Privacy Policy

A version of 20.10.2020.

I. Introduction

The administrator of personal data collected in accordance with this Policy is joinEdTech Marcin Myśliwczxyk with a registered office in Poland in Gdansk (80-288), at ul. Piecewska 33/141 with Tax ID: PL9570800357, REGON: 362757257. Contact details: phone: +48 600430086, e-mail: support@joinedtech.com.

II. Definitions

For the purpose of this Policy the following definitions apply:

a. Administrator/joinEdTech – means joinEdTech limited liability company with a registered office in Poland in Gdansk (80-172), at ul. Trzy Lipy 3 with Tax ID: PL5842785694, REGON: 383943294, registered in the District Court Gdańsk-Północ in Gdańsk, VIII Commercial Division of the National Court Register under KRS number: 0000796072.

b. Personal data – means information about an identified or identifiable natural person. An identifiable natural person is a person who can be directly or indirectly identified, in particular on the basis of an identifier such as name, identification number, location data, internet identifier, or one or more specific factors determining the physical, physiological, genetic, psychological, economic, cultural or social identity of a natural person.

c. Candidate - means a natural person who (i) expresses the will to employ himself as an employee and submits a job application on the Job Board or will be redirected to the Advertiser's website in order to apply for a job or (ii) sets up an account on the Job Board.

d. Advertiser - means a natural person, a legal person or an organizational entity without legal personality running a business activity that expresses the will to employ an employee and submits a job advertisement or sets up an account on the Job Board.

e. Recommending Person - means a natural person who, via the Job Board, sends another person potentially interested in the advertisement published on the Job Board, information about this advertisement - the recommendation.

f. Recommended Person - means a natural person whose Recommending Person sends via Job Board information about the advertisement published on the Job Board.

g. Personal Data Processing - means an operation or set of operations performed on Personal Data or Personal Data Sets in an automated or non-automated manner, such as collecting, recording, organizing, ordering, storing, adapting or modifying, downloading, browsing, using, disclosing by sending, distribution or other types of sharing, matching or combining, limiting, deleting or destroying.

h. Terms and Conditions – means Term and Conditions for the rendering of electronic services within the Job Board maintained at www.joinedtech.org.

i. Regulation or 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).

j. Job Board – means Internet service run by joinEdTech at: www.joinedtech.org.

k. User, Users – means any person who uses the services offered by the Job Board.

III. General rules

1. joinEdTech respects the right of Advertisers, Candidates, Recommending Persons, and the Recommended Persons for privacy and personal data protection that are processed in accordance with GDPR and this Policy.

2. joinEdTech informs that it does not share with the Advertisers, Candidates, Recommending Persons or the Recommended Persons additional technical measures to prevent the acquisition and modification of Personal data transmitted electronically by unauthorized persons.

3. It is not allowed to use the Job Board anonymously or using a nickname, which is justified by the character of providing services where personal identification is important. This does not apply to the Recommending Persons and the Recommended Persons.

IV. The scope of Personal data collection

1. joinEdTech makes every effort to ensure that Personal Data is processed in accordance with applicable law and that it is protected against loss, destruction, disclosure, unauthorized access or improper use. joinEdTech guarantees the confidentiality of all data provided to it by taking effective security measures and protecting Personal Data. In case of suspicion that Personal data is not properly secured or if there is evidence of abuse, please contact us at the following e-mail address: support@joinedtech.org

2. Each time, the purpose, scope and recipients of Personal Data processed by joinEdTech arise from the consent of the User or the regulations of law and are further specified as a result of actions taken by the User on the Job Board or within other channels of communication with the User.

3. The admistrator may proces User’s Personal Data defined in this Privacy Policy. In each case it shall be at least the following Personal data: a. name and surname, b. email address, c. phone number.

