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Privacy Policy

This policy includes information on personal data processing in the Objectivity Group.

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Find a process for which you have provided us with your data and learn how we process it.
In the event of inconsistencies between this Privacy Notice and the clauses provided to you in connection with a relevant process, the provided clause shall prevail.

 

The Objectivity Group consists of:

  • Objectivity Bespoke Software Specialists sp. z o.o. with its registered office in Wrocław at ul. 142a,
  • Objectivity IT Solutions sp. z o.o. (entered in the Register of Employment Agencies, number 13900 with its registered office in Wrocław at ul. Strzegomska 142a,
  • Objectivity Ltd. with its registered office in Coventry, 9 Westwood House, Westwood Business Park Coventry, CV4 8HS, United Kingdom and
  • Objectivity GmbH with its registered office in Frankfurt am Main, 75 Neue Mainzer Str, 60311 Frankfurt, Germany.

 

Table of contents

  1. Recruitment process
  2. Client and its staff
  3. Supplier
  4. Events
  5. Handling requests
  6. Contact form on our website
  7. Fanpage

01

Recruitment process

Data controller/Objectivity Group: The Joint Controllers of your personal data are i) Objectivity sp. z o.o. and 2) Objectivity IT Solutions sp. z o.o. (entered in the Register of Employment Agencies under a number 13900) both with their registered offices in Wrocław (54-429) at ul. Strzegomska 142a, and – if you apply for a position in the ordering, sales department or any executive position in any of the departments – 3) Objectivity Ltd. with its registered office in Coventry, 9 Westwood House, Westwood Business Park Coventry, CV4 8HS, in the United Kingdom, as well as 4) Objectivity GmbH with its registered office in Frankfurt am Main, 75 Neue Mainzer Str, 60311 Frankfurt, Germany. 

Additional information: In the Objectivity Group we use a group-wide HR base, since a particular recruitment does not have to necessarily be related to employment in a pre-specified company. In addition, the people in our parent company (Objectivity Ltd.) may participate in the candidate’s evaluation for key positions in other Group companies – therefore your data will be jointly controlled by more than one entity.

Data Protection Officer (DPO): In cases related to data processing, our may contact us at: dpo@objectivity.co.uk.

Purposes of processing and legal basis: Your data will be processed for purposes of recruitment for a specific position based on Article 6(1)(b) of General Data Protection Regulation – GDPR (to take steps at the request of the data subject prior to entering into a contract). The data will also be processed for purposes of facilitating the recruitment processes and tools based on Article 6(1)(f) (i.e. the legitimate interest of the Joint Controllers in the form of the development of tools used for recruitment process. If you also consent to your personal data processing with effect for the future, your data will be processed to conduct future recruitment based on Article 6(1)(a) (consent).

If we make contact with you, we may retain basic information on the recruitment process (e.g. the name of the position, date of contact/meeting and the reason for closing the recruitment process) to facilitate recruitment processes in the future. In this scope the personal data are processed on the basis of art. 6(1)(f) of the GDPR i.e. on the basis of our legitimate interest which is the retention of knowledge on the previous recruitment processes in order to maintain adequate quality of handling the candidates.

Recipients of the personal data: The personal data recipients are: individuals formally authorized to process personal data (engaged by the Joint controllers) and entities which process personal data on behalf of the Joint Controllers on the basis of appropriate data processing agreements, i.e. HRlink provider – Online Technologies with its seat in Szczecin, Poland and which other providers of IT services.

Transfers of data to third countries: Due to the use of Microsoft Azure cloud services, personal data may potentially be transferred to third countries (outside of the European Economic Area). We use limitation on storage locations to EEA only, but in extraordinary situation, e.g. the need of internal support in Microsoft, such transfer may take place. In such event the transfer is secured by Standard Contractual clauses (https://eur-lex.europa.eu/legal-content/PL/TXT/?uri=celex:32010D0087).

The term of processing: If you apply for a current position, the data is processed until the end of a recruitment process. If you consent to data processing so as to conduct future recruitment, the data will be processed until the consent is revoked, unless you use other, equivalent measure, e.g. you request the deletion of your data. Whereas, data processing for purposes of facilitating recruitment processes and tools based on Article 6(1)(f) takes place as long as there is an overriding and legitimate interest of the Joint controllers, unless (prior to that) you object to such data processing – pursuant to your GDPR right.

We process basic information on the recruitment process (e.g. the name of the position, date of contact/meeting and the reason for closing the recruitment process) for the period of 3 years after the end of the process.

