I. INTRODUCTION
This document provides a description of the privacy policy of Dynaminds Sp. z o.o. with its registered office at ul. Mokotowska 1, 00-640 Warsaw, hereinafter Dynaminds. The Privacy Policy of Dynaminds (the Policy) defines the principles and method of processing and use of data and information from clients and users of all websites belonging to Dynaminds: i.e. www.dynaminds.pl

Please read this Policy carefully. By accessing or using any websites belonging to Dynaminds, sending us any personal information or reading the contents of this Policy, the User accepts its terms and confirms that he/she is familiar with its content.

II. TERMS USED IN THE POLICY
PersonalData − means any information relating to an identified or identifiable natural person. Identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an email address or a telephone number of the person and other data which, when combined with the above, may identify the User.

GDPR − means European Parliament and Council Regulation (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 the repeal of Directive 95/46/EC (general data protection regulation), according to which Dynaminds processes the Users’ Personal Data.
Specialist− a job candidate offered by Dynaminds to its clients.

User – a job candidate, newsletter subscriber, competition or training session participant, the person making an inquiry, recommending someone for a job, or visiting websites belonging to Dynaminds.

Services − understood as services performed by Dynaminds electronically, via the website, i.e.: newsletter subscription, sending inquiries via the contact form, sending documents necessary for the recruitment process, applying for the participation in competitions, applying for the participation in training sessions, setting up an account in the candidate’s portal.

III. PROVISION OF PERSONAL DATA
By providing his/her Personal Data to www.dynaminds.pl and other websites belonging to Dynaminds, the User confirms that he/she has the necessary permissions to disclose personal data to be used by Dynaminds in the manner described in this Policy.

IV. PERSONAL DATA CONTROLLER
The Controller of Users’ Personal Data transmitted in connection with the use of the Dynaminds websites, in particular in conducting recruitment processes, conducting training sessions, sending marketing information such as newsletters, accepting subscriptions for conferences or events, or use of other services available via the website, is Dynaminds Sp. z o.o., ul. Mokotowska 1, 00-640 Warsaw, tel. +48 22 112 10 55

V. DATA PROTECTION OFFICER
Dynaminds has appointed a Data Protection Officer. The contact details of the Data Protection Officer: daneosobowe@dynaminds.pl

VI. PURPOSES AND LEGAL BASIS OF PERSONAL DATA PROCESSING
The Controller processes Personal Data in order to:

Transmit sales and marketing information (including the Dynaminds newsletter) to Users via an e-mail addresses they provided, on condidtion that the User has consented thereto. The legal basis for sending newsletters is the User’s consent to the processing of Personal Data (Art. 6(1) (a) of the GDPR). Consent for sending unsolicited commercial information to Users in accordance with Art. 10 of the Act on electronic services is expressed by Users independently and separately.
Provide responses to the User’s inquiries sent through the contact form via the e-mail address or phone number provided thereby.
In the case of contact with the User in order to provide a response, the legal basis for the processing of Personal Data is the consent of the User to the processing of personal data (Art. 6(1)(a) of the GDPR).
Consider job applications submitted by the User and conduct a recruitment process by Dynaminds, with the prior consent of the User to the processing of data contained in the CV or the respective form.In the case of consideration of a job application, the legal basis for the processing of Personal Data is the consent of the User to the processing of personal data (Art. 6(1)(a) of the GDPR).
Organize and conduct competitions for DynamindsThe legal basis for the organization of competitions is the consent of the User (Art. 6(1)(a) of the GDPR).
Organize and conduct open and dedicated training sessions.In the case of training sessions the legal basis for the processing of Personal Data is an agreement for the provision of training services concluded with Dynaminds by sending the respective order form (Art. 6(1)(b) of the GDPR).

VII. USER RIGHTS
In accordance with Chapter III, Art. 15-21 of the GDPR, the User has the following rights in connection with the processing of his/her Personal Data by Dynaminds:

  • The right to access his/her Personal Data,The right to rectify the processed data,
  • The right to delete the data (“the right to be forgotten”),
  • The right to limit the processing of the data,The right to data portability,
  • The right to object to the further processing,
  • The right to not to be subjected to decisