Privacy policy

     I)          GENERAL INFORMATION

At 313C, we provide recruitment services that combine the best psychometric practices with the unique Candidate Experience, providing our clients with HRTech recruitment solutions in the form of competency games. The result of these activities are intelligent online tools that allow to examine the competences and development potential of Candidates, and thus enable fair, accurate and significant recruitment processes from the Candidate’s perspective. Using many years of experience, we support our clients by providing additional services supporting the recruitment and selection of Candidates. All these services require data processing. We attach the highest importance to the security and quality of processing personal data that we are the Controller, as well as those that have been entrusted to us. We strictly follow our own procedures and the guidelines of other Controllers, while imposing the same rigor on our suppliers. We make every effort to maintain the protection of personal data and privacy, as well as the fulfillment of the information obligation in accordance with Article 13 (1) and (2) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.

   II)          PURPOSE OF THIS DOCUMENT

We want to properly inform our Clients, Candidates and Users of 313C services about the scope of personal data processing. In this document, we explain on how we take care of your personal data, how we collect it and on what legal grounds it is processed. We would also like to inform you about the applicable rights as well as security and entities that process personal data on the basis of separate agreements. This Privacy Policy applies to all services that contain reference to it.

 III)          DEFINITIONS

CONTROLLER  means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

DATA PROTECTION OFFICER (DPO) means a person appointed by CONTROLLER that supports it in the implementation all personal data protection obligation.

CANDIDATE means a natural person participating in the recruitment process to 313C or to the Client for whom 313C provides recruitment services.

ONLINE RECRUITMENT GAME (named also SELECTION GAME or COMPETENCY GAME) means a tool made available by 313C on the recruitment platform that enables Users to complete a competency test. Alternatively, it can also be called.

RECRUITMENT FORM means a type of questionnaire that is being used to collect selected data of Candidates during recruitment process.

CUSTOMER means a legal person or organizational unit for which 313C provides services.

CUSTOMER REPRESENTATIVE means a natural person who, for the needs of the client, contacts us in order to establish / conduct cooperation.

USER means a natural person using the 313C Recruitment platform. 

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

IV)          CONTROLLER

i) Responsible for the processing of personal data within the meaning of Art. 4 (7) GDPR is: 313C spółka z ograniczoną odpowiedzialnością with its registered office at 29 Smoleńsk Street, 31-112 Kraków.

ii) 313C is a specialized employment agency listed in the National Register of Employment Agencies under number 13070.

iii) Contact details of the Controller: biuro@313c.com.pl or under the postal address mentioned above. 

   V)          DATA PROTECTION OFFICER

i) Data protection policy at 313C Sp. z o. o. is supervised by the appointed Data Protection Officer.

ii) One of the most important Data Protection Officer’s tasks is to ensure that your rights are respected while your personal date is being processed by 313C.

iii) You can contact the Data Protection Officer via e-mail at: iod@313c.com.pl.

VI)          WHAT IS PERSONAL DATA AND WHOSE PERSONAL DATA WE DO PROCESS

i) Personal data is any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to a given identifier.

ii) At 313C, we process personal data of our websites’ visitors, Candidates, Clients and their representatives, potential Clients and their representatives and Users.

VII)          YOUR RIGHTS AND CHOICES

i) We kindly inform about your right to:

Access your personal data (art. 15 GDPR) you have the right to obtain from us conformation as to whether or not personal data concerning you is being processed, and, where that is the case, access to your personal data. Additionally you can request information about the scope and purposes of data processing, as well as request to get a copy of that data.

Request for data rectifaction or correction (art. 16 GDPR)  if the personal data is incorrect you can request rectification, if the data is incomplete you can request supplementation or correction.

Request for data erasure (art. 17 GDPR) in some circumstances, you can request us to delete or remove your personal data we process. In particular, when: the consent that your data was processed based on has been withdrawn, the collected data is no longer needed for the purposes for which it was collected, you objected to the processing of data by 313C based on the legitimate interest of the controller.

In case the objection was raised or consent withdrawn, we may retain certain personal data, in particular: name, surname, telephone number and e-mail address for the purpose of the establishment, exercise or defence of legal claims.

Request to restrict data processing (art. 18 GDPR) you can request restriction of the processing of your personal data when the collected data is incorrect; there is no legal basis for data processing; they are not needed by the Controller, but they are required by data subject; the data subject has objected to processing pursuant to art. 21 (1) pending the verification whether the legitimate grounds of the controller override those of the data subject.

Data portability (art. 20 GDPR) you can request to receive your personal data from 313C  in a structured, commonly used and machine-readable format and transmit those data to another controller. You can also request from us to transmit those data directly to another controller.

