PRIVACY POLICY
Effective date: 31st Jan, 2025
Information on the Processing of Personal Data at Joras Ventures Sp. Z O.O.
DEFINITION
* Personal Data Administrator: Joras Ventures Sp. Z O.O.
* Personal Data: Any information relating to an identified or identifiable natural person ("data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
* Policy: This Privacy Policy.
* GDPR: 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.
* Service: The website jorasventures.com (the "Website") and the recruitment and employment services provided by Joras Ventures.
* User: Any individual who visits the Website or uses one or more of the Services described in the Policy, including job seekers and potential employers.
TRANSPARENCY OF PERSONAL DATA
1. Joras Ventures Sp. Z O.O. collects and processes personal data in connection with its commercial activities as an employment agency, specializing in connecting job seekers with employers, and providing employment leasing services. This is done in accordance with applicable law, including, in particular, the GDPR and the Personal Data Protection Act of 10 May 2018, and the data processing rules provided therein.
2. The Administrator always provides information about the processing of data when collecting it, including the purpose and legal basis for processing. Joras Ventures collects personal data only to the extent necessary for the stated purpose and processes it only for the required period of time.
3. Joras Ventures ensures the security and confidentiality of personal data that is processed and provides data subjects with access to information about such processing. In the event that, despite the security measures taken, a breach of personal data protection occurs (e.g., a “leak” or loss of data), Joras Ventures informs the personal data subjects about such an event in accordance with the law.
ADMINISTRATOR CONTACT DETAILS
Joras Ventures Sp. Z O.O.
Address: Ul. Solipska 3 / 5, 02-482 Warszawa, Poland
E-mail: info@jorasventures.com
HOW WE ENSURE THE SECURITY OF PERSONAL DATA
1. In order to protect the confidentiality of data, Joras Ventures has implemented procedures that allow access to personal data only to authorized persons and only to the extent necessary in connection with the tasks they perform. Joras Ventures applies organizational and technical solutions to ensure that all operations with personal data are recorded and performed only by authorized persons.
2. Joras Ventures shall also ensure that all organizations cooperating with it provide guarantees for the application of appropriate security measures when processing personal data on behalf of Joras Ventures. This includes, but is not limited to, data hosting providers and other service providers used in the recruitment process.
3. Joras Ventures analyzes the risks and continuously monitors the correctness and effectiveness of the data security measures applied, and checks and identifies any risks associated with data processing. This includes regular security audits, penetration testing, and employee training on data protection best practices.
DATA PROCESSING IN CONNECTION WITH THE USE OF THE WEBSITE AND SERVICES
In connection with the User's use of the Website and our Services, Joras Ventures collects data to the extent necessary to provide the services offered, as well as information about the User's activity on the Website. The principles and purposes of processing personal data obtained during the User's use of the Website and Services are described in detail below.
PURPOSES AND LEGAL BASIS FOR DATA PROCESSING ON THE WEBSITE AND SERVICES
Using the jorasventures.com Website
1. Personal data of all persons using the Service (including IP address or other identifiers, as well as information collected using cookies or other similar technologies) and who are not registered Users (i.e. persons who do not have a profile on the Service) are processed by Joras Ventures:
* For the purpose of providing services in electronic form within the framework of providing Users with content collected on the Site, providing an offer of Joras Ventures' services, providing contact forms - in this case, the legal basis for processing is the need for processing to fulfill the agreement (Article 6(1)(b) of the GDPR).
* For analytical and statistical purposes - in this case, the legal basis for processing is the legitimate interest of Joras Ventures (Article 6(1)(f) of the GDPR), which consists in analyzing the activities of Users, as well as their preferences, in order to improve the functionality used and the services provided.
* For the purposes of possible establishment, investigation, or defense of claims - the legal basis for processing is the legitimate interest of Joras Ventures (Article 6(1)(f) of the GDPR); consisting in the protection of its rights.
* For the marketing purposes of Joras Ventures - the legal basis for processing is the legitimate interest of Joras Ventures (Article 6(1)(f) of the GDPR) in promoting its services, where this is consistent with the user's preferences, or based on explicit consent where required.
