Smart Topaz sp. z o.o.

This document will tell you how and on what basis we process your personal data when you contact us or use one of our services.

You will learn, among others:

  • why we may process your data;
  • for what purpose we process your data;
  • whether you are obliged to provide us with your data;
  • how long we keep them;
  • whether there are other recipients of your personal data;
  • whether we process your data outside the European Economic Area;
  • whether we process your data by automated means, including whether we profile data.
     

The first part of the Privacy policy contains information we are obliged to provide to everyone, regardless of the purpose of processing.

The second part contains information for persons who apply for a job in the Smart Topaz team (internal recruitment). This section applies to persons applying for a job with us by contacting joinus@smarttopaz.com.

The third part contains information for persons who apply for a job with our client for whom we are looking for employees or associates (external recruitment). Depending on the information contained in the advertisement, we are looking for an associate who will support our client via service outsourcing, or an employee or associate who will work directly with the client. This section applies to people who apply through our website.

The fourth part contains information for persons who communicate with us directly via the contact form available on our website or by sending us an e-mail or calling us.

The fifth section contains information for persons we contact when using data from publicly available sources, such as LinkedIn, exclusively related to business activities, for the sole purpose of establishing an appropriate and relevant relationship (employment, provision of services to a client, inclusion in a recruitment database), as well as when contacting persons referred by another person.

The sixth part contains information for persons - our potential clients’ representatives - whom we contact using data from publicly available sources, such as LinkedIn or company websites, exclusively related to business activity.

Part I. General Information

Contact details of your Data Controller

The Controller of your personal data is Us, Smart Topaz sp. z o.o. with its registered office in Warsaw (00-066), ul. plac Stanisława Małachowskiego 2, entered in the Register of Entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw in Warsaw, XII Commercial Division of the National Court Register, KRS number: 0000872097, NIP (Tax ID) number: 7011007185.

You can contact us in several ways regarding all matters concerning our services, as well as the processing of your personal data:

E-mail: office@smarttopaz.com
Tel.: +48 22 300 06 78

Where do we obtain your personal data from?

The personal information we collect through our website comes directly from you. This happens when:

  • you browse our website;
  • you send us your CV in order to take part in a recruitment process aimed at establishing cooperation with us;
  • you send us your CV to take part in a recruitment process aimed at finding you a job with our clients;
  • you send us questions or a request for a proposal.
     

We may also process your data if you provide it to us yourself, e.g. by giving us a business card, in order to establish a business relationship.

We may collect personal data we process through publicly available sources, mainly:

  • from your professional profile on LinkedIn - in this scope we only use your basic data to contact you with a view to starting a business relationship or finding you a suitable job;
  • directly from you, when you send us your application documents, if you agree for us to save a summary of your profile.
     

It may also happen that we receive your contact details from someone who has recommended you as a specialist in a particular field. In this case, we may contact you to verify whether you are interested in cooperation.

What rights do you have in relation to the processing of your personal data?

Below we set out your rights in relation to data protection and our processing of your data. The rights you have in particular circumstances depend on the purpose and basis of the processing of your data.

Right of access to data

You have the right to be informed about the personal data we hold about you. When you make a request for access to your data, you will be provided with information about the processing of your personal data, including in particular the purposes and legal basis of the processing, the scope of the data held, the entities to which the personal data are disclosed and the planned date of deletion.

Right of rectification

You have the right to have the personal data held about you rectified and/or supplemented without delay. It is our duty to ensure that our mutual communication is based on data that is true, complete and up-to-date.

Right to restrict processing

You have the right to ask us to restrict the processing of your personal data if you dispute the accuracy of data held about you, if processing is carried out without a legal basis or if you have presented your objection to data processing.

Right to erasure

You have the right to request erasure of your personal data held by us, if retention of the data is not necessary to ensure freedom of expression, freedom of access to information, to comply with a legal obligation, for reasons of public interest, to report or defend against claims or to assert rights under the law.

Right to information

If you have notified us of your right to rectification, erasure or restriction of processing, we will notify all recipients of your personal data of how to rectify, erase or impose restrictions on the processing of that data, unless this is impossible to carry out or involves a disproportionate effort.

Right to data portability

You have the right to obtain a copy of the data provided to us, which will be sent to you or a third party in a structured, standard, machine-readable format. If you request that the data be sent to another controller, this will be done as long as it is technically possible. This right only applies if we process your data on the basis of your consent or in connection with the performance of a contract.

