HR Level UP Information Obligation

In accordance with Articles 13 and 14 of 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), hereinafter referred to as the “GDPR”, we inform you that we process your personal data, which we collect in connection with our correspondence, efforts to conclude, and the conclusion and performance of a contract in connection with our recruitment, training, mentoring, and competency assessment services (Assessment Center / Development Center / Feedback 360°), among other things. The data was provided to us directly by you or the entity with whom the contract was concluded and for which you perform professional duties, including under an employment relationship or other similar legal relationship.

Data Controller

The controller of your personal data is HR LEVEL UP sp. z o.o. (limited liability company) with its registered office in Warsaw, at: Złota 59 Street, 00-120 Warsaw, entered into the register of entrepreneurs of the National Court Register, maintained by the District Court for the Capital City of Warsaw in Warsaw, XII Commercial Division of the National Court Register under KRS number: 0000950443, NIP: 5252894229, REGON: 521142870, share capital: PLN 5,000.00.

Scope of Processed Data

We process your personal data collected in connection with correspondence, the intention to conclude, and the conclusion and performance of the aforementioned agreement. This data may include, in particular, the following information:

  • first and last name,
  • business email address,
  • business phone number,
  • company,
  • position,
  • address of permanent place of business activity,
  • NIP number.

Purposes and Legal Bases of Processing

Data is processed for the following purposes and on the following legal bases:

  • conclusion and performance of the agreement (Art. 6(1)(b) GDPR),
  • including invoices issued in connection with the agreement in accounting documentation and fulfilling other accounting and bookkeeping obligations imposed by law (Art. 6(1)(c) GDPR),
  • establishing, pursuing, or defending claims related to the agreement, which is our legitimate interest (Art. 6(1)(f) GDPR),
  • conducting correspondence, which is our legitimate interest (Art. 6(1)(f) GDPR).

Recipients of Data

The following entities may participate in the processing of your personal data:

  • accounting office – for bookkeeping purposes, which involves processing personal data contained in accounting documents,
  • IT support – for providing IT services, which may involve access to personal data processed within IT resources,
  • email, cloud drive, and online messenger software provider – for storing personal data on the email server, cloud drive, and online messenger,
  • subcontractors – for providing services that involve access to personal data, including providers of eRecruiter, Thomas International, Gallup StrengthsFinder systems.

All the above entities participate in the personal data processing based on concluded data processing agreements. All these entities ensure an adequate level of personal data protection.

Your personal data may be transferred to tax authorities as part of fulfilling obligations related to public-law settlements. Your personal data may also be transferred to other bodies or institutions authorized by law, if necessary to fulfill obligations imposed by law or to assert our rights.

Should we need to use professional legal assistance, your personal data may be transferred to law firms providing us with legal assistance to the extent necessary to assert our rights or defend against claims.

Transfer of Data to Third Countries

Due to the use of hosting, cloud services, and subcontractors, data may be transferred to third countries in connection with its storage on servers located outside the European Economic Area. Providers of these services ensure an adequate level of personal data protection through compliance mechanisms such as certification programs or standard contractual clauses.

Data Retention Period

Your personal data will be stored until the end of the limitation period for claims arising from the agreement. Furthermore, your data will be stored for such a period as required by law for accounting documentation.

Rights Related to Processing

In connection with the processing of personal data, you have the following rights:

  • the right to access your data and receive a copy thereof,
  • the right to rectification (correction) of your data,
  • the right to erasure of data (if, in your opinion, there are no grounds for us to process your data, you may request that we erase it),
  • the right to restriction of data processing (you may request that we restrict the processing of data solely to its storage or to performing actions agreed with you, if, in your opinion, we have incorrect data or process it without justification),
  • the right to object to data processing (you have the right to object to data processing based on a legitimate interest; you should indicate your specific situation which, in your opinion, justifies our cessation of the objected processing; we will stop processing your data for these purposes unless we demonstrate that the grounds for our data processing override your rights or that your data is necessary for us to establish, pursue, or defend claims),
  • the right to data portability (you have the right to receive from us, in a structured, commonly used, machine-readable format, the personal data you have provided to us based on an agreement or your consent; you may instruct us to send this data directly to another entity),
  • the right to lodge a complaint with a supervisory authority (if you find that we are processing data unlawfully, you may lodge a complaint with the President of the Personal Data Protection Office or another competent supervisory authority).

To exercise your rights, please send your request to the email address: joanna.chrobak@hrlevelup.pl. Please remember that before fulfilling your rights, we will need to properly identify you.

Information on the Requirement / Voluntariness of Providing Data

Providing your data is a condition for concluding the agreement.

Profiling

The Controller may use IT systems (e.g., eRecruiter, Thomas International, Gallup StrengthsFinder systems) for partially automated data analysis, including competence profiling. Profiling does not lead to decisions that produce legal effects concerning the data subject. The decision to use the proposed services always rests with you.