Privacy Policy of GoldenLine Sp. z o.o.

Valid from 11 May 2018

We are very happy that you decided to visit our website. We would like to inform you that the Website, which is owned by GoldenLine Sp. z o.o., collects and processes your personal data. This document defines the principles and purposes of processing such data, and provides information on your rights and the way in which you can exercise them.

Definitions

GoldenLine/We – GoldenLine Sp. z o.o., a company with its registered office in Szczecin (70-471) at al. Wojska Polskiego 8, entered into the register of entrepreneurs of the National Court Register maintained by the District Court for the capital city of Warsaw in Warsaw, 12th Commercial Division, under the KRS number: 241921, REGON: 140216958, NIP: 5262891445, with the share capital in the amount of PLN 3 221 000,00 zł.

Personal Data – all information about a natural person that is identified or identifiable due to one or more specific factors determining the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, including the device's IP number, location data, online identifier and information collected through cookies and other similar technology.

Website – the Website provided by GoldenLine Sp. z o.o. at the current address - www.goldenline.pl - and at all addresses which redirect to this address, as well as with any other addresses which constitute its supplement or continuation and any address which could replace it.

User/you - a natural person visiting the Website or using one or several services or functionalities made available on the Website.

GDPR - the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.

Profile - a place on the Website which is made available to the User where data is entered, managed and published by the User in accordance with the privacy settings selected by the User.

Policy – this Privacy Policy.

Regulations – the regulations of the Website.

A. OBJECTIVES AND LEGAL BASIS FOR PROCESSING OF DATA ON THE WEBSITE

1. Using the Website

If you use the Website as a registered or unregistered user (i.e. you do not have a Profile on the Website), GoldenLine processes your Personal Data. This data should be understood as information concerning IP addresses or other identifiers and data collected through cookies or other similar technologies. Your activity on the Website, including your Personal Data, are recorded in the system logs. Information collected in logs is processed primarily for purposes related to the provision of services, i.e. for:

analytical and statistical purposes – to continuously improve the quality of services provided on the Website and tailor its functionalities to your needs. In such a case, the legal basis for processing would be the legitimate interest of GoldenLine consisting in analysing the Users' activity and their preferences;
the purpose of detecting fraud, as well as identifying and counteracting any threats to the stability and correct operation of the Website;
the marketing purposes of GoldenLine and other entities, in particular, those related to presenting you with behavioural advertising - to inform you about the current offer and new functionalities of the Website and about the offers of our business partners. Detailed rules for the processing of personal data for marketing purposes are described in the MARKETING section below.

2. Registration on the Website

When you decide to register on the Website, you must provide the data necessary to create and maintain the Profile (name and e-mail address).

You can also provide additional information to complete your Professional Profile, which will allow the service to be implemented in full. Such data can be deleted at any time, and their provision is completely voluntary.

The Personal Data you provide during the registration and filling your Professional Profile are processed:

in order to provide you with services related to running and maintaining the Profile on the Website. The legal basis for the processing of data required during registration is the fact that they have to be processed to perform the agreement, and in respect to processing of the data provided to complete the Profile, the legal basis is the User’s consent;
for analytical and statistical purposes, which allow GoldenLine to constantly improve the quality of the services provided on the Website and tailor its functionalities to your needs. Once again, the legal basis for processing is the legitimate interest of GoldenLine. We will therefore analyse your activity on the Website, collecting data on your use of the account and your preferences;
in order to establish, exercise or defend GoldenLine against any claims – the legal basis for processing is in this case GoldenLine’s legitimate interest to protect its rights;
In order to achieve marketing purposes of GoldenLine and other entities – the principles of processing personal data for marketing purposes are described in the MARKETING section.

GoldenLine allows you to log in to your account on the Website via social networks (Facebook). When you choose this form of logging in, only the data necessary to register and operate your Profile will be downloaded from your social network account, and it will be done only after receiving your consent.

