I. INTRODUCTION
The following document describes SEAM Group’s privacy policy hereinafter: the policy defines the rules, methods of processing and use of data as well as information from candidates, customers, and users of all digital properties belonging to SEAM Group, including:
- https://www.seamgroup.com/
- LinkedIn profile
- Twitter profile
- Facebook profile
- YouTube profile
Please read the Policy carefully. By entering or using a website belonging to SEAM Group and sending us any Personal Data in connection with job applications, recommending a friend to work, sending a request for an offer/cooperation, etc. The user accepts the terms of this Policy and confirms they have read its content.
Terms used in the Privacy Policy
Personal data – defined as Personal data within the meaning of the GDPR, i.e., all information relating to an identified or identifiable natural person. These data identify directly or indirectly a natural person with regards to the name, e-mail address, or telephone number of the natural person and other data that, in connection with the above-mentioned, may identify the User.
GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals regarding the processing of personal data and on the free movement of such data, and repealing Directive 95/46 / EC (General Data Protection Regulation), pursuant to which SEAM Group and its Subsidiaries process Users’ Personal Data.
SEAM Group – SEAM GROUP with its registered office in the United States of America (hereinafter referred to as the “the Controller”) for web site, newsletter, (worldwide)
SEAM Group Europe – SEAM GROUP Europe with its registered office in Warsaw, ul. Stawki 2, 00-193 Warsaw, Poland , entered into the Register of Entrepreneurs of the National Court Register kept by the District Court for the capital city of Warsaw, XIII Commercial Division of the National Court Register, under KRS number 0000469907, NIP number: 9512368771 (hereinafter referred to as the “the Controller”) for activities dedicated to EMEA (recruitment, employment, EMEA contractors)
Specialist – a job candidate offered by SEAM Group to its customers.
Subsidiaries – a company or entity that is directly or indirectly controlled by SEAM Group, where “control” means: (a) in the case of corporate entities, direct or indirect ownership of more than fifty percent (50%) of stocks or shares entitled to vote, or (b) in the case of non-corporate entities, holding directly or indirectly more than fifty percent (50%) of the equity with the power to direct such non-corporate entities. The subsidiary company is, in particular, SEAM Group Europe
User – job candidate, newsletter subscriber, competition participant, person asking a question, training participant, contractor, employee of contractor, person recommending a friend to work and visiting websites belonging to SEAM Group, as well as a person using the candidate’s portal.
Services – services provided by SEAM Group electronically, via the website, i.e .: subscribing to the newsletter, sending inquiries via the contact form, sending documents necessary in the recruitment process, application for participation in competitions, application for participation in training, creation of an account on the candidate portal.
Providing Personal Data
By providing personal data on www.seamgroup.com and any other website that belongs to SEAM Group, the User confirms that he/she has all necessary permissions to disclose personal data that will be later used by SEAM Group in a manner described in this Policy.
Personal Data Controller
Area of data processing | Controller | Contact data |
Information on the processing of personal data of JOB CANDIDATES (employment on the basis of an employment contract) Information on the processing of personal data (natural persons): Contractors Information on the processing of personal data of EMPLOYEES Information on the processing of personal data (natural persons): Representatives of Contractors | The Controller, i.e. the entity deciding how your personal data will be used, is SEAM GROUPE EUROPE with its registered office in Warsaw (hereinafter referred to as the “the Controller”). | In matters regarding the processing of your personal data, you can contact the Controller: • By e-mail (e-mail): daneosobowe@seamgroup.com; |
Information on the processing of personal data of persons contacting using the form on the website Information on the processing of personal data of SUBSCRIBERS | The CONTROLLER, i.e. the entity deciding how your personal data will be used, is SEAM GROUPE with its registered office in the United States of America (hereinafter referred to as the “the Controller”). | In matters regarding the processing of your personal data, you can contact the Controller: • by e-mail: daneosobowe@seamgroup.com |
Any questions regarding regulations concerning personal data processing described in this Policy should be sent to the Data Protection Team appointed by SEAM Group at daneosobowe@seamgroup.com
II. PROCESSING OF PERSONAL DATA BY SUBSIDIARIES
SEAM Group is a company that has Subsidiaries. All rules on personal data processing by Subsidiaries (including goals, scope, time, conditions of data sharing, exercising user rights) are the same as those described in following chapters of Privacy Policy.
Any definitions set out in Chapter I of this Policy in case of Subsidiaries apply to Users whose Personal Data those Subsidiaries process independently or jointly with SEAM Group and other subsidiaries.
In each Subsidiary, there are internal procedures for the implementation of rights, identical to those applied by SEAM Group. Each User whose Personal Data Subsidiaries process, may submit a request concerning exercising their rights to the e-mail address indicated in the table below. All details regarding the rights are described in Chapter VI of this Policy.
