Personal data protection

Privacy Policy of Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ)

1. Introductory Provisions

Thank you for visiting our website. We place great importance on protecting your personal data and therefore we would like to disclose the following information concerning the processing of your personal data when visiting our website and when using our services.

Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) publishes this document, which includes the basic principles of personal data processing when visiting and providing services via the websites www.profesia.sk, www.profesia.cz ,www.edujobs.sk, www.tulu.cz, www.tulu.sk, www.platy.sk,www.platy.cz(hereinafter referred to as the "Website").

Please read the contents of this Personal Data Processing Policy (hereinafter referred to as “Policy”) carefully. The Policy is always available on the Website, where it may be viewed, or downloaded and saved on your device at any time.

Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to the personal data processing and on the free movement of such data, repealing Directive 95/46/EC on the protection of personal data (hereinafter referred to as the “GDPR”).

Any legislative changes or changes in our internal processes may result in changes to this Policy, and therefore Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) reserves the right to amend the contents of the Policy.

2. Personal Data Controller

Personal Data Controller consists of joint controllers:

Profesia, spol. s r.o., with registered office at Pribinova 19, 811 09 Bratislava, Slovak Republic, CRN: 35800861;

LMC s.r.o., Menclova 2538/2, Libeň, 180 00 Prague 8, Czech Republic, CRN: 264 41 381;

LMC (currently registered as NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ), with its registered office in Warsaw, address: BL Astoria, Przeskok 2, 00-032 Warsaw, the Republic of Poland, entered into the register of entrepreneurs maintained by the District Court for the capital city of Warsaw in Warsaw, XII Commercial Division of the National Registry Court under entry no. KRS 0000988078, NIP 5252920122, REGON: 522873400.

(hereinafter “Controller”)

3. Principles of Personal Data Processing and Security

Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) processes personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to the personal data processing and on the free movement of such data, repealing Directive 95/46/EC on the protection of personal data (hereinafter referred to as the “GDPR”).

The basic principles of processing your personal data are:

“Principle of legality, fairness and transparency" - We always process your personal data legally, fairly and transparently,

“Principle of limited use” - Your personal data is collected for specific, explicit and legitimate purposes and is not further processed in a way that is incompatible with the original purpose of such processing,

“Principle of accuracy” - We only process personal data which is correct and updated as needed,

“Principle of data minimisation” - We only process the specific personal data necessary to accomplish the purpose of its processing,

“Principle of retention minimisation” - We retain your personal data in a format that only permits your identification when necessary for the purposes for which the personal data is processed,

“Principle of integrity and confidentiality” - We process personal data in a way that guarantees reasonable protection of personal data, including protection against unauthorised or unlawful processing and accidental loss, destruction or damage, by employing appropriate technical or organisational measures.

4. Processing of Personal Data When Visiting the Website

Purpose and Scope of Personal Data Processing

We only record and use the personal data of Website visitors in the scope necessary to operate a functional Website and its content and services. This means that we only collect the personal data that your browser automatically transmits and temporarily retain this data in a log file. The following data is involved: The IP address of the requesting computer, the date and time of access, the name and URL of the downloaded file, the website from which it is accessed, the browser used and possibly the operating system of your computer, as well as the name of your Internet access provider.

General administration of the Website, providing a smooth connection to the Website, and facilitating convenient use of the Website are the purposes of processing such data.

Legal Basis

Article 6(1)(f) GDPR is the legal basis for personal data processing as the processing of the above data is necessary to operate the Website. Providing the personal data mentioned above for the purposes of processing is not a statutory or contractual requirement; however, it is impossible to visit our Website without such processing. A data subject is authorised to opt out of the processing of this data.

Retention Period

Personal data is processed for the period necessary to accomplish the purpose of its processing. A data subject’s personal data is deleted once the purpose is accomplished.

5. Processing of Personal Data When Visiting and Providing Services at www.profesia.skwww.profesia.cz

With respect to Alma Career’s processing of your personal data, please find the following information about the specific processes, scope and purposes of data processing, the legal basis for such processing and the relevant retention periods.

5.1. Contact Form

Purpose and Scope of Personal Data Processing

A Website visitor may decide to contact Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) using the online contact form. When using the contact form, it is necessary that you provide us with the following details: first name, last name, email address and the body of a message. Personal data in this case is processed to accomplish our mutual communication and to resolve your suggestion or complaint.

