Version update: 28/08/2019
Talent Alpha Sp. z o.o. created this policy in line with its commitment to your privacy as website user (“Users”) and/or a person with whom we cooperate, including our clients, business partners and their representatives persons’ and Alpha Specialist (referred to as “you”, “yours”). Unless specifically referred to a given category of data subjects, the below provisions applies to all of them. For the terms of this policy Talent Alpha Sp. z o.o. with its registered office at Podole 76, 30-394 Cracow, Poland is a controller of data collected in connection with this website and our business. The terms “we”, “us”, “our” refer to Talent Alpha Sp. z o.o. (“Talent Alpha”, “TA”). If you have any questions regarding processing of your personal data please contact us at: firstname.lastname@example.org.
Terms used in the policy
GDPR – means European Parliament and Council Regulation (EU) 2016/679 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 (general data protection regulation).
Personal Data − means any information relating to an identified or identifiable natural person. Identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an email address or a telephone number of the person and other data which, when combined with the above.
Sensitive Personal Data – special categories of Personal Data said in art. 9 of the GDPR and Personal Data said in art. 10 of the GDPR (i.e. racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, criminal convictions and offences or related security measures, genetic data, biometric data for the purpose of uniquely identifying a person, health, sex life, sexual orientation.
Alpha Specialist – Individuals including Contractor’s employees, co-workers, contractors and sub-contractors who will ever become a member of the talent pool database.
Processing – means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Contractor – business partner of TA that provides via its specialists services to TA clients’ based on the TA orders.
Purposes and Legal Basis of Processing We process
Personal Data in order to:
- Execute the agreement concluded by you as our business partner, Contractor, client or in order to undertake actions on your request before conclusion of the agreement as regards the processing of your data as a sole entrepreneur or your company’s representatives authorised to conclude the agreement with us (Art. 6.1.b) of the GDPR) and to make cooperation/ execution of the agreement easier as regards the processing of your contact persons’/representatives’ personal data (Art. 6.1. f) of the GDPR).
- Provide responses to your inquiries sent through the website contact form, e-mail or phone. In such case the legal basis for the processing your Personal Data is our legitimate interest in contacting you in reference to your inquiry (Art. 6.1. f) of the GDPR).
- Send direct marketing information (including the Talent Alpha newsletter) to users, clients and business partners (Contractors), via e-mail addresses they provide on the legal basis of their consent (Art. 6.1. a) of the GDPR) and in case we have already a relevant relation with you, based on our legitimate interest (Art. 6.1. f) of the GDPR). In cases where we will do marketing profiling, we shall process your Personal Data based on your consent, if required. (Art. 6.1. a) of the GDPR). Consent/s for sending marketing in accordance with Art. 10 of the act on rendering services by electronic means and / or Art. 172 of Polish Telecommunications Act is expressed by you independently and separately.
- Organize competitions by Talent Alpha, conferences or events. Your Personal Data will be processed only if you registered as participant. The legal basis for the organisation of competitions is a consent (Art. 6.1. a) of the GDPR).
- Organize and conduct open and dedicated training sessions. In the case of training sessions the legal basis for the processing of Personal Data is an agreement for the provision of training services concluded with Talent Alpha by sending electronically the respective order form (Art. 6.1. b) of the GDPR).
- If you are an Alpha Specialist whose services may be needed by our clients, processing of your Personal Data will take place mostly as a result of TA cooperation with our business partner (Contractor) who hired you and shared your Personal Data with us and for pursuing TA business. In such a case we will process your Personal Data to:
- pursue our business, i.e. connect you – Alpha Specialist with enterprise clients’ by matching projects suitable for your professional experience and sending your Personal Data to clients on this basis; by managing the relation with you to enable you, as an Alpha Specialist to participate in the Talent Alpha clients’ projects. In such case the legal basis for the processing of your Personal Data is our legitimate interest in (Art. 6.1. f) of the GDPR).
- If you are an Alpha Specialist whose services may be needed by our clients, we will process your Personal Data for the purposes of testing your skills, evaluate matching roles and your placement. Processing of your Personal Data will take place mostly as a result of cooperation with our business partner (Contractor) who hired you and shared your Personal Data with us. The Personal Data we receive include your professional skills, experience, education and your contact details. If this is the case you will find more information on processing your Personal Data in section 4 below. The legal basis of the processing will be our legitimate interest in assigning you to a project (Art. 6.1. f) of the GDPR).