Key information concerning SEAM Group’s Subsidiaries which process personal data in compliance with this Policy is presented below:
Subsidiary | Personal Data Administrator | Internet website | Contact to Personal Data Administrator | Adress for submitting requests |
SEAM Group Europe | SEAM Group Europe, ul Stawki 2, 00-193 Warsaw Poland, National Court Register kept by the District Court for the capital city of Warsaw, under KRS number 0000469907, NIP number: 9512368771 | seamgroup.com/pl | SEAM Group Europe Sp. z o.o., ul. Stawki 2, 00-192 Warsaw, Poland |
III. PROCESSING OF PERSONAL DATA – PURPOSES, LEGAL BASIS, SCOPE, SOURCE
SEAM Group processes Personal Data for various purposes for which it needs a specific scope of Personal Data from the User, and each purpose of processing has its legal basis resulting from the provisions of the GDPR and sectoral regulations that contain regulations regarding the protection of Personal Data:
Purpose of processing personal data | Legal basis for processing personal data | Scope of processed personal data | SOURCE OF PERSONAL DATA |
Conducting recruitment for the needs of SEAM Group | Article 6(1)(b) of the GDPR to the extent that it forms the basis for the processing of personal data at your request, before concluding an employment contract. Article 6(1)(a) of the GDPR and article of the 9(2)(a) GDPR), which can be expressed by simply sending us this personal data. Article 6(1)(a) of the GDPR and article 9(2)(a) of the GDPR expressed by posting a declaration (declaration of consent) proposed by us in your CV or ticking a checkbox (if it is placed next to the job advertisement) Art. 221 § 1 of the Labor Code – for Poland | • Name(s) and surname, date of birth, contact details, education, professional qualifications and data on the course of previous employment (Article 221 § 1 of the Labour Code); • And other personal data (e.g. image recorded in a photograph, information about a disability), if provided by you. You are not obliged to do so, but sending us such data means that you have consented to their processing for recruitment purposes. Other information contained in the application documents (CV, cover letter) | • We receive your personal data that we collect and process directly from you. In addition, your personal data may be transferred to us by other controllers (e.g. pracuj.pl portal, if you have created an account there with the option of sharing your profile with employers). • It may also happen that your data is made available to us by a current employee, thus recommending a specific person. |
Conducting recruitment for projects carried out for SEAM Group customers | Art. 6 sec. 1 point a GDPR – consent to the processing of personal data Article 221 § 1 of the Labor Code Article 6 (1) (a) f GDPR – legitimate interest of SEAM Group as the administrator of personal data | Name(s) and surname, date of birth, contact details, education, professional qualifications and data on the course of previous employment (Article 221 § 1 of the Labour Code); • And other personal data (e.g. image recorded in a photograph, information about a disability), if provided by you. You are not obliged to do so, but sending us such data means that you have consented to their processing for recruitment purposes. Other information contained in the application documents (CV, cover letter) | • We receive your personal data that we collect and process directly from you. In addition, your personal data may be transferred to us by other controllers (e.g. pracuj.pl portal, if you have created an account there with the option of sharing your profile with employers). • It may also happen that your data is made available to us by a current employee, thus recommending a specific person. |
Processing of personal data of EMPLOYEES | Article 6(1)(b) of the GDPR 221 § 1-5 of the Labor Code | We collect all the data requested by law in order to conclude, perform and terminate the employment contract. | We receive your personal data that we collect and process directly from you. |
Processing of personal data of persons contacting using the form on the website Sending answers to Users, to the e-mail addresses or telephone numbers provided by them, to previous inquiries sent via the contact form, as well as to contact the Users and answer their previously sent messages and inquiries.
| Article 6 (1) (a) f GDPR – legitimate interest of SEAM Group as the Administrator of personal data | Full name | We receive your personal data, which we collect and process, directly from you using the form on the website of which we are the administrator (IT). If you are interested in contacting us in connection with the presented issue or the presented need, you provide data in the form, and clicking on the “Send” button will send this data to the Controller. |
Processing of personal data of SUBSCRIBERS Sending marketing and promotional information about products and services, events, and news, including subscription to the newsletter.
| Art. 6 sec. 1 point a GDPR – consent to the processing of personal data Art. 10 sec. 2 of the Act on the provision of services via electronic means | Name and surname (if the e-mail address consists of first name and surname) place of work, telephone number, job title, country (if required in the form) | We receive your personal data, which we collect and process, directly from you using the form on the website of which we are the administrator (IT). If you are interested in receiving marketing information and other information about our business, you provide data in the form, and clicking on the “Subscribe” button will send this data to the Controller. |
Providing the User with marketing information by phone or SMS | Art. 6 sec. 1 point a GDPR – consent to the processing of personal data | Full name | We receive your personal data, which we collect and process, directly from you using the form on the website of which we are the administrator (IT). |
Pursuing and defending rights in the event of mutual claims. | Article 6 (1) (a) f GDPR – legitimate interest of SEAM Group as the Administrator of personal data | Full name | We receive your personal data that we collect and process directly from you. |
Organizing and conducting trainings | Art. 6 sec. 1 point b GDPR – conclusion and performance of the contract between the User and SEAM Group
| • name, surname, address of residence, telephone number, e-mail address, bank name, and bank account number, information on the performance of the training contract; • and other personal data, insofar as this is related to the training contract concluded with you and your participation in the training. | We receive your personal data that we collect and process directly from you. |
Organization and conducting of competitions | Art. 6 sec. 1 point a GDPR – consent to the processing of personal data | Full name | We receive your personal data that we collect and process directly from you. |
Organization of conferences, seminars, events, webinars | Art. 6 sec. 1 point a GDPR – consent to the processing of personal data | Full name | We receive your personal data that we collect and process directly from you. |
Processing of personal data (natural persons): Contractors | Article 6(1)(b) of the GDPR (i.e. the contract concluded with you) Article 6(1)(c) of the GDPR (processing of personal data in connection with obligations imposed by law on the Controller). | • name, surname, company, NIP, REGON, registered office, address of residence, telephone number, e-mail address, bank name, and bank account number, subject of the transaction, date of transaction, information on the performance of the contract ; | We receive your personal data that we collect and process directly from you. |
Processing of personal data (natural persons): Representatives of Contractors | • We process your personal data in order to perform actions aimed at concluding a contract or to perform a contract concluded with a contractor with whom you are employed, regardless of the legal basis for employment; • in this case, the basis for the processing of your personal data is the legitimate interest of the Controller (e.g. article 6(1)(f) of the GDPR), which consists in establishing and maintaining contact with the customer/contractor and performing the concluded contract. | name, surname, address of the place of work, correspondence address (business), e-mail address (business), telephone number (business), job title. | We receive your personal data that we collect and process: • directly from you (e.g. during the first contact in connection with the conclusion and performance of a contract with a contractor with whom you are employed or represented, regardless of the basis of employment or representation) ; • from the contract with whom you are employed or represented, regardless of the basis of employment or representation; |
Contacting customers’ and suppliers’ representatives to coordinate activities under the contracts. | Article 6 (1) f GDPR – legitimate interest of SEAM Group as the Administrator of personal data | Full name | We receive your personal data that we collect and process: • directly from you (e.g. during the first contact in connection with the conclusion and performance of a contract with a contractor with whom you are employed or represented, regardless of the basis of employment or representation) ; • from the contract with whom you are employed or represented, regardless of the basis of employment or representation; |
The following chapters provide more detailed information on the Personal Data processed:
- As for the processing of Personal Data for the purposes of recruitment – Chapter VI of this Policy.