2. The User's actions on the Site, including their personal data, are recorded in system logs (a special computer program used to maintain a chronological record containing information about events and actions in relation to the IT system used to provide services by Joras Ventures). The information collected in the logs is processed in connection with the provision of services. Joras Ventures also processes them for technical purposes, in particular, data may be temporarily stored and processed to ensure the security and proper functioning of IT systems, for example, in connection with the creation of security copies, testing changes to IT systems, detecting violations or protecting against abuse and attacks.
Job Applications and Recruitment Services
1. When you apply for a job through our Website or otherwise provide us with your CV/resume and other personal information, we process your data for recruitment purposes. This includes:
* Personal data collected: Name, contact details (email, phone number, address), nationality, passport details, visa information (if applicable), date of birth, education and employment history (CV/Resume), skills and qualifications, job preferences, language proficiency, and any other information you provide.
* Purposes of processing:
* To assess your suitability for job vacancies.
* To communicate with you regarding your application and the recruitment process.
* To share your information with potential employers (with your consent).
* To manage and administer our recruitment processes.
* Legal basis for processing: The legal basis for processing is the necessity of processing for the performance of a contract (Article 6(1)(b) of the GDPR) and/or the legitimate interest of Joras Ventures in conducting recruitment activities (Article 6(1)(f) of the GDPR), where applicable. Your explicit consent will be obtained before sharing your data with potential employers.
2. If we find a suitable match for your profile and you give us permission, your data will be shared with potential employers (clients).
3. We may also use third-party service providers (e.g., background check services, language assessment tools) to assist in the recruitment process. These providers will be contractually obligated to protect your personal data.
Employer Services and Employment Leasing
1. When you engage Joras Ventures as an employer or client, we process your data for the purpose of providing employment leasing services. This includes:
* Personal data collected: Contact details, company information, job descriptions, requirements for the employees, payment information, and communication records.
* Purposes of processing:
* To match your staffing needs with suitable candidates.
* To manage employment contracts and payroll.
* To provide ongoing support and communication.
* Legal basis for processing: The legal basis for processing is the necessity of processing for the performance of a contract (Article 6(1)(b) of the GDPR) and the legitimate interests of Joras Ventures in managing client relationships (Article 6(1)(f) of the GDPR).
Contact Forms
1. As part of the Service, it is possible to contact Joras Ventures using electronic contact forms. Using the form requires the User to provide personal data necessary to contact him/her and respond to a request or provide an offer. The User may also provide other data to facilitate contact or service. Providing data marked as mandatory is necessary to receive and process a request, and failure to provide such data will result in the impossibility of providing services. Providing other data is voluntary.
2. Personal data must be processed:
* To identify the sender and process his/her request sent via the form provided - the legal basis for processing is the need for processing to fulfil the contract for the provision of services (Article 6(1)(b) of the GDPR);
* For analytical and statistical purposes - the legal basis for processing is the legitimate interest of Joras Ventures (Article 6(1)(f) of the GDPR); which consists in maintaining statistics on requests sent by Users through the Website in order to improve its functionality;
* To conduct satisfaction surveys, in particular by sending messages to an e-mail address with a request to complete a satisfaction survey - the legal basis for processing is the legitimate interest of Joras Ventures (Article 6(1)(f) of the GDPR) in maintaining a high quality of service and the level of satisfaction of Users with the services offered.
Marketing Activities as part of the Service's activities
1. Joras Ventures processes the personal data of Users for the purpose of carrying out marketing activities, which may include the following:
* Showing you marketing content that does not take into account your preferences (contextual advertising);
* Sending e-mail notifications about interesting offers and services, which in some cases contain commercial information;
* Implementation of direct marketing of goods and services (distribution of commercial information via e-mail and telemarketing).
2. In order to carry out marketing activities, Joras Ventures in some cases uses profiling. This means that by means of automated data processing Joras Ventures evaluates individual factors concerning individuals in order to analyze their behavior or make a forecast for the future.
Newsletter service
1. For those who have provided their e-mail address for this purpose, a newsletter service is available on the Website. Providing data is necessary for the provision of the newsletter service, and failure to comply will result in the newsletter not being sent. This form of communication with the User may include profiling.