Legal Basis

Article 6(1)(a) GDPR is the legal basis for personal data processing, i.e. your express consent. Personal data processing is necessary to resolve your request and therefore we ask that you provide your express consent for such purpose. Providing the personal data mentioned above for this purpose is not a statutory or contractual requirement; however, it is impossible to respond to your request or suggestion without such processing. You can revoke your consent to the personal data processing at any time.

Retention Period

You can revoke your consent to the personal data processing at any time, otherwise Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) will process your personal data for a period of 3 years from its acquisition. Your personal data will be deleted upon expiry of this period.

5.2. Personal Data in the CV Database

Purpose and Scope of Personal Data Processing

Among the services we provide to job seekers is the ability to complete an online form on the Website or send in a printed form to the address of Alma Career’s registered office and in this way, create a CV and to disclose/provide it to Alma Career’s business partners using the CV database published on the Website.

The CV database is a shared database with the above-specified companies, who are its co-creators and who process personal data in the database as joint controllers. Cooperation among the controllers is stipulated in a written agreement concluded for an indefinite duration and defining the conditions for processing personal data among the controllers.

The joint controllers have agreed that:

- each of the controllers will serve as a contact point for the data subject; each of the controllers will publish information about their contact points on their websites,

- a data subject may exercise their rights under GDPR with each of the controllers and towards each of the controllers,

- each of the controllers shall fulfil the disclosure obligation contained in Article 13 GDPR,

- Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) shall perform the obligations and tasks related to rights exercised by data subjects.

The purpose of the processing of such personal data is to provide assistance to the data subject as a job seeker to find a suitable job opportunity. Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) is authorised to disclose/provide the personal data contained in a data subject’s CV to its business partner based on the consent of the data subject and for the purposes disclosed in the previous sentence.

In order to provide assistance in the search for a job, Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) is authorized to inform the data subject via SMS message or email about the fact that its business partner has expressed interest in the data subject's CV. A data subject is authorised to opt out of processing this data in such a way.

CVs stored in the CV database include: at least one contact information (email address or phone number), the highest level of completed education, specification of the job field and position they are interested in, identification of the location in which they are looking for a job, the type of employment sought and gender (for statistical processing purposes only). A job seeker alone decides what other data to provide in a CV.

Registration on the Website is required to create a CV in the CV database. Registration requires the use of a login email address and a password; registration may be cancelled at any time by sending an email to Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) in which you state your intent to cancel your registration.

Legal Basis

Your personal data may be processed in the CV database and provided to a business partner by the Controller specified above under Article 6(1)(a) GDPR, i.e. with the data subject’s consent.

Your personal data can also be processed in the CV database under Article (6)(f) GDPR, i.e. legitimate interest, for the purpose of providing information (via SMS message or email) that the Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) business partner has shown interest in your CV. Once you unsubscribe your phone number or email, we will no longer send you the electronic messages and will not process your personal data for such purposes.

Retention Period

Personal data contained in a data subject’s CV is disclosed/provided to our business partners via the Website for a period of 3 months from the date of your consent to such processing of this personal data. Once this period expires, your personal data provided in the CV will be retained if you decide to once again disclose/provide your CV to our business partners.

Data contained in the CV database shall be rendered permanently anonymous and shall only be used for statistical purposes after a period of 3 years has passed since your most recent login into your registered account on the Website. Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) is obliged to permanently delete personal data upon a written request from a data subject.

5.3. Personal Data in a Response to a Job Advert

Purpose and Scope of Personal Data Processing

A response to a job advert published on the Website includes: at least one contact information (email address or phone number), the highest level of completed education and gender (for statistical processing purposes only). It is at the sole discretion of the job seeker as to what additional details to provide in a response to a job advert.

The purpose of the processing of such personal data is to provide assistance to the data subject as a job seeker to find a suitable job opportunity. Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) therefore archives the responses sent by job seekers to job adverts posted on the Website and ensures they are sent (provided) to the business partner who published the job advert on the Website.

Legal Basis

Any data found in responses to job adverts published on the Website archived by Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) are considered personal data under GDPR. Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) may only process this personal data under Article 6(1)(a) GDPR, i.e. with the data subject’s consent.