Source of data: If you have been found via recruitment agency the source of your personal data is such agency.

Scope of data: If you have been found via recruitment agency the scope of your personal data is basically the same as the data you have shared with the agency – especially in your CV.

Your entitlements: You have the right of access to and rectification, obtaining a copy or erasure of personal data or the restriction of processing and the right to data portability, as well as the right to object to processing – in accordance with the provisions of General Data Protection Regulation (GDPR).

Consent withdrawal: Any consent for personal data processing is voluntary. If you consent to the processing of your personal data in future recruitment processes, you have the right to withdraw your consent at any time, but it will not affect the lawfulness of personal data processing before the withdrawal.

Complaint with a supervisory authority: You have the right to lodge a complaint with the data protection supervisory authority if you believe that the processing of your personal data infringes the provisions of GDPR.

Voluntariness: Providing any personal data is voluntary. However not providing it may obscure or make impossible continuing the recruitment process.

02

Client and its staff

Data controller: If you represent a potential client, the joint data controllers of your personal data are:

  • Objectivity Ltd. with its seat in Coventry, 9 Westwood House, Westwood Business Park Coventry, CV4 8HS, United Kingdom;
  • Objectivity GmbH with its registered office in Frankfurt am Main, 75 Neue Meinzer Str, 60311 Frankfurt, Germany;
  • Objectivity z o.o. and Objectivity IT Solutions sp. z o.o., both with its seat in Wrocław (54-429), 142a Strzegomska Str., Poland.

Notwithstanding the foregoing, if you represent an entity which has entered into such a contract, the data controller of your personal data is the Objectivity company with which the contract has been concluded.

Contact: In matters related to data processing, you may contact us at: dpo@objectivity.co.uk.

Purposes of processing: Your personal data might be processed for purposes related to:

  • contact purposes, e.g. responding to your requests and current correspondence;
  • our cooperation, e.g. the performance of our agreement;
  • securing financial documentation (information from invoices) as well as securing potential legal claims after our agreement expires;
  • if you are a representative of our Client or potential Client – marketing and promotion of our business towards the Client.

Legal basis for processing:

  • if you represent our Client, the legal basis for processing is Article 6(1)(f) GDPR, i.e.
    justified interest of the data controller which is (depending on the circumstances): performance of the contract, contact, accounting purposes, securing documentation for potential legal claims or defences and, potentially, marketing and promotion of our business;
  • if you represent our potential Client, the legal basis for processing is Article 6(1)(f) GDPR, i.e. justified interest of the data controller which is (depending on the circumstances) contact and, potentially, marketing and promotion of our business;
  • if you are a member of our Client’s team engaged in the performance of our agreement or a person cooperating with such a team, the legal basis for the processing of your personal data is Article 6(1)(f) GDPR, i.e. our legitimate interest in contact and securing documentation for potential legal claims or defences;

Recipients of the personal data: Recipients of personal data are: individuals formally authorized to process personal data (engaged by the Controller) and entities which process personal data on our behalf on the basis of appropriate data processing agreements which are our IT service providers.

Transfers of data to third countries: We do our best to limit personal data transfer outside of the European Economic Area (EEA). In particular, we limit storage locations to locations within the EEA only. Your personal data might be transferred outside of the EEA only as an exception. In such situations the transfer is secured by relevant transfer mechanisms, e.g. Standard Contractual Clauses approved by the European Commission (Standard Contractual Clauses (SCC) | European Commission (europa.eu)).

The term of processing:

  • If you represent or cooperate with our Client, we process your personal data until the expiry of the limitation period on claims relating to our agreement and claims related to accounting documents (e.g. invoices) issued in connection with our cooperation;
  • If you represent our potential Client we might process your personal data until we cease to have a legitimate interest in doing so or until you express an objection;
  • If you are a member of the Client’s team engaged in the performance of our agreement or a person cooperating with such a team, we may process your personal data throughout the duration of the agreement with the Client and until the expiry of the term of limitation of claims relating to our agreement and claims related to accounting documents (e.g. invoices) issued in connection with our cooperation;

Afterwards we might process your personal data if and as long as we have a legitimate interest to do so or until you express an objection.

Your entitlements: You have the right of access to and rectification, obtaining a copy or erasure of personal data or the restriction of processing and the right to data portability, as well as the right to object to processing – in accordance with the provisions of General Data Protection Regulation (GDPR).

Complaint: You have the right to lodge a complaint with the data protection supervisory authority if you believe that the processing of your personal data infringes the provisions of GDPR.

