PRIVACY POLICY

We respect your privacy and take particular care to protect your personal data. For this reason, we protect all communications addressed to us (including electronically by e-mail) according to this Privacy Policy. We want everyone who visits our portal or otherwise comes into contact with us to know how their privacy is protected and how they can protect it themselves. For this reason, it is worth reading our Privacy Policy.

We also advise that we reserve the right to modify this Policy depending on varying external circumstances, legal and organisational solutions used or IT tools (including security/cybersecurity measures).

HOW TO FIND THE OFTEN REPEATED TERMS OF THIS POLICY

1. In this Privacy Policy, a User (or “you”) is any natural person who visits the portal, as well as any person(s) involved in the recruitment process.

2. 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.

3. In this Privacy Policy, personal data mean all information about a natural person who is identified or identifiable thanks to one or more peculiar attributes, including device IP, location data, online handle, and information collected using cookies or other similar technologies.

WHO IS RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA?

4. The controller of your personal data is SWLEX. o.o. (ul. Szelągowska 49, 61-626 Poznań, National Court Register (KRS) entry no.: 0000413516).

5. The Controller operates an Internet portal located at https://www.swlex.pl. Remember that, when you visit the portal, fill out the contact form, or send us a message, including an electronic message, you accept the terms and conditions of this Privacy Policy.

6. Our Privacy Policy applies solely to our Internet portal. Any addresses that may be linked from our website will be subject to other privacy policies and cookie policies. We suggest that you read these policies.

7. We also use social media (Facebook, Linkedin), where you can find information about us and how to contact us. The rules of personal data protection in these media have however been regulated separately by their owners. We suggest that you read the rules of data protection used in these websites (privacy policies and cookie policies).

8. Submitting your personal data is voluntary, whereby, for example, submitting non-mandatory data during the recruitment process requires that you consent to their processing. If you refuse to submit your data or to grant such consent, we will not be able to provide you with services or process your data.

9. The Controller uses due diligence to select and apply suitable technical and organisational measures to ensure protection of processed personal data. Full access to databases is limited to persons duly authorised by the Controller and equipped with suitable access rights.

10. The Personal Data Protection System in effect at the Controller and the individual solutions applied are regularly reviewed and updated when necessary (such activities are also performed on an ongoing basis, especially with respect to technical security measures).

11. For this reason, your personal data are secured against access by unauthorised parties, as well as against processing in violation of applicable provisions of law.

12. The personal data we process are not subject to automated decision-making, including profiling.

13. Visitors may browse our portal without prior registration or submitting their personal data.

WHAT KINDS OF PERSONAL DATA DO WE PROCESS?

14. Due to operating an Internet portal as well as company pages in social media (Facebook, LinkedIn), we collect and use the following personal data:
a. The e-mail address, first name and surname, and details of inquiries posted using our contact forms.
b. E-mail address and first name given while subscribing to our newsletter;
c. IDs and details of comments in our blog, if it is necessary to remove or otherwise moderate selected comments;
d. An ID assigned to visitors and the related statistical information about visits to our website and activities undertaken during the visit;
e. Information about visits to our website and how it was reached by the user. This information is processed using cookies and used for marketing purposes.

15. We use personal data collected from Users who used a contact form to draft and send answers to their inquiries. In cases where giving a clear and exhaustive answer to a question sent to us requires obtaining further details, we try to contact the inquirer to collect the required information.

16. The personal data submitted while subscribing to our newsletter are used to send personalised messages about SWLEX sp. z o.o. activities (for example new articles published in our blog).

17. Personal data collected by us while handling inquiries submitted via the contact form may be used for marketing purposes – we will ask you for a separate consent in this respect.

18. Information about activities of visitors to our website (and our pages in the above social media) reach us in statistical form, and we are unable to analyse the behaviour of any specific User who is a natural person. The information is used to study and improve the readability of the website and the contents to be found therein.

19. Data collected for marketing purposes are subsequently used to, among others, display our advertising in websites that offer such possibility.

FOR WHAT PURPOSE DO WE PROCESS PERSONAL DATA?

