PRIVACY AND PERSONAL DATA PROCESSING POLICY

Welcome to the website (“Website”) owned by Generation9 S.A., based in Warsaw, at ul. Wilcza 42/12, 00-679 Warsaw, registered in the Register of Entrepreneurs of the National Court Register maintained by the District Court for the capital city of Warsaw, 13th Commercial Division of the National Court Register under KRS number: 0001147187, NIP: 5214100693, REGON: 540597698, hereinafter referred to as “GENERATION9”, “we”, “our”, or “us”, depending on the context.

GENERATION9 places great importance on the protection of the privacy of individuals and their personal data collected in connection with our business activities.

As a responsible organization, we understand that information has a specific value and constitutes a resource that requires proper protection. We are committed to adequately informing you about matters related to personal data processing, particularly in light of the provisions of personal data protection laws, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons concerning the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”). Therefore, in this privacy policy (hereinafter: “Policy”), we present key information related to personal data processing in the company’s activities.

This Policy provides information about personal data processing, including a description of how we collect, use, and protect the personal data entrusted to us, the purposes and legal grounds for processing, and the rights of individuals whose data is processed.

The Privacy Policy consists of:

  1. General information applicable to all personal data processing operations by GENERATION9, and
  2. Specific thematic sections that, for different data processing operations, indicate specific purposes and legal grounds for processing, categories of recipients, data retention periods, and other information required by law.

PERSONAL DATA ADMINISTRATOR

The administrator of your personal data is Generation9 S.A., based in Warsaw, ul. Wilcza 42/12, 00-679 Warsaw, registered in the Register of Entrepreneurs of the National Court Register maintained by the District Court for the capital city of Warsaw, 13th Commercial Division of the National Court Register under KRS number: 0000672062, NIP: 5252706305, REGON: 366991292.

CONTACT REGARDING PERSONAL DATA

Would you like to notify us of a personal data breach, submit a request regarding your rights as a data subject, or have questions or concerns about the protection of your personal data?

Contact details of the Data Protection Officer for GENERATION9: Patrycja Żarska-Cynk
Email: dpo@generation9.co
Address: Generation9 S.A., ul. Wilcza 42/12, 00-679 Warsaw, with the note “Data Protection Officer”.

JOINT ADMINISTRATOR RELATIONSHIPS

In processes related to the website and as the owner of GENERATION9 profiles on social media, to achieve business goals and ensure the highest standards of services provided, we process your personal data within joint controller relationships with other entities.
Joint controllers independently decide on the purposes and means of data processing, but to varying degrees, within a certain set of information typically collected in an application, service, or system. GENERATION9 is solely responsible for the personal data it processes within the framework of cooperation with the aforementioned entities.
Information regarding joint controller relationships can be found directly in the chapter DETAILED INFORMATION ON DATA PROCESSING.

TRANSFER OF PERSONAL DATA

Personal data will only be transferred by the controller to trusted entities, such as companies providing and maintaining selected IT systems and solutions, accounting, legal, postal, and courier service providers.
As a rule, personal data will not be transferred outside the EEA (European Economic Area) or disclosed to international organizations. However, if the controller uses service providers from outside the EEA that have not been recognized by the European Commission as providing an adequate level of personal data protection, the transfer of personal data to such entities will be based on standard data protection clauses adopted by the European Commission, which ensure appropriate safeguards for privacy and the rights and freedoms of individuals. A copy of the standard contractual clauses can be obtained from the controller.

HOW TO EXERCISE YOUR RIGHTS

In connection with our processing of your personal data, you have the right to:

  • withdraw consent for processing (if we are acting based on such consent),
  • request access to your personal data,
  • request the rectification of your personal data,
  • request the deletion or restriction of the processing of your personal data,
  • object to the processing of data based on legitimate interests (unless there is an overriding legal basis) or for direct marketing purposes,
  • the right not to be subject to automated decision-making that significantly affects you,
  • the right to data portability in a machine-readable format to you or another data controller,
  • file a complaint with the supervisory authority, which in Poland is the President of the Personal Data Protection Office.

If you have any questions regarding this policy, the general processing of your personal data, or your data protection rights, please contact us at dpo@generation9.co.

DETAILED INFORMATION ON THE PROCESSING OF YOUR DATA

We may process your personal data in various ways and in different situations, depending on whether you are a Customer, Business Partner, User of our online and social media services, or if you are interested in working at GENERATION9.
Regardless of the situation, we commit to not selling, commercializing, or using your personal data in violation of applicable data protection laws.

We have organized information about personal data processing into categories dedicated to different groups of individuals, allowing you to quickly find the information that applies to you.

