PRIVACY POLICY
- for personal data of job applicants -
Date of publication: 13-06-2025
1. Who we are and how you can find us
KOLOMOLO sp. z o.o. with its registered seat in Kraków (address: ul. Grzegórzecka 8/2, 31-530 Kraków, Poland), entered into the registry of entrepreneurs of the National Court Register under the number: 0000960241 (hereinafter referred to as: „KOLOMOLO” or “We”) is a controller of job aplicants’ personal data obtained within recruitment process. You can contact us via e-mail to the address: contact@kolomolo.com
2. Why do we process your personal data
If we consider you a suitable candidate, we process your personal data in order to ensure your participation in the recruitment process.
We will process your data in order to:
- contact you and conduct the recruitment process,
- evaluate your qualifications for work at the position you are applying for,
- evaluate your abilities and skills necessary to work at the position you are applying for,
- ensure your participation in future recruitment processes.
3. What personal data do we process and under what legal basis
We may process the following data of job applicants:
- name(s) and surname(s);
- date of birth;
- contact details indicated by such a person (e.g. correspondence address, e-mail address, telephone number);
- education;
- professional qualifications;
- employment history;
- other personal data contained in your application documents such as CV, motivation letter, letter of reference or others;
- personal data made publicly available on business or professional social media;
- other personal data acquired during an interview to the extent permitted by law.
Personal data of job applicants indicated in points d) – f) above may be asked for only when required to perform work of a specific type or in a specific position. At KOLOMOLO, we need to analyse your education, professional qualifications and employment history to understand if you will be able to perform your future responsibilities successfully.
We may ask for other data than those mentioned in points a) – f) above only if it is necessary to exercise rights or to fulfil an obligation arising from the law provision. However, they still can be processed under your consent.
The legal basis for the processing of your personal data is:
- in relation to personal data mentioned under points a) – f) above – a provision of law and the necessity of processing to take steps at your request prior to entering into a contract [Article 6 par. 1 point b) 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, hereinafter referred to as: the “GDPR”];
- in relation to personal data mentioned under point g) above (not applicable to personal data relating to criminal convictions and offences should you include them in your application documents) – your consent [Article 6 par. 1 point a) of the GDPR]. You can withdraw your consent at any time by contacting us. Note that such withdrawal will not affect the lawfulness of processing based on consent before its withdrawal;
- in relation to personal data mentioned under point h) above – the necessity of processing for the purposes of pursuing our legitimate interests [Article 6 par. 1 point f) of the GDPR]. We have a legitimate interest in actively searching for potential job candidates by looking through their publicly available profiles on business or professional social media (eg. LinkedIn, your organization’s website), otherwise we would not be able to judge whether you might be interested in a given position.
- in relation to personal data mentioned under point i) above – the necessity of processing for the purposes of pursuing our legitimate interests [Article 6 par. 1 point f) of the GDPR]. We have a legitimate interest in verifying your skills and abilities – it is necessary to assess whether you are the right person for the position we are recruiting for.
If the data you provide to us includes sensitive data, we will process it only on the basis of your express and separate consent. The consent may be withdrawn at any time by contacting us at: contact@kolomolo.com. Note that such withdrawal will not affect the lawfulness of processing based on consent before its withdrawal. In the absence of the consent data will be deleted immediately.
If you give your consent to this, KOLOMOLO will also store and process your personal data for the purposes of future recruitment processes. You can withdraw your consent at any time by contacting us. Note that such withdrawal will not affect the lawfulness of processing based on consent before its withdrawal.
4. To whom we disclose your personal data
We may disclose your data to external entities providing services to us, including legal, hosting, IT or consulting services. Your data may also be made disclosed to entities providing us with IT and other technical, technological and organizational solutions used in the current operations of our company.
We may share information about you to entities that, as part of their business, are professionally engaged in conducting recruitment and talent search processes or provide tools or software to improve these processes.
We may also publish job offers through specialized online job portals. You can find detailed information regarding the processing of your personal data in the privacy policies posted on these sites.
The operations described above may involve (due to the location of some entities’ headquarters or servers) the transmission of your data to the so-called third countries (outside the European Economic Area), where the GDPR is not applicable. However, this always happens on the basis of legal instruments provided for in the GDPR, guaranteeing adequate protection of your rights and freedoms.
