This is a translation for convenience. The Polish version is legally binding, Polityka prywatności.
1. Personal Data Controller
The controller of the personal data of Website Users, Business Clients and Job Candidates is the following entity.
| Item | Registration and contact details |
|---|---|
| Company name | EMOR SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ |
| Registered office | ul. Lubicz 24/8, 31-504 Kraków, Polska |
| NIP | 5272698477 |
| KRS | 0000473444 |
| REGON | 146813900 |
| Operational branches | Kraków, ul. Lubicz 24/8, 31-504 Warszawa, ul. Grochowska 23/31 bud. D, 04-186 Wrocław, ul. Świebodzka 4A/2, 50-046 |
| E-mail address | biuro@emor.com.pl |
| Contact telephone numbers | For companies and B2B partners +48 690 856 400 For candidates and recruitment +48 790 731 500 |
2. Purposes, Legal Bases and Data Retention Periods
The Controller processes personal data for strictly defined, lawful and legitimate purposes, in accordance with the principles of purpose limitation, data minimisation and storage limitation.
| Purpose of processing | Legal basis (RODO / GDPR) | Scope of data | Retention period |
|---|---|---|---|
| Ongoing recruitment of employees and candidates | Art. 6(1)(c) RODO in conjunction with Art. 22¹ of the Kodeks pracy (Polish Labour Code) (data required by the Code) and Art. 6(1)(a) RODO (additional data from the CV) | Identification data, contact details, education, employment history, professional licences and qualifications | Until the relevant recruitment process is completed |
| Future recruitment processes | Art. 6(1)(a) RODO (voluntary consent of the candidate) | Full data contained in the application and the recruitment form | Until consent is withdrawn, for a maximum of 2 years from the date of application |
| Handling of enquiries and contact forms | Art. 6(1)(f) RODO (legitimate interest of the Controller, efficient business communication) | First name, surname, e-mail, telephone, company name, content of the enquiry | For the duration of the correspondence and up to 12 months after it ends |
| Conclusion and performance of a contract (B2B, staff leasing, outsourcing) | Art. 6(1)(b) RODO (necessity for the performance of a contract) | Data of the business entity, data of persons representing it and designated as contacts | For the term of the contract and until civil law claims become time-barred (3-6 years) |
| Accounting and tax obligations | Art. 6(1)(c) RODO in conjunction with the ustawa o rachunkowości (Accounting Act) and the Ordynacja podatkowa (Tax Ordinance) | Billing data for invoices, NIP, name, address, transaction amounts | 5 years from the end of the calendar year in which the tax payment deadline expired |
| Website analytics and online marketing | Art. 6(1)(a) RODO (consent to cookies) and Art. 6(1)(f) RODO (legitimate interest) | IP address, cookies, technical browser parameters, on-site behaviour | Until the cookies expire or the user withdraws consent |
3. Categories of Personal Data Processed
The Controller collects and processes the following categories of personal data.
- Job candidates and temporary workers. First name and surname, date of birth, contact details (telephone number, e-mail address, residential address), information on education and professional qualifications, specialist licences (e.g. UDT, driving licence categories), previous employment history and any additional information voluntarily provided in application documents (CV, cover letter).
- Clients, contractors and their representatives. Company identification data, NIP, REGON, business address, names and surnames of contact persons, job titles, business e-mail addresses and contact telephone numbers.
- Users of the emor.com.pl website. Online identifiers (including cookies), IP addresses, approximate geolocation, data concerning the device, operating system, web browser and activity within the website's subpages.
4. Recipients of Personal Data
Personal data may be transferred to third parties only to the extent necessary to achieve business and legal purposes.
- User Employers and end Clients. Entities commissioning staff leasing and outsourcing, to which candidates and workers are assigned in order to perform work or provide services.
- Providers of IT, hosting and operating system services. Entities providing server maintenance, e-mail, ATS recruitment software, CRM systems and website support tools.
- Entities providing legal and accounting support. External accounting offices, law firms and audit firms providing professional services to the Controller.