Legal basis of Alma Career’s business partner

Alma Career’s business partner (who published the job advert) is only authorised to process the personal data of a job seeker on a legal basis under GDPR and for the purposes of finding a suitable employee, while it is at the sole discretion of Alma Career’s business partner to decide on the legal basis for the personal data processing. One such example is in a situation when processing is required to fulfil an agreement in which the job seeker is a contracting party. Via the Website, a job seeker sends their CV along with attachments to Alma Career’s business partner who published the job advert. They may also grant consent to this business partner via the Website to process their personal data for inclusion in any future hiring processes, or in the given business partner’s database of job seekers. It is at the sole and voluntary discretion of the job seeker to provide consent to such personal data processing by the business partner.

Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) does not obtain personal data under the authorisation from the business partner. Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) obtains personal data and then provides it to the business partner based on the job seeker’s express consent. When publishing a job advert, Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) and the business partner who publishes such job advert function as independent personal data controllers and, as such, they work independently and on their own behalf after receiving such personal data. This has no prejudice towards the right of a job seeker as a data subject to exercise their rights under GDPR with each controller and towards each controller.

Retention Period

In order to use this service, a registration on the Website is required. Registration requires the use of a login email address and a password; registration may be cancelled at any time by sending an email to Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) in which you state your intent to cancel your registration. Consent to the personal data processing is given to Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) for a fixed period of time, i.e. three years from the last login to the job seeker's registration created on the Website. After a period of three years, personal data will be rendered anonymous and used for statistical purposes only. A job seeker has access to their responses to job adverts on the Website (to view, reuse, resend, etc.) during this period. The period of three years is considered the time in which no significant changes are expected with respect to the job seeker’s qualifications. The three-year period was determined on the basis of HR-specific knowledge and expertise. A job seeker may revoke consent to personal data processing at any time during the above-specified three-year period.

5.4. Sending Matching Job Adverts via Email

Purpose and Scope of Personal Data Processing

Among the Services provided to job seekers is also the possibility to create an ‘agent’ via the Website for sending job offers by email. The agent allows the job seeker to define specific search criteria for job adverts published by Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) business partners. The job adverts are then sent to the job seeker’s provided email address.

Legal Basis

Given that an email address may be considered personal data under GDPR, the data subject must provide consent under Article 6(1)(a) GDPR to their personal data processing prior to activating the agent service; personal data processing in the scope of the email address is a technical necessity for providing this service.

Registration on the Website is required to create an agent (for technical reasons). Registration on the Website requires the use of a login email address and a password; registration may be cancelled at any time by sending an email to Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) in which you state your intent to cancel your registration.

Retention Period

5.5. Recommending a Job Advert to a Friend

Purpose and Scope of Personal Data Processing

Job seekers may recommend a job advert published on the Website to another person directly via the Website. These job adverts are then sent with editable message content from the job seeker and identification of the email address of the job seeker who sent the link to the given job advert.

Legal Basis

Given that an email address may be considered personal data under GDPR, the data subject must give consent under Article 6(1)(a) GDPR to the processing of their personal data prior to sending their recommendation.

Registration on the Website is required to recommend a job advert to a friend (for technical reasons). Registration requires the use of a login email address and a password; registration may be cancelled at any time by sending an email to Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) in which you state your intent to cancel your registration.

Retention Period

5.6. Communicating in Job Forums

Purpose and Scope of Personal Data Processing

Job seekers have the ability to communicate with other job seekers in the job forums via the Website. This opportunity is only accessible by registering an account on the Website (for technical reasons). The data subject’s email address is used to register an account on the Website.

Legal Basis

Given that an email address may be considered personal data under GDPR, the data subject must provide consent under Article 6(1)(a) GDPR to the processing of their personal data prior to their registration. Personal data processing of an email address is a technical necessity for communicating in job forums.

Retention Period

5.7. Requesting References via the Website

Purpose and Scope of Personal Data Processing

Job seekers may request a reference from a former employer via the Website. This opportunity is only accessible by registering an account on the Website (for technical reasons). The data subject’s email address is used to register an account on the Website.