- As for the processing of Personal Data in connection with marketing activities – Chapter VII of this Policy.
- As for the processing of Personal Data in connection with organizing and conducting training – Chapter VIII of this Policy.
- As for the processing of Personal Data in connection with the organization of events, conferences, seminars, webinars – Chapter IX of this Policy
- As for the processing of Personal Data in connection with organizing and conducting competitions – Chapter X of this Policy.
- As for the processing of Personal Data in connection with the performance of contracts (suppliers, customers) – Chapter XI of this Policy.
Legitimate interest of SEAM Group as the Administrator of personal data
Legitimate interest is one of the legal grounds provided for in Art. 6 sec. 1 GDPR, which assumes that there are situations in which the Personal Data Controllermay perform specific processing of Personal Data. Such legitimate interests that we use at SEAM Group include:
- Possibility of pursuing claims or defending against them. Promoting SEAM Group, sending marketing information.
- Implementation of cooperation agreements with customers and suppliers.
- Conducting negotiations, discussions with potential customers
- Conducting recruitment for projects carried out for SEAM Group’s customers
- Handling inquiries sent to SEAM Group – providing answers to Users.
In the event of contact with the User in order to provide an answer, the legal basis for the processing of Personal Data is the legitimate interest of SEAM Group as the Controller of Personal Data provided on the contact form (Article 6 (1) (f) of the GDPR). The legitimate interest is manifested in the possibility of responding to the inquiry sent, providing the User with a comprehensive answer. Without the processing of Personal Data, in particular contact data, we will not be able to provide an answer, and thus, help in resolving an issue indicated in the inquiry.
IV. STORING OF PERSONAL DATA
The processing of personal data generally continues until the purpose for which the Personal Data was obtained and processed and stored, for the purpose of achieving it, ceases to exist. After achieving the goal or its termination, SEAM Group removes all personal data obtained from the User. However, there are situations in which SEAM Group stores Personal Data even if the purpose of processing has been achieved or will no longer be achieved. This is due to legal requirements or business needs.
Importantly, the provisions of the GDPR make it possible to show the exact duration of the storage of Personal Data (days / weeks / months / years) and to indicate the criteria for data storage for a given period of time, e.g. “for the period of limitation of the User’s potential claims against SEAM Group”, “until withdrawal consent to the processing of Personal Data “.
Below, information on the storage periods of Personal Data.
Purpose of processing personal data | Personal data storage period | The basis for the storage of personal data | Purpose |
Conducting recruitment for the needs of SEAM Group | Personal data of persons who have not been selected is not stored but is deleted immediately after the end of the recruitment process . *** Until you withdraw your consent to the processing of this personal data before the end of the recruitment process or after the end of the recruitment process, when you have not been selected for the position for which you applied. *** Until you withdraw your consent to the processing of personal data, but not longer than 12 months. | The legal basis is article 6(1)(b) of the GDPR to the extent that it forms the basis for the processing of personal data at your request, before concluding an employment contract. The legal basis is your consent (article 6(1)(a) of the GDPR and article of the 9(2)(a) GDPR), which can be expressed by simply sending us this personal data. ***
The legal basis is your consent (article 6(1)(a) of the GDPR and article 9(2)(a) of the GDPR expressed by posting a declaration (declaration of consent) proposed by us in your CV or ticking a checkbox (if it is placed next to the job advertisement) You can withdraw your consent at any time in any way, including sending a message to the addresses indicated in point 2 above. The processing of personal data until the consent is withdrawn is lawful. | We process your personal data (listed in Art. 221 § 1 of the Labor Code) in order to assess your qualifications for a specific position and to make a decision on your candidacy and possible employment. We also process your personal data, which you are not obliged to provide, in order to assess your qualifications for a specific position and to make a decision on your candidacy and possible employment. We also process your personal data (listed in Art. 221 § 1 of the Labor Code) in order to assess qualifications for a specific position in the future (future recruitment or when recruitment was not announced, but you have sent us your CV). |
Conducting recruitment for projects carried out for SEAM Group customers | Until the consent to the processing of Personal Data is withdrawn | Art. 6 sec. 1 point a GDPR – consent to the processing of personal data | We process your personal data (listed in Art. 221 § 1 of the Labor Code) in order to assess your qualifications for a specific position and to make a decision on your candidacy and possible employment. We also process your personal data, which you are not obliged to provide, in order to assess your qualifications for a specific position and to make a decision on your candidacy and possible employment. |
Processing of personal data of persons contacting using the form on the website Sending answers to Users, to the e-mail addresses or telephone numbers provided by them, to previous inquiries sent via the contact form, as well as to contact the Users and answer their previously sent messages and inquiries. | We store your data until you withdraw your consent to the processing of this personal data. | The legal basis is your consent (article 6(1)(a) of the GDPR, i.e. the consent of the data subject. You can withdraw your consent at any time in any way, including by sending a message to the addresses indicated in point 2 above. The processing of personal data until the withdrawal of consent is lawful. | We process your personal data, which you provide in the form on the website, in order to contact you regarding the presented issue or the presented need. |
Information on the processing of personal data of | We store your data until you withdraw your consent to the processing of this personal data. | The legal basis is your consent (article 6(1)(a) of the GDPR, i.e. the consent of the data subject. You can withdraw your consent at any time in any way, including by sending a message to the addresses indicated in point 2 above. The processing of personal data until the withdrawal of consent is lawful. | We process your personal data, which you provide in the form on the website, in order to send you marketing and other information that relate to our business. |