- Providers of analytics and advertising services. Including Google LLC, Meta Platforms Ireland Ltd. and Microsoft Corp., on the basis of consents given to cookies.
- State authorities and institutions. Tax authorities, the Zakład Ubezpieczeń Społecznych (ZUS, Social Insurance Institution), the Państwowa Inspekcja Pracy (PIP, National Labour Inspectorate), courts and law enforcement authorities, solely within the limits and on the basis of generally applicable law.
5. Transfer of Data outside the European Economic Area (EEA)
As a rule, the Controller does not transfer personal data outside the European Economic Area (EEA). Where global analytics and marketing tools are used (e.g. Google Analytics, Meta Pixel), the transfer of data to entities in the United States is based on appropriate legal safeguards.
- An implementing decision of the European Commission establishing an adequate level of protection under the EU-US Data Privacy Framework, or
- Standard Contractual Clauses (SCC) adopted by the European Commission, ensuring a high standard of data security.
6. Rights of Data Subjects
Persons whose data are processed by EMOR sp. z o.o. have the following rights guaranteed by the provisions of RODO.
| Right | Scope and description of the right |
|---|---|
| Right of access (Art. 15 RODO) | The right to obtain information as to whether data are being processed and to obtain a free copy of the data. |
| Right to rectification (Art. 16 RODO) | The right to request the prompt correction of inaccurate data or the completion of incomplete data. |
| Right to erasure (Art. 17 RODO) | The right to request the permanent erasure of data (the "right to be forgotten"), unless legal exceptions apply. |
| Right to restriction of processing (Art. 18 RODO) | The right to request that processing be restricted to storage of the data only, in specified circumstances. |
| Right to data portability (Art. 20 RODO) | The right to receive the data in a structured, commonly used format (e.g. CSV, XML, JSON). |
| Right to object (Art. 21 RODO) | The right to object to processing of data based on the legitimate interest of the Controller. |
| Right to withdraw consent | The option to withdraw consent at any time without affecting the lawfulness of processing carried out before its withdrawal. |
To exercise the above rights, please send a request by e-mail to biuro@emor.com.pl.
If you consider that the processing infringes the provisions of RODO, you also have the right to lodge a complaint with the supervisory authority, the Prezes Urzędu Ochrony Danych Osobowych (PUODO, President of the Personal Data Protection Office), ul. Stawki 2, 00-193 Warszawa, helpline 606-950-000.
7. Cookies and Tracking Technologies
The emor.com.pl website uses cookies, which are small text files stored in the memory of the user's terminal device. Cookies are used for the following purposes.
- Necessary (technical). Enabling the website, sessions and secure form submission to function properly.
- Analytical and statistical. Used to study aggregated and anonymous user behaviour, optimise the structure of the website and analyse traffic sources.
- Marketing. Enabling advertising content and promotional messages in advertising systems to be tailored to the interests of recipients.
The user may change their preferences at any time via the consent bar (Cookie Banner) on the website or change the privacy settings in their web browser, blocking or deleting stored cookies.
8. Information on the Requirement to Provide Data and on Profiling
Providing personal data for recruitment purposes to the extent required by Art. 22¹ of the Kodeks pracy (Polish Labour Code) is a necessary condition for taking part in the recruitment process. Providing data beyond that scope and consenting to future recruitment processes are entirely voluntary.
Providing data in contact forms and commercial enquiries is voluntary, but necessary to receive a reply or to have an offer prepared.
Personal data are not subject to automated decision-making producing legal effects concerning data subjects, including profiling within the meaning of Art. 22 RODO.
9. Personal Data Security Measures
The Controller applies appropriate technical and organisational measures to ensure the security of the personal data processed, including encryption of connections using an SSL/TLS certificate, access control, regular backups and procedures protecting against unauthorised access, loss or destruction of information.
10. Final Provisions
The Controller reserves the right to amend this Privacy Policy in the event of changes in legislation, technological developments or an expansion of the services offered. The current version of the document is published and permanently available on the emor.com.pl website.