Information on the Processing of Personal Data
(Poland)
1. Introduction
CoolPeople Sp. z o.o., Tax ID (NIP) 8952014114, with its registered office at ul. Żelazna 2, 40-851 Katowice, KRS: 0000425690 (hereinafter "CoolPeople", the "Controller", or "we"), pays due attention to the protection of your personal data.
CoolPeople Sp. z o.o. is part of the CoolPeople group, which operates in the field of providing professional IT and other technology services, IT resources, recruitment and staffing services. In the course of these activities, we process personal data of candidates and IT specialists, external contractors, our clients' contact persons, business partners, suppliers, website visitors, and other individuals who communicate with us.
The purpose of this document is to inform you, in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation, "GDPR") and the Polish Personal Data Protection Act of 10 May 2018 (Journal of Laws 2018, item 1000), about which personal data we process, for what purposes, on what legal basis, to whom we disclose them, and what rights you have.
We observe the principles of lawfulness, fairness and transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity and confidentiality (Article 5 GDPR).
2. What personal data we process
Depending on the category of data subject to which you belong (see Section 6), we process in particular: identification data (name, title, date of birth, and for entrepreneurs Tax ID and REGON); contact data; professional data (position, qualifications, education, courses and certifications, experience, language skills); cooperation data (availability, financial expectations, project preferences); billing and payment data; communication data; and technical website data (IP address, generally anonymised for statistics; browser and OS type; activity on the website).
We generally do not process special categories of personal data (Article 9 GDPR).
3. Purposes of processing
Provision of services; recruitment; communication with clients and candidates; performance of contractual obligations; management of business relationships; marketing; compliance with legal obligations (accounting and taxation); protection of legal claims; and operation, security and traffic measurement of the website.
4. Legal basis for processing
- performance of a contract [Art. 6(1)(b)];
- compliance with a legal obligation [Art. 6(1)(c)] — in particular accounting and tax law;
- legitimate interests [Art. 6(1)(f)] — news and opportunities, managing business relationships, protecting legal claims, network and website security, and intra-group transfers for internal administrative purposes (Section 7);
- consent [Art. 6(1)(a)] — where required, in particular for transfers to business partners and for marketing cookies; revocable at any time.
Marketing conducted via electronic means (e-mail, SMS, telephone) additionally requires separate consent under the Polish Telecommunications Law and the Act on Providing Services by Electronic Means, regardless of the personal data processing legal basis indicated above.
Withdrawal of consent does not affect the lawfulness of prior processing.
5. Sources of personal data
Directly from you; from our clients; and from public sources and professional platforms (in particular LinkedIn and job portals) where we search for candidates. Where obtained other than directly from you, we inform you under Article 14 GDPR at the latest within one month, or upon first communication.
6. Categories of data subjects
Candidates and IT specialists; external contractors; employees and contact persons of clients; business partners; suppliers; website visitors; and other individuals who communicate with us.
7. Who processes your personal data
We process your personal data as a controller, as we determine the purposes and means of the processing.
For internal administrative purposes, we may transfer your personal data to other companies of the CoolPeople group on the basis of our legitimate interest under Article 6(1)(f) GDPR in conjunction with Recital 48 GDPR. The group companies are in particular:
Czech Republic
- CoolPeople Technology a.s., ID No.: 29034400, with its registered office at Na strži 2097/63, Krč, 140 00 Praha 4
- CoolPeople Holding s.r.o., ID No.: 05288398, with its registered office at Na strži 2097/63, Krč, 140 00 Praha 4
- CoolPeople Personal s.r.o., ID No.: 24158216, with its registered office at Na strži 2097/63, Krč, 140 00 Praha 4
- CoolPeople Services s.r.o., ID No.: 24138011, with its registered office at Na strži 2097/63, Krč, 140 00 Praha 4
Slovak Republic
- CoolPeople s.r.o., ID No.: 45 614 903, with its registered office at Karadžičova 8, Bratislava - mestská časť Ružinov 821 08
- CoolPeople Personal s.r.o., ID No.: 56 871 201, with its registered office at Karadžičova 8, Bratislava - mestská časť Ružinov 821 08
Austria
- CoolPeople GmbH, FN 446661f, with its registered office at Mariahilfer Straße 71, 1060 Vienna
Switzerland
- CoolPeople Switzerland GmbH, CHE-367.502.928, with its registered office at Kreuzstrasse 26, 8008 Zürich
Status of the group companies. The individual group companies generally act as separate controllers, each determining the purposes and means of processing for its own activities. Where a specific processing operation involves the joint determination of purposes and means (e.g. a jointly operated candidate database), the companies concerned would act as joint controllers under Article 26 GDPR and conclude a corresponding arrangement; where one company acts exclusively on the instructions of another, it acts as a processor under Article 28 GDPR. The specific arrangement will be confirmed according to the actual circumstances of the group.
We also disclose your personal data to processors and other recipients, in particular:
- providers of IT and cloud services and systems;
- providers of recruitment and relationship-management tools (ATS/CRM);
- providers of accounting, tax and legal services;
- public authorities, where required by law.
We have concluded a data processing agreement under Article 28 GDPR with each processor.
8. Transfer of data outside the EEA
We process personal data as a rule within the European Union and the European Economic Area. Where a transfer to a third country takes place (e.g. where we use a provider based outside the EEA), we ensure that this occurs only in compliance with the conditions of Chapter V GDPR (Articles 44–49) — in particular on the basis of an adequacy decision (Art. 45) or standard contractual clauses adopted by the European Commission (Art. 46).
9. Retention period
Only as long as necessary and thereafter as required by law or corresponding to our legitimate interest: for the contractual relationship and the running of limitation periods; for the period required by accounting and tax law; candidate data based on consent for or until withdrawal; cookies as set out in Section 13.
10. Security of personal data
Appropriate technical and organisational measures; processing only by authorised persons bound by confidentiality; access rights managed and reviewed regularly.
11. Automated decision-making and profiling
No automated decision-making producing legal or similarly significant effects within the meaning of Article 22 GDPR takes place. For marketing/website operation we may use cookies and measurement/targeting tools; you may object (Section 13).
12. Your rights
Access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), data portability (Art. 20), objection (Art. 21), withdrawal of consent, and the right to lodge a complaint with the supervisory authority.
The supervisory authority in Poland is the President of the Personal Data Protection Office (UODO), ul. Stanisława Moniuszki 1A, 00-014 Warsaw, www.uodo.gov.pl.
We handle your request without undue delay and at the latest within one month, extendable by a further two months in complex cases. We may request additional information to verify your identity.
13. Cookies and similar technologies
Necessary cookies (session identifier, storage of consents) on the basis of our legitimate interest, and analytical and marketing cookies and tools on the basis of your consent — in particular Google Analytics, Facebook Pixel and the Leady tool. The use of these tools may involve the transfer of data to providers outside the European Economic Area (in particular to the USA) — see Section 8 on transfers of data outside the EEA. You may grant, refuse or change consent via the cookie settings on our website:
14. Contact details and updates
- E-mail: dpo@coolpeople.pl
- Address: Żelazna 2, 40-851 Katowice
We may update this notice from time to time. The current version is always available on our website.