Providing the User with marketing information by phone or SMS | Until the consent to the processing of Personal Data is withdrawn | Art. 6 sec. 1 point a GDPR – consent to the processing of personal data | We process your personal data, which you provide in the form on the website, in order to call you with informations relate to our business. |
Pursuing and defending rights in the event of mutual claims. | Limitation period for potential claims | Article 6 (1) f GDPR – legitimate interest of SEAM Group as the Administrator of personal data | We process your personal data requested by law for claim procedure |
Organizing and conducting trainings for Users and employees of SEAM Group customers. | Time to organize and conduct the training. | Art. 6 sec. 1 point b GDPR – conclusion and performance of the contract between the User and SEAM Group | The purpose of processing your personal data is to perform the contract concluded with you for participation in the training. The legal basis is article 6(1)(b) of the GDPR (i.e. the contract concluded with you). In addition, we process your personal data for purposes resulting from the provisions of tax law and then the legal basis is these provisions and article 6(1)(c) of the GDPR (processing of personal data in connection with obligations imposed by law on the Controller). |
Organization and conducting of competitions | Time to organize and conduct the competition | Art. 6 sec. 1 point a GDPR – consent to the processing of personal data | We process your personal data, which you provide in the form on the website, in order to participate in competition. |
Organization of conferences, seminars, events, webinars | Time of organization and implementation of the event / seminar / conference / webinar | Art. 6 sec. 1 point a GDPR – consent to the processing of personal data | We process your personal data, which you provide in the form on the website, in order to participate in conferences, seminars, events, webinars |
Contacting customers’ and suppliers’ representatives to coordinate activities under the contracts. | The time of SEAM Group’s cooperation with a customer / supplier or the period of negotiations with a potential supplier / customer. | Article 6 (1) f GDPR – legitimate interest of SEAM Group as the Administrator of personal data | The purpose of processing your personal data is to perform the contract concluded with you. |
Information on the processing of personal data (natural persons): Contractors. | Your personal data will be stored until the limitation period for claims that may arise from the contract that connects us with you expires. | The legal basis is article 6(1)(b) of the GDPR (i.e. the contract concluded with you). In addition, we process your personal data for purposes resulting from the provisions of tax law and then the legal basis is these provisions and article 6(1)(c) of the GDPR (processing of personal data in connection with obligations imposed by law on the Controller). | The purpose of processing your personal data is to perform the contract concluded with you. |
Information on the processing of personal data (natural persons): Representatives of Contractors | Your personal data will be stored until the limitation period for claims that may arise from the contract expires; this is due to the fact that in order to establish, pursue or defend claims, information about the person with whom the Controller directly contacted regarding the performance of the contract may be necessary. | in this case, the basis for the processing of your personal data is the legitimate interest of the Controller (e.g. article 6(1)(f) of the GDPR), which consists in establishing and maintaining contact with the customer / contractor and performing the concluded contract . | We process your personal data in order to perform actions aimed at concluding a contract or to perform a contract concluded with a contractor with whom you are employed, regardless of the legal basis for employment; |
Information on the processing of personal data of EMPLOYEES
| Your personal data will be stored in accordance with the legal provisions determining the period of storage of personal data of employees. | The legal basis is article 6(1)(b) of the GDPR to the extent that it forms the basis for the processing of personal data at your request for the performance of an employment contract. | We process your personal data (listed in art. 221 § 1-5 of the Labor Code) in order to conclude, perform and terminate the employment contract. |
The abovementioned list of store periods for Personal Data is general and does not contain details that are relevant in each case. The mentioned details were recorded:
- In connection with recruitment for SEAM Group customers
- In connection with cooperation with suppliers, customers
V. TRANSFER OF PERSONAL DATA
There are situations in which SEAM Group transfers the User’s Personal Data to other external entities – companies, entrepreneurs, or public institutions. The transfer of Personal Data results from:
- Provisions of law requiring the transfer of data to a specific public institution (police, court, prosecutor’s office, etc.);
- SEAM Group’s internal needs regarding obtaining a specific service to support the achievement of business goals (entities providing legal advisory services, legalization of foreigners’ stay, booking accommodation in hotels, sending mass-mailings, etc.).
The transfer of Personal Data takes place in the form of sharing or entrusting them. Below is an explanation of the differences between the indicated forms.
Sharing Personal Data | Entrusting Personal Data |
Enstrusting Personal Data consists of transferring data to another entity based on one of the legal grounds specified in the provisions of the GDPR – specifically: Art. 6 Sec. 1. i.e. | Entrustment is the transfer of Personal Data based on Art. 28 GDPR – SEAM Group, as the Administrator of Personal Data, transfers them to another entity by concluding a special so-called contracts for entrusting the processing of personal data. |
SEAM Group provides or entrusts Personal Data to the following entities:
Sharing Personal Data | Entrusting Personal Data |
SEAM Group customers (in the scope of contact details of representatives) | Entities providing mass marketing e-mail / SMS mailing services |
SEAM Group’s potential customers (in the scope of contact details of representatives) | Entities providing services that conduct certification exams at the end of courses and training |
Suppliers (in the scope of contact details of representatives) | Training providers |
Public administration bodies authorized under the provisions of law | Entities intermediating in the organization of events (owners of portals for registering for events) |
SEAM Group provides Users’ Personal Data to its customers in connection with their recruitment for the purpose of employment, then delegation to provide services under the outsourcing of specialists or entire teams. SEAM Group has concluded appropriate agreements and contracts specifying the rules for disclosing Personal Data. Each User has the right to access information to which customer Personal data has been made available on the terms set out in Chapter V of this Policy.
