Privacy Policy

The aim of this document (hereinafter referred to as the “Policy”) is to explain how we, ITDS Poland (hereinafter referred to as “We/Us” or “ITDS”), process your personal data while interacting with us you visit our website at www.itds.pl (hereinafter referred to as the “Website”).

We process your personal data for specific purposes, though always caring about your privacy.

The Policy provides information about how We process your personal data, and in particular:

• identifies the types of personal data We collect;
• explains how and why We collect and use your personal data;
• explains when and why We will share personal data with other entities; and
• explains the rights and choices you have regarding your personal data.

We want it to be clear to you whether the Policy also applies to the processing of your personal data. The Policy applies if you are a:

• visitor to the Website, i.e. you make a visit to the Website or contact Us via a contact form;
• Subscriber, i.e. you have subscribed to Our newsletter or you download Our case study;
• Business Partner, i.e. you provide any products or services to Us, use Our services or work with Us on joint ventures;
• Business Partner’s Representative, i.e., you represent an entity that provides any products or services to Us, uses Our services, or works with Us on joint ventures;
• Referring Person, i.e. you refer a candidate for one of the IT positions in currently open recruitments conducted by Us;
• Job Candidate, i.e. you participate in Our recruitment process under Labor Code via Website or you send us your application documents for this or future recruitment processes;
• Candidate for Contractor, i.e. you are a sole proprietor or a representative of an entity and participate in Our recruitment process via Website or you send us your application documents for this or future recruitment processes.

This Policy is supposed to help you understand how We collect data, for what purposes and how you can exercise your rights pursuant to the Regulation 2016/679 (hereinafter referred to as “GDPR”). In the matters concerning data processing in relation to visiting the Website, you can contact Us at info@ITDS.pl.

Information on how we use cookies can be found in our Cookie Policy.

The data controller of your personal data is ITDS Polska sp. z o.o. with its registered seat in Warsaw, entered into 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 under number KRS: 0000586898, NIP: 7010520905, REGON: 363016333.

In matters related to the processing of personal data you can contact Us by mail or by e-mail address info@ITDS.pl or privacy@ITDS.pl.
We have also appointed a Data Protection Officer with whom you can contact at by mail (at ITDS address) or by e-mail: privacy@ITDS.pl.

If you are a visitor to the Website, We collect information during your use of the Website, during conversations, when you exchange emails, when you fill out a contact form. This may include, but is not limited to, your name, mailing address, email address, and phone number.

If you are a Subscriber, We collect your data provided in a newsletter or case study form. This includes your name, surname and email address, and may also include phone number and other contact information.

If you are a Business Partner, We collect information provided to us in the documents sent by you, during conversations and e-mail exchanges, including in particular information necessary to conclude and perform an agreement. This may include, in particular, your name, surname, e-mail address, telephone number, company, business address, PESEL, NIP, REGON, bank account number. Your data may also come from publicly available sources.

If you are a Business Partner’s Representative, We collect information provided to us in the documents sent by you, during conversations and e-mail exchanges. This may include, in particular, your name, contact details, position, data concerning the entity you represent. Your data may also be provided to us by the entity you represent both before and during your cooperation with us.

If you are a Referring Person, We collect your data provided in a Referral Program form. This includes your name, surname and email address, other contact information and data necessary to pay out bonus.

If you are a Job Candidate, We collect information provided to us in the documents sent by you, in the forms filled in by you on the Website, during conversations and e-mail exchanges. This may include, in particular your name, date of birth, contact details, education, professional qualifications and previous employment history, as well as other personal data which you provide to us on your own initiative. Remember that providing your personal data to the extent stipulated by law, including art. 22¹ § 1 and 4 of the Labor Code (Kodeks Pracy), is necessary to participate in the recruitment procedure. Providing the remaining data is voluntary, and their omission will not result in any negative consequences towards you, especially it will not constitute a reason justifying refusal to employ you.

If you are a Candidate for Contractor, We collect information provided to us in the documents sent by you, in the forms filled in by you on the Website, during conversations and e-mail exchanges. This may include, in particular your name, date of birth, contact details, education, professional qualifications and previous employment history, as well as other personal data which you provide to us on your own initiative or that are required by Our client.

If you are a visitor to the Website, We process your data:

• for the purpose of Our legitimate interests, i.e. for ensuring security, running the Website, adapting the Website’s functionality to users’ needs, for the purpose of contact in response to your questions, requests, comments, for the purpose of handling your request directed via the contact form or by other means, for reporting purposes, internal administrative and marketing purposes (Article 6(1)(f) of the GDPR);

If you are a Subscriber, We process your data:

• on the basis of your consent (Article 6(1)(a) of the GDPR) for provision of newsletter via e-mail;
• to provide you with services of electronic form, such as case study, on your request (Article 6(1)(b) of the GDPR)
• for the purpose of Our legitimate interests (Article 6(1)(f) of the GDPR), i.e. ensuring security, running the Website, adapting the Website’s functionality to users’ needs, for the purpose of contact in response to your questions, requests, comments, for the purpose of handling your request directed via the contact form or by other means, for reporting purposes, internal administrative and marketing purposes;

If you are a Business Partner, We process your data:

• for the conclusion and performance of the contract (art. 6(1)(b) of the GDPR);
• in order to comply with legal obligations (Article 6(1)(c) of the GDPR), in particular with regard to the settlement of tax debts and the storage of financial records;
• in order to pursue Our legitimate interests (Article 6(1)(f) of the GDPR) related to the operation of the business, the Website, maintaining business relationships, ongoing contact, conducting marketing activities, as well as pursuing and defending against claims;

If you are a Business Partner’s Representative, We process your data:

