PRIVACY POLICY

As of July 24, 2018

1. This “Privacy Policy” document (hereinafter referred to as “Policy”) sets out the rules for processing personal data of users in the fairplacefinance.pl domain (hereinafter referred to as “Website”).
2. The policy is a document fulfilling the information obligation described in Article 13 of Regulation of the European Parliament and of the Council (EU) 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC (Journal of the EU L 119, p. 1) (general regulation on data protection) (hereinafter referred to as “GDPR”) in relation to persons visiting the Website and making their personal data available through it.
3. The security rules in accordance with the GDPR shall apply to personal data processed through the Website.
4. The data controller is Fair Place Finance spółka z ograniczoną odpowiedzialnością (hereinafter referred to as “Fair Place Finance”) based in Łódź, ul. Jaracza 52, 90 – 249 Łódź, entered into the Register of Entrepreneurs of the National Court Register under the number of KRS 0000587029, for which the register files are kept by the District Court for Łódź – Śródmieście in Łódź, XX Economic Department of the National Court Register, REGON: 363023758, NIP: 7322177021.
5. The user’s personal data is collected and further processed by Fair Place Finance for purposes related to the implementation of individual functionalities of the Website. In particular, the following functionalities are available on the Website:
   • recruitment,
   • contact form,

   Additionally, the Website is monitored by means of appropriate analytical tools and for this purpose special files called “cookies” are used, described in detail below, as well as in the “Cookies Policy” available on the Website.
   Providing data is always voluntary in these cases.

6. Fair Place Finance processes personal data respecting the following rules:
   • based on the legal basis and in accordance with the law (legalism);
   • honestly and honestly (reliability);
   • in a transparent manner for the data subject (transparency);
   • for specific purposes and not “for spare”, no more than necessary (minimization);
   • with attention to data accuracy (correctness);
   • no longer than needed (temporality);
   • ensuring adequate data security (security).
7. Depending on the purpose for which the user data is processed, Fair Place Finance indicates the appropriate legal basis for the processing of user data,
   • implementation of the so-called legally legitimate interests, e.g. accepting a contact inquiry and replying to it – Article 6 item 1 letter f) of the GDPR;
   • processing necessary to fulfill the legal obligation incumbent upon the controller, e.g. when it is necessary to disclose personal data to public authorities – Article 6 item 1 letter c of the GDPR;
   • when the user is asked to consent to the processing of data for a designated purpose and this consent is expressed in Article 6 item 1 letter a) of the GDPR.
8. The scope of data collected automatically includes data of the user’s web server protocol. We only activate logging in exceptional cases to investigate cases that require support and to guarantee the stability and security of the Website server’s integrity (Article 6 item 1 letter f) of the GDPR).
   Each data set contains:\

    

   • date and time of calling;
   • client and server IP address, port and protocol status;
   • name of the file or page being called and the time of the call;
   • information on logging in to the relevant internet service, as long as the user logs in to their account;
   • browser type and referrer (last client’s open page).
9. Fair Place Finance declares that we use cookies on the Website. By using the Website, the user consents to the implementation of cookies in the terminal device (telecommunications device intended for connecting directly or indirectly to the ends of the Internet, including: phone, smartphone, computer or tablet) (hereinafter referred to as “Device”), as explained below .Cookies are used to:

    

   • adjusting the content of the Website to the user’s preferences and optimizing the use of the Website; in particular, these files allow to recognize the user’s Device and properly display the Website, adapted to their individual needs;
   • creating statistics that help to understand how the user uses websites, which allows improving its structure and content;
   • providing the user with advertising content more tailored to their interests.

   Cookie files are small files containing a string of characters in which specific information is stored in an open or encrypted manner. Cookies are sent by the server to the user’s Device and saved there. They are used initially to identify the Device through which the Website is opened. Each cookie has an expiration date after which it expires.. By means of cookies, the user’s way of moving on the Website, as well as on other websites can be tracked. Cookies improve the communication between our server and the user’s Device, thus making the use of the Website more comfortable. Cookies can come not only from the owner of the Website, but also from other entities. Using the browser, the user can display cookies stored on the Device, delete them or set such configuration so that only selected cookies are saved, or that no cookies are saved at all. Keep in mind that if you deactivate saving cookies, some functions on the Website will not work or will not work properly.