Transfer of personal data between SEAM Group companies
SEAM Group is a company that has Subsidiaries, in particular SEAM Group Europe. Due to the fact that the Subsidiaries use IT systems belonging to SEAM Group for organizational facilitation in the implementation of recruitment and marketing purposes, managing relations with customers, suppliers, etc., SEAM Group transfers Users’ Personal Data to its Subsidiaries. The transfer of Personal Data to subsidiaries is carried out pursuant to art. 6 sec. 1 point f GDPR, i.e. the legitimate interest of SEAM Group as the Personal Data Administrator. The legitimate interest manifests itself in the following matters:
- Search for User-Candidates by SEAM Group and its Subsidiary for a joint project for a customer.
- Joint negotiations with a potential customer in order to conclude a cooperation agreement.
- Joint search for a subcontractor to assist in the implementation of the project for the customer, which is run by the employees of SEAM Group and its subsidiaries.
The transfer of Personal Data to the Subsidiaries takes place by enabling the employees of these companies to access the CRM system belonging to SEAM Group. And the use of one, common CRM system for the abovementioned purposes is the so-called co-administration of Personal data, i.e. SEAM Group and its Subsidiaries jointly decide on the purposes (for what?) and methods (how?) of processing Users’ Personal Data. In order to protect Personal Data, SEAM Group has concluded special agreements with its subsidiaries – agreements for the co-administration of Personal Data. In the context of Subsidiaries based in a country not belonging to the European Union or the European Economic Area, SEAM Group concluded additional contractual clauses with such subsidiaries securing the processed data and meeting the requirements of Art. 44-49 GDPR. These clauses are concluded due to the fact that in the case of subsidiaries based in a country outside the European Union or the European Economic Area, the rules set out in the GDPR do not apply to Personal Data processed by such entities.
VI. USER RIGHTS
Each User has the rights related to the processing of his Personal Data by SEAM Group, in accordance with Chapter III: Art. 15-22 GDPR:
What law? | What is it? | Situations excluding the implementation of the law |
The right to access one’s Personal Data (Article 15 of the GDPR) | The User receives a list of Personal Data obtained from him by SEAM Group and processed in documents and IT systems.(At any time you can find out what data of yours the Controller processes and you can receive a copy of your personal data.) | None |
The right to rectify the processed data (Article 16 of the GDPR) | The User may report the need to update, supplement the Personal Data provided to SEAM Group or request correction if SEAM Group uses incorrect data. (When you notice that your personal data is incorrect, or when, for example, your name, telephone number, e-mail address have not changed) | None |
The right to delete data (“the right to be forgotten”) (Article 17 of the GDPR) | SEAM Group deletes all Personal Data obtained from the User. This right is exercised without undue delay in one of the following circumstances: | Legal provisions that require further processing – the storage of Personal Data despite the lack of purpose for their processing. |
Right to restriction of processing (art 18) | The User may request the restriction of the processing of his Personal Data, i.e. he may oblige SEAM Group, for example, not to disclose them to another entity to be used for the implementation of marketing mailing, to withhold access to them by SEAM Group employees. The User may exercise this right in the following situations: | None |
Right to transfer of Personal Data (art. 20 GDPR) | The User may submit a request for SEAM Group to prepare a report / statement with his Personal Data, and then for SEAM Group to provide the report / statement to another entity – the Personal Data Administrator. This right is exercised if: | None |
Right to object to further data processing (Art.21 GDPR) | The User may object to SEAM Group against further processing of their Personal Data, regardless of the reason. From the moment the objection is raised, SEAM Group cannot continue processing Personal Data. | SEAM Group will prove to the User that its own legitimate interests for data processing override the User’s rights. |
The right not to be subject to decisions based solely on automated processing, including profiling (Article 22 of the GDPR) | The User has the right to be assessed on the basis of comprehensive actions based on the Personal Data obtained from the User, not only by special algorithms that bring the data together, but also by actions taken by employees. | Making decisions is necessary for the performance of the contract between SEAM Group and the User. |
The right to withdraw consent to the processing of Personal Data (Article 7 (3) of the GDPR) | The User may revoke the previously expressed voluntarily consent to the processing of his Personal Data. Wherever consent is the only legal basis for SEAM Group to process Personal Data, this right is strictly enforced. That is, inter alia: | None |
The right to file a complaint against the processing of Personal Data (Article 13 (2) (d) of the GDPR; Article 14 (2) (e) of the GDPR) | The user may notify the GDPR control authority – in Poland it is: The President of the Office for Personal Data Protection, that SEAM Group violates the provisions of the GDPR, that, for example, it fails to secure data, has obtained more data than is actually necessary for a specific purpose. Contact details: | None |
The implementation of each of the above rights takes place at the User’s request sent to daneosobowe@seamgroup.com SEAM Group examines the submitted application and sends a reply within 1 month from the date of receipt of the application together with an indication of the result of the examination – what specific actions have been taken with the estimated time for the processing of the entire application, if specific activities require a longer processing time.
SEAM Group reserves the right to respond to a request for the exercise of any right later than the abovementioned date: up to two months (resulting from Article 12 (3) of the GDPR), due to the number of inquiries or the complex nature of the inquiry sent. By complexity, we understand the need to compile data from many IT systems or the need to consult more than one person from a department or departments in order to obtain information that is the subject of the application. In each case, SEAM Group undertakes to inform the User about this fact, providing justification.
SEAM Group also reserves that it may refuse to exercise any of the rights specified in Art. 15 – 22 of the GDPR in a situation where the User submits applications in a continuous, excessive manner, without any justification. Each time SEAM Group will justify the refusal to exercise the right indicated in the application. By persistent and excessive nature, we mean sending subsequent requests with a similar request to the original one, despite the examination and notification of its processing, e.g. The User sends the request for access to information, SEAM Group executes it – it sends a summary of the information it has, and the User sends the second and the same request again, without explaining the reason for the repeated request for information.
Under the right to withdraw consent, the User may at any time withdraw consent to further processing of Personal Data for purposes that require consent, provided that the withdrawal of consent does not affect the lawful use of Personal Data in activities based on consent before its withdrawal. The following chapters provide details on how to withdraw consent for a specific purpose (recruitment, marketing, competitions, etc.)