We have obtained your personal data directly from you in connection with the negotiation and execution of an agreement or from publicly available sources.
We process personal data such as contact details (e.g., phone number, email address), employment details (position, place of employment), and identification data (first and last name).

Purposes of data processing and legal basis

  1. Establishing communication and maintaining business relationships – the processing is necessary for the legitimate interests of the controller, which involve the purchase of goods and services necessary for conducting business (Article 6(1)(f) of GDPR).
  2. Executing contractual provisions – processing is necessary for actions taken before entering into a contract and for fulfilling the provisions of the contract (Article 6(1)(b) of GDPR).
  3. Maintaining accounting and tax records – processing is necessary to fulfill legal obligations arising from Article 74 of the Accounting Act and other tax-related laws (Article 6(1)(c) of GDPR).
  4. Pursuing claims and defending against claims – processing is necessary for the legitimate interests of the controller (Article 6(1)(f) of GDPR).
  5. Marketing of own services – processing is necessary for the purposes arising from the legitimate interests of the controller (Article 6(1)(f) of GDPR), and in cases where communication occurs via specific channels [phone, email], based on the consent given in this regard (Article 6(1)(f) of GDPR in connection with Article 10(1-2) of the Act on the Provision of Electronic Services or Article 172(1) of the Telecommunications Law).

Own service marketing may be preceded by profiling, understood as automated matching of content provided based on the client’s interests or needs, when processing is necessary for the purposes arising from the legitimate interests of the controller (Article 6(1)(f) of GDPR). If the profiling significantly affects your decisions, it will only be done with your consent.

Processing Period

Personal data is processed for the following periods:

  • Until a valid objection/request for deletion is submitted – applies to points 1 and 5 above, excluding email and telephone communication.
  • Until the contract is terminated or expires – applies to point 2 above.
  • Five years from the end of the calendar year in which the contract was terminated or expired – applies to point 3 above.
  • Until the expiration of claims – applies to point 4 above.
  • Until consent is withdrawn – applies to points 5 and 6 above.

Additional Information

Providing data is voluntary, but necessary for entering into and executing the contract. Data processing in the marketing of our own services may be preceded by profiling, understood as the automated matching of provided content according to the client’s interests or needs. If profiling significantly affects your decisions, the mechanism is activated only after you give your consent.

We have obtained your personal data directly from you in connection with the negotiation and execution of a contract or from publicly available sources.
We process personal data such as contact details (e.g., phone number, email address), employment details (position, place of employment), and identification data (first and last name).

Purposes of data processing and legal basis

  1. Establishing communication and maintaining business relationships – processing is necessary for the legitimate interests of the controller, which involve the purchase of goods and services necessary for conducting business (Article 6(1)(f) of GDPR).
  2. Evaluating and classifying service and goods providers, and the quality of their work – the legal basis for processing is the necessity to process for the legitimate interests of the controller (Article 6(1)(f) of GDPR).
  3. Executing contractual provisions – processing is necessary for actions taken before entering into a contract and for fulfilling the provisions of the contract (Article 6(1)(b) of GDPR).
  4. Maintaining accounting and tax records – processing is necessary to fulfill legal obligations arising from Article 74 of the Accounting Act and other tax-related laws (Article 6(1)(c) of GDPR).
  5. Pursuing claims and defending against claims – processing is necessary for the legitimate interests of the controller (Article 6(1)(f) of GDPR).

Processing Period

Personal data is processed for the following periods:

  • Until a valid objection/request for deletion is submitted – applies to points 1-2 above.
  • Until the contract is terminated or expires – applies to point 3 above.
  • Five years from the end of the calendar year in which the contract was terminated or expired – applies to point 4 above.
  • Until the expiration of claims – applies to point 5 above.

Additional Information

Providing data is voluntary, but necessary for entering into and executing the contract. In the process of personal data processing, there is no automated decision-making, including profiling.

We have obtained your personal data directly from you in connection with the negotiation and execution of an agreement with the Contractor you represent, or from publicly available sources.

We process personal data in the scope of contact details (e.g., phone number, email address), employment information (position, place of employment), and identification data (first name, last name).

Purposes of data processing and legal basis

  1. Ongoing communication related to business and commercial relations with the Contractor – processing is necessary for the legitimate interests of the administrator (Article 6(1)(f) of the GDPR).
  2. Claims and protection against claims – processing is necessary for the legitimate interests of the administrator, including protecting the business interests (Article 6(1)(f) of the GDPR).
  3. Marketing of own services, when processing is necessary for the legitimate interests of the Administrator (Article 6(1)(f) of the GDPR). In the case of communication via [telephone, email], processing is based on the consent given for that purpose (Article 6(1)(f) of the GDPR in connection with Article 10(1-2) of the Act on Providing Electronic Services or Article 172(1) of the Telecommunications Act).
  4. Marketing of own services may be preceded by profiling, understood as the automated adjustment of content based on client interests or needs, when processing is necessary for the legitimate interests of the Administrator (Article 6(1)(f) of the GDPR). If profiling significantly affects your decisions, it is only conducted after obtaining your consent.