Obligation to provide data:  Providing personal data is voluntary but not providing personal data may make it more difficult or impossible to contact or to commence or continue cooperation with Objectivity.

Marketing opt-out: If you receive marketing content from us, please be informed that you can opt-out from our marketing activities at any time.

03

Supplier

Data controller: The data controller of your personal data is entity from Objectivity group which you or your company has contracted with:

  • Objectivity Ltd. with its seat in Coventry, 9 Westwood House, Westwood Business Park Coventry, CV4 8HS, United Kingdom;
  • Objectivity GmbH with its seat in Frankfurt am Main, Neue Mainzer Str. 75, 60311, Germany;
  • Objectivity sp. z o.o. with its seat in Wrocław, 142a Strzegomska Str., 54-429, Poland,
  • Objectivity IT Solutions with its seat in Wrocław, 142a Strzegomska Str., 54-429, Poland.

Contact: In matters related to data processing, you may contact us at: dpo@objectivity.co.uk.

Purposes of processing: Your personal data might be processed for purposes related to:

  • contact purposes, e.g. responding to your requests and current correspondence;
  • our cooperation, e.g. the performance of our agreement;
  • securing financial documentation (information from invoices) as well as securing potential legal claims after our agreement expires.

Legal basis for processing: If you are an individual or a sole trader the legal basis for processing is Article 6(1)(b) GDPR (performance of the contract) and – after termination of our agreement – Article 6(1)(f) GDPR, (our legitimate interest in contact and securing documentation necessary to pursue or defend potential legal claims). If you represent a supplier which is a legal entity, the legal basis for processing is Article 6(1)(f) GDPR – our legitimate interest which is (depending on the circumstances) performance of the contract, contact and securing documentation for the purpose of pursuing or defending against potential legal claims.

Recipients of the personal data: Recipients of personal data are: individuals formally authorized to process personal data (engaged by the Controller) and entities which process personal data on our behalf on the basis of appropriate data processing agreements which are our IT service providers.

Transfers of data to third countries: We do our best to limit personal data transfer outside of the European Economic Area (EEA). In particular, we limit storage locations to locations within the EEA only. Your personal data might be transferred outside of the EEA only as an exception. In such situations the transfer is secured by relevant transfer mechanisms, e.g. Standard Contractual Clauses approved by the European Commission (Standard Contractual Clauses (SCC) | European Commission (europa.eu)).

The term of processing: Your personal data will be processed until the expiry of the limitation period on claims relating to our agreement and claims related to accounting documents (e.g. invoices) issued in connection with our cooperation.

Your entitlements: You have the right of access to and rectification, obtaining a copy or erasure of personal data or the restriction of processing and the right to data portability, as well as the right to object to processing – in accordance with the provisions of General Data Protection Regulation (GDPR).

Complaint: You have the right to lodge a complaint with the data protection supervisory authority if you believe that the processing of your personal data infringes the provisions of GDPR.

Obligation to provide data: Providing personal data is voluntary but not providing personal data may make it more difficult or impossible to contact or to commence or continue cooperation with Objectivity.

04

Events

If you report that you wish to participate in an event, your personal data will be processed by Objectivity Bespoke Software Specialists sp. z o.o. with its registered office in Wrocław 54-429 at ul. Strzegomska 142 (“Objectivity”). If you register for an event via an external portal, please also read the privacy policies and notices available on such portals.

Data controller: Objectivity is the controller of your personal data.

Purpose and legal basis of the processing:  Your data will be processed on the basis of Article 6(1) (f) of the General Data Protection Regulation – “GDPR” (legitimate interest of the controller in the form of the organization of an event) to conduct the event. If, during an event, you have signed an additional statement, e.g. you have transferred your rights to materials produced during such an event under a separate agreement, your data may be processed for the duration of that agreement’s validity and the limitation period under Article 6(1) (b) of GDPR (performance of a contract) and Article 6 (1)(f) of GDPR (controller interest – exercise of legal claims), respectively.

Recipients of the personal data: Recipients of personal data are: individuals formally authorized to process personal data (engaged by the Controller) and entities which process personal data on our behalf on the basis of appropriate data processing agreements which are our IT service providers.

Transfers of data to third countries: We do our best to limit personal data transfer outside of the European Economic Area (EEA). In particular, we limit storage locations to locations within the EEA only. Your personal data might be transferred outside of the EEA only as an exception. In such situations the transfer is secured by relevant transfer mechanisms, e.g. Standard Contractual Clauses approved by the European Commission (Standard Contractual Clauses (SCC) | European Commission (europa.eu)).

