I. INTRODUCTION
This document describes the privacy policy of Britenet Limited Liability Company, based at Aleje Jerozolimskie 44, 00-024 Warsaw, NIP 951-219-77-37, REGON 140727009, KRS: 0000264919, (hereinafter: Britenet). Britenet's Privacy Policy (hereinafter: Policy) defines the rules, method of processing and use of data and information from candidates, clients and users of all websites belonging to Britenet, i.e. www.britenet.eu and the use of cookies.
Please read the Policy carefully. By accessing or using a site belonging to Britenet, you accept the terms of this Policy and acknowledge that you have read the Policy.
II. GLOSSARY OF TERMS
Personal data - according to the GDPR, any information about an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by means of an identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the natural person;
GDPR - means 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 (General Data Protection Regulation), pursuant to which Britenet processes Personal Data of Users.
Specialist - a job candidate offered by Britenet to its clients.
Services - should be understood as the services provided by Britenet electronically, through the website.
User - a job candidate, a contest participant, a person asking a question, a person recommending a friend for a job, a person visiting sites belonging to Britenet.
III. PROVISION OF PERSONAL DATA
By providing your Personal Information on the Site www.britenet.eu and others belonging to Britenet, you acknowledge that you have the necessary permissions to disclose Personal Information to be used by Britenet as described in this Policy.
Provision of personal data is voluntary, but necessary in order to take action at the request of the User as a data subject before concluding a contract, and failure to provide data will prevent the administrator from taking the requested action (including, for example, preventing the processing of an inquiry about the provision of services, application to participate in recruitment), as well as prevent the conclusion and execution of a contract. Lack of consent for the processing of data for the purpose of marketing the administrator's own products or services, for the purpose of sending the administrator's commercial information electronically does not give rise to any negative consequences, while lack of consent for the processing of personal data for the purposes of future recruitment will result in the inability to consider your recruitment application in the course of future recruitment.
IV. PERSONAL DATA CONTROLLER
The administrator of the Users' Personal Data provided in connection with the use of Britenet Websites, in particular in connection with conducting recruitment processes using them, accepting registrations for events, using other services contained on the Website is Britenet sp. z o.o., based at Aleje Jerozolimskie 44, 00-024 Warsaw.
V. RECIPIENT OF PERSONAL DATA
According to the provisions of the GDPR, a "recipient" of personal data is a natural or legal person, public authority, entity or any other entity to which personal data is disclosed, whether or not it is a third party. Your personal data is not processed exclusively by Britenet and its personnel. We provide our services, including recruiting for many of our contractors. Your data is therefore processed by such categories of recipients as:
- Britenet's employees and associates,
- Britenet's contractors,
- entities that provide marketing services to us,
- companies that have equity affiliations with Britenet,
- professional entities that provide Britenet with tax, legal, audit and billing advice,
- parcel delivery operators,
- payment operators.
VI. PURPOSES OF PERSONAL DATA PROCESSING AND LEGAL GROUNDS FOR PROCESSING
The Administrator processes Personal Data for the purpose of:
- To send Users, to the e-mail addresses, telephone number provided by them, answers to the inquiries sent via the contact form in advance.
In the case of contacting the User for the purpose of responding, the legal basis for the processing of Personal Data is the consent of each User to the processing of Personal Data (Article 6.1.a of the GDPR). - To take action at the request of the User prior to the conclusion of a contract (e.g. to process an inquiry for the provision of services, to participate in recruitment) - on the basis of Article 6(1)(b) of the GDPR
- In the case of the conclusion of a contract, in order to perform the contract to which you will be a party (e.g., a contract for the provision of services), in particular accounting, archiving and tax settlement obligations - on the basis of Article 6(1)(b) of the GDPR;
- In addition - in the case of concluding a contract with you - in order to secure and realize the legitimate interests of the administrator (in particular, to enable the administrator to pursue claims arising from the contract concluded with you) - on the basis of Article 6(1)(f) of the GDPR;
- Your consent for the marketing of the administrator's own products or services, as well as for the purposes of future recruitment - on the basis of Article 6(1)(a) of the GDPR
VII. RIGHTS OF THE USER (Pursuant to Chapter III, Articles 15-21 GDPR)
You have the following rights in connection with the processing of your Personal Data by Britenet:
- Right of access to your Personal Information,
- The right to rectify the processed data,
- The right to erasure of data ("right to be forgotten"),
- The right to restrict data processing,
- Right to data portability,
- The right to object to further data processing,
The exercise of each of the above rights is carried out at the request of the User.
As part of your rights, you may at any time withdraw your consent to further processing of Personal Data for purposes that require consent, provided that withdrawal of consent shall not affect the lawful use of Personal Data in activities performed on the basis of consent prior to withdrawal.
Under the right of access, you are entitled to obtain the following information, in the form of copies:
- Purposes of Personal Data Processing;
- Categories of Personal Data that are subject to processing, e.g., first name, last name, phone number;
- Information about the recipients or categories of recipients of the data
- Information on the rights of the data subject
- Information about the possibility of filing a complaint with the Data Protection Authority;
- Information about the source of the data, if the data was not obtained directly from the User - an indication of the person or company or institution that provided the Personal Data;
At the same time, Britenet informs you that each subsequent copy of Personal Data involves a reasonable fee based on administrative costs. Britenet will process the submitted request and send a response within 1 month from the date of receipt of the request. Britenet stipulates that it has the possibility of both not responding to the request and responding later than stated above (by another two months) due to a large number of inquiries or the complicated nature of the submitted request. In both of the above situations, Britenet will inform the User with a justification.
