I. INTRODUCTION

This document is a description of the privacy policy of Commoditech sp. z o.o. with headquarters at ul. Mokotowska 1, 00-640 Warsaw (hereinafter: Commoditech). The Commoditech privacy policy (hereinafter: the Policy) defines the principles, method of processing and using data and information from candidates, clients and users of websites belonging to Commoditech: i.e. www.commodimed.com.

Please read the Policy carefully. By accessing or using the website belonging to Commoditech and sending us any personal data in connection with applications for a conference, competition, recruitment or training, etc. and by reading the content of this Policy, the User accepts the terms of this Policy and confirms that he has read it content.

II. TERMS USED IN POLICY

Personal data  – means Personal Data within the meaning of the GDPR, i.e. all information about an identified or identifiable natural person that directly or indirectly identifies a natural person, in particular such as the name, e-mail address or telephone number of the natural person and other data that in combination with the above, they may identify the User.

GDPR  – means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46 / EC (General Regulation on data protection), according to which Commoditech processes Users’ personal data.

Specialist  – a job candidate offered by Commoditech to his clients.

User  – a job candidate, newsletter subscriber, contest participant, person asking a question, training participant, person recommending a friend to work, a person visiting pages belonging to Commoditech.

Services  – it is necessary to understand services provided by Commoditech by electronic means, via a website, i.e.: subscription to the Newsletter, sending a question via the contact form, sending documents necessary in the recruitment process, notification of participation in competitions, notification of participation in training, setting up an account on the candidate’s portal .

III. PROVIDING PERSONAL DATA

By providing your Personal Data on the website www.commodimed.com and other belonging to Commoditech, the User confirms that he has the necessary permits to disclose personal data that will be used by Commoditech in the manner described in this Policy.

IV. PERSONAL DATA ADMINISTRATOR

The administrator of Users’ Personal Data provided in connection with the use of Commoditech websites, in particular in connection with the use of recruitment processes using them, conducting trainings, sending marketing information, including newsletters, accepting subscriptions for conferences, events, and using other services contained on website is Commoditech Sp. z o. o. ul. Mokotowska 1, 02-640 Warsaw, tel. 791 662 241.

V. DATA PROTECTION SUPERVISOR

A Data Protection Inspector has been appointed at Commoditech. Contact details for the Data Protection Inspector:  personaldata@commoditech.pl

VI. PURPOSES OF PROCESSING PERSONAL DATA AND LEGAL BASIS FOR THEIR PROCESSING

The administrator processes Personal data in order to:

  1. sending Users, to their e-mail addresses, commercial and marketing information, including the Commoditech newsletter, provided that the User has agreed to receive them.
    In the case of sending newsletters, the legal basis is the User’s consent to the processing of Personal Data (art.6 par.1 point a GDPR).
    Consent to sending unsolicited commercial information to Users in accordance with art. 10 of the Act on the provision of electronic services is expressed by Users independently and separately.
  2. sending Users to the e-mail addresses provided by them, the telephone number of responses to previously asked questions sent via the contact form.
    In the event of contact with the User in order to answer, the legal basis for the processing of Personal Data is the consent of each User to process personal data (Article 6 paragraph 1 point a of the GDPR).
  3. consideration of the job application sent by the User and possible recruitment process, after prior consent by the User to process data contained in the CV or form by Commoditech.
    In the case of processing Personal Data for the purpose of considering an application for a job, the legal basis is the consent of each User for the processing of personal data (Article 6 paragraph 1 point a of the GDPR).
  4. organization and conducting of competitions by Commoditech.
    In the case of competitions, the legal basis for the processing of Personal Data is the consent of the User (art.6 par.1 point a GDPR).
  5. Organizing and conducting open and dedicated trainings.
    In the case of training, the legal basis for the processing of Personal Data is the contract for the provision of training services concluded with Commoditech by sending an order form (Article 6 paragraph 1 point b of the GDPR).
VII. USER’S RIGHTS

In accordance with chapter III, art. 15-21 GDPR, the User has the following rights in connection with the processing of his Personal Data by Commoditech:

  1. the right to access your Personal Data,
  2. the right to rectify processed data,
  3. the right to delete data (“right to be forgotten”),
  4. the right to limit data processing,
  5. the right to transfer data,
  6. the right to object to further data processing,
  7. the right not to be subject to decisions based solely on automated processing, including profiling.

The implementation of each of the above rights is at the request of the User. Commoditech considers the submitted application and sends a response within 1 month of receipt of the application.

As part of the rights, the User may at any time withdraw consent to further processing of Personal Data for purposes that require consent, provided that the withdrawal of consent does not affect the legal use of personal data in activities carried out on the basis of consent before its withdrawal.

Under the right of access, the User is entitled to obtain the following information in the form of a copy:

  1. purposes of processing Personal Data;
  2. categories of Personal Data – what data we process, e.g. name, surname, telephone number;
  3. information about recipients or categories of data recipients – to whom (person, company, institution) data may be transferred;
  4. information about the right to request Commoditech to rectify data, delete it or limit its processing and to object to specific data processing;
  5. information on the possibility of submitting a complaint to the Office for Personal Data Protection;
  6. information about the data source, if the data was not obtained directly from the User – an indication of the person or company or institution that provided the Personal Data;
  7. on the use of profiling: on what principles it is taken, what can be the consequences of profiling for the User.