Duration of processing: Your data will be processed until the end of the event, following the event for the period necessary to settle claims related to
the event and secure accounting documents, if any (as a rule 5 years from the end of a financial year). If, during an event, you have signed an additional statement, e.g. you have transferred your rights to materials produced during such an event under a separate agreement, your data will be processed until such rights or claims related to their transfer, management and use expire.

Your entitlements: You have the right to access, rectify, obtain a copy of, erase, and restrict the processing of your personal data and the right to data portability, as well as the right to object to processing – in accordance with the provisions of the General Data Protection Regulation (GDPR).

Consent withdrawal: If you give your consent, you have the right to withdraw it at any time, but such withdrawal of consent shall not affect the lawfulness of personal data processing before its withdrawal.

Complaint with a supervisory authority: You have the right to lodge a complaint with the data protection supervisory authority if you believe that the processing of your personal data infringes the provisions of GDPR.

Freedom to provide data and consent: Providing personal data is voluntary but not providing personal data may make it more difficult or impossible to participate in an event.

05

Handling requests

Data controller: The controller of your personal data is:

  • Objectivity Bespoke Software Specialists sp. z o.o. with its registered office in Wrocław 54-429 at ul. Strzegomska 142a (OBSS),
  • Objectivity IT Solutions sp. z o.o. with its registered office in Wrocław 54-429 at ul. Strzegomska 142a (OITS) and/or
  • Objectivity Ltd. with its registered office in Coventry, 9 Westwood House, Westwood Business Park Coventry, CV4 8HS, in the United Kingdom (OLTD),
  • Objectivity GmbH with its registered office in Frankfurt am Main, 75 Neue Meinzer Str, 60311 Frankfurt, Germany,

Depending on the reason for your contact. The data controller is the company of whose status as a data controller you have already been informed (e.g. if you worked in OBSS and you contact us with respect to the processing of your personal data in connection with your employment – you have already received information that your data controller is OBSS).

Contact: In matters related to data processing, you may contact our data protection officer at: dpo@objectivity.co.uk.

Purposes and duration of processing and legal basis: Your data is processed to handle your request and after it is closed for the limitation period to de- fend against any claims. The legal basis of processing is Article 6(1)(f) of GDPR – legitimate interest of the data controller in the form of handling requests and defence against claims.

Recipients of personal data: Recipients of personal data are: individuals formally authorized to process personal data (engaged by the Controller) and entities which process personal data on our behalf on the basis of appropriate data processing agreements which are our IT service providers.

Transfers of data to third countries: We do our best to limit personal data transfer outside of the European Economic Area (EEA). In particular, we limit storage locations to locations within the EEA only. Your personal data might be transferred outside of the EEA only as an exception. In such situations the transfer is secured by relevant transfer mechanisms, e.g. Standard Contractual Clauses approved by the European Commission (Standard Contractual Clauses (SCC) | European Commission (europa.eu)).

Your entitlements: You have the right to access, rectify, obtain a copy of, erase, and restrict the processing of your personal data and the right to data portability, as well as the right to object to processing in accordance with the provisions of the General Data Protection Regulation (GDPR).

Complaint with a supervisory authority: You have the right to lodge a complaint with the data protection supervisory authority if you believe that the processing of your personal data infringes the provisions of GDPR

Obligation to provide data: Providing personal data is voluntary but not providing personal data may make it more difficult or impossible to handle your request. For example, if you decide not to provide your email address, we will not be able to write to you.

06

Contact form on our website

This information applies if you contact us via the formula on our website. However, if your contact is connected with one of the issues mentioned in other sections, please refer to the appropriate section for more precise information which will apply from the moment we determine the actual purpose of your correspondence.

Data controller: Joint data controllers of your personal data are:

  • Objectivity Bespoke Software Specialists sp. z o.o. with its registered office in Wrocław 54-429 at ul. Strzegomska 142a (OBSS),
  • Objectivity IT Solutions sp. z o.o. with its registered office in Wrocław 54-429 at ul. Strzegomska 142a (OITS) and
  • Objectivity Ltd. with its registered office in Coventry, 9 Westwood House, Westwood Business Park Coventry, CV4 8HS, in the United Kingdom (OLTD),
  • Objectivity GmbH with its registered office in Frankfurt am Main, 75 Neue Meinzer Str, 60311 Frankfurt, Germany.

Contact: In cases related to data processing, our may contact our data protection officer at: dpo@objectivity.co.uk.