20. We process personal data based on:
1) Article 6(1)(a) of the GDPR (your consent) – to conduct the recruitment process (including future recruitments), ensure participation in events organised by the Controller (for example Business Breakfasts), answer questions sent via the dedicated form found on the SWLEX website, send commercial and marketing information as well as examine opinions showing satisfaction ratings;
2) Data collected via cookies, used to analyse user behaviours in our website for marketing purposes, are processed based on voluntary consent that may be withdrawn at any time (Article 6(1)(a) of the GDPR and Article 173, item 2 of the Telecommunications Law Act),
3) Article 6(1)(b) of the GDPR – to perform an agreement entered into with out Clients, if any; for this purpose, we may analyse the activities of Users and their preferences and to market our own products or services,
4) Article 6(1)(c) of the GDPR – to fulfil a legal obligation imposed on the Controller,
5) Article 6(1)(f) of the GDPR (legitimate interest of the Controller) – primarily to assert or secure claims and to engage in direct marketing.

FOR HOW LONG DO WE PROCESS PERSONAL DATA?

21. As a rule, personal data are processed as long as a service is provided or until an order is completed, until previously granted consent is withdrawn, or until a successful objection to the processing of data is made in cases when the basis for processing is the legitimate interest of the Controller. The duration of cookie processing depends, for example, on the kind of collected files.

22. Data used to send the newsletter are retained until consent is withdrawn or a request to stop their use is submitted. The user may unsubscribe from the mailing list at any time by clicking the link at the very end of the e-mail message (unsubscribe).

23. Personal data collected in connection with handling inquiries sent via forms are retained for 24 months.

24. Data used to study the activities of users in our website are immediately anonymised.

25. In addition, in case of hiring, data are processed (and retained) in accordance with applicable provisions of law (including for the period of employment and for the period necessary to complete the recruitment process, not later however than for 2 months from the date of selecting a suitable candidate). In cases where you consented to the processing of your personal data for the purposes of future recruitments, they will be processed until such consent is withdrawn.

26. The data processing period may be prolonged in cases where processing is necessary to establish, assert and defend against potential claims, and after that time only when and insofar as required by the provisions of law. After the end of the processing period the data are irretrievably deleted or anonymised.

DATA RECIPIENTS

27. In connection with providing services, personal data may be disclosed to third parties, in particular our Clients or Partners (for example during business events organised or co-organised by the Controller), vendors and manufacturers responsible for the servicing/update/supply of IT systems, the website (the hosting company), marketing services, and other entities such as companies providing audit, consulting, courier and similar services.

28. Personal data collected for marketing purposes are made available to Facebook and Linkedin that handle the display of our ads.

29. We do not cooperate with any party that does not guarantee proper protection of personal data, in particular with EEA-based parties that do not abide by GDPR requirements or our Privacy Policy.

COOKIES POLICY

30. Our websites use cookies. These are small text files sent by the Web server and stored by the computer’s browser software. When a browser reconnects to a site, the site recognises the type of device used for the connection. Cookie parameters allow the information found therein to be read only by the website that set the cookie. Therefore, cookies make the use of previously visited websites easier.

31. The collected information may include the IP address, type of browser used, language, operating system, Internet Service Provider, date and time, location, and information submitted to the site via the contact form.

32. The collected data are used to monitor and check how users are using our websites and to optimise website operation by ensuring more efficient and streamlined navigation. We monitor user information using tools such as Google GTM, Google Ads, Facebook Ads, LinkedIn Ads and Google Analytics. In administering our websites, we also use Wordpress, while in e-mail campaigns we rely on the support of Active Campaign.

33. Cookies help to identify Users, allowing us to align the content of the website they use with their needs. By storing their preferences, we are able to accurately adjust ads targeted at them. We use cookies to ensure the highest user experience in our website, and the data we collect are used only internally to optimise our activities.