2. Personal data is processed within the framework of the newsletter service:
* For the provision of the newsletter service - the legal basis for processing is the necessity of processing for the performance of the contract (Article 6(1)(b) of the GDPR);
* For sending marketing content to the User as part of a mailing list - the legal basis for processing, including using profiling, is the legitimate interest of Joras Ventures (Article 6(1)(f) of the GDPR) in connection with consent to receive the mailing list;
* For analytical and statistical purposes - the legal basis for processing is the legitimate interest of Joras Ventures (Article 6(1)(f) of the GDPR), which consists in analyzing the activity of Users on the Site in order to improve the functional capabilities used;
* For the purposes of possible presentation and investigation of claims or defense against claims - the legal basis for processing is the legitimate interest of Joras Ventures (Article 6(1)(f) of the GDPR), which consists in protecting its rights.
DIRECT MARKETING ACTIONS
If the User has given consent to receive marketing information via email, SMS and other means of electronic communication using forms posted on the Site, the User's personal data will be processed for the purpose of sending such information. The basis for data processing is the Administrator's legitimate interest in sending marketing information within the framework of the User's consent (direct marketing). The User has the right to object to the processing of data for direct marketing purposes, including profiling. The data will be stored for these purposes for the entire duration of the Administrator's legitimate interest, unless the User objects to receiving marketing information.
SOCIAL MEDIA
Joras Ventures processes the personal data of Users visiting Joras Ventures' profiles maintained on social networks (Facebook, LinkedIn, etc.). This data is processed solely in connection with maintaining the profile, including for the purpose of informing Users about Joras Ventures' activities and promoting various offers, events or services, as well as for the purpose of communicating with Users through the specified social networks. The legal basis for Joras Ventures' processing of personal data for these purposes is its legitimate interest (Article 6(1)(f) of the GDPR), which consists in promoting Joras Ventures' commercial brand and maintaining contacts with the community associated with this brand.
COOKIES AND OTHER SIMILAR TOOLS
1. We use cookies on our website, which contain information that allows us to tailor content to your needs, improve the performance of our website and analyze traffic to our website.
2. If you do not agree with our use of cookies or want to limit their use, you can refuse to use our website or change your browser settings. You should be aware that limiting or exclusive use of our cookies may affect some of the features available on our website. For more information on how to change your cookie settings, please visit your browser's Help menu.
* Types of Cookies Used:
* Essential cookies: These are necessary for the basic functionality of the Website.
* Functional cookies: These remember your preferences (e.g., language).
* Analytical/Performance cookies: These help us analyze Website traffic and performance.
* Marketing cookies: These are used to track your browsing activity to show you relevant ads.
* Third-Party Cookies: We use cookies from the following third parties:
* Google Analytics:
Google Analytics cookies are files used by Google to analyze your use of the Website, to compile statistics and reports on the Website’s activity. Google does not use the data collected to identify you personally, nor does it combine this information to identify you.
* Google Ads:
Google AdWords is a tool that allows us to evaluate the effectiveness of advertising campaigns conducted by the Administrator and analyze data such as keywords or the number of unique users. The Google Adwords platform also allows us to display our advertisements to people who have visited the Website in the past.
* Facebook Pixel:
Facebook Pixels is a tool for measuring the effectiveness of advertising campaigns conducted by the Administrator on Facebook. The tool allows for advanced data analysis to optimize the Administrator's activities, as well as use other tools offered by Facebook.
* Social Plugins
The Service uses plugins for social networks (Facebook, YouTube, Instagram, LinkedIn, TikTok). Plugins allow the User to make content published on the Site available to the social network of their choice. Using plugins on the Service results in the social network receiving information about the User's use of the Service and may assign it to the User's profile created on the social network. The Administrator has no idea about the purposes and extent of data collection by social networks. Detailed information on this issue can be found on the portals of the specified social networks.
PERIOD OF PROCESSING PERSONAL DATA
1. The period of data processing by Joras Ventures depends on the type of services provided and the purpose of processing. As a rule, data is processed for the entire period of service provision or order fulfillment, until the expressed consent is revoked or an effective objection to data processing is made in cases where the legal basis for data processing is the legitimate interest of Joras Ventures.
2. The data processing period may be extended in cases where the processing is necessary to establish, assert or defend against possible claims, and then only if and to the extent required by law. Upon expiry of the processing period, the data must be irrevocably deleted or anonymized.