Right to object

If your personal data is processed on the basis of our legitimate legal interest, you have the right to object at any time to further processing. We will consider your application in accordance with the regulations.

Right of withdrawal of consent

If your data is processed on the basis of consent, you have the right to withdraw it at any time, with future effect. This will not affect the legality of data processed to date.

Right to lodge a complaint with a supervisory authority

If the processing of your personal data violates data protection legislation or if your data protection rights have been infringed in any other way, you can lodge a complaint with the supervisory authority. The supervisory authority competent in the territory of Poland is the President of the Office for Personal Data Protection in Warsaw. Before exercising your right to complain, we encourage you to contact us first so that we can clarify any concerns you may have.

Consideration of your request

If you make a request to us to exercise your right, we will respond to your request within one month of receiving it. If it is necessary to extend this deadline, we will inform you of the reasons for such an extension.

Response to your request will be sent to the e-mail address from which you send your request or, in the case of requests made by letter, by traditional mail to the address you provide, unless you indicate in your letter that you wish to be contacted by e-mail (in which case you must provide your e-mail address).

Links to other sites

Where we provide links to third-party websites, this Privacy policy does not apply and does not describe how such entities processes your personal data. We encourage you to read these entities’ respective privacy policies published on their websites.

Visits to our website

Google Analytics

On our site we use tools from Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, Google Analytics, which allow us to collect statistical information about your use of our site such as IP address, device type, browser type. We do this in order to know, among others, the number of users accessing our website. This information is only processed in a way that does not allow us to identify anyone directly. Please note, however, that Google may process your data on a server in the United States. In these cases, Google may process your personal data outside the European Economic Area, but this takes place on the basis of so-called standard contractual clauses, provisions of the contract concluded between us and Google which guarantee an adequate degree of secure processing of your personal data.

If you are interested in the details related to the processing of data within Google Analytics, we encourage you to read the explanations prepared by Google here.

Cookies

Like almost all websites, we also use cookies.

Cookies, which are used to ensure the functionality, security and availability of the website, are essential for the correct operation of the website. These cookies let us know that you have accepted our Privacy policy and Cookie policy. We use these cookies on the basis of our legitimate legal interest.

Cookies that are used for statistical purposes (Google Analytics) are optional and we only use them on the basis of your consent.

You can read more about how we use cookies and how to change your cookie preferences on our Cookie policy page.

Changes to the Privacy policy

The Privacy policy is subject to periodic review and update as reasonably necessary. You can read about the changes to date below.

March 2021
We launched our website and published the first version of our Privacy policy.

August 2021

We expanded the content of the Privacy policy by adding sections five and six. At the same time, we updated the first part (where we obtain your data from) and the third part (data retention period).

Part II. Data Processing as Part of an Internal Recruitment Process

Below we present to you the principles of personal data processing that apply when you apply for a job in the Smart Topaz team (internal recruitment). For this purpose, we collect data by asking you to send us an e-mail together with your CV to the address indicated under About Us/Join Us. We also recruit internally via LinkedIn, by providing information about ongoing recruitments on our professional profiles. Sending a CV to the address indicated therein results in the processing of personal data under the terms of this section.

For what purpose do we process your data?

We process your personal data to assess your eligibility to work in our team; to assess your abilities and skills needed to work in our team; to select the right person to work for us.

If you want us to process your personal data also in case of future recruitment processes or in the future, if we are not actively recruiting at the moment, please include your consent to the processing of data for this purpose in your CV.

On what legal basis do we process your data?

The legal basis for processing your personal data is:

  • legal obligation to provide personal data resulting from Article 22(1) § 1 and 2 of the Labour Code;
  • your consent to the processing of the data contained in your application documents in the scope exceeding the mandatory data resulting from the Labour Code in order to participate in an individual recruitment process, which you express by sending us an application containing a broader catalogue of data than that resulting from the Labour Code;
  • your consent for the purpose of participating in future recruitment processes expressed by inserting the appropriate clause in your application documents;
  • our legitimate interest - with regard to data collected during the interview, the results of the selection tests. We have a legitimate interest in testing your skills and abilities and selecting the right person for the job.
     

How long do we process your data?

We will process your personal data for the duration of the recruitment process for the position you have applied for and, in the event of a negative outcome of the recruitment process, for no longer than 3 months. If the recruitment process is successful, we will conclude a contract with you.

We will keep your personal data for 36 months if you have given separate consent for us to process your personal data for the purpose of participating in future recruitments. If you withdraw your consent, the relevant data will be deleted immediately.