3. Contact forms

You can contact us by using our electronic contact forms. Using the form requires providing certain Personal Data which are necessary for us to be able to contact you and respond to your inquiry. You can also provide other data to facilitate contact or handling of your inquiry. Providing data marked as mandatory is required in order for the inquiry to be received and handled, and failure to do so results in the inquiry being impossible to handle. Providing any other data is voluntary.

The Personal Data which you provide in contact forms is processed:

in order to identify the sender and handle their inquiry sent in the form provided by GoldenLine – the legal basis for processing is the fact that they have to be processed to perform the agreement for the provision of the service;
to achieve analytical and statistical purposes – the legal basis for processing is the legitimate interest of GoldenLine to keep statistics of inquiries submitted by Users via the Website in order to be able to improve its functionality.

4. Personalisation and customisation of content

Additionally, GoldenLine processes your Personal Data in order to implement activities aimed at tailoring the Website’s content to your needs. GoldenLine can use profiling in order to implement its profile services. Consequently, your behaviour on the website – e.g. the job offers you displayed, information about your experience you provided – is used by GoldenLine to provide you with content which might interest you.

The above-mentioned activities may include:

providing content - in particular job offers - that match your stated preferences, e.g. you have stated that you want to receive information about new job offers for a „senior accountant”;
providing content - in particular job offers - selected on the basis of the data provided by you on the Profile;
providing content - in particular job offers - selected on the basis of analysing your behaviour on the Website.

Our legitimate interest in recommending job offers tailored to your preferences and activities constitutes the legal basis for the processing of Personal Data in order to personalise and adjust the content of the Website. This is an integral part of implementation of the Profile service in GoldenLine and if you do not consent to this form of profiling, GoldenLine will be unable to continue to provide you with the Profile service.

B. MARKETING

GoldenLine processes your Personal Data in order to carry out marketing activities that may include:

displaying marketing content that is not tailored to your preferences (including contextual advertising);
displaying marketing content corresponding to your interests (behavioural advertising);
sending you e-mail notifications about the content you are interested in (newsletter service);

GoldenLine uses profiling in some cases in order to implement marketing activities. This means that thanks to the automatic data processing, GoldenLine evaluates selected factors related to natural persons in order to analyse their behaviour or create a forecast of their future behaviour.

1. Contextual advertising

GoldenLine processes your personal data for marketing purposes related to presenting you with advertising content, including contextual advertisements (i.e. advertising content which is not tailored to your preferences). The processing of personal data for this purpose takes place in connection with the implementation of the legitimate interest of GoldenLine.

2. Behavioural advertising

The data controller and its trusted partners process your Personal Data, including the data collected through cookies and other similar technologies for marketing purposes related to presenting you with behavioural advertising (i.e. advertising that is especially tailored to match your preferences). In particular, we cooperate with partners in the following areas:

traffic analysis for our websites,
analytics employed for advertising purposes and to tailor content to individual users’ preferences
personalisation of ads
using social media plugins

Profiling constitutes part of the processing of Personal Data conducted for this purpose. The use of the personal data collected via this technology for marketing purposes, in particular, in the promotion of third party services and goods, requires your consent, because in some cases our trusted partners may also use the data obtained from our websites to pursue their own goals and goals of entities they cooperate with. The consent can be withdrawn at any time. Your data will be processed for this purpose until your consent is withdrawn.

You can check the status of your consent here

Please be advised that, for example, due to the lack of a direct relationship with some of the Trusted Partners (in particular those of them that constitute clients that order placement of advertising on our websites through a trusted partner, for example, an advertising network), for reasons beyond our control, we cannot provide their names.

The list of our trusted partners is constantly updated and its content may change.

Joint Personal Data Controllers

In order to display advertising tailored to your interests and preferences, we use solutions provided by Yieldbird Sp. z o.o., a company with registered office at al. Wojska Polskiego 8, 70-471 Szczecin. Yieldbird is the joint controller of the personal data processed for this purpose. The main part of the arrangements specifying the scope of responsibilities of joint controllers, including the rules concerning exercising the website’s users' rights, as well as the list of recipients to whom the data are disclosed in relation to the display of behavioural advertising, is available at the following address: https://yieldbird.com/pl/partnerzy.