V. The purpose of Personal Data Processing – general provisions

i. Providing Personal Data is necessary to use the services of the Job Board, including creating an account and to use the offers of Advertisers. Each time the scope of personal data required to perform a given service is indicated in advance on the Job Board and in the Terms and Conditions. Not submitting data may result in the inability to use the services of the Job Board.

ii. Possible purposes of collecting and processing Users' Personal Data by joinEdTech:

a. conclusion and performance of a contract for the provision of services (e.g. an account) and accepting and processing of complaints:

i. The main purpose of the processing of Personal Data and other information by joinEdTech is to maintain the Job Board, provide safe and guaranteed efficiency of services for Users and provide services. On the Job Board website, the User may create a User account by filling the registration form. If the User creates an account by filling the registration form, joinEdTech will process the first and last name, telephone number and e-mail address which the User has entered in the form and the password.

ii. Providing some data is also necessary to use the services and functionality of the account. The consequence of their failure is the lack of the possibility of providing certain services and functionality by joinEdTech.

iii. Except for the data which provision has been marked as "obligatory", providing other data is voluntary.

iv. The legal basis for processing is Article 6 par. 1 letter b GDPR (indispensability to perform the contract for the provision of electronic services).

v. In case the User has an account on the Job Board, the User's data shall be processed during the time when the User will use the account, and in the event of its liquidation, expiration or termination of the contract for the provision of electronic services (regardless of the reason and basis of its termination), no longer, than it is necessary for the purpose of handling complaints and claims related to the use of services provided by joinEdTech (statutory limitation period for claims).

b. security of claims:

i. In order to determine, settle and enforce claims, joinEdTech may process some of the Personal Data provided by the User, in particular the name and surname, contact details, data concerning the use of Job Board’s services and other data that shall be necessary to prove the existence of the claim, its execution and defense against claims in proceedings before courts and other state authorities.

ii. The legal basis for data processing is Article 6 par. 1 letter f GDPR, ie the legitimate interest of joinEdTech. Data in this respect are processed for the statutory limitation period of claims.

iii. However, data processing shall only include their storage, with the exclusion of any other operations on these data, subject to different duties of joinEdTech indicated in the applicable regulations or imposed on joinEdTech by the authorized bodies.

c. creating statistics on the use of the Job Board’s website and profiling:

i. joinEdTech monitors the quality of services it provides to fulfill the expectations of the Users. For this purpose, statistics of the use of particular functions and subpages of the Job Board are carried out by the use of internal analytical tools, as well as statistical tools provided by partners providing analytical services.

ii. The User of the Job Board can agree to process their personal data for advertising purposes, market research and research on the behaviour and preference of the Users. The results of the research will be used in order to improve the quality of the services provided by the Job Board. The lack of agreement has no influence on the rights and obligations of the user.

iii. In order to accomplish this goal, data about User's activity on the Job Board are processed (e.g. websites and subpages of the Job Board visited by the User, the amount of time spent on the website, the User's IP address, location, device ID and data about the browser and operating system used by the User).

iv. Analysis of online behavior will allow the Administrator to understand the users' habits and expectations better and to adapt to their needs and interests. Thanks to this technology, the Administrator not only can present the User an advertisement tailored to him/her, but also among the available offers, present primarily those that best fulfill the needs of the User. The information collected and contained in cookies may be stored after the end of the browser session, which allows, for example, to use them during subsequent visits of the User.

v. The legal basis for data processing is Article 6 par. 1 letter f GDPR, ie the legitimate interest of joinEdTech in facilitating the use of the services provided by joinEdTech by electronic means for the Users and in improving the functionality of these services.

d. Cookies i. The Administrator declares that processes data regarding the connection of the final device to the Advertiser, Candidate, Recommending Person and Recommended Person with the technical infrastructure of the Job Board by the use of Google Analytics - uses „Cookies”. These data are collective and anonymous - they do not contain features that identify specific natural persons.

ii. Cookies are small text files sent by the joinEdTech to the end users and stored there. Cookies can only be read by the joinEdTech.