Who is the recipient of your personal data?

The recipients of your personal data, i.e. the external entities that may be involved in the processing of your data, will be our trusted subcontractors - IT service providers for data hosting and business mail services, as well as the entity providing us with the software used to maintain the recruitment database.

Nature of data provision

Provision of personal data required by the Labour Code is mandatory. Without providing this data, you will not be able to participate in the recruitment process.

Provision of other data is voluntary.

Other relevant information

Your data will not be subject to automated processing or profiling. Your data will not be processed outside the European Economic Area.

What rights do you have?

Your rights are set out in Part I of this Privacy policy.

Part III. Data Processing as Part of an External Recruitment Process

Below we set out the principles for processing personal data that apply when you apply for a job offered by our client or when you wish to work with us to provide outsourcing services to our client. Information on the nature of the recruitment is contained in the advertisement (contract with the client - outsourcing, employment contract with the client - direct cooperation with the client). For this purpose, we collect data by asking you to send us an e-mail together with your CV to the address indicated under Direct Search.

If you want us to be able to process your personal data also in case of future recruitment processes, provide your consent to further data processing by either including consent to processing of data for this purpose in your CV or by answering "Yes" to our question about your consent. The question may be found in the autoresponder you receive when you send your CV.

For what purpose do we process your data?

We process your personal data to assess your eligibility to work in the position you are applying for; to assess your abilities and skills needed to work in the position you are applying for; to select the right person to work for our client.

If you consent to the processing of your data in future recruitment processes, we will also contact you after the end of this specific recruitment process if there is a future job offer suited to your competences with another of our clients.

On what legal basis do we process your data?

The legal basis for processing your personal data is:

  • your consent to the processing of the data contained in your application documents in order to participate in a unitary recruitment process, which you express by sending us your application;
  • your consent to participate in future recruitment processes, provided either by including a relevant clause in your application documents or by replying “Yes” to the question on data processing for indicated purposes sent via the autoresponder confirming submission of your CV;
  • our legitimate interest - with regard to data collected during the interview, the results of the selection tests. We have a legitimate interest in testing your skills and abilities and selecting the right person for the job.
     

How long do we process your data?

We will process your personal data for the duration of the recruitment process for the position you have applied for and, in the event of a negative outcome of the recruitment process, for no longer than 3 months. If the recruitment process is successful, we will conclude a contract with you.

If you consent to the processing of your data in future recruitment processes, we will include your data in our recruitment database. We are a recruitment agency and we will contact you in order to offer you a suitable job or cooperation for the period of validity of the consent given, until it is withdrawn. If you withdraw your consent, the relevant data will be deleted immediately.

Who is the recipient of your personal data?

The recipients of your personal data, i.e. the external entities that may be involved in the processing of your data, will be our trusted subcontractors - IT service providers for data hosting and business mail services, as well as the provider of recruitment support software.

Provided you meet the formal requirements for the position applied for, your personal data will only be shared with one potential employer (client) for whom we are recruiting. The prospective employer to whom we share your data will be required to provide you with further information regarding the processing of your personal data. We do not pass on your personal data to a position for which you are not applying without your consent.

Nature of data provision

Provision of data is voluntary.

Other relevant information

Your data will not be subject to automated processing or profiling. Your data will not be processed outside the European Economic Area.

What rights do you have?

Your rights are set out in Part I of this Privacy policy.

Part IV. Processing of Data through Communication Channels

Below we set out the principles for processing your personal data applicable when you e-mail us with a question or request an offer, use our contact form or contact us in any other way using the data available on our website.

For what purpose do we process your data?

We process your personal data in order to answer your questions, to provide you with an offer of cooperation, to take further steps to conclude a contract.

On what legal basis do we process your data?

The legal basis for processing your personal data is:

  • your consent given by sending us a specific question;
  • necessary actions to conclude a contract in terms of presentation of the offer and communication aimed at concluding the contract.
     

How long do we process your data?

We will process your data until you withdraw your consent, and with regard to activities aimed at concluding a contract - for the duration of the contract, the period of the statute of limitations for claims, the period resulting from legal regulations determining the duration of keeping accounting documents.

Who is the recipient of your personal data?

The recipients of your personal data, i.e. the external entities that may be involved in the processing of your data, will be our trusted subcontractors - IT service providers for data hosting and business mail services.

Nature of data provision

Provision of your data is voluntary.