More information on the cooperation between GoldenLine Sp. z o.o a Yieldbird Sp. z o.o. related to their roles as joint controllers of personal data can be found here: https://yieldbird.com/pl/dane/.

3. Newsletter

GoldenLine provides the newsletter service to those users who have provided their e-mail address for this purpose. Such information has to be provided for GoldenLine to be able to send newsletters, and if a user does not provide such data, the service cannot be implemented.

In this case, Personal Data is processed:

in order to provide the newsletter service – the legal basis for processing is the fact that personal data has to be processed for GoldenLine to be able to perform the agreement;
in the case of sending you marketing content as part of the newsletter – the legal basis of the processing, including profiling, is the legitimate interest of GoldenLine related to your expressed consent to receive the newsletter;
for analytical and statistical purposes – the legal basis of the processing is the legitimate interest of GoldenLine in analysing your activity on the Website in order to improve the employed functionalities;
in order to establish, exercise or defend GoldenLine against any claims – in such cases the legal basis for processing is the legitimate interest of GoldenLine.

4. Direct marketing

Your Personal Data may also be used by GoldenLine to present you with marketing content through various channels, i.e. via e-mail, provided that you have consented to receiving such content. Importantly, such consent can be withdrawn at any time.

C. SOCIAL NETWORKS

GoldenLine processes Personal Data of Users that visit its social media profiles (Facebook, YouTube, Instagram, Twitter, Pinterest, LinkedIn, and Google+). These data are processed only in the scope connected with running the Profile, including informing Users about GoldenLine’s activity and promoting various types of events, services and products. The legal basis for the processing of personal data for this purpose is the GoldenLine’s legitimate interest in promoting its own brand.

D. COOKIES

Cookies are small text files which are installed on users’ devices when they browse the Website, regardless of whether they are registered and logged in, or not. Cookies usually contain the domain name of the website they originally come from, data on how long they have been stored on the end device and a unique number. In the Policy, all information concerning cookies applies also to other similar technologies used within the Website.

1. “Service” cookies

We use the so-called “service” cookies primarily for the purpose of providing services which are delivered electronically and improving the quality of these services. Therefore, GoldenLine and other entities which provide it with analytical and statistical services (see trusted partners) use cookies by storing information or accessing information already stored in your telecommunications end devices (computers, telephones, tablets, etc.). Cookies which are used for this purpose include:

cookies with data entered by the User (session ID) for the duration of the session;
authentication cookies used for services that require authentication for the duration of the session;
cookies used to ensure security, e.g. used to detect instances of authentication-related fraud;
session cookies of multimedia players (e.g. flash player cookies) for the duration of the session;
permanent cookies used to personalise your interface for the duration of the session or a little longer;
cookies used to monitor traffic on the website, i.e. data analytics, including cookies.

2. “Marketing” cookies

GoldenLine and our trusted partners use cookies also for marketing purposes, including in connection with behavioural advertising displayed to you – you can find more information on this topic in section B point 2 of this document. In order to achieve it, GoldenLine and its trusted partners store information or access information already stored in your telecommunications end devices (computers, telephones, tablets, etc.). GoldenLine cannot use cookies or personal data collected by cookies for aby marketing purposes, in particular, in the promotion of services and goods of third parties, without your consent. The consent can be withdrawn at any time.

E. DATA RECIPIENTS

Your data may be transferred to service providers that provide services for GoldenLine and state administration authorities.

1. Service providers that provide services for GoldenLine

Your Personal Data will be disclosed to external entities in connection with implementation of the Services, including in particular to suppliers responsible for the operation of GoldenLine’s IT systems, such as:

research companies,
couriers and postal operators (only for the purpose of responding to inquiries submitted via traditional mail),
marketing agencies (in the scope of marketing services, which have been described in detail in the three previous chapters),
entities associated with GoldenLine, including companies from its capital group, Agora SA,
entities providing services related to maintaining the Website’s backup and data storage,
suppliers providing serviced related to handling the inquires submitted via contact forms,
provider of the e-mail client,
entities providing services concerning analysis and preparation of the Website’s statistics (as described above in the previous section).