iii. During the User's visit on the Job Board, joinEdTech may automatically collect data regarding the visit, such as the website's domain name, from which the User has been referred to the Website, browser type, operating system type, IP address, User ID, other information transmitted via the http protocol. Additionally, joinEdTech may process operating data or device location information through which access to the Website takes place.

iv. Cookies allow joinEdTech among others to ensure the proper functioning of the Job Board, to improve the speed and security of using the Job Board, to improve the functions used by the User and the use of marketing tools. The User may limit or completely deactivate Cookies at any time.

v. joinEdTech uses Cookies for the following purposes:

● measuring the traffic of Users on the Job Board using the Google Analytics code,

●customizing the content of the Job Board to the preferences of Users and optimizing this content - memorizing the lack of consent to display specific content, collecting data about the popularity of specific job ads, the number of clicks on individual parts and buttons on the website,

● identifying and maintaining the User's session when logged into the Account.

vi. Use of Cookies by joinEdTech requires the User's consent. It is assumed that the User consent to use cookies by joinEdTech, in respect of which his Internet browser settings allow to use Cookies through the Job Board.

vii. Users may at any time change their settings in the Cookies web browser, especially in such a way as to block the automatic handling of Cookies or to inform them of each time they place Cookies through the Job Board on the User's device.

viii. joinEdTech informs that the restrictions on the use of Cookies may affect some of the functionality available on the Job Board or prevent the use of the Job Board.

ix. joinEdTech declares that the use of Cookies by joinEdTech does not cause any configuration changes in the User's end devices or the software installed on them.

x. As part of marketing activities, CadidFuture may use the services of the following entities that use Cookies on the Job Board: ● Google AdWords, ● Google Analytics, ● Pixel Facebook. For more information on the Cookies of these entities, please refer to their privacy policies.

xi. The legal basis for keeping statistics is the legitimate interest of the Administrator (Article 6 par. 1 letter f of the GDPR), which consists in conducting analyzes of the User's activity on the Job Board in order to improve the functionalities used.

f. Advertising campaigns:

i. As part of advertising activities, joinEdTech uses, among others, technologies provided by external advertising partners. These are among others: ● Google, ● Facebook (Pixel Facebook), ● User.com, ● MailChimp, ● Surveys.

ii. The nature and form of advertising messages depend on the interests, place of residency and other parameters that allow individualizing the advertising message.

iii. In the case of data processing for the purpose of direct marketing of the Administrator's own products or services, the legal basis for such processing is the fulfillment of legally justified purposes carried out by the Administrator (Article 6 par. 1 letter f of the GDPR).

iv. Personal data of Users who took part in the survey organized by joinEdTech are deleted within 2 weeks from the date of their receipt.

v. The data of persons who have consented to receive trade information by e-mail, such as name and e-mail address, are stored until the request for deletion or opposition is submitted, regardless of the other terms listed below.

g. Social portals:

i. The Administrator also processes Personal Data of Users visiting profiles conducted on social media (Facebook, YouTube, Instagram, LinkedIn, Twitter).

ii. These data are processed only in connection with running a profile, including the purpose of informing Users about the activity of joinEdTech and promoting various types of events, services and products. The legal basis for the processing of personal data by the Administrator for this purpose is its legitimate interest (Article 6 par. 1 letter f of the GDPR), which consists in promoting its own brand.

h. Newsletter:

i. Trade information related to commercial activities run by the Administrator or the cooperating entities may only be sent in accordance with the will expressed by the User for the purpose of performing the contract for the provision of the newsletter service.

ii. For sending the newsletter joinEdTech uses the e-mail address provided by the User. Confirmation, consisting in the User's, as the owner of the e-mail address, consent to receive the newsletter, is required here.

iii. In the case of targeting marketing content to the User as part of the newsletter, in connection with the expressed consent to receive the newsletter, the legal basis for processing personal data, including profiling, is the legitimate interest of the Administrator consisting in promoting the Administrator's brand (Article 6 par. 1 letter f of the GDPR).