Other relevant information

Your data will not be subject to automated processing or profiling. Your data will not be processed outside the European Economic Area.

What rights do you have?

Your rights are set out in Part I of this Privacy policy.

Part V. Processing of Applicant Data from Public Sources

Below we provide information about data processing that applies when we contact you for the first time via LinkedIn in order to find out whether you are interested in a job or service for our client, possibly in obtaining further support with changing jobs, which involves subsequent inclusion of your data in our recruitment database. LinkedIn is a portal that allows professionals to communicate. We only use this portal to contact selected individuals who may be interested in establishing a relationship. If you are not interested in cooperation, we will delete your data immediately. If, on the other hand, you express a further desire to cooperate, we will support you in finding a better job.

This information also applies when we contact you on the basis of data received from a third party who has referred you to us as a specialist. In these circumstances, we will only process the data to verify your interest in cooperating with us - if there is no interest, we will delete the data immediately.

For what purpose do we process your data?

We process your initial contact details in order to make contact with you and to find out whether you are interested in our support in finding you a better job.

We then process the remaining data that you provide us with or that you have consented to in order to offer you job offers that are tailored to you.

On what legal basis do we process your data?

The legal basis for processing your personal data is:

  • our legitimate interest - in terms of the basic contact information you make publicly available on your professional profile on LinkedIn or that we receive from a person who recommends you. We have a legitimate interest in contacting you and offering you an opportunity to find a better job;
  • your consent to the processing of personal data contained in your application documents or data provided by you on LinkedIn, expressed during communication by telephone, email or via LinkedIn, to include your data in our recruitment database and to offer you matched job opportunities.
     

How long do we process your data?

We only process the basic contact data obtained from your LinkedIn profile or received from the person who referred you for the time necessary to establish contact, but no longer than 6 months. If you are not interested in our support in finding you a job within this period, we will delete your data.

If you consent to your data being included in our recruitment database, we will process your data until you withdraw your consent.

Who is the recipient of your personal data?

The recipient of your personal data, i.e. an external entity that participates in the processing of your data, is a software provider that supports the conduct of recruitment processes, including the creation and maintenance of a recruitment database. The designated provider operates and maintains our recruitment database using AWS servers located in Germany and Ireland.

Provided you are interested, you meet the formal requirements for the position applied for and you want to participate in a specific recruitment process, your personal data will only be shared with one potential employer for whom we are recruiting. The prospective employer to whom we share your data will be required to provide you with further information regarding the processing of your personal data. We do not pass on your personal data to a position for which you are not applying without your consent. We always ask for your consent before passing on your data.

Nature of data provision

Provision of data is voluntary. Please note, however, that if you do not give us your details, we will not be able to help you find a better job.

Other relevant information

Your data will not be subject to automated processing or profiling. Your data will not be processed outside the European Economic Area.

What rights do you have?

Your rights are set out in Part I of this Privacy policy.

Part VI. Processing of Data for Marketing of Own Services

The information below applies to persons - our potential clients’ representatives - whom we contact using data from publicly available sources, such as LinkedIn or company websites, exclusively related to business activity.

For what purpose do we process your data?

We process your initial contact details in order to make contact with you and to find out whether you are interested in mutual cooperation.

If you confirm, we process your data in order to offer you cooperation.

On what legal basis do we process your data?

The legal basis for processing your personal data is:

  • our legitimate interest - in terms of the basic contact information you make publicly available on your professional profile on LinkedIn, on a website or that we receive directly from you in another form. We have a legitimate interest in contacting you and offering you cooperation;
  • your consent to the processing of personal data expressed during communication by telephone, email or via LinkedIn, to the processing of your data in the future for the purpose of making you offers of cooperation.
     

How long do we process your data?

We only process contact data obtained directly from you or from publicly available sources for the time necessary to establish contact, but no longer than 6 months.

If you consent to receive offers of cooperation, we will process your data until you withdraw your consent.

Who is the recipient of your personal data?

The recipient of your personal data, i.e. an external entity that participates in the processing of your data, is a software provider that supports the conduct of recruitment processes, including the creation and maintenance of a recruitment database. The designated provider operates and maintains our recruitment database using AWS servers located in Germany and Ireland.

Nature of data provision

Provision of data is voluntary. Please note, however, that if you do not give us your details, we will not be able to establish cooperation.

Other relevant information

Your data will not be subject to automated processing or profiling. Your data will not be processed outside the European Economic Area.

What rights do you have?

Your rights are set out in Part I of this Privacy policy.