Legal Basis

Given that an email address may be considered personal data under GDPR, the data subject must provide consent under Article 6(1)(a) GDPR to the processing of their personal data prior to registration. Personal data processing of an email address is a technical necessity for sending a request for a reference.

Retention Period

Consent is given for a fixed period of 3 years from the last login to the job seeker's account created on the Website, but consent can be revoked at any time.

5.8. Registration on the Website

Purpose and Scope of Personal Data Processing

Job seekers are required to register on the Website to use certain services. A job seeker may use any login email and password to register. Registration allows job seekers to communicate in the job forum, ask for a reference, recommend an offer to a friend, send suitable job offers by email, respond to a job offer, create and publish a CV on the Website.

Legal Basis

Retention Period

Consent to personal data processing can be revoked at any time, otherwise the consent will expire after 3 years from the last login to the job seeker's account created on the Website. Consent can be revoked at any time.

6. Processing of Personal Data When Visiting and Providing Services at www.edujobs.sk

6.1. Contact Form

Purpose and Scope of Personal Data Processing

A Website visitor may decide to contact Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) using the online contact form. When using the contact form, it is necessary that you provide us with the following details: first name, last name, email address and the body of a message. In this case, personal data is processed to ensure our mutual communication and to resolve your suggestions or complaints.

Legal Basis

Retention Period

You can revoke your consent to personal data processing at any time, otherwise Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) will process your personal data for a period of 3 years from its acquisition. Your personal data will be deleted upon expiry of this period.

6.2. Personal Data in a Response to a Job Advert

Purpose and Scope of Personal Data Processing

Among its services, Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) makes it possible to publish job adverts on the Website; these job adverts are published by the business partners of Alma Career. Job seekers are permitted to respond to these job adverts. The response to the published job advert on the Website includes: name and surname, at least one contact information (email or telephone), attached CV, or other documents. It is at the sole discretion of the job seeker as to what additional details to provide in a response to a job advert. The purpose of the processing of such personal data is to provide assistance to the data subject as a job seeker to find a suitable job opportunity. Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) therefore archives the responses sent by job seekers to job adverts posted on the Website and ensures they are sent (provided) to the business partner who published the job advert on the Website.

Legal Basis

Legal basis of Alma Career’s business partner.

Alma Career’s business partner (who published the job advert) is only authorised to process the personal data of a job seeker on a legal basis under GDPR and for the purposes of finding a suitable employee. One such example is in a situation when processing is required to fulfil an agreement in which the job seeker is a contracting party. Via the Website, a job seeker sends their CV along with attachments to Alma Career’s business partner who published the job advert. They may also grant consent to this business partner via the Website to process their personal data for inclusion in any future hiring processes, or in the given business partner’s database of job seekers. It is at the sole and voluntary discretion of the job seeker to provide consent to such personal data processing by the business partner. Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) does not obtain personal data under the authorisation from the business partner. Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) obtains personal data and then provides it to the business partner based on the job seeker’s express consent. When a job advert is published, both Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) and the business partner who published the job advert have the status of independent personal data controller. After obtaining personal data, Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) and the client act towards the job seeker separately and in their own name, unless the client has created an account on the Website. Within the account, Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) processes personal data on behalf of the client as a personal data intermediary. This has no prejudice towards the right of a job seeker as a data subject to exercise their rights under GDPR with each controller and towards each controller.

Retention Period

Consent to the personal data processing is given to Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) for a fixed period of 3

months. After the 3-month period, the personal data will be rendered anonymous and further used exclusively for statistical purposes. A job seeker may revoke consent to personal data processing at any time during the above-specified three-year period.

6.3. Sending Matching Job Adverts via Email

Purpose and Scope of Personal Data Processing

Legal Basis

Given that an email address may be considered personal data under GDPR, the data subject must give consent under Article 6(1)(a) GDPR to their personal data processing prior to activating the agent service; personal data processing in the scope of the email address is a technical necessity for providing this service. Registration on the Website is required to create the agent (for technical reasons). Registration on the Website requires the use of a login email address and a password; registration may be cancelled at any time by sending an email to Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) in which you state your intent to cancel your registration.

Retention Period

Consent to personal data processing is granted for a fixed period of 3 years, but consent may be revoked at any time.

