractors who will have access to the data subject’s personal data to ensure maximum security.
2.6. In any case of transfer of personal data to a third country, the data subject is entitled to obtain a copy of the data.
3. DATA RECIPIENT
3. 1 Talent Bridge may entrust the processing of personal data to third parties in order to perform certain activities. In that case, the recipients of the individual’s data may be: a hosting provider for Talent Bridge, an email service provider, a company providing technical support, a service provider for sending emails, a law firm, an accounting firm.
3.2. Personal data collected by Talent Bridge may also be made available: to the relevant state authorities upon their request under the relevant provisions of law, or to other persons and entities – in cases provided for by law.
3.3. Each entity to which Talent Bridge entrusts personal data for processing, based on the entrustment agreement for the processing of personal data (hereinafter “Entrustment Agreement”) shall guarantee an adequate level in terms of security and confidentiality of personal data processing. An entity that processes personal data of data subjects based on the Entrustment Agreement may process personal data of such data subjects, through another entity, only on the basis of Talent Bridge’s prior consent.
3.4. Sharing of personal data with unauthorized parties according to this Privacy Policy, may only take place with the prior consent of the subject.
- RIGHTS OF THE DATA SUBJECT
4.1. Each data subject has the right to: (a) have the personal data collected about him/her deleted both from the system belonging to Talent Bridge and from the databases of entities with which Talent Bridge cooperates or has cooperated, (b) have the processing restricted, (c) have the personal data collected by Talent Bridge ported, including to receive them in a structured form, (d) request Talent Bridge to access and rectify your personal data, (e) object to the processing, (f) revoke Talent Bridge’s consent at any time without affecting the lawfulness of the processing performed on the basis of consent before its revocation; (g) file a complaint against Talent Bridge to a supervisory authority (the President of the Office for Personal Data Protection).
5.OTHER DATA
5.1. Talent Bridge may store http requests, and therefore some information may be stored in the server log files, including the IP address of the computer from which the request came, the station name of the data subject – identification carried out by the http protocol, if possible, the date and system time of registration on the TalentBridge site and arrival of the request, the number of bytes sent by the server, the URL of the site previously visited by the data subject if he or she entered the Talent Bridge site using a link, information about the browser, information about errors that occurred in the execution of the http transaction. Logs may be collected as material for the proper administration of Talent Bridge. Only persons authorized to administer the information system have access to the information. Log files may be analyzed to compile statistics of Talent Bridge website traffic and errors that occur. A summary of such information does not identify an individual.
6. SECURITY
- 1. Talent Bridge uses technical and organizational measures to ensure the protection of the processed personal data appropriate to the risks and categories of protected data, and in particular technically and organizationally protects the data from being made available to unauthorized persons, from being taken by an unauthorized person, from being processed in violation of the Act, and from being altered, lost, damaged or destroyed, among others SSL certificates are used. The collection of collected personal data is stored on a secured server and data is also protected by Talent Bridge’s internal procedures on personal data processing and information security policy.
6.2. Talent Bridge has also implemented appropriate technical and organizational measures, such as pseudonymization, designed to effectively implement data protection principles, such as data minimization, and to give processing the necessary safeguards to meet the requirements of the RODO and protect the rights of data subjects.
6.3. At the same time, Talent Bridge points out that the use of the Internet and electronically provided services may be at risk of malicious software (malware) entering the ICT system and device of a given user, as well as unauthorized access to data, including personal data, by third parties. In order to minimize these risks, the data subject should use appropriate technical safeguards, e.g. using up-to-date antivirus software or protecting his/her identification on the Internet. In order to obtain detailed and professional information regarding the preservation of security on the Internet, Talent Bridge recommends seeking it from entities specializing in such IT services.
7. COOKIES
7.1. In order for the website to function properly, Talent Bridge uses cookie technology. Cookies are packets of information stored on a given user’s device, via Talent Bridge, usually containing information consistent with the purpose of a given file, by means of which a given user uses the Talent Bridge website – these are usually: service address, posting date, expiration date, unique number and additional information consistent with the purpose of a given file.
7.2. Talent Bridge uses two types of Cookies: (a) session cookies, which are deleted permanently when a given user’s browser session ends; (b) persistent cookies, which remain after the end of the browser session on a given user’s device until they are deleted.
7.3. Based on Cookies, both session and permanent, it is not possible to determine the identity of a given user. The Cookies mechanism does not allow the collection of any personal data.
7.4. Talent Bridge cookies are safe for the device of a given user, in particular, they do not allow viruses or other software to enter the device.
7.5. Cookies generated directly by Talent Bridge cannot be read by other services. External Cookies (i.e. Cookies placed by entities that cooperate with Talent Bridge) can be read by an external server.
7.6. The user in question can change his/her own settings regarding Cookies at any time, specifying the conditions for storing them, through the settings of the Internet browser or through the configuration of the service.
7.7.The user in question can change his/her own settings regarding Cookies at any time, specifying the conditions for storing them, through the settings of the Internet browser or through the configuration of the service.
7.8. First of all, a given user may disable the storage of Cookies on his/her device, according to the instructions of the browser manufacturer, but this may result in the unavailability of some or all of the functions of the Talent Bridge website.
7.9. The user in question may also delete the cookies stored on his device himself at any time, according to the instructions of the browser manufacturer.
7.10. Talent Bridge uses proprietary Cookies for the following purposes: website configuration and customization of the content of the pages according to the preferences or behavior of a particular user; audience analysis and research, number of clicks and paths through the site to improve the design and organization of content on the site, time spent on the site, number and frequency of visitors to the Talent Bridge site.
7.1. Detailed information on the handling of Cookies is available in the settings of the Internet browser used by the data subject.
8.FINAL PROVISIONS
8.1. This Privacy Policy is effective as of 02/03/2021.