Object to personal data processing (art. 21 GDPR) when we process your data on the basis of a legitimate interest.

Withdraw you consent (art. 7 (3) GDPR) you can withdraw your consent to data processing at any time. Such a withdrawal does not affect personal data processing that was carried out before the withdrawal.

ii) In order to exercise any of the rights mentioned above, please contact out Data Protection Officer via email (iod@313c.com.pl) or by traditional means to the address indicated in IV i).

iii) Furthermore, you have the right to lodge a complaint with a supervisory authority concerning the processing of your personal data.

VIII)          SECURITY OF YOUR PERSONAL DATA

i) 313C as a controller conducts a risk analysis on an ongoing basis to ensure that your personal data is processed by us in a safe manner – ensuring, above all, that only authorized persons have access to the data and only to the extent that it is necessary due to tasks they perform.

ii) 313C as a controller ensures that all operations on personal data are registered and performed only by authorized employees and associates.

iii) 313C as a controller takes all necessary steps to ensure that its subcontractors and other cooperating entities guarantee the application of appropriate security measures whenever they process personal data on behalf of the controller.

 IX)          WHAT PERSONAL DATA DO WE PROCCES, WHY AND ON WHAT LEGAL BASIS

i) Participation in the recruitment process to 313C (sending a CV and filling in the recruitment form):

Type of personal data: data contained in the submitted recruitment form and CV file: e.g. name (s) and surname, e-mail address, telephone number, home address, date of birth, employment history, links to social profiles [across different recruitment processes the scope of data may vary] and the results of the competence game [if part of the process].

Purpose: (I) conducting the current recruitment process to which the application was submitted, including candidates’ satisfaction survey, (II) conducting future recruitment processes, including candidates’ satisfaction survey and sending information about job openings, (III) sending information on recruitment offers, sending marketing information regarding the services of 313C, including commercial offers, materials in the form of e-books, information about events or invitations to participate in research, (IV) sending answers to inquiries / requests regarding services offered by 313C, (V) keeping the data in case of the necessity of establishment, exercise or defence of legal claims, (VI) preparation of an employment or a civil law contract, in case the recruitment process is positive.

Legal basis: Art. 6 (1) a GDPR (consent, separate for each purpose I to IV), Art. 6 (1) b GDPR (necessity for the performance of a contract). Art. 6 (1) c GDPR (necessity for compliance with a legal obligation to which the controller is subject; purpose V) and Art. 6 (1) f GDPR (necessity for the purposes of the legitimate interests pursued by the controller or by a third party).

Retention period: (I) in the case of consent to participate in the current recruitment process, personal data will be stored for up to 90 days after the process is ended. After this time, personal data will be anonymized. (II) in the case of consent to participate in future recruitment processes, personal data will be stored for a period of 5 years from the last update or until the consent to their processing is withdrawn. After this time, personal data will be anonymized. (III) in the case of consent to receive information materials, personal data will be stored for a period of 5 years from the last update or until the consent to their processing is withdrawn. After this time, personal data will be anonymized.

Providing personal data is voluntary, but necessary for the purposes mentioned above.

ii) Participation in the recruitment process to 313C’s client (sending a CV and filling in the recruitment form)

Type of personal data: data contained in the submitted recruitment form and CV file: e.g. name (s) and surname, e-mail address, telephone number, home address, date of birth, employment history, links to social profiles [across different recruitment processes the scope of data may vary] and the results of the competence game [if part of the process].

Purpose: (I) conducting the current recruitment process for the 313C’scustomer to which the application was submitted, including candidates’ satisfaction survey, (II) conducting future recruitment processes, including candidates’ satisfaction survey and sending information about job openings, (III) sending information on actual recruitment offers, (IV) providing the 313C’s customer with the recommended applications, (V) keeping the data in case of the necessity of establishment, exercise or defence of legal claims.

Legal basis: Art. 6 (1) a GDPR (consent, separate for each purpose I to III), Art. 6 (1) b GDPR (necessity for the performance of a contract) and Art. 6 (1) f GDPR (necessity for the purposes of the legitimate interests pursued by the controller or by a third party).

Retention period: (I) in the case of consent to participate in the current recruitment process, personal data will be stored for up to 90 days after the process is ended. After this time, personal data will be anonymized. (II) in the case of consent to participate in future recruitment processes, personal data will be stored for a period of 5 years from the last update or until the consent to their processing is withdrawn. After this time, personal data will be anonymized. (III) In the case of purpose IV personal data will be processed for the duration of any claims or for the period necessary for 313C to fulfill its legal obligations.

Providing personal data is voluntary, but necessary for the purposes mentioned above.

iii) Solving an online recruitment game

Type of personal data: name (s) and surname, e-mail address, telephone number, position name, result of the online recruitment game.