iv. The user may unsubscribe from the newsletter at any time by canceling his consent without incurring costs, apart from the costs of providing information according to the basic tariff. For this purpose, it is sufficient to send a text notification to the contact details listed in item I. (eg e-mail, fax, letter). In each newsletter an additional link to unsubscribe from the newsletter is available.

i. Competitions:

i. The Administrator processes Users’ Personal Data, provided in the application form for participation in a given competition organized by joinEdTech. The form indicates, which information fields are required and which are voluntary to complete. The condition for registration of participation in a given competition organized by joinEdTech is the complement of fields marked as required.

ii. The legal basis for data processing is the legitimate interest of the Administrator (Article 6 par. 1 letter f of the GDPR), consisting in the promotion of products and services of joinEdTech by organizing competitions. If the User is the winner of a given competition, the Administrator shall process User's Personal Data also in order to fulfill his tax obligations related to the settlement of the prize (Article 6 par. 1 letter c of the GDPR).

iii. Detailed information on the Personal Data Processing are specified each time in the competitions’ regulations.

j. Communication:

i. The Administrator may communicate with the User by means of system information, notifications, e-mail, messages in social media channels, chat tools on the Job Board website, by phone or conventionally via letters and parcels.

ii. The User may, at any time, contact directly the Administrator by sending a relevant message in writing, by e-mail to the Administrator's address indicated at the beginning of the Policy, by telephone at the telephone number indicated at the beginning of the Policy and via chat tools on the Job Board.

iii. The Administrator shall store the correspondence with the User for statistical purposes and for the best and quickest response to appearing inquiries, as well as in the scope of complaint settlements and possible decisions on administrative interventions in the indicated account. The addresses and data collected in this manner shall not be used for communication with the User for purposes other than execution of the order.

iv. When the User contacts the Administrator in order to perform certain actions (eg submit a complaint), the Administrator may ask the User again to provide data, including personal data, e.g. in the form of name, surname, e-mail address, etc., to confirm the identity of the User and allow return contact in a given case. The above applies to the same data, including personal data, which were previously provided by the User, and on which processing the User consented. Providing this data is not mandatory but may be necessary to perform actions or obtain information that shall interest the User.

VI. The purpose of Personal Data Processing – specific provisions

A. Advertiser – Personal Data Processing

1. joinEdTech informs that it processes the Personal data of the Advertiser and his/her employees in the scope necessary to provide them with the service ordered including forwarding job applications.

2. The Advertiser or their employees may agree to the processing of their personal data: email address and phone number by joinEdTech for the purposes of direct marketing of their services during and after the duration of the service provided. The consent is voluntary.

3. The consent granted by the Advertiser or their employees is voluntary and may be withdrawn at any time by sending a written note to the email address of joinEdTech.

4. The data will not be disclosed to third persons with the exception of transferring the data to PayLane sp. z o.o. in the scope necessary to perform the payment service.

B. Candidate

1. joinEdTech informs that it processes the personal data of the Candidate in the scope necessary to provide the service ordered including forwarding job applications to the Advertiser.

2. The Job Board will be processing the personal data mentioned in Section IV par. 3 of this Privacy Policy as well as other personal data given in the application form, Candidate’s Profile account (sex, year of birth, date of birth, website, localization), CV form and the data given in the positive “like” assessment. In case of downloading personal data from social media services, the Job Board will process only data made available by the given service. In case of subscribing to new advertisements, joinEdTech will be processing data on the generic preferences of the Candidate, concerning the job advertisements.

3. joinEdTech informs that the scope of the processing of personal data is broader than the one given in Section IV par. 3 because of the nature of the services provided.

4. Processing Candidate’s Personal data will be terminated not later than five weeks after submission of job application. Backup copies including Personal data shall be deleted after 365 days from the date of submitting the job application.