- The legitimate interest of Talent Alpha:
- for contacting you – to answer your queries;
- for processing contact persons’ data to execute the agreement with our client, business partner (Contractor) is regarded as facilitation of the execution of the agreement;
- for direct marketing communication is regarded as widespread of Talent Alpha services;
- with respect to Alpha Specialists evaluating, matching roles and your placement, internal management of our relation – is regarded as simplification and ensuring of the effectiveness of management of the assigning of Alpha Specialist to TA client’s project.
- If consent is required for the processing in question, it will be sought from you separately to ensure that it is freely given and informed. To the extent Talent Alpha is relying in your consent to process your personal data, you have the right to withdraw your consent to such processing at any time. You can do this by contacting data protection team at email@example.com. The withdrawal of your consent does not affect the lawfulness of processing based on consent before its withdrawal.
Provision of your Data
Note, that whenever you provide us directly with your Personal Data, the provision of your Personal Data, in each case is voluntary, however without its provision you won’t be able to receive certain information (e.g. marketing newsletters) or take part in training, conferences, competitions, events or we won’t be able to address your enquiry or in case of Alpha Specialists to match client’s project suitable for you and as a consequence to be able to recommend your services to our clients.
We may also receive your Personal Data not directly from you in case when you are a representative/ contact person of our business partner (Contractor), client as regards your contact details such as name, surname, business title, business e-mail, business phone number obtained from our client, business partner (Contractor) and when you are an Alpha Specialist as regards your contact details, professional skills, experience, education we may get such information from you directly or from our business partner (Contractor)/ your employer who hired you. We may also get such information from other person/entity who recommended you and your LinkedIn profile. In specific situations we may also process other data, like data relating to your work status (e.g. residence and work permit if needed).
Sensitive Personal Data
Talent Alpha do not process Sensitive Personal Data unless:
- The Processing is required or permitted by law; or
- Talent Alpha has obtained your explicit consent, where relying on consent is permitted or appropriate under applicable law.
- Access: You are entitled to request access to your Personal Data that we process.
- Correction: You are entitled to ask that any incomplete or inaccurate Personal Data we hold about you is corrected.
- Erasure: You are entitled to ask us to delete or remove your Personal Data in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the Personal Data is still required in relation to the purposes for which they were collected.
- Restriction: In some circumstances, you are entitled to ask us to suspend the processing of certain Personal Data, for example, if you want us to establish its accuracy or the reason for processing it.
- Data portability: In some circumstances, you may ask us to transfer your Personal Data to another party.
- Objection: Where we are processing your personal data based on our legitimate interests (or those of a third party), you may object the processing. However, we may be entitled to continue processing your Personal Data if we can demonstrate compelling legitimate ground for the processing.
- Withdrawing your consent: where your Personal Data is processed upon your consent you have the right to withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
- execution of the agreement – period of our cooperation with you and the lapse of the statute of limitations periods;
- answering your enquiries – for the time period of our correspondence and longer if justified to ensure we have a content of such correspondence;
- sending marketing – for the period of sending you our materials up to the period you shall file your objection to such processing;
- keeping yours, as an Alpha Specialist, Personal Data in our database in order to match projects suitable for your professional experience with our clients. We will process your data for as long as our cooperation with an entity who hired you is in place and in case we base our processing on a consent, as long as it is valid.
- our subcontractors where relevant;
- our business partners;
- entities cooperating with us in the assessment and selection process of Alpha Specialists.
- If you are an Alpha Specialist, we advise that your Personal Data will be shared and processed by clients of Talent Alpha. You will get the information about the client in project descriptions;
- entities authorised by law to obtain Personal Data.
You may have certain rights in relation to your Personal Data. Some of these rights only apply in certain circumstances. If you would like to exercise any of these rights, please contact us at: firstname.lastname@example.org.
You also have the right to file a complaint to a Data Protection Authority. In Poland you can make a compliant to Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193, Warsaw, Poland.
How long we keep your Personal Data
Talent Alpha retains personal data to meet the purposes for which the data was collected or in order to ensure compliance with applicable law or to protect legitimate company interests (e.g. statute of limitations periods). We will store your personal data for the purpose of:
With who we share your Personal Data
Your data provided to us can be disclosed to:
Transfers of Personal Data to third countries
TA does not transfer Personal Data to third countries.
How we secure your Personal Data
Talent Alpha maintains appropriate administrative, technical and physical safeguards designed to protect Personal Data against accidental or unlawful destruction, accidental loss, alteration, unauthorised disclosure or access, use, and all other unlawful forms of processing of personal data in our possession.