Purpose: enabling the Candidate to solve online recruitment game, calculate competence score and share it with 313C customer / entity that conduct recruitment process (or other process) that Candidate participate in.

Legal basis: Art. 6 (1) b GDPR (necessity for the performance of a contract), Art. 6 (1) a GDPR (consent) and Art. 6 (1) f GDPR (necessity for the purposes of the legitimate interests pursued by the controller or by a third party).

Retention period: (I) personal data processed on the basis of Art. 6 (1) b GDPR and Art. 6 (1) f GDPR f) of the GDPR, mentioned above, will be stored at least for the period of enabling you to solve the online recruitment game, as well as for the duration of any claims or for the period necessary for the 313Cto fulfill its legal obligations (II) personal data processed on the basis of Art. 6 (1) a GDPR will be stored until you withdraw your consent but no later than the duration of any claims or for the period necessary for 313C to fulfill its legal obligations.

Providing personal data is voluntary, but necessary for the purposes mentioned above.

iv) Monitoring the activity and ensuring IT security of the 313C recruitment portal and competence games

Type of personal data: IP address, browser data (name, version, time, language, headers), operating system and device, referring URL.

Purpose: data mentioned above is registered as part of system logs and used to ensure the security of IT systems operation, diagnostics of possible problems, optimization of the solution, analysis of possible violations and handling of technical issues.

Legal basis: 6 (1) f GDPR (necessity for the purposes of the legitimate interests pursued by the controller or by a third party – ensuring the correct and safe functioning of IT systems used in recruitment and other processes, as well as their development and optimization).

Retention period: personal data will be kept as long as it is necessary for the establishment, exercise or defence of legal claims or for the period necessary for 313C to fulfill its legal obligations, no longer than 3 years.

See additional information in Section X (Cookies).

v) Using the 313C website

Type of personal data: IP address, time spent on the website, other identifiers and information collected via cookies..

Purpose: providing online services and sharing content via the website, conducting analytical and statistical research.

Legal basis: 6 (1) f GDPR (necessity for the purposes of the legitimate interests pursued by the controller or by a third party – promotion of 313C and adapting the content to the needs of current and potential Clients and Candidates).

Retention period: (I) for the provision of online services – for the duration you use of the website or for the duration of a saved cookie. (II) until you submit an effective objection to data processing, where the basis for processing is our legitimate interest.

See additional information in Section X (Cookies).

vi) Contacting us via contact form on the 313C’s website

Type of personal data: name (s), surname, telephone number, e-mail address and any other data provided voluntarily in the contact form.

Purpose: making contact with the person completing the form, answering questions/inquiries contained in the form

Legal basis: 6 (1) f GDPR (necessity for the purposes of the legitimate interests pursued by the controller or by a third party – promotion of our services on the professional market).

Retention period: we process personal data mentioned for the duration of the inquiry service in the contact form and for the period of limitation of claims, i.e. a period of 3 years or until you submit an effective objection to the processing of your data.

vii) Participation in a webinar

Type of personal data: name (s), surname, telephone number, e-mail address and company name.

Purpose: organizing a webinar, participating in a webinar, making contact with participant, sending materials related to the webinar.

Legal basis: (I) In the case of organizing a webinar – Art. 6 (1) f GDPR (necessity for the purposes of the legitimate interests pursued by the controller or by a third party – promotion of our online recruitment tools on the market, expanding the knowledge of participants in the field of recruitment and psychometrics, popularizing the use of competence games in recruitment processes). (II) In the case of participating in a webinar, making contact with participant or sending materials related to the webinar  – Art. 6 (1) a GDPR (consent).

Retention period: (I) personal data processed on the basis of Art. 6 (1) a GDPR will be stored for 2 years or until you withdraw your consent. (II) personal data processed on the basis of Art. 6 (1) f GDPR f) of the GDPR, mentioned above, will be stored for the duration of any claims or for the period necessary for the 313Cto fulfill its legal obligations

Providing personal data is voluntary, but necessary for the purposes mentioned above.

viii) Providing an account (including a test account) on the 313C Recruitment Platform

Type of personal data: name (s) and surname, e-mail address, telephone number, position name.

Purpose: enabling access to the 313C Recruitment Platform.

Legal basis: Art. 6 (1) b GDPR (necessity for the performance of a contract).