Purposes and duration of processing and legal basis: Your data is processed to handle your request or inquiry. After the correspondence is finished, your data might be processed to pursue or defend against any claims for the limitation period applicable to them. The legal basis of processing is Article 6(1) (f) GDPR – our legitimate interest which is handling requests and inquiries and pursuing or defending against claims.

Recipients of personal data: Recipients of personal data are: individuals formally authorized to process personal data (engaged by the Controller) and entities which process personal data on our behalf on the basis of appropriate data processing agreements which are our IT service providers.

Transfers of data to third countries: We do our best to limit personal data transfer outside of the European Economic Area (EEA). In particular, we limit storage locations to locations within the EEA only. Your personal data might be transferred outside of the EEA only as an exception. In such situations the transfer is secured by relevant transfer mechanisms, e.g. Standard Contractual Clauses approved by the European Commission (Standard Contractual Clauses (SCC) | European Commission (europa.eu)).

Your entitlements: You have the right to access, rectify, obtain a copy of, erase, and restrict the processing of your personal data and the right to data portability, as well as the right to object to processing – in accordance with the provisions of the General Data Protection Regulation (GDPR).

Complaint with a supervisory authority: You have the right to lodge a complaint with the data protection supervisory authority if you believe that the processing of your personal data infringes the provisions of GDPR.

Obligation to provide data: Providing personal data is voluntary but not providing personal data may make it more difficult or impossible to handle your request or inquiry. For example, if you decide not to provide your email address, we will not be able to write back to you.

07

Fanpage

Data controller: The Joint Controllers of your personal data are Objectivity Bespoke Software Specialists sp. z o.o. and Objectivity IT Solutions sp. z o.o., both with their registered offices in Wrocław (54-429) at ul. Strzegomska 142a, Objectivity Ltd. with its registered office in Coventry, 9 Westwood House, Westwood Business Park Coventry, CV4 8HS, United Kingdom, as well as Objectivity GmbH with its registered seat at Neue Mainzer Str. 75, 60311 Frankfurt am Main, Germany. You should also know that if you leave personal data at any www portal, its owner may become a separate data controller.

Purposes and legal basis of the processing: Your data will be processed in order to maintain the website/fanpage or for other purposes compliant with the way you use such website/fanpage (e.g. contact purposes if you send us a question), as well as to secure legal claims. The legal basis of the processing is Article 6(1) (f) of the General Data Protection Regulation – “GDPR”, i.e. legitimate interest of the controller being maintaining the website/fanpage, contact (if applicable) or securing legal claims.

Data recipients: Recipients of personal data are individuals formally authorized to process personal data (engaged by the Joint Controllers on the basis of employment contract or other contract) and entities which process personal data on our behalf on the basis of appropriate data processing agreement – in particular our IT services providers and the entities which maintain the portal you use. Other recipients are the entities which receive data from the portal owner. For more details please refer to the privacy policy of the appropriate portal (e.g. Facebook, LinkedIn, YouTube, Dribble, Twitter, Instagram, Meetup, etc.).

Transfers of data to third countries: Your personal data will be processed by Objectivity only within the European Economic Area (EEA). If Great Britain exits the EU, the transfer to Objectivity Ltd. will be secured by an agreement based on Model Contractual Clauses approved by the European Commission (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32004D0915). The foregoing does not exclude transfer of your personal data outside of the EEA if it follows form the terms of the portal you use.

Duration of processing: Personal data left of the portal are usually processed for as long as there is a legitimate interest on Objectivity’s side and as long as allowed by retention policy of the respective portal where our website/fanpage is maintained (for more information please check the privacy policy of the respective portal). Most of the time the portal will provide you with mechanisms which enable the user to manage the previously introduced content or reaction (e.g. adding and deleting “likes” or comments).

If you leave your data for contact purposes, it will be processed as long as the correspondence lasts. Afterwards your data may be processed throughout the period of limitation of claims, if justified by the significance and the purpose of the correspondence.

Your entitlements: You have the right to access, rectify, obtain a copy of, erase, and restrict the processing of your personal data and the right to data portability, as well as the right to object to processing – in accordance with the provisions of the General Data Protection Regulation (GDPR).

Contact: In matters related to personal data processing you may contact us at: dpo@objectivity.co.uk.

Complaint with a supervisory authority: You have the right to lodge a complaint with the data protection supervisory authority if you believe that the processing of your personal data infringes the provisions of GDPR.

Freedom to provide data: Any personal data is provided voluntarily.

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