5. Processing Personal data regarding the account which Candidate fills out himself/herself will be terminated through permanent deletion within five weeks after deleting the account.

6. Personal data in the CV form is processed from the moment of entering it to the form till removing it from the form (deleting the form). Processing Personal data will be terminated through permanent deletion within five weeks after removing it from the form (deleting the form).

7. Personal data downloaded from the social media service will be automatically updated during logging in or refreshing the login token in its social media service.

8. Processing Personal data with a positive “like” assessment, generated by a given Candidate, will be terminated through deleting it after deleting the account of the Candidate.

9. joinEdTech informs that sharing an application by Candidate with Advertiser through the Site is tantamount to sharing with Advertiser all of Candidates personal data which are included in application forms ( including image) and those which were shared on Candidate’s profile. Advertiser is also the Administrator of applications.

C. Recommending Person

1. In order to send a recommendation it is necessary to agree to the Processing of Personal data in the scope necessary to realize the provided services, including sending recommendations and the information on potential recommendations.

2. The Personal data of the Recommending Person will be forwarded to the Advertiser and the Recommended Person that may have their seat or residency outside the European Union.

D. Recommended Person

1. joinEdTech informs that it processes the Personal data of the Recommended Person in the scope necessary to provide the service of sending recommendations as well as the rights of the Recommending Person in the scope necessary to realise the provided services, including sending recommendations and the information on potential recommendations.

2. The Personal data of the Recommended Person will be forwarded to the Advertiser and the Recommending Person that may have their seat or residency outside the European Union.

3. The Recommended Person shall be immediately notified about processing their Personal data.

4. The Recommended Person has a right to submit a written justified demand to stop processing their personal data due to their specific situation or protest against forwarding their Personal data to another data administrator.

VII. Possible recipients of Users' Personal Data

1. In addition to the entities indicated in Section VI. of Policy, in order to maintain the User's account, provide the ordered services and current support, the User's data may be transferred for processing to specialized entities. The data may be shared in particular with:

a. IT service providers,

b. marketing agencies, marketing partners and suppliers of marketing platforms,

c. entities that process and coordinate the execution of payments,

d. cloud service providers,

e. service providers in the scope of data analysis,

f. consultants, lawyers, accountants and other professional service providers,

g. entities associated with the Administrator personally and by capital, which help him to provide our services or perform data processing tasks on our behalf - where such entities process data on the basis of the contract concluded with the Administrator and only in accordance with his instructions.

2. The Administrator also makes Users' data available to authorized state authorities, if they turn to the Administrator in connection with the tasks they perform. These may include, in particular, organizational units of the prosecutor's office, the Police, the President of the Office for Personal Data Protection, the President of the Office of Competition and Consumer Protection or the President of the Office of Electronic Communications.

VIII. Transmission of data to third countries (outside the European Economic Area)

1. As part of the use by the Administrator of tools supporting his ongoing activities, made available to, for example, entities indicated in Section V, par. 2 letters d-f, such as Google, Facebook, your personal data may be transferred to a country outside the European Economic Area, in particular to the United States of America (USA) or other countries in which the cooperating entity maintains tools for processing Personal Data in cooperation with the Administrator.

2. Appropriate security measures of Users’ Personal Data were provided by the Administrator through the use of data protection clauses that meet the requirements of the GDPR. In the case of transfer of data from Europe to the USA, some entities located there may additionally provide an adequate level of data protection within the so-called Privacy Shield (more information at: https://www.privacyshield.gov/).

IX. The period of storage of personal data

1. The Administrator guarantees that Personal Data will be stored only for the time that is necessary to achieve the purposes for which the data was collected.

2. The data will be stored as long as they are needed to provide services by Administrator to Users or to delete the account by the User depending on what occurred earlier.

3. The period of storage of Personal Data is determined individually and depends on the nature of the data, the reason for its collection and processing. After this time, the data is deleted or anonymized in such a way that it is impossible to determine the identity of the User.