Under the right to access information, the User is entitled to obtain the following information in the form of a report or statement:
- Purpose of processing Personal Data
- Categories of Personal Data – what data we process, e.g. name, surname, telephone number;
- Legal bases for data processing
- Information on recipients or categories of recipients of data – to whom (a person, company, institution) this data may be transferred;
- Information on the right to request from SEAM Group the rectification of data, their deletion or limitation of their processing and to object to specific data processing;
- Information on the possibility of lodging a complaint to the President of the Personal Data Protection Office;
- Information about the data source, if the data has not been obtained directly from the User – indication of the person or company or institution that provided the Personal Data;
- On the use of profiling: on what terms it is undertaken, what may be the consequences of profiling for the User
SEAM Group also informs that each subsequent copy of Personal Data is associated with a fee resulting from the costs incurred in connection with the creation of another copy of Personal Data. SEAM Group notifies the User about the costs after assessing the scope of the information indicated in the application.
With regards to the right to delete Personal Data, SEAM Group deletes not only data obtained from the User himself, but also information obtained as a result of the analyzes, e.g. information about the User’s interests in specific categories of information, products, services based on the User’s-consumer activities; information about the professional experience of the User-candidate obtained as a result of the interview, the candidate’s own assessment based on the course of the interview.
Exceptions to the implementation of the law, shown in the table, result from applicable law. SEAM Group analyzes each case of an exception individually for each case – the relationship between SEAM Group and the User.
What is crucial, this right shall always be executed. Legal or internal – business requirements are only factors that extend the full implementation of the request for the removal of Personal Data.
The right to object to the further processing of Personal Data is that the User indicates that he does not want his Personal Data to be used for purposes that are pursued as legitimate interests within the meaning of Art. 6 sec. 1 point f GDPR. After receiving the objection, SEAM Group analyzes whether the objection may be taken into account or whether there are grounds to reject it, as it is not an absolute right. There may be situations in which the User’s right to object to further data processing will make it impossible for SEAM Group to achieve the goal. Examples of the purposes of processing Personal Data in a legitimate interest, where the objection may be disregarded:
- Intention to pursue claims against the User or defense against potential claims on the part of the User.
- The User is a candidate recruited by a SEAM Group customer, recruitment interviews are ongoing, and the User does not want his Personal Data to be still processed.
Each case is analyzed individually. The result of the analysis, together with the decision and justification for not considering the objection, is sent to the User by SEAM Group as part of the examination of the submitted application.
If the analysis shows that SEAM Group has no prerequisites for further processing of Personal Data, the objection is accepted and SEAM Group deletes the Personal Data.
With regards to the right not to be subject to decisions based solely on automated processing, including profiling – it is important that no automated activities are performed at SEAM Group. Employees compile Personal Data, as discussed in more detail in Chapter XII of this Policy. Typical automated processing activities are e.g. carrying out a creditworthiness assessment.
VII. PROCESSING OF PERSONAL DATA IN RECRUITMENT PROCESSES
As SEAM Group, we recruit for our own needs and for customers, to whom we provide specialist delivery services or specialist teams, so-called body leasing. Therefore, we would like to inform you that the data of the User – candidate (hereinfrom in this chapter: candidate) may also be processed by SEAM Group customers, as mentioned in the content of the job advertisement, indicating that we are recruiting for the customer.
The legal basis for the acquisition and processing of Personal Data for recruitment by SEAM Group is the candidate’s consent (Article 6 (1) (a) of the GDPR). At the same time, we would like to inform you that by agreeing to the recruitment processes, this consent will apply to both recruitment for a specific position included in the job advertisement, and for future recruitment for similar positions tailored to the profile and professional experience. As a candidate, you can withdraw your consent to further processing at any time, in accordance with Chapter VIII of this Policy, which, however, does not affect the lawful use of Personal Data in activities carried out on the basis of consent before its withdrawal.
However, it is important to emphasize that there is a specific scope of Personal Data obtained from the candidate, which results directly from the law – art. 221 § 1 of the Labor Code, which fills in art. 6 sec. 1 point c GDPR – a legal provision authorizing or obliging to obtain and process Personal Data. These are the following data:
- (First name(-es) and surname;
- Date of birth;
- Contact details provided by the User in the CV / cover letter;
- Education;
- Vocational qualifications;
- The history of previous employment.
Other data, incl. regarding the assessment of the candidate’s competences from previous employers, public image, SEAM Group acquires on the basis of the candidate’s voluntary consent.
As far as the sources of obtaining Personal Data for the purpose of recruitment processes are concerned, these are the following:
- Candidate applications submitted in response to job advertisements posted on portals such as pracuj.pl and on our website SEAM Group (https://www.seamgroup.com/about-us/careers/)
- Candidate’s referral system.
In this situation, the recommending person enters his data and the data of the recommended person and places a CV under the form with the User’s data. SEAM Group verifies the CV of the recommended person, received from the recommending person, in terms of the consent of the recommended person to the processing of Personal Data that meets the requirements of the GDPR. If the consent has been concluded, SEAM Group has the right to use this data for recruitment processes. - Direct contact with the candidate via social networking sites LinkedIn, Goldenline (so-called headhunting).
The SEAM Group recruiting employee contacts the candidate directly from LinkedIn / Goldenline level, sends a request for the candidate’s interest in the presented job offer and further contact. After receiving information about the interest in the offer, the employee registers the candidate in the CRM system by entering only the first and last name and contact details available on the candidate’s profile on LinkedIn / Goldenline, generates a special form to obtain consent for recruitment processes, while the recruitment is continued. Once the candidate accepts this special form, SEAM Group is entitled to carry out future recruitments – sending the candidate new job offers. - CV sent by the candidate on his / her own initiative via the form on SEAM Group web site
Recruitment for the needs of customers
As mentioned at the beginning of the chapter, SEAM Group recruits for its own needs and for its customers. Recruitment for customers is carried out:
- By posting a job advertisement with information about recruitment for the customer.
