GDPR PRIVACY POLICY General Information

We place great emphasis on protecting your personal data and handling it in accordance with the General Data Protection Regulation of April 27, 2016 (GDPR).

Personal Data Administrator

Personal Data Administrator for your personal data collected during recruitment processes is Malwina Filipiuk, operating under the business name “Malwina Filipiuk MooreTalents,” with a principal place of business in Warsaw, at Bitwy Warszawskiej 1920 roku 21/136, 02-366 Warsaw, REGON: 521202915, VAT Number: 7962671942 (referred to as the “Administrator”). The Administrator processes personal data.

Purpose of Personal Data Processing

The purpose of processing personal data is:

• To conduct current recruitment processes (based on consent, explicitly confirmed through the submission of application documents).
• To conduct future recruitment processes (based on consent).
• To present and send job offers electronically.
• To correspond and present the Administrator’s services to potential employers/clients (based on consent).

Recruitment processes are carried out by the Administrator on behalf of potential employers/clients located both within Poland and in the EU (you will be informed of such cases). Employers independently define the purposes and methods of processing the data without being subject to the Administrator’s instructions. However, this does not exempt employers/clients from complying with GDPR obligations.

Additionally, personal data will be processed for:

• Concluding and implementing contracts with Administrator’s clients
• Asserting and defending claims.

The Administrator may also build a database of potential employees based on the Administrator’s legitimate interest by gathering information from professional platforms (e.g., LinkedIn, Goldenline, Business Groups) or through market recommendations from industry professionals. The source of personal data described in Art. 14 GDPR are the above entities. The scope of such data includes among others: name, email address, phone number, and professional experience.

Providing personal data is voluntary but necessary for participating in recruitment processes or concluding and performing agreements with clients, as well as for asserting and defending claims.

Types of Personal Data Processed

The types of personal data processed may include:

• Name and surname.
• Residential/registered or correspondence address.
• Contact telephone number.
• Education (including postgraduate studies or courses).
• Professional experience.
• Information regarding certificates and professional skills.
• Email address or other communication channels.
• Date of birth (optional in recruitment, provided voluntarily in the CV).
• Client data such as company name, NIP, REGON, KRS, email, phone number, and other necessary information.

The categories of your personal data that may be processed in recruitment procedures are determined by Article 221 § 1 of the Labour Code. If a Candidate voluntarily provides data beyond the scope specified in that provision, this shall be deemed to constitute the Candidate’s consent to the processing of such data by the Administrator.

Legal Basis for Personal Data Processing

The legal basis for personal data processing includes:

• Consent explicitly provided through an affirmative action such as sending application documents (Article 6(1)(a) GDPR) – ongoing recruitments.
• Consent for future recruitment purposes (Article 6(1)(a) GDPR) – collecting personal data for the purpose of subsequent contact for recruitment purposes and sending job offers.
• Necessity for actions related to concluding agreements with employers/contractors (Article 6(1)(b) GDPR).
• Legitimate interests pursued by the Administrator (Article 6(1)(f) GDPR) such as communication, defending claims or building a database of individuals potentially interested in job changes.

Methods of Obtaining Personal Data

Your personal data may have been obtained through:

• Voluntary submission by the candidate.
• Market recommendations from third parties.
• Publicly available sources such as LinkedIn, Goldenline or business portals/groups.

Sharing Personal Data

Your personal data may be shared with:

• Authorized associates of the Administrator and potential employers/clients (with your consent).
• Public authorities or entities authorized to request data under applicable laws (e.g., courts, law enforcement agencies).

Duration of Personal Data Processing

The duration of data processing depends on its purpose:

• Retention period of the recruitment process:
  • Ongoing recruitment processes – no longer than until their completion, provided that you have given your consent (through a clear affirmative action – submitting application documents) to participate only in a specific recruitment process.
  • Future recruitment processes – until you withdraw your consent for the processing of personal data, if you have agreed to participate in future recruitment processes conducted by the Administrator. This consent may be revoked at any time by sending an email to: malwina@mooretalents.pl.
• Legal provisions that may oblige us to process data for a specified period.
• The period necessary to protect the company’s interests – limitation periods for claims.
• In the case of data processing within the database of individuals potentially interested in changing jobs (data obtained from market recommendations and publicly available sources such as LinkedIn), until an objection is raised with regard to the processing of personal data for this purpose.

Rights of Individuals Whose Data Is Processed

Furthermore we inform that you have the right to:

• Access your personal data.
• Request the rectification of your personal data if it is incorrect, as well as the completion of incomplete personal data.
• Request the deletion of your personal data, particularly in cases where you withdraw your consent for processing and there is no other legal basis for processing.
• Request the restriction of the processing of your personal data.
• Object to the processing of your data due to your particular situation in cases where we process your data based on our legitimate interest.
• Request the transfer of your personal data.
• Lodge a complaint with the data protection supervisory authority, namely the President of the Personal Data Protection Office.
• If your data is processed based on consent, you have the right to withdraw your consent for data processing at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. Withdrawing consent does not entail any negative consequences for you. Legal basis: Article 7(3) of the GDPR.
  You can withdraw your consent by sending a statement of withdrawal to the following email address: malwina@mooretalents.pl

Additional Information and Contact Details

The Administrator does not use automated decision-making systems.

Data is not transferred outside the EU.

For matters related to personal data processing, you can contact:

• Address: Bitwy Warszawskiej 1920 roku 21/136, 02-366 Warsaw.
• Email: malwina@mooretalents.pl, phone: +48 503 627 909