34. Our website uses the following kinds of cookies:
1) “analytics” cookies, allowing us to collect information on the manner of using the website’s pages;
2) “functional” cookies, allowing us to “remember” the settings chosen by the user and personalise the user interface, for example as regards the selected language or the region of the user, font size, website appearance etc.
3) “statistical” cookies, allowing owners of websites to understand how different Users behave while visiting their pages. Based on information about the User’s browser, which serves as a sort of identifier, it is possible to store the sequence of actions taken by a website visitor. Such data are subsequently combined with information about the activity of other users and presented to us in the form of charts and tables whose contents has been anonymised.
4) “marketing” cookies, allowing us to recognise that a previous visitor to our website is currently visiting the website of an advertising publisher. In other words, these files allow us to trace users in order to show them ads that reflect their previous activities, including their interests and preferences.

35. You can change the conditions under which cookies are stored or received by configuring your browser’s settings, for example:  https://support.microsoft.com/pl-pl/help/17442/windows-internet-explorer-delete-manage-cookies; http://support.mozilla.org/pl/kb/ciasteczka; http://support.mozilla.org/pl/kb/ciasteczka; http://support.google.com/chrome/bin/answer.py?hl=pl&answer=95647

36. Software used to browse websites (a web browser) usually allows cookies to be stored in the User's end device by default. Website Users may change their settings in this respect. Your web browser allows you to delete cookies. It is also possible to block cookies automatically. Detailed information about this can be found in the help section or documentation of the User’s web browser.

37. Articles in our website may contain embedded content (videos, images, articles etc.) Embedded content from other websites behaves just as if the user visited the source website directly.

38. The websites may collect User information, use cookies, attach additional external tracking systems, and monitor interactions with embedded materials, including tracking User interactions with embedded materials if they have an account and are logged in the source website. We are not, however, responsible for any measures used in other websites and social media pages, and we recommend in this respect that you read the means and measures of protecting personal data applicable there (privacy policies and cookie policies).

39. We use cookies to personalise our content and advertising in order to offer social media functions and analyse the traffic in our website. To be able to connect activities you engage in during separate sessions, a cookie contains information on the configuration and type of the web browser. We share information on how you use our website with our social media, advertising and analytical partners. Our partners may combine such information with other data obtained from you or collected while you use their services (according to their privacy policies and cookie policies).

YOUR RIGHTS

40. You have the right to access the content of your data and obtain their copies, the right to rectify, delete, restrict the processing of and transfer your data, the right to object to data processing based on legitimate interest of the Controller or processing for direct marketing purposes, and the right to withdraw your consent at any time without affecting the lawfulness of processing (if based on consent) made before the withdrawal of consent.

41. If it is believed that the processing of personal data violates the provisions of the GDPR or other provisions dealing with the protection of personal data, a data subject may file a complaint with the President of the Personal Data Protection Office.

42. A request to exercise the rights of data subjects can be submitted in writing or by e-mail using the contact details of the Controller listed below.

43. The request should accurately state to what it applies, if possible, in particular what right the data subject wants to exercise and what processing operation does the request refer to.

44. If the Controller is unable to determine the content of the request or identify the person concerned based on the notification made, the requester will be contacted for additional information.

COPYRIGHT

45. Except as noted otherwise, the owner of copyright to content published in the Internet portal is SWLEX Sp. z o.o. Copyright protection also extends to the trade dress and layout of content displayed in the website. Except as noted otherwise, content published in the portal can be processed without obtaining the written consent of the website’s owner, provided that such content may not be commercially traded as separate products and that www.swlex.pl is named as their source of origin .

46. SWLEX Sp. z o.o. grants its consent to use the website content (in whole or in part) in the following fields of exploitation:
a. copying,
b. printing,
c. digital reproduction,
d. posting on publicly available Internet websites,
e. quoting in own works.

CONTACT DETAILS OF THE CONTROLLER

47. Since we obliged to do so under applicable law, we have appointed a Data Protection Officer, who is Dariusz Leśniewski. In case of doubts concerning the scope and purpose of processing of your personal data and the rights you are entitled to in this respect, please read our Privacy Policy or contact us at iod@swlex.pl, by calling +48 503126275, or in writing at the address of our seat stated above.

We know we are responsible for the protection of data entrusted to us by Users. We take security very seriously. Therefore, we take care to secure your data against unauthorised access of third parties and verify the methods we use to collect, store and process information. We use suitable technical, physical and organisational security measures. Access to data is granted to employees and other parties only on a need-to-know basis to process them solely for the purposes described in this Privacy Policy.

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