Information on the Processing of Personal Data
(Slovakia)
1. Introduction
CoolPeople s.r.o., Company ID (IČO) 45 614 903, with its registered office at Na strži 2097/63, Krč, 140 00 Praha 4, registered in the Commercial Register of the District Court Bratislava III, Section Sro, Insert No. 65932/B (hereinafter "CoolPeople", the "Controller", or "we"), pays due attention to the protection of your personal data.
CoolPeople 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, visitors to our websites, and other individuals who communicate with us.
The purpose of this document is to inform you, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (the General Data Protection Regulation, "GDPR") and with Act No. 18/2018 Coll., on personal data protection, about which personal data we process, for what purposes, on what legal basis, to whom we disclose them, and what rights you have in relation to their processing.
When processing personal data, 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 the following categories of personal data:
- Identification data — first name and surname, title, date of birth, and, for self-employed persons, Company ID and Tax ID;
- Contact data — mailing address, e-mail address, telephone number;
- Professional data — job position, information on qualifications, education, completed courses and certifications, professional experience, language skills;
- Cooperation data — availability, financial expectations (expected remuneration / rate), project preferences;
- Billing and payment data — bank account number, invoicing details;
- Communication data — the content of e-mail and other communication, data entered into contact forms;
- Technical data from the website — IP address (generally processed in anonymised form for statistical purposes), browser and operating system type, information on your activity on the website.
We generally do not process, and do not ask you to provide, special categories of personal data (Article 9 GDPR).
3. Purposes of processing
We process your personal data in particular for the following purposes: provision of services (matching IT specialists with clients, provision of IT capacity and technology services); recruitment; communication with clients and candidates; performance of contractual obligations; management of business relationships; marketing; compliance with legal obligations (in particular accounting and taxation); protection of legal claims; and the operation, security and traffic measurement of the website.
4. Legal basis for processing
Each processing operation is based on one of the following legal bases under Article 6(1) GDPR:
- performance of a contract [Art. 6(1)(b)];
- compliance with a legal obligation [Art. 6(1)(c)] — in particular under accounting and tax legislation;
- legitimate interests [Art. 6(1)(f)] — informing you about 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; you may withdraw it at any time.
Withdrawal of consent does not affect the lawfulness of processing carried out before its withdrawal.
5. Sources of personal data
We obtain personal data directly from you; from our clients (contact details of their staff); and from public sources and professional platforms (in particular professional social networks such as LinkedIn and job portals) where we search for suitable candidates. Where we obtain your data other than directly from you, we will inform you in accordance with Article 14 GDPR at the latest within one month of obtaining them, or upon our first communication with you.
6. Categories of data subjects
Candidates and IT specialists and suppliers; external contractors; employees and contact persons of clients; other business partners; website visitors; and other individuals who communicate with us.
7. Who processes your personal data
We process your personal data as a controller. 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:
Slovak Republic
- CoolPeople Personal s.r.o., ID No.: 56 871 201, with its registered office at Karadžičova 8, Bratislava - mestská časť Ružinov 821 08
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
Austria
- CoolPeople GmbH, FN 446661f, with its registered office at Mariahilfer Straße 71, 1060 Vienna
Poland
- CoolPeople Sp. z o.o., NIP 8952014114, with its registered office at ul. Żelazna 2, 40-851 Katowice, Polsko
Switzerland
- CoolPeople Switzerland GmbH, CHE-367.502.928, with its registered office at Kre
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.
You can request the current list of processors using the contact information provided in Section 13.
8. Retention period
We retain personal data only for as long as necessary and thereafter for the period required by law or corresponding to our legitimate interest: for the duration of the contractual relationship and the running of the relevant limitation periods; for the period required by accounting and tax legislation; candidate data based on consent for or until consent is withdrawn; cookies as set out in Section 12.
9. Security of personal data
The company has implemented an information security management system in accordance with the ISO/IEC 27001:2022 standard, which is regularly audited by an accredited certification body.
Appropriate technical and organizational measures are in place to ensure the security of personal data and to protect it against unauthorized or accidental access, alteration, destruction, loss, or misuse. Risk analyses are conducted at regular intervals. Personal data is processed only by authorized and regularly trained personnel bound by a duty of confidentiality; access permissions are managed and regularly reviewed.
10. 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 and website operation we may use cookies and measurement/targeting tools; you may object to their use (Section 12).
11. Your rights
In relation to the processing of your personal data, you have the following rights, which you may exercise at any time using the contact details in Section 13:
- the right of access to your personal data (Art. 15 GDPR);
- the right to rectification of inaccurate data and completion of incomplete data (Art. 16);
- the right to erasure ("right to be forgotten", Art. 17);
- the right to restriction of processing (Art. 18);
- the right to data portability (Art. 20);
- the right to object to processing based on legitimate interests and to direct marketing (Art. 21);
- the right to withdraw consent where processing is based on consent, without affecting the lawfulness of prior processing;
- the right to lodge a complaint with the supervisory authority.
The supervisory authority in the Slovak Republic is the Office for Personal Data Protection of the Slovak Republic (Úrad na ochranu osobných údajov Slovenskej republiky), Galvaniho Business Centrum II, Galvaniho 7/B, Bratislava, www.dataprotection.gov.sk.
We will handle your request without undue delay and at the latest within one month, extendable by a further two months in complex cases. We may ask for additional information to verify your identity.
12. Cookies and similar technologies
Our website uses cookies and similar technologies. We use:
- necessary cookies (e.g. session identifier, storage of consents) — on the basis of our legitimate interest in operating the website;
- analytical and marketing cookies and tools — on the basis of your consent; these are in particular Google Analytics, Facebook Pixel and the Leady tool.
You may grant, refuse or change at any time your consent to cookies that require it via the cookie settings on our website:.
13. Contact details and updates
You may contact us in matters of personal data protection and the exercise of your rights:
- E-mail: dpo@coolpeople.sk
- Address: Karadžičova 8, Bratislava - mestská časť Ružinov 821 08
We may update these terms from time to time. The current version is always available on our website. We recommend that you review this document regularly.