Processing period

Data is processed for the following periods:

  • Until a legitimate objection/request for data deletion is made or until the processing purpose ceases – applies to point 1 above.
  • Until the expiration of claims – applies to point 2 above.
  • Until consent is withdrawn – applies to points 3-4 above.

Additional information

Providing data is voluntary but necessary for entering into and executing the agreement. The processing of data for marketing purposes may be preceded by profiling, understood as the automated adjustment of content to the client’s interests or needs. If profiling significantly affects your decisions, the mechanism is activated after you give your consent.

We have obtained your personal data directly from you via a contact form, email message, or phone call.

We process personal data in the scope of contact details (e.g., phone number, email address), employment information (position, place of employment), identification data (first name, last name), and other data you provide in communication.

Purposes of data processing and legal basis

  1. Recording correspondence and responding to inquiries – processing is necessary for the legitimate interests of the administrator, including timely responses to inquiries, timely payment of suppliers, and maintaining the quality of cooperation with contractors and other interested parties (Article 6(1)(f) of the GDPR).
  2. Claims and protection against claims – processing is necessary for the legitimate interests of the administrator, including protecting the business interests (Article 6(1)(f) of the GDPR).

Processing period

Data is processed for the following periods:

  • Until a legitimate objection/request for data deletion is made or until the processing purpose ceases – applies to point 1 above.
  • Until the expiration of claims – applies to point 2 above.

Additional information

Providing data is voluntary but necessary to receive a response to your inquiry. No automated decision-making or profiling occurs in the process of personal data processing.

We have obtained your personal data directly from you through the application you submitted, direct communication (e.g., during a recruitment interview), and, with your consent, from other agreed-upon sources of information. During the recruitment process, we may also generate additional information about you, such as opinions and competency assessments.

In the course of recruitment processes, we may create your recruitment profile by collecting the following categories of your personal data:

  • Contact details: name, address, email address, phone number.
  • Information provided in the application: your professional career history, employment history, date of birth, image, education, skills, language proficiency, and any other information included in your application.
  • Other data: any information you choose to share with us during the recruitment process and any data we generate in relation to your application.

It is possible that the process may involve special categories of data (as defined in Article 9 of the GDPR), such as health information, but we will only process such data if you voluntarily submit it along with your application.

Additionally, we may obtain the following information during recruitment:

  • Competency assessment: based on your application and observations made during the recruitment process, we may generate evaluative information and opinions regarding your candidacy. We may also ask you to undergo an assessment of your competencies, skills, character traits, or cognitive abilities.
  • References: we may decide to obtain references from individuals or institutions from your professional career. We will only contact individuals whose contact details you have provided and only after obtaining your consent.

Purpose and legal basis for data processing

  • Conducting and resolving the recruitment process for the position you are applying for:
    • Based on Article 6(1)(b) GDPR, i.e., to take necessary steps at your request prior to entering into a contract – in terms of the data provided during recruitment, as specified in Article 221¹ of the Labor Code of June 26, 1975, as well as based on your consent (Article 6(1)(a) GDPR) for data exceeding the scope specified in Article 221 §1 of the Labor Code of June 26, 1974.
    • Based on Article 6(1)(f) GDPR, i.e., for the purpose of pursuing the legitimate interests of the controller – in terms of data generated during the recruitment process.
  • Considering your recruitment profile, i.e., your application and other information generated in relation to your application, in future recruitment processes for a period of 12 months from the date of consent.
  • Establishing, pursuing, or defending against claims, based on Article 6(1)(f) GDPR, i.e., to pursue the legitimate interest of the controller in assessing the risk of claims being made against us and defending against them.

Data processing period

Your personal data will be processed for the duration of the recruitment process, and after this period, it will be stored for a period during which claims may be filed by either party, i.e., 6 months from the date of submitting your application. Additionally, if you withdraw from the recruitment process, your personal data will be stored for a period of 6 months from the date of submitting your application.

If you consent to the processing of your personal data for future recruitment purposes, we will process your data for this purpose until consent is withdrawn, but for no longer than 12 months from the date of submitting your application and providing this consent.