4. Personal data may be stored for longer if such obligation results from the provisions of law or it is necessary for the Administrator to defend or seek claims against the User.

X. Viewing and correcting of stored Personal Data

1. In relation to the processing of Personal Data by the Administrator, the Users have the following rights:

a. the right to request access to, to rectify, delete or limit the processing of Personal Data,

b. the right to object to the processing of Personal Data,

c. the right to transfer Personal Data,

d. the right to withdraw consent to the processing of Personal Data for a specific purpose, if the User previously gave such consent,

e. the right to lodge a complaint to the supervisory authority in connection with the processing of the User's Personal Data by the Administrator.

2. The above mentioned rights Users may excercise in accordance with the rules described in art. 16 - 21 GDPR, by sending a message to the e-mail address: support@joinedtech.org.

3. All received applications will be treated with special attention and implemented in the shortest possible time. In the case of some applications (of complex nature or concerning the processing of data subject to specific legal regulations) the execution time may be longer, however, in each case, within one month the User shall be informed about the actions taken by the Administrator in order to complete the application. By providing answers and in order to ensure that the Administrator properly implements the application, the Administrator reserves the right to verify the User's identity.

XI. The risks associated with the use of services provided electronically

1. The Personal Data Administrator wishes to inform Users that using services provided electronically at the time of inadequate care for the security of their data, they expose themselves to, among others, at risk of:

a. interference with User’s data of unauthorized persons, which may view, copy, modify and delete User's data,

b. receiving unsolicited e-mail,

c. phishing of the User's data,

d. interference by third parties in the transmission of information between the User's system and the Administrator's system,

e. infecting the User's system with malware,

f. counterfeiting the protocols and security certificates.

2. In order to minimize above mentioned risks:

a. you should not give your password and login to anyone,

b. you should always use the current versions of the software, e.g. browser,

c. you should check the certificate before logging into the Job Board.

XII. Security

1. The Administrator uses technical and organizational measures to ensure the protection of Personal Data processed in accordance with the risks and categories of data protected, in particular, protects data against unauthorized access, unauthorized removal, processing in violation of applicable laws and change, loss, damage or destruction, such as:

a. securing the set of data against unauthorized access,

b. SSL certificate on the Job Board website, where users' data are provided,

c. access to the account only after providing an individual login and password,

d. advanced authorization to the Advertiser's Panel (token per URL),

e. encryption of data used for User’s authorization.

XIII. Final provisions

1. In matters related to this Privacy Policy please contact us at: support@joinedtech.org.

2. joinEdTech reserves the right to change the Policy in the future - this may happen, among others for the following important reasons:

a. changes in the binding provisions, in particular regarding the protection of Personal Data, telecommunications law, services provided electronically and regulating consumer rights, affecting the rights and obligations of the User;

b. development of functionalities or electronic services dictated by the progress of Internet technology, including the application / implementation of new technological or technical solutions affecting the scope of the Policy.

3. In case of change of the Policy, the new version shall be published on the website www.joinedtech.org. The new version of the Privacy Policy enters into force on the day of its publication.

4. In case of any doubts or contradictions between the Policy and the consents granted by the User, regardless of the provisions of the Policy, the basis for taking and determining the scope of activities by the Administrator are consents voluntarily granted by the User or provisions of law.

5. In the scope not regulated in the Privacy Policy, the provisions of the GDPR and the mandatory provisions of law in force on the territory of the Republic of Poland shall apply.

6. The Privacy Policy has been prepared in English.

7. The Polish court having jurisdiction over the joinEdTech seat shall investigate any disputes arising out of or in connection with this Privacy Policy, if the exclusive jurisdiction does not apply.

8. The Job Board may contain links to other websites. joinEdTech advises that after going to other websites, you should read the privacy policies set out there, including the Advertiser's privacy policy. This Policy applies only to the indicated activities of joinEdTech.