Retention period: personal data processed on the basis of Art. 6 (1) b GDPR mentioned above, will be stored for the period of the contract between 313C and its Customer, as well as for the duration of any claims or for the period necessary for the 313Cto fulfill its legal obligations

ix) Social media (Facebook, Linkedin)

Type of personal data: name (s), surname, IP address, link to the profile, information about the device, information about the interest in our website on the portal (“Like” and “Interested” buttons) and other technical data collected by social networks

Purpose: maintaining our profile on social networks and promoting our own brand, events and activities related to it

Legal basis: Art. 6 (1) f GDPR (necessity for the purposes of the legitimate interests pursued by the controller or by a third party – promotion of our online recruitment tools on the market, expanding the knowledge of participants in the field of recruitment and psychometrics, popularizing the use of competence games in recruitment processes).

Retention period: personal data will be stored for the period of maintaining active profiles on social media by us or until you withdraw your consent.

   X)          COOKIES

i) Cookie files are small text files that are stored by your browser on your device to save certain information. They mainly contain information on the name of the website of their origin, their unique number, and the storage time on the end device.

ii) Cookies used by 313C do not change the configuration of the user’s device or software and do not have a negative impact on its functioning.

iii) 313C may use cookies to:

a. Ensure the correct functioning of the website

b. Analysis of user traffic and the manner of using our websites

c. display the content of the website to your individual preferences by recognizing the device.

iv) You may at any time fully or partially change the settings of your browser in order to:

a. disable the storage of cookies on your device (althoug this may cause that not all subpages will work properly)

b. obtain information about their inclusion in your device

c. other options (available options can be checked in the settings of your web browser). Please be informed that most browsers are set to accept saving files (cookies) on the end device by default.

v) To check how cookies are managed in your browser, see the links below or check your browser settings:

a. MS Edge: link

b. Mozilla Firefox: link

c. Google Chrome: link

d. Opera: link

e. Safari: link

vi) Some 313C webpages and services may contain links to other websites managed by third parties, including, for example, plugins for sharing content via social media (e.g. Facebook, LinkedIn, Google). These sites may place cookies on the User’s device while using their services, regardless of settings in 313C over which 313C has no control. Detailed information can be found in the Privacy Policies & Conditions belonging to the above-mentioned entities.

 XI)          HOW TO CONTACT US 

i) In case of any questions regarding personal data processed by 313C contact us via email iod@313c.com.pl or by post to: ul. Smoleńsk 29, 31-112 Krakow, Poland.

ii) Your message should contain at least: your contact details and the content of the application.

iii) We may contact you in order to detail or verify the submitted inquiry.

iv) If we are unable to identify a natural person on the basis of the submitted request, we will ask the applicant for additional information. Providing such data is not obligatory, but failure to provide it will result in the refusal to fulfill the request.

XII)          DATA TRANSFER

i) Personal data may be shared with relevant persons and entities authorized under the provisions of law to obtain personal data, as well as persons cooperating with the Controller on the basis of civil law contracts and the Controller’s employees authorized to process personal data.

ii) Personal data may be shared with other controllers, entities and bodies authorized to process them, including 313C Clients on the basis of specific agreements concluded between the parties.

iii) The data may be shared with entities processing them at our request on the basis of contracts concluded with the controller, but only for the purpose and scope necessary for the implementation of the above-mentioned purposes, including entities providing IT services or other services to us to ensure the proper functioning of recruitment processes or the Recruitment Platform and competence games. Such entities process data only in accordance with our instructions.

iv) Some of our suppliers will have access to personal data from a third country (countries outside the European Economic Area). Some of our suppliers, and in particular entities specializing in analytics and ensuring website security (in particular Google Recaptcha, Google Analytics, Google Tag manager), may locate their headquarters outside the European Economic Area. For third countries/companies which fall under an adequacy decision, the adequacy decision also applies. More information on this topic is published here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu_en.

v) 313C, acting as a processor, may process personal data transferred from other entities (including other controllers) on the basis of separate agreements, strictly in accordance with the guidelines of the transferring authorities and the law.

vi) In the event of a legal obligation, we reserve the right to disclose information about you if we are required to surrender it to competent authorities or law enforcement bodies acc. to: Art. 6 (1) c GDPR (legal obligation).

XIII)          RECIPIENTS (GENERAL INFORMATION)

i) IT outsourcing.

ii) Suppliers responsible for the operation and security of IT systems.

iii) Providers specialized in hosting services.

iv) Suppliers providing ATS systems.

v) Entities specializing in providing analytical and website security services (Google Tag Manager, Google Analytics, Google ReCaptcha). More information can be found in their privacy policy: https://policies.google.com/privacy.

XIV)          ON AUTOMATED INDIVIDUAL DECISION-MAKING AND PROFILING

313C as a Controller may process the data using an IT system and relevant software, however you as a data subject will not be a subject to a decision based solely on automated processing, including profiling (Art. 22 (1) (4).

This Privacy Policy is verified, checked and updated on an ongoing basis. We reserve the right to change it in whole or in part – the current version is published at https://313c.com.pl/privacy-policy/