USER RIGHTS
1. Data subjects have the following rights:
* The right to information about the processing of personal data - on this basis, Joras Ventures provides the person who made such a request with information about the processing of personal data, including, in particular, the purposes and legal grounds for processing, the volume of stored data, the subjects to whom the personal data are disclosed, and the planned date of their deletion;
* The right to receive a copy of the data - on this basis, Joras Ventures provides a copy of the processed data concerning the person who made the request;
* The right to make corrections - on this basis, Joras Ventures corrects any inconsistencies or errors in the personal data being processed, and also supplements or updates them if they are incomplete or have changed;
* Right to erasure (Right to be forgotten) - on this basis you may request the erasure of data the processing of which is no longer necessary for any of the purposes for which it was collected;
* The right to restrict processing - on this basis, Joras Ventures ceases to perform operations with personal data, with the exception of operations to which the data subject has given consent, and their storage in accordance with the adopted storage rules, or until the reasons for restricting processing disappear (for example, a decision of the supervisory authority is made permitting further processing);
* Right to data portability - on this basis, to the extent that the data are processed in connection with a concluded contract or consent obtained, Joras Ventures must issue the data provided by the data subject in a computer-readable format. It is also possible to request that the data be sent to another subject - provided, however, that both Joras Ventures and the other subject have the technical capacity to do so;
* Right to object to processing for marketing purposes - the data subject may at any time object to the processing of personal data for marketing purposes without having to justify such objection;
* Right to object to the processing of data for the purposes of a satisfaction survey - the data subject may at any time object to the processing of personal data for the purposes of a satisfaction survey, in particular to sending messages to an e-mail address asking for an opinion (feedback) or to complete a satisfaction questionnaire, without having to justify such objection;
* Right to object to other purposes of processing - the data subject may at any time object to the processing of personal data on the basis of the legitimate interests of Joras Ventures (e.g. for analytical or statistical purposes or for reasons related to the protection of property). The objection in this regard must contain justification and is subject to assessment by Joras Ventures;
* Right to withdraw consent - where data is processed on the basis of consent, the data subject has the right to withdraw it at any time, but this does not affect the lawfulness of the processing carried out before the withdrawal of such consent;
* Right to lodge a complaint - if the processing of personal data is considered to be in breach of the GDPR or other data protection legislation, the data subject may lodge a complaint with the President of the Data Protection Authority (Prezes Urzędu Ochrony Danych Osobowych (UODO)).
2. A request to exercise the rights of data subjects can be submitted:
* in writing to the address: Joras Ventures Sp. Z O.O., Ul. Solipska 3 / 5, 02-482 Warszawa, Poland;
* by e-mail to: info@jorasventures.com
3. The request should, as far as possible, indicate precisely what exactly is being requested.
4. If Joras Ventures cannot determine the content of the request or identify the applicant based on the notification received, Joras Ventures shall request additional information from the applicant.
5. Responses to applications will be given within one month from the date of their receipt. If it is necessary to extend this period, Joras Ventures will inform the applicant of the reasons for the extension.
6. The response will be sent to the e-mail address from which the application was sent, or in the case of an application sent by post, by regular mail to the address indicated by the applicant, unless it is clear from the content of the message that the applicant wishes to be contacted by e-mail (in which case the e-mail address must be indicated).
DATA RECIPIENTS
1. In connection with the provision of services, personal data will be provided to suppliers responsible for the operation of IT systems and to organizations associated with Joras Ventures, including companies of its group and business partners.
2. If the User gives his consent, his data may also be provided to other organizations for their own purposes, including marketing purposes. This would primarily relate to sharing a candidate's data with a potential employer.
3. Joras Ventures reserves the right to disclose selected information about the User to competent authorities or third parties who request such information on the basis of an appropriate legal basis and in accordance with the provisions of applicable law.
DATA TRANSFER OUTSIDE THE EUROPEAN ECONOMIC AREA
* Joras Ventures may transfer User’s personal data outside of the EEA. This may occur when recruiting candidates from countries outside of EEA or when using services of providers located outside the EEA.
* When data is transferred to countries outside the EEA, we will ensure that appropriate safeguards are in place to protect your data. These safeguards may include:
* Using Standard Contractual Clauses (SCCs) approved by the European Commission.
* Ensuring the recipient country has an adequate level of data protection.
* Obtaining your explicit consent for the data transfer.
* If you would like to know more about the safeguards in place, you can contact us at data@jorasventures.com.
REVISION OF PRIVACY POLICY
The policy is reviewed on an ongoing basis and updated as necessary. We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the updated Privacy Policy on our Website and updating the "Effective Date" at the top. We encourage you to review this Privacy Policy periodically to stay informed about our privacy practices.