GENERATION9 and recruitment platforms such as Pracuj.pl are joint controllers of your personal data when you respond to our job offer through such platforms.

Each of the above joint controllers independently decides on the purposes and means of data processing, but to varying extents. GENERATION9 is only responsible for the personal data it processes.

When using job board services independently and separately from GENERATION9 as the owner of the recruitment account, when you communicate with us via these platforms, they are also responsible for processing your data. If you create an account on job board platforms such as Pracuj.pl, the companies managing them will further process the data for their own purposes, as detailed in their privacy policies. The privacy policy of Grupa Pracuj SA (Pracuj.pl) is available at this link.

Additional information

Providing personal data is voluntary, but within the scope specified in Article 221 §1 of the Labor Code, it is necessary for participation in the recruitment process. The processing of personal data does not involve automated decision-making, including profiling.

We have obtained your personal data directly from you during your use of the Website or interactions on our social media accounts. On the Website, we use cookies and analytical tools provided by social media services. You can read more about this in our Cookie Policy.

Purposes of Data Processing and Legal Basis

  • Establishing communication and maintaining relationships with the User of the Website or through social media services – processing is necessary for the legitimate interests of the controller in maintaining communication with potential clients and supporters of the Generation9 brand (Article 6(1)(f) GDPR).
  • Claim enforcement and protection against claims – processing is necessary for the legitimate interests of the controller (Article 6(1)(f) GDPR).
  • Marketing of our own services, where processing is necessary for purposes resulting from the legitimate interests of the controller (Article 6(1)(f) GDPR), and in the case of using a specific communication channel [e.g., phone, email], based on the consent given for that purpose (Article 6(1)(a) GDPR in connection with Article 10(1-2) of the Act on Providing Services by Electronic Means or Article 172(1) of the Telecommunications Law).
  • Marketing of our own services may be preceded by profiling, understood as automated matching of content provided based on the interests or needs of the client, where processing is necessary for the purposes resulting from the legitimate interests of the controller (Article 6(1)(f) GDPR). Profiling that significantly affects your decisions will only occur if such consent has been given.

Data Processing Period

Your personal data will be processed for the period during which you remain an active User of the Website, and after that, for the period necessary to comply with legal regulations, enforce claims, or defend against claims, but no longer than 6 years.

Your personal data processed in social media services:

  • Data collected in private messages – will be processed for the time necessary to respond to your inquiries or until the end of cooperation.
  • Data contained in comments under a selected publication – will remain available until they are deleted by the author of the publication or entry.
  • Personal data collected by social media platforms, such as post history or activity history, are subject to retention according to the rules outlined in the terms and conditions of these platforms.
  • Statistical data regarding visitors to the GENERATION9 fan page will be processed for the time these data remain available in the social media platform’s services.

The controller does not archive personal data or your activity in social media services.

Data processed for the purpose of sending marketing information will be processed until the consent given for this purpose is withdrawn. It is important to note that withdrawing consent does not affect the legality of data processing carried out before the withdrawal.

GENERATION9, as the creator of profiles on the social media platforms listed below, is a Joint Controller of the personal data published on these profiles along with the following entities:

Each of the above Joint Controllers independently decides on the purposes and means of data processing, but within different scopes. GENERATION9 is responsible only for the personal data it processes.

When using social media services, independent and separate from GENERATION9 as the owner of business accounts on these platforms, these platforms are also responsible for processing your data when you communicate with us through them. If you create an account on these social media services, the companies managing them will further process your data for their own purposes, as described in detail in their Privacy Policies.

If you have any questions or requests directed to the social media platform owners, please contact them:

Additional Information

Providing data is voluntary but necessary to use the functionalities of the social media services and profiles. The processing of data for the marketing of our own services may be preceded by profiling, which is understood as automated matching of content based on the interests or needs of the client. If profiling significantly affects your decisions, it is only initiated after you have provided consent.

COOKIES AND OTHER TRACKING TECHNOLOGIES ON SERVICES

Within the website in the domain Heneration9.pl (hereafter referred to as the Service), and on independent websites created by us (landing pages), we use information stored via cookies, which are data stored on users’ devices intended for accessing websites (e.g., computer, tablet, phone). These typically contain the name of the website from which they originate, the duration of their storage on the device, and a unique number. When you visit our website, you can read more about this in our Cookie Policy.

FINAL INFORMATION

We continuously develop our competencies, modernize processes, and subject the adopted data processing model and security measures to audits, which may result in changes to the communications directed at you and shared here. We reserve the right to update these communications. The privacy policy may also change due to changes in legislation or updates in the purposes of data processing.

Information about changes in documents will be published in the Service under the Privacy Policy section.