Commoditech informs at the same time that each subsequent copy of Personal Data is associated with a fee arising from the costs incurred in connection with the creation of another copy of Personal Data.

Commoditech reserves that it has the option of not answering the request or answering it later than up to two months due to the number of inquiries or the complex nature of the inquiry. By the complicated nature we understand the need to collate Data from many IT systems, the need to consult more than one person from a department or departments in order to obtain the information being the subject of the application.

In both of the above situations, Commoditech undertakes to inform the User about this fact, providing justification each time.

VIII. PROCESSING OF PERSONAL DATA FOR THE RECRUITMENT AND UNDER THE CANDIDATE COMMAND SYSTEM

Commoditech conducts recruitments for its own needs and for clients, which it provides, among others Specialist delivery services. Therefore, we would like to inform that User data may also be processed by Commoditech clients, about which we inform in the content of the job advertisement, indicating that we are recruiting for the client. At the same time, we would like to inform you that by agreeing to recruitment processes, this applies to recruitment for a specific position in the job advertisement as well as for future recruitment. This means that we will store Personal Data in our database in order to send information about job offers tailored to your profile and professional experience. At any time, the User, in accordance with chapter VII of this Policy, may withdraw consent to further processing,which does not affect the legal use of personal data in activities carried out on the basis of consent before its withdrawal.

User’s Personal Data may also be processed when the User instructs the User. In this situation, the referring person enters his data and the details of the recommended person and places the CV under the form with the User’s data. Commoditech verifies the CV of the recommended person from the referring person regarding the consent of the recommended person to process Personal Data that meets the requirements of the GDPR. If consent has been given, Commoditech has the right to use this data for recruitment processes.

IX. PROCESSING OF PERSONAL DATA FOR MARKETING PURPOSES

By submitting an inquiry, registering for a training, conference or other event organized by Commoditech, the User may consent to the processing of Personal Data for the purpose of sending marketing information about offered Commoditech products and services, including newsletters. Consent may be withdrawn at any time, subject to the rules set out in chapter VII of this Policy.

X. PROCESSING OF PERSONAL DATA IN ORGANIZATION AND CONDUCT OF TRAINING

One of the areas of Commoditech’s activity are open and dedicated trainings for Commoditech clients and any interested person. Therefore, Commoditech will process Personal Data of Users reporting participation in training, to the extent necessary to carry out matters related to training.

XI. PROCESSING OF PERSONAL DATA AND PROFILING

In Commoditech profiling takes place understood as a form of automated processing of personal data, involving the use of certain data about the User. The data acquired include information from social media profiles, location, data provided by Users using forms on the Commoditech website.

This allows us to:

  • more aware and better suited selection of job offers, corresponding to the skills and experience of Users (in the case of candidates for work at Commoditech),
  • matching the marketing and advertising materials sent to the interests and needs of Users.

The User may object to profiling at any time in accordance with Chapter VII of this Policy, but this involves the impossibility of sending marketing and commercial information or receiving new job offers tailored to the profile and professional experience.

XII. SAFETY RULES

Commoditech has implemented appropriate security measures (organizational and technical) to protect Personal Data against loss, misuse, unauthorized processing or modification. The Administrator undertakes to protect all information disclosed by Users in accordance with the standards of security protection and confidentiality. Access to Users’ Personal Data has been restrictively restricted so that this information does not fall into the hands of unauthorized persons. Access to Personal Data is limited by the number of authorized Commoditech employees.

Commoditech is entitled to disclose data to entities authorized under applicable law.

XIII. COOKIES

Commoditech declares that  we use cookies on the website www.commodimed.com and others belonging to Commoditech. By using this website, the User agrees to the cookie being placed on the device as explained below.
Cookies used on the website  www.commodimed.com and others belonging to Commoditech can be set by our website or by a third party website.
Cookies are used to:

  1. adapt the content of website pages to the User’s preferences and optimize the use of websites; in particular, these files allow to recognize the device of the website user and properly display the website tailored to his individual needs,
  2. creating statistics that help understand how website users use websites, which allows improving their structure and content,
  3. providing users with advertising content more tailored to their interests.

Types of cookies used by Commoditech:

  • “Necessary” cookies, enabling the use of services available on the website, e.g. enabling the use of sessions;
  • “Functional” cookies, enabling “remembering” the settings selected by the User and personalizing the User’s interface, eg in terms of the selected mobile / desktop version, the last phrases entered by the user, the appearance of the website, etc .;
  • “Analytical” cookies, enabling the monitoring of Users’ activity on the website.

The user has the option of blocking the saving of cookies by changing the browser settings accordingly. Disabling cookies may affect the functioning of the website. If you not change your browser settings, you accept the cookies used.

XIV. CHANGE POLICY

Due to the development and progress of technology and changing legal provisions, the principles set out in this Privacy Policy may change. The User will be notified of any change in these rules by posting new content on this website at  www.commoditech.pl/privacy-policy