7. Personal Data Processing When Visiting and Providing Services at www.tulu.cz, www.tulu.sk

7.1 Personal Data Processing When Providing Services During the Use of the Tulu Online Tool

When using the tulu online tool, personal data obtained by the client may be processed, therefore the client is a personal data controller who, through the contract, has entrusted Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) with personal data processing as an intermediary. The client is obliged to inform the data subjects about this.

The purpose of processing personal data is to fulfil the rights and obligations of the personal data controller towards the data subjects.

The intermediary shall process the personal data obtained from the client.

The intermediary shall comply with the generally binding legislation concerning personal data protection when processing personal data. The intermediary shall process the client’s personal data exclusively in the form stipulated herein and in accordance with the client’s individual documented instructions.

More information about the agreement on the personal data processing concluded between the client and Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) can be found in the General Trade Conditions of Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ)SK published at www.tulu.sk.

7.2. DigiSign Service – Electronic Signing of Documents

When using the tulu online tool, clients are entitled to electronically sign documents under the General Trade Conditions of Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ)SK published at www.tulu.sk. When providing this service, personal data obtained by the client is processed. Legal basis for the personal data processing is the agreement on the personal data processing concluded between the client as the personal data controller and Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) as the intermediary of personal data. This service is provided by a subcontractor.

8. Personal Data Processing When Visiting and Providing Services at www.platy.sk, www.platy.cz

8.1. Providing Salary Analysis

Visitors of www.platy.sk, www.platy.cz can easily compare their salaries or order a salary analysis, taking into account the job position and region specified in a short online form.

What personal data do we request from you and why do we process it?

In order to handle your order properly and to provide good services, we need to know the data subject’s email address, as our services are rendered through electronic communication.

Personal data collected for the purposes of fulfilling the contract are kept until the expiry of legal deadlines (e.g. according to tax regulations).

If you have chosen a payment card or an online payment gateway as a payment method, after completing the order we will redirect you to the relevant payment service provider. After entering the access data, you can make a payment through this service provider. In order to process the payment, we transfer information about the amount of the payment to the selected payment service provider. Further information on data processing carried out by payment service providers can be found in the information texts.

8.2. Quarterly Report of Current Salary Comparison

Visitors of www.platy.sk, www.platy.cz can also enter their email address when completing the form. Since under the Regulation and the Act an email address may be considered personal data, it is essential that the data subject gives consent to personal data processing (Under Article 6 GDPR) before submitting their email.

The email address of the data subject serves as the address for quarterly delivery of the salary comparisons processed by the controller. The consent can be revoked at any time, otherwise the consent will expire after 1 year from the date of its issue, and the data in the scope of the email address will be deleted.

8.3. Long-term Monitoring of the Developments in the Respondent's Salary

Visitors of www.platy.sk , www.platy.cz can also enter their email address and salary when filling out the online form. Since under GDPR an email address may be considered personal data, it is essential that the data subject gives consent to personal data processing (Under Article 6 GDPR) before submitting their application.

The email address of the data subject serves as the address for the respondent’s long-term salary monitoring. Consent may be revoked at any time.

9. Personal Data of Employees of Alma Career's Business Partners

When using the services, business partners can provide and publish contact information for their employees in the following scope: first name, last name, email address, phone number and position. Such data is classified under GDPR as information that the controller – which in this case is the employer of the data subject – is authorised to provide to its contractor, if necessary, in the course of the performance of the data subject’s work-related duties or other functional responsibilities. Providing or publishing personal data may not interfere with the status, dignity and security of the data subject. This data will be processed for a maximum of 10 years from the delivery of the last order of the business partner; after this period the data will be permanently deleted.

10. Newsletter (Latest News)

Purpose and Scope of Personal Data Processing

Visitors to the Website may subscribe to our newsletter. We plan to send the newsletter to individuals who have not specifically subscribed to the newsletter but whose email addresses we received directly from them in the process of providing our services. Personal data in this case is processed to keep Website visitors and our clients informed about the latest news related to our services. We process the following data for subscribing and sending our newsletter: email address.

Legal Basis

Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) has a legitimate interest under Article 6(1)(f) GDPR to process your personal data for the purposes of distributing the newsletter. Providing the above personal data for this purpose is not a statutory or contractual requirement; however, it is impossible to send you the newsletter without such processing.