• in order to pursue Our legitimate interests (Article 6(1)(f) of the GDPR) related to entering into and performing a contract with the entity you represent, maintaining business relations and ongoing contact, conducting marketing activities, as well as pursuing and defending against claims;

If you are a Referral Person, We process your data:

• organise and execute the Referral Program, including receiving of the referrals and verify the entitlement to receive the bonus, payment of the bonus and to assess complaints, remarks and reservations of the Referring Persons (art. 6(1)(b) and (f) of the GDPR);
• perform legal obligations, in particular those resulting from Tax Law (Article 6(1)(c) of the GDPR);
• in order to pursue Our legitimate interests (Article 6(1)(f) of the GDPR) related to the operation of the business, the Website, maintaining business relationships, ongoing contact, conducting marketing activities, as well as pursuing and defending against claims;

If you are a Job Candidate, We process your personal data:

• on the basis of your consent for the current and future recruitment processes (Article 6(1)(a) of the GDPR);
• on the basis of your consent in regard to special category data if you have provided it to us on your own initiative (Article 9(2)(a) of the GDPR);
• in order to comply with the ITDS’s legal obligations as an employer and the corresponding rights of a job applicant under the law, including employment law (Article 6(1)(c) of the GDPR);
• in order to pursue Our legitimate interests (Article 6(1)(f) of the GDPR) related to the operation of the Website, ongoing contact, providing you with information about job opportunities, as well as pursuing and defending against claims

If you are a Candidate for Contractor, We process your personal data:

• on the basis of your consent for the current and future recruitment processes (Article 6(1)(a) of the GDPR);
• on the basis of your consent in regard to special category data if you have provided it to us on your own initiative (Article 9(2)(a) of the GDPR);
• in order to pursue Our legitimate interests (Article 6(1)(f) GDPR) related to the operation of the Website, ongoing contact, background checking, providing you with information about job opportunities, as well as pursuing and defending against claims.

When necessary for the purposes for which we process your data, We may make your data available to:

1. entities entitled to receive them under the law;
2. entities processing personal data on our behalf, i.e. companies providing certain services for us, the performance of which involves the processing of personal data. For example, entities providing us with HR and finance, marketing or hosting services, entities providing us with consultancy services and others (so-called “processors”);
3. entities within the capital group of which ITDS is a part.

Additionally, if you are a Job Candidate or a Candidate for Contractor, we may share your data with Our client for whom you will be performing work or services.

Whenever we share your data, we will ensure that the sharing has a legal basis and includes only the minimum information necessary to fulfil the purpose of the processing for which the data is being shared.

If necessary for the purposes referred to in Section 4, your data may be transferred outside the European Economic Area. In any transfer of your data outside the EEA we will ensure the highest level of security.

If you are a visitor to the Website, We will retain your personal information as long as necessary for the purposes of operating the Website.

If you are a Subscriber, We will retain your data as long as necessary for marketing purposes or for provision of services. In case of newsletter, we will process data until you withdraw your consent.

If you are a Business Partner or its Representative, We store your data for the period of performance of the contract concluded with you or the entity you represent. After that period, to the extent necessary, we will retain your data for the period resulting from legal requirements (e.g. the obligation to keep financial records for 5 years), statutes of limitation on claims (3 years for the statute of limitations on claims arising from business activities), or as necessary to fulfill the other purposes of data processing indicated in this Policy.

If you are a Referring Person, We store your data for the period of the Referral Program. After that period, to the extent necessary, we will retain your data for the period resulting from legal requirements (e.g. the obligation to keep financial records for 5 years), statutes of limitation on claims or as necessary to fulfill the other purposes of data processing indicated in this Policy.

If you are a Job Candidate or Candidate for Contractor, We will hold your data until the end of the recruitment process, and longer only if you have consented to us processing it for future processes.

In exercising your rights in relation to the processing of your personal data, you may direct the following requests to us:

1. where we process your personal data on the basis of your consent, you may withdraw that consent at any time; withdrawal of consent does not affect the lawfulness of the processing we have carried out on the basis of that consent up to the time of withdrawal;
2. you can request access to and obtain a copy of your personal data;
3. you can request rectification of your personal data if it is incorrect or incomplete;
4. the right to data portability;
5. in relation to your particular situation, you may object to the processing of your personal data where we are processing it on the basis of our legitimate legal interest;
6. in cases provided for by law – e.g. if your data is outdated, redundant, processed unlawfully, and if you have withdrawn your consent to the processing of your personal data (where consent was the basis for such processing) or you have successfully raised an objection to the processing of your personal data – you can request the erasure of your personal data;
7. you can also request the restriction of data processing.

In order to exercise the above rights, please contact us by correspondence or at the following email address: info@ITDS.pl or a dedicated email concerning privacy: privacy@itds.pl

In any case in which you consider that our processing of your personal data violates the provisions of the GDPR, you also have the right to lodge a complaint with the President of the Office for Personal Data Protection (Prezes Urzędu Ochrony Danych Osobowych).

It is fully optional for you to give Us your data; however, without it we will not be able to realize the objectives stipulated above, and in particular we will be unable to:

1. answer your request;
2. provide you with information concerning the ITDS’s recruitment process;
3. provide you with newsletter or case study;
4. enter into an agreement or perform such an agreement;
5. provide you with services or receive your services;
6. perform the recruitment process.

If you are a Business Partner’s Representative and you do not provide Us with your data yourself, it comes from the entity you represent or it has been collected by us from publicly available sources (e.g. the entity’s website).

If you are a Job Candidate or Candidate for Contractor and you do not provide Us with your data yourself, your data comes from Referring Person or publicly available sources, such as LinkedIn or a background check.