VIII. PROCESSING OF PERSONAL DATA FOR RECRUITMENT PURPOSES
Britenet conducts recruitment for its own purposes and for the benefit of clients to whom it provides recruitment. Therefore, we inform you that your data may also be processed by Britenet's clients, as mentioned in the job advertisement, indicating that we are recruiting for a client. At the same time, we would like to inform you that by giving your consent to the recruitment processes, this consent will apply both to recruitment for the specific position included in the job advertisement and for future recruitment. This means that we will store Personal Data in our database in order to send you information about job offers tailored to your profile and work experience. You may withdraw your consent for further processing at any time, in accordance with Section VI of this Policy, which will not affect the lawful use of your Personal Data in activities performed on the basis of your consent prior to its withdrawal.
The User's Personal Data may also be processed in the situation of a referral of the User by a referrer. In this situation, the recommender enters his/her data and the data of the recommended person and posts the resume under the form with the User's data. Britenet verifies the referral's resume received from the referrer with respect to the referrer's consent to the processing of Personal Data meeting the requirements of the GDPR. If the consent is included, Britenet has the authority to use the data for recruitment processes.
IX. PROCESSING OF PERSONAL DATA FOR MARKETING PURPOSES
By submitting an inquiry, registering for an event organized by Britenet, the User may consent to the processing of Personal Data for the purpose of sending marketing information about Britenet products and services offered. Consent may be withdrawn at any time, subject to the rules set forth in Section VI of this Policy.
X. TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES
Your personal data is transferred to third countries in case the services that Britenet provides are also to be performed in the territory of a third country. Your personal data may also be transferred to entities that provide Britenet with tax, legal, audit and billing advice, if they carry out their activities in a third country. In each of the aforementioned cases, we secure the processing of your personal data, in particular by entering into confidentiality and personal data processing agreements in a manner that complies with the provisions of generally applicable EU and Polish data protection law and under conditions designed to ensure the security of the processing of your personal data. We do not transfer your personal data to international organizations. We also do not transfer your personal data to third countries if such transfer is not possible or is precluded by generally applicable laws.
XI. RETENTION PERIOD OF PERSONAL DATA
Your personal data will be stored for the following periods:
a) data processed on the basis of your consent (Article 6(1)(a) GDPR)-until you withdraw your consent to its processing, unless the controller determines earlier that the data has become obsolete;
b) data processed for the purpose indicated in point V lit. 2) above - for the period necessary to take and carry out actions at your request as a data subject before entering into a contract;
c) data processed in case of entering into a contract with you and for the purpose indicated in point V letters 3) and 4) above - for the period necessary for the performance of the contract linking you with the controller, as well as for the period of limitation of claims and criminal actions that may arise from the contract, and for the period required by law, such as tax law. The administrator may keep your personal data for a longer period than indicated only if there is another basis for processing your personal data as specified in Article 6(1) of the DPA;
XII. SAFETY RULES
Britenet has implemented appropriate security measures (organizational and technical) to protect your Personal Data from loss, misuse, unlawful processing or modification. Realizing the importance of protecting your Personal Data, we use, among other things.:
- encryption of your data through HTTPS service using 2048 bit RSA encryption key during transmission,
- in certain cases processes of anonymization, pseudonymization and encryption of your personal data
- other hardware, network and system security measures, such as: firewalls, licensed hardware and network anti-virus software, controlled access via a secured VPN and many other IT security solutions,
- electronic and physical mechanisms for controlling access of persons to buildings and premises where your personal data is processed (e.g.including magnetic and electronic keys, security locks, alarm system),
- other security measures to protect your personal data.
The Administrator undertakes to protect any information disclosed by Users in accordance with standards of security protection and confidentiality. Access to Personal Information is limited to the number of authorized Britenet employees.
Britenet is authorized to share data with entities authorized under applicable law.
XIII. POLICY CHANGE
Due to development and changing laws, the rules set forth in this Privacy Policy may change. The User will be informed of the change of these rules by posting the new content of this document on the website. https://britenet.eu/privacy-policy/.
XIV. COOKIES FILES
If you use Britenet's websites and the systems available through these websites (in particular, to generate inquiries sent via the contact form), when you browse these websites, so-called "cookies" are created. These are text files of small size that are stored on your device through which you browse the websites. They are commonly used to ensure the operation of websites and other services provided over the Internet, and to improve and develop these websites, which is done by reading the contents of these files.
Britenet collects information contained in "cookies", such as the date you connect to the website or the IP address of the device from which you connect to the website - this is data showing how you use our websites. This information is used for administrative and statistical purposes and aimed at improving these websites and enhancing your user experience. In addition, this data, which is processed automatically, may be used to analyze the behavior of the recipients of content on these websites (e.g., time spent on the website) or to personalize the content of the websites, in particular by providing online advertisements.
You do not have to accept cookies (you can accept the use of cookies both by selecting the appropriate button on our website and by making the appropriate settings in your web browser), but doing so may result in this website not working fully properly.
XV. PERSONAL DATA CONTACT
If you have any questions or concerns regarding the protection of your personal data, you may contact us by traditional correspondence at the registered office address of Britenet Ltd. and via email address: [email protected].