In the case of the transfer of personal data to a third country within the meaning of the GDPR, when the European Commission has not issued a decision on the adequate protection of personal data for those countries (in accordance with Article 45 of the GDPR), we take appropriate measures to ensure an adequate level of data protection in the event of transfer. These include the European Union's standard contractual clauses or binding internal data protection regulations. In cases where this is not possible, we base the transfer of data on the exceptions described in Article 49 of the GDPR, in particular express consent or the necessity of the data transfer to fulfill the terms of the contract or to perform pre-contractual activities. The legal basis for data transfers to third countries is therefore, unless otherwise stated, the consent referred to in Article 6(1)(a) of the GDPR in conjunction with Article 49(1)(a) of the GDPR. At the same time, we would like to inform you that in the case of sending data to a third country for which no decision on adequate protection of personal data or adequate guarantees have been issued, there is a possibility and risk that authorities in the third country will gain access to the transferred data for the purpose of collection and analysis, and that the possibility of enforcing the rights of data subjects cannot be guaranteed.
5. How long do we process your personal data
Your personal data is processed until the end of the recruitment process related to the position for which you are applying. After this time, they are delated, unless you expressed your consent for processing your personal data for the purposes of future recruitment processes. In such case your data will be stored for up to 12 months.
Sensitive data that we have received from you without an explicit and separate consent for its processing will be deleted immediately.
In the event when we obtain your personal data from publicly available sources (social media of a business or professional nature), we contact you no later than 30 days from obtaining the data (in accordance with Article 14 par. 3 of the GDPR).
6. How we enable you to exercise your rights
We strive to make you happy with working with the recruitment process in which you participate. Remember, however, that you have many privileges that will allow you to influence the way we process your personal information, and in some cases cause you to stop such processing. These rights are:
1) the right of access by the data subject (regulated in Article 15 of the GDPR)
Article 15
Right of access by the data subject
- The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
- the right to lodge a complaint with a supervisory authority;
- where the personal data are not collected from the data subject, any available information as to their source;
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
- Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.
- The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
- The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.
2) right to rectification of your data (regulated in Article 16 of the GDPR)
Article 16
Right to rectification
The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
3) right to erase your data (regulated in Article 17 of the GDPR)
Article 17
Right to erasure (‘right to be forgotten’)
- The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
- the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;
- the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
- the personal data have been unlawfully processed;
- the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
- the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).
- Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
- Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
- for exercising the right of freedom of expression and information;
- for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);
- for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
- for the establishment, exercise or defence of legal claims.
4) right to restrict of processing of your data (regulated in Article 18 of the GDPR)
Article 18
Right to restriction of processing
- The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
- the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
- the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
- the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
- the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.
- Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
- A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.
5) right to data portability of your data (regulated in Article 20 of the GDPR)
Article 20
Right to data portability
- The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
- the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and
- the processing is carried out by automated means.
- In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
- The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
- The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.
6) right to object to the processing of your data (regulated in Article 21 of the GDPR)
Article 21
Right to object
1. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.
3. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
4. At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.
5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.
6. Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To use any of the rights described above, please contact us by e-mail at the address we contacted you or at the address: contact@kolomolo.com
7. Complaint to the supervisory authority
According to Article 77 of the GDPR you are entitled to submit a complaint to the supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place where the alleged violation is committed, if you believe that the processing of personal data regarding you violates the provisions of the GDPR.
In Poland, the supervisory body is the President of the Office for Personal Data Protection. You can make a complaint, among others by traditional mail to the following address: ul. Stawki 2, 00-913 Warsaw, Poland or electronically through portal ePUAP2. You can also get more detailed information on the website: https://uodo.gov.pl/ ;
To contact another supervisory authority responsible for the protection of personal data, please visit the website of the European Data Protection Board available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en ;
8. Is the provision of data necessary to conclude an agreement with us
At this point we do not conclude any agreement with you.
9. Where did we obtain your data
You probably responded to our job advertisement yourself or applied via a specialized job portal or by writing an e-mail to us. In this case, we received the first part of the data from you.
It is also possible that we have found information about you, for example by browsing your publicly available profiles on business or professional social media, or someone recommended you to us as a good specialist.
Sometimes we use the services of professional entities that, as part of their business, professionally conduct recruitment processes and find talent. In such a case, a recruitment company will first contact you on our behalf and your candidacy will be presented to us at a later stage.
10. Automated decision-making and profiling
We do not make decisions in an automated manner or subject any personal data to profiling as understood by the GDPR.