The list of our suppliers can be found here. The list is constantly updated and its content may change.

The level of protection of personal data outside the European Economic Area (EEA) differs from that provided by European law. For this reason, we ensure that any transfers of your personal data to locations from outside the EEA have an adequate level of protection, primarily through:

cooperation with entities processing personal data in countries for which a relevant decision of the European Commission has been issued;
use of standard contractual clauses issued by the European Commission;
applying binding corporate rules approved by the competent supervisory authority;
in the case of data transfer to the US – through cooperation with entities participating in the Privacy Shield approved by the decision of the European Commission

We will inform you about the intention to transfer personal data outside the EEA at the data collection stage.

2. State administration authorities

We reserve the right to disclose information to competent authorities or third parties who submit a request for such information on the basis of on an appropriate legal basis and in accordance with the applicable law.

F. USERS’ RIGHTS

You have the following rights:

the right to access data content and requests their rectification,
the right to erase data,
the right to restrict processing of data,
the right to transfer data,
the right to object to data processing, and
the right to lodge a complaint with the supervisory authority responsible or dealing with the protection of personal data.

If you have registered on the Website and consented to the processing of Personal Data, you can withdraw your consent at any time by clicking the “Delete the account” button in the „Settings” tab or by sending a message to: iodo@goldenline.pl. In the case of data that you provided voluntarily by completing your Profile, you can delete said data at any time by editing the scope of information included in the Profile. In the case of other categories of data or in a situation in which you are an unregistered User of the Website, you can send the relevant message to the following e-mail address: iodo@goldenline.pl

1. Right to object

You have the right to object to the processing of your personal data for direct marketing purposes, including profiling, at any time. This processing is conducted on the basis of the legitimate interest of GoldenLine. You also have the right to object to the processing of your data at any time for any reasons related to your particular situation.

G. PERSONAL DATA PROCESSING PERIOD

We will continue to store your Personal Data as long as you have a Profile on the Website or until you withdraw your consent to the processing of Personal Data which you have provided on your Profile after registration. Storing of personal data is necessary for the correct provision of services specified in the Regulations, as well as for marketing purposes. We will stop processing your Personal Data if you delete your Profile or withdraw your consent to the processing. We will either delete your Personal Data or anonymise them, with the reservation that some of the data (name, e-mail address, history of the Profile and information about consents granted) will continue to be processed during subsequent 3 years to establish, exercise or defend GoldenLine against any possible claims.

In the case of entries which you have posted on groups, in the sections containing opinions on employers, as well as recommendations, etc., your Personal Data is processed on the basis of a legitimate interest in order to defend us against any claims related to our role as a hosting provider for the goldenline.pl website for a period of 6 years from the moment of your posting of these entries – be advised that they can also be quoted by other users. This legitimate interest arises from the Act on provision of services by electronic means. Such data will be anonymised when the claims related to the publication of content on the Website expire.

If you use a Website function without being logged in, we will process your Personal Data during the period in which your device stores the cookie files, user agent, and data on the tabs and information you display on the Website.

H. PERSONAL DATA SECURITY

We regularly conduct risk analyses to ensure that your Personal Data is processed in a secure manner. Access to your Personal Data is only granted to authorised persons and only to the extent that it is necessary for them to be able to perform their tasks. We make sure that all operations involving your Personal Data are recorded and made only by authorised employees and associates. All entities with which we cooperate give us their guarantees that they apply appropriate security measures in the course of processing your Personal Data.

I. CONTACT DETAILS FOR THE CONTROLLER

GoldenLine Sp. z o.o. is the Controller of your Personal Data.

You can contact our Personal Data Protection Officer about any issue related to personal data protection by using the following e-mail address: iodo@goldenline.pl.

J. AMENDMENTS TO THE POLICY

The protection of your Personal Data is a dynamic process which is subject to constant changes. The aim of such changes is to ensure that your rights are protected in the most effective way possible, so the Policy is continuously reviewed and amended with this goal in mind. We will inform Users about any changes and amendments via the Website or by sending relevant e-mails.