   We use the following cookies on the Website:

   • “necessary” cookies, enabling the use of services available on the Website;
   • cookies used to ensure security;
   • “performance” cookies, enabling the collection of information about the use of the Website;
   • “functional” cookies, allowing “remembering” the settings selected by the user
   • “advertising” cookies, enabling the delivery of advertising content to the user more tailored to their interests.

   Cookies are classified as follows:

   1. session cookies that are deleted from the Device’s memory after the end of a given browser session or when the user’s end device is turned off. The mechanism of session cookies does not allow the collection of any personal data or any confidential information from the user’s device;
   2. permanent cookies that are stored in the user’s Device memory, remaining there until they are deleted or expired. The mechanism of persistent cookies does not allow the collection of any personal data or any confidential information from the user’s Device.

   Fair Place Finance uses external cookies in order to:

   • presenting on the Website a map indicating the location of the Fair Place Finance headquarters, via the online service maps.google.com (external cookies administrator: Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA.). The use of Google maps is intended to make the Website more attractive and to facilitate the location of sites designated by us on the Website. This constitutes a legitimate interest in accordance with Article 6 item 1 letter f) of the GDPR;
   • collecting general and anonymous statistical data via analytical tools of Google Analytics (external cookie administrator: Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA). Google Analytics cookies are stored on the basis of Article 6 item 1 letter f) of the GDPR. The Website operator has a legitimate interest in analyzing the user’s behavior in order to optimize both the Website and the ad;
   • Website tag management (tag) via Google Tag Manager (external cookie administrator: Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA). This tool allows the operation of other tags that can collect data under certain circumstances. Google Tag Manager does not use this data. Additional information about Google Tag Manager is included in the usage guidelines for this product: http://www.google.com/analytics/tag-manager/use-policy/. The legal basis for the processing of user data is Article 6 item 1 letter f) of the GDPR.

   The user may at any time have the option to disable or restore the cookie collection option by changing the settings in the web browser.

10. From the candidate for work (hereinafter referred to as “Job Applicant”) at Fair Place Finance, we collect the basic data stipulated in
    Article 22 [1] item 1 of the Act of 26 June 1974 Labor Code (Journal of Laws from 2018 position 0 no. 917 consolidated text), such as name (s) and surname, date of birth, education, course of previous employment, as well as other personal data when it is necessary to fulfill the employer’s obligation imposed by the law. Providing these data by the Job Applicant is a statutory requirement as to the Job Applicant employed under an employment agreement. As long as there is a legal obligation in this scope, their application is voluntary, however, consequence of their failure to do so shall result in inability to establish an employment. When sending CV to Fair Place Finance, the Job Applicant may also provide other data, such as their image captured in the photo. Providing this data by the candidate is entirely voluntary, which finds the legal basis of Article 6 item 1 letter a) of the GDPR. Fair Place Finance processes personal data only if:

     

    1. processing is necessary to perform contractual obligations towards the Job Applicant or as required by the Job Applicant is necessary to take specific actions before the conclusion of the employment agreement (Article 6 item 1 letter f) of the GDPR), including to carry out the recruitment process;
    2. processing is necessary in order to fulfill our legal obligations or if it is directly required by law, i.e. Article 22 [1] of the Labor Code in conjunction with Article 6 item 1 letter c) of the GDPR);
    3. processing is necessary for the realization of Fair Place Finance’ legitimate interests and does not unduly affect the interests of the Job Applicant or fundamental rights and freedoms (Article 6 item 1 letter f) of the GDPR). The legitimate interests are the instigation or establishing by Fair Place Finance of civil claims in the course of its activity, as well as the defense against such claims;
    4. in some cases, when we obtained the prior consent of the candidate (Article 6 item 1 letter a) of the GDPR) – that applies in particular to consents for the processing of data for the purpose of further recruitment. If Fair Place Finance processes personal data of the Job Applicant on the basis of consent, it may be revoked at any time in the same simple manner as it was given. Failure to agree to the processing of data to which the candidate is not required will not result in refusal to establish a work relationship with a given candidate, and its cancellation will not result in negative consequences for a specific candidate.