Article 6(1)(a) GDPR is the legal basis for personal data processing if you have subscribed to the newsletter, i.e. your express consent.

You may opt to unsubscribe from the newsletter at any time. Unsubscribing from the newsletter is considered opting out of the processing of your personal data, which is your right under Article 21(1) and (2) GDPR.

Once you unsubscribe from the newsletter, we will no longer send you the electronic newsletter and will not process your personal data for such purposes.

Retention Period

We will retain your personal data for the purposes of your subscription and distribution of the newsletter for the duration of such time that you subscribe to the newsletter, or for a period of 3 years from the date on which you provide consent.

11. Subcontractors

Google Ireland Limited, and specifically the Google Cloud Platform service as defined in the Google Cloud Platform Terms of Service published online at: https://cloud.google.com/terms/;

Hotjar Limited, C 65490, Level 2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta;

Functional Software Inc. (Sentry) 132 Hawthorne Street, San Francisco, California 94107, USA, through an agreement concluded in accordance with the decision of the European Commission of 7 June 2021 on standard contractual clauses for the transfer of personal data to processors established in third countries under Directive 95/46/EC of the European Parliament and of the Council, due to the judgment of the EU Court of Justice of 16 July 2020 in Case C 311/18.

Mailjet SAS, 13 - 13 bis Rue de I’Aubrac, 75012 Paris, France.

Quality Unit, s.r.o., Vajnorská 100/A, Bratislava, Slovakia

TOPefekt s.r.o, registered office at B. Němcové 767/13, 787 01 Šumperk, Czech Republic

Digital Solutions s.r.o., CRN: 25998706, with registered office at 17. listopadu 203, Zelené Předměstí, 530 02 Pardubice, Czech Republic

Via Mobile, s.r.o., Mateja Bela 7, 811 06 Bratislava, Slovak Republic

Amazon Web Services EMEA SARL (Cloud services), 38 avenue John F. Kennedy, L-1855 Luxembourg

12. Cookies

Scope and Purpose of Processing

Cookies are small data files that are downloaded onto a device (PC, tablet, mobile phone, etc.) while on the Website. The Controller uses cookies to examine the effectiveness of the Website. Cookies generally do not contain any information intended to identify individual persons, but instead are used to identify the browser on a specific device. Cookies may be temporary or permanent, which remain on the device – even after closing the browser – for the time specified in the cookies.

These permanent cookies can be checked every time the Website is visited. The information we collect via the Website includes: the browser type, the web address from which the Website was visited, the device operating system, and the IP address of the device. To display more relevant ads, some cookies are set up by a third-party advertising system, such as Google Ad sense. This may be disabled in a Google account. A computer may be set to refuse cookies, although in this case it is possible that some website functions will not work.

We use permanent cookies for better user orientation and individualised presentation of services. We also use the so-called temporary cookies (session cookies), which are automatically deleted after closing the browser. You can set your browser to inform you about the use of cookies. This will ensure the transparency of the use of cookies. Important: if you completely exclude the use of cookies, you may not be able to use certain features of our Website. We use the following five categories of cookies on our Website: necessary cookies, performance cookies, functionality/personalisation cookies, transient cookies, and targeting cookies.

Necessary cookies: are required for visitors to be able to navigate the Website and use its functions. Without these cookies we cannot provide you with certain services or Website features. These cookies are used to identify registered users.

Performance cookies: these cookies collect information about how visitors use the Website. These cookies do not collect any data that can be used to identify visitors. All information collected through these cookies is anonymous.

Functionality/personalisation cookies: these cookies allow you to remember previous information about the visitor (such as username, language or selected market) to offer optimised functions tailored to the visitor's needs. These cookies do not collect information that can be used for advertising purposes and cannot track where you have been on the Internet outside of our Website.

Functional/personalised cookies: are used to recognise visitors to the Website. The Website uses temporary cookies, which are automatically deleted when the browser is closed. This type of cookie allows us to store your session ID, which allows you to assign various browser requests to a common session and allow us to recognise your terminal device during further visits to the Website.

Targeting cookies: these cookies are used to tailor advertising to you and your interests even more specifically; they are placed on the websites of advertising networks with the consent of the Controller’s Website. They recognise that the user has visited the Website and this information is then provided to another entity, e.g. advertising companies.