- Contact with the candidate already registered in our CRM database, in connection with participation in the previous recruitment, with the consent given to SEAM Group for the processing of Personal Data for the purpose of carrying out future recruitment processes.
- Direct contact with the potential candidate via social networking sites LinkedIn, Goldenline (so-called headhunting).
Generally, SEAM Group first recruits, conducts interviews and technical tests (verification of practical skills). The result of the interview is a decision whether the candidate will be offered to the customer or not. If so – the recruiting employee prepares a CV in a special format, consisting of the candidate’s data such as: name, date of birth, description of education, work experience, completed courses and training.
The CV prepared in this way is forwarded to the customer by an employee representing SEAM Group in contacts with the customer. The customer verifies the candidate presented and decides whether they wish to conduct an interview. If so – the customer arranges an interview with the candidate through the SEAM Group employee responsible for contact with the customer. After the interview, the customer decides whether or not to hire a candidate.
In the context of Personal Data provided to the customer and processed by him, the following issues are relevant:
- SEAM Group is the Administrator of personal data – it acquires data and processes it for the purpose of the recruitment process for work for the customer. The processing of Personal Data is based on the candidate’s consent to recruit (Article 6 (1) (a) of the GDPR).
- Transfer of Personal Data to the customer based on the legitimate interest of SEAM Group as the Personal Data Controller(Article 6 (1) (f) of the GDPR) in the form of their disclosure. The legitimate interest is manifested in ensuring the implementation of the cooperation agreement concluded with the customer for the preparation and delegation of a candidate-specialist or a team of candidates-specialists to perform the work specified in the cooperation agreement. Importantly, at the very beginning of the recruitment process, the candidate receives information that the recruitment is carried out for the customer’s needs, to perform work for them. The aforementioned consent applies to situations when SEAM Group verifies the submitted application.
- The customer becomes a separate administrator of personal data, independently provides the appropriate legal basis for the processing of the received personal data of the candidate. It obtains consent (or provides another legal basis from the GDPR) and sends an information clause to meet the GDPR requirement of art. 13-14.
- The personal data of the candidate recruited to the customer is stored by SEAM Group for a period of 2 years counted from the end of the recruitment. Importantly, this only applies to candidates rejected by the customer – who have not been hired.
- It results from the provisions in the contracts with each customer: a clause concerning the prohibition of re-offering the candidate and his professional profile for 2 years, in a situation where the candidate has already participated in the recruitment completed with a negative result.
- The candidate always has the right to withdraw consent to the processing of Personal Data, without affecting the actions taken before its withdrawal. As for the withdrawal of consent for SEAM Group (i.e. recruitment for SEAM Group’s internal needs), the procedure is described in Chapter VIII of this Policy. However, when it comes to the customer, the candidate contacts the customer using contact details provided in the information clause.
- The candidate may object to the transfer of Personal Data by SEAM Group to the customer, the processing of his data by the customer. The objection will be considered by SEAM Group, the data will be deleted, however this is equal to the candidate’s resignation from participation in the recruitment process. this means the candidate’s resignation from participation in the recruitment process.
An important issue in recruiting for customers are additional requirements on the part of some customers to carry out the so-called background check. This process consists of verifying the information provided by the candidate in the CV: information about education, work experience, completed courses, training, language skills (level of proficiency in foreign languages). Verifications are carried out by SEAM Group in accordance with the requirements specified in the cooperation agreements. They are followed by, among others:
- Certificates and diplomas,
- References from previous employers
In addition to the above, the customer may require a background check extended to include information on criminal record, credit history, and financial matters (debt). In Poland, there is a general prohibition of verification of the abovementioned information, except for the exceptions specified directly in Polish law (banking law, provisions on the rules for obtaining information on a clean criminal record, etc.). Therefore, in contracts with customers, SEAM Group agrees that the background check of the information contained in the CV is carried out by SEAM Group, and in the field of no criminal record, credit history, and financial matters, the customer conducts the background check on the candidates.
Transfer of personal data between SEAM Group companies with regards to recruitment purposes
Recruitment processes are conducted by SEAM Group independently, however, there are situations where SEAM Group seeks and recruits a candidate together with its subsidiaries. Such situations are related to recruitment for customers, especially those with extensive structures – with branches in many countries, which means that work for customers is carried out jointly, the supply of specialists or teams of specialists is carried out jointly. Joint recruitment allows the Subsidiaries to have access to the Personal Data of candidates in the CRM system belonging to SEAM Group.
In the context of the GDPR, the candidate’s Personal Data is shared with the customer. The legal basis for disclosure is a legitimate interest (Article 6 (1) (f) of the GDPR) resulting from the concluded body leasing contract with the customer, in which the customer requires the transfer of Personal Data in order to verify the candidates presented and their professional competences, whether they are adequate for the service that the Specialists would perform.
Automated decision-making, including profiling
We will not make automated decisions about you that would produce legal effects on you or similarly affect you.
VIII. PROCESSING OF PERSONAL DATA FOR MARKETING PURPOSES
By submitting an inquiry or signing up for a training, conferences or other event organized by SEAM Group, the User may consent to processing of personal data in order to receive marketing information on products and services offered by SEAM Group, including newsletters. The rules for obtaining such consent have been described in the chapter VI points 1-2 of this Policy. The consent may be withdrawn anytime taking into consideration rules defined in the chapter VIII of this Policy.
User’s consent for processing personal data (Art 6 (1) (a) of GDPR) is the legal basis for sending newsletters. It can be granted while providing one’s e-mail address in the newsletter subscription form or gated content as well as by checking a box while completing a contact or recruitment form. Providing the e-mail address in the newsletter subscription form is a clear affirmative action of consenting to processing personal data as defined in the Art 4 (11) of GDPR regarding the definition of consent as well as connected 32nd motif of GDPR explaining the clear affirmative action.
According to the abovementioned motif, a clear affirmative action includes informing SEAM Group that User’s e-mail address provided in the form may be used for sending newsletter that includes SEAM Group’s promotional information. It is one of acceptable forms of consenting to using provided e-mail address for the defined purpose (such forms also include checking a box located near the content of the consent).