    Fair Place Finance processes personal data of the candidate in order to:

    1. take recruitment activities;
    2. preparation of the Job Applicant’s employment agreement;
    3. compliance with the legal obligations imposed on Fair Place Finance;
    4. use of data in further recruitments conducted by Fair Place Finance – if given consent by a individual Job Applicant.
11. The period of storage of personal data depends on their processing in order to:
    • recruitment – throughout the recruitment process, not longer than 6 months. After this time, the personal data of the candidate regarding information about the recruitment will be processed during the expiration period for civil claims in order to allow Fair Place Finance to defend against any claims or to seek such claims if there is a risk of such claims being filed against or against Fair Place Finance; as a rule, it is not longer than 3 years from the end of the recruitment process. If the candidate agrees, the personal data of the candidate may be stored for use in further recruitment conducted by Fair Place Finance for a period of up to one year;
    • for other purposes listed in the Policy – for a period of one year, except that the period of data processing included in the personal and payroll documentation of Fair Place Finance covers 50 years from the end of the employment relationship.
12. Fair Place Finance entrusts the processing of personal data to the service providers it uses, who, depending on the contractual arrangements, are either subject to Fair Place Finance recommendations regarding the purposes and methods of data processing (then acting as processors) or independently define the goals and methods of their processing (acting then as controllers). Fair Place Finance uses the services of suppliers who process your personal data only on our instructions. They provide the service of traffic analysis and website hosting for Fair Place Finance. Fair Place Finance provides personal data of the user if such requests are requested by authorized state authorities, in particular the courts, organizational units of the prosecutor’s office and the police, the President of the Office for Personal Data Protection, the President of the Office of Electronic Communications or the President of the Office of Competition and Consumer Protection.
13. Fair Place Finance informs that in accordance with the provisions of Chapter III, contained in Articles 15-21 of the GDPR, the user has the following rights in connection with the processing of their personal data by Fair Place Finance:
    • the right to access their personal data
    • the right to rectify the data being processed;
    • the right to delete data – the so-called “the right to be forgotten”
    • the right to limit data processing
    • the right to data transfer
    • the right to object to the further processing of data.

    The implementation of each of the above-listed rights takes place at the user’s request, submitted by e-mail to the following e-mail address: kontakt@fairplacefinance.pl. Fair Place Finance resolves the application and sends the response within one month of the day it receives application. As part of the exercise of his rights, the user may also at any time withdraw consent to the further processing of personal data for purposes that require consent, with the reservation that the withdrawal of consent does not affect the legal use of personal data in activities undertaken on the basis of consent before its withdrawal. Fair Place Finance reserves that we have the functional right to respond to the user’s request later than the above (up to two months), where the criteria are the number of requests or the complexity of the request sent. Complicated nature means the necessity to compile data from many IT environments or the necessity to consult the content of the application with more than one person from a given controller`s department or controller’s departments in order to obtain information subject to the user’s request. In such situations, Fair Place Finance undertakes to inform the user about the occurrence of such an event, giving the actual justification every time.

14. We have implemented appropriate organizational and technical security measures to protect personal data against loss, misuse, unlawful processing or modification. Fair Place Finance undertakes to protect all information disclosed by the user in accordance with security and confidentiality standards. Access to this personal data has been limited in a restrictive way, so that this information is not in the hands of unauthorized persons.
15. This Privacy Policy may at any time be amended by Fair Place Finance in whole or in part and shall apply in a new wording from the time it is published on the Website.​

COOKIES POLICY

The website does not automatically collect any information, except for information contained in cookie files. Cookie files (so-called “cookies”) are IT data, in particular text files, which are stored in the website user’s end device and are intended for using the website. Cookies usually contain the name of the website from which they originate, their storage time on the end device and an unique number. The subject that places cookies on the website user’s end device and who has access to them is the website administrator.
Cookies are used to:

• adjusting the content of the website pages to the user’s preferences and optimizing the use of websites; in particular, these files allow to recognize the device of the website user and properly display the website, tailored to his individual needs;
• creating statistics that help to understand how the website users use them.

The website uses the following types of cookies:

• necessary cookies, enabling the usage of services available on the website,
• cookies used to ensure security,
• performance cookies, enabling the collection of information on the use of website pages;
• functional cookies that enable “memorizing” settings selected by the user and personalization of the user’s interface,
• advertising cookies, which enable users to provide advertising content more tailored to their interests.

In many cases, software used for browsing websites (web browser) allows cookies to be stored in the user’s device by default. Website users can change their cookie settings at any time. These settings can be changed in particular in such a way as to block the automatic handling of cookies in the web browser’s settings or inform them of each entry in the device of the website user. Detailed information about the possibilities and ways of handling cookies are available in the software (web browser) settings.

The website administrator informs that restrictions on the use of cookies may affect some of its functionalities.
Cookies placed on the website user’s end device may also be used by advertisers and partners cooperating with the website administrator.