Marketing cookies are used to track the preferences of the Website user for the purpose of targeting advertising, i.e. the display of marketing and advertising notifications (including on third-party sites) in accordance with these preferences.

Legal Basis

In light of the above, we would like to inform you that personal data processing using cookies according to Article 6(1)(f) GDPR is carried out on the basis of the legitimate interest of Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ)(necessary cookies) or Article 6(1)(a) GDPR, so-called express consent of the data subject (especially targeted cookies, marketing cookies, cookies recording activity and personalised cookies).

It is at the discretion of a Website visitor to reject cookies. You can delete cookies or pre-set your internet browser so that it either refuses to accept cookies or notifies you when the server tries to send you cookies.

If you provide consent to the use of cookies based on a reference (‘cookie banner’) on the Website, the legal basis for the personal data processing for the affected cookies is your consent under Article 6(1)(a) GDPR.

Retention Period

Data transmitted by cookies is only processed for the time necessary to achieve the purpose described above. Cookies are deleted as soon as the data transmitted by them is no longer needed.

13. Plug-ins

Our Website contains social network plug-ins:

‘Facebook’ (Facebook Inc., located at 1601 S. California Ave., Palo Alto, California 94304, USA), More information: https://en-gb.facebook.com/policy.php

‘YouTube’ (YouTube LLC, located at 901 Cherry Ave., San Bruno, CA 94066, USA), More information: https://policies.google.com/privacy?hl=en&gl=de

‘LinkedIn’ (LinkedIn Corporation, 2029 Stierlin Ct, Mountain View, CA 94043, USA). More information: https://www.linkedin.com/legal/privacy-policy?trk=uno-reg-guest-home-privacy-policy

These services are provided by their relevant companies (‘providers’). Based on the data transmitted by the relevant services via social plug-ins, the service is able to log you into your account, if it is necessary. After logging in to one of the provider's social networks, the operator can immediately assign a visit to this Website to your profile.

If you work with social media plug-ins, the relevant information is also transferred directly to the providers’ servers and stored there. This information can also be published on a social network and displayed there under your contacts. To prevent such immediate association of data collected via our Website to your profile, you must log out of your relevant provider's account before visiting our Website. Information on the scope and purpose of data collection by the relevant service, as well as on further processing and such use of your data, can be found in the data protection and privacy information found directly on the website of the relevant provider's service.

14. Rights of data subjects

Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) will take appropriate measures to provide the data subject with all the information referred to in Articles 13 and 14 GDPR and all communications under Articles 15 to 22 and Article 34 GDPR that relate to the processing, in a concise, transparent, comprehensible, and easily accessible form, formulated clearly and simply, especially in the case of information intended specifically for children. Information shall be provided in writing or by other means, including electronic means where appropriate. If the data subject so requests, information may be provided verbally, as long as the identity of the data subject has been proven in another way.

The data subject has the right to obtain confirmation from the Controller if their personal data has been processed and, if so, they have the right to access this personal data and the following information:

- the purposes of the processing;

- the categories of the personal data concerned;

- the recipients or categories of recipients to whom the personal data has been or will be provided, particularly recipients in third countries or international organisations;

- where possible, the foreseeable period of retention of the personal data or – if that is not possible – the criteria for its determination;

- the existence of the right to require the controller to correct personal data relating to the data subject, or to delete or restrict the processing thereof, or to object to such processing;

- the right to file a complaint with the supervisory authority;

- where personal data has not been obtained from the data subject, any available information as to the source of such data;

- the existence of automated decision making, including profiling.

A data subject has the right to have the personal data controller correct any incorrect personal data relating to them without undue delay. With regard to the purposes of the processing, a data subject has the right to complete partial personal data, including doing so in the form of a supplementary statement.

A data subject is entitled to request that Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) delete their personal data. All consents to the processing of personal data provided to Profesia, spol. s r.o., LMC s.r.o., LMC (CURRENTLY REGISTERED AS NEIRONE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ) are revocable. Please send your request to the email address: [email protected]

The supervisory authority is the Office for Personal Data Protection of the Slovak Republic. A data subject is entitled to file a complaint with the supervisory authority.

This Personal Data Processing Policy comes into force on 01.01.2023