Consent to sending unsolicited marketing information, according to Art. 10 of rules for electronically supplied services and Art. 172 (1) of Telecommunication Act, is provided by the user independently and separately by checking a dedicated box located near the content of the consent.
In order to obtain some materials uploaded to SEAM Group’s website, it may be necessary to complete a form that requires providing personal data. Such data will be processed according to the consent (Art 6 (1) (a) of GDRP) expressed by a clear affirmative action. If the User wishes to receive other marketing information, he/she may state so by checking a relevant box. If the User will not state so, it means that he/she is not interested in receiving other information thus SEAM Group will not send it.
Automated decision-making, including profiling
We will not make automated decisions about you that would produce legal effects on you or similarly affect you.
Information Regarding Your Data Protection Rights Under General Data Protection Regulation (GDPR)
For the purpose of this Privacy Policy, we are a Data Controller of your personal information.
If you are from the European Economic Area (EEA), our legal basis for collecting and using your personal information, as described in this Privacy Policy, depends on the information we collect and the specific context in which we collect it. We may process your personal information because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it’s not overridden by your rights
- For payment processing purposes
- To comply with the law
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. In certain circumstances, you have the following data protection rights:
- The right to access, update or to delete the personal information we have on you
- The right of rectification
- The right to object
- The right of restriction
- The right to data portability
- The right to withdraw consent
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your personal information. For more information, please contact your local data protection authority in the European Economic Area (EEA).
IX. PROCESSING OF PERSONAL DATA WHEN ORGANIZING AND CONDUCTING TRAININGS
One of the areas of SEAM Group’s activity are open and dedicated training for SEAM Group’s customers and any other interested person. Therefore, SEAM Group will process the Personal Data of Users declaring participation in training, to the extent necessary to carry out matters related to the training. Details on the purposes for which the Users’ Personal Data – training participants are processed and other information are specified in the dedicated chapter on the protection of Personal Data in the Training Regulations available at the time of enrollment for the training.
Automated decision-making, including profiling
We will not make automated decisions about you that would produce legal effects on you or similarly affect you.
XI. PROCESSING OF PERSONAL DATA IN CONNECTION WITH THE ORGANIZATION AND CONDUCTING OF COMPETITIONS
SEAM Group processes Users’ personal data in connection with organizing and conducting events. By signing up for the competition – using a special form or by sending an application to a dedicated e-mail address – the User gives consent to the processing of his Personal Data for the implementation of all activities related to the organized competition. Consent stands for the legal basis for data processing (Article 6 (1) (a) of the GDPR) expressed in the form of an explicit affirmative action. The User may at any time withdraw consent under the rights in accordance with Chapter V, but this means that he / she will not be able to continue participating in the competition. Details on the purposes for which the Users’ Personal Data – competition participants are processed and other information are specified in the dedicated chapter on the protection of Personal Data in the Training Regulations available at the time of enrollment for the competition.
Automated decision-making, including profiling
We will not make automated decisions about you that would produce legal effects on you or similarly affect you.
XII. PROCESSING OF PERSONAL DATA OF CUSTOMERS, POTENTIAL CUSTOMERS, SUPPLIERS
SEAM Group processes Personal Data of:
- Customers and suppliers – representatives of persons entered in the National Court Register, proxies as well as contact persons and delegated employees for the coordination of cooperation;
- Potential customers and suppliers – representatives entered in the National Court Register, proxies and contact persons in connection with the ongoing talks on potential cooperation.
Detailed information is presented below:
Personal Data Controller: | SEAM Group |
Source of obtaining Personal Data: | Public registers of business entities (applies to persons representing a business entity) |
Purpose of processing Personal Data | Coordination of cooperation. |
Legal basis: | Article 6 (1), point f GDPR – legitimate interest of SEAM Group as the administrator of personal data |
Scope of processed personal data | Full name |
Personal data storage period | The time of SEAM Group’s cooperation with a customer / supplier or the period of negotiations with a potential supplier / customer. |
Recipients of Personal Data | Public administration bodies authorized under the provisions of law |
Personal Data protection rights | Details are presented in Chapter V of this Policy |
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Automated decision-making, including profiling
We will not make automated decisions about you that would produce legal effects on you or similarly affect you.
XIV. SECURITY
SEAM Group has implemented appropriate (organizational and technical) security measures to protect personal data from loss, misuse, unauthorized processing or modification. SEAM Group is obliged to protect any information disclosed by Users in accordance to security and confidentiality standards.
XV. COOKIES
SEAM Group declares that www.seamgroup.com and other websites that belong to SEAM Group use cookies. By using this website, the User agrees to the storage of cookies on his/her device as explained below.
Settings regarding cookies used on the www.seamgroup.comand other websites may be modified via our website or via a third-party website. Cookies are used to:
- Customize content of webpages to User’s preferences, and to optimize their use (in particular, these files allow identification of User’s device and proper display of the webpage tailored to their individual needs),
- Create statistics that help to understand how Users use the websites which leads to improving its structure and content,
- Deliver m content tailored to Users’ interests.
Types of cookies used by SEAM Group:
- “Essential” cookies that enable the use of services available through the site e.g. allowing the use of sessions;
- “Functional” cookies that allow the website to “remember” settings chosen by the User and personalize the interface e.g. in terms of selected mobile/desktop version, the last phrases typed by the User, website’s appearance etc.;
- “Analytical” cookies that allow us to monitor the activity of Users on the website.
The User may block saving cookies by changing his/her browser settings. Disabling cookies may affect the functioning of the website. No change in User’s browser settings means accepting the use of cookies.
XVI. MODIFICATIONS TO THE POLICY
In relation to the development and progress of technology and changing regulations, the principles set out in this Privacy Policy may change. Any changes to these rules will be communicated to Users by publishing the new contents of this document on the www.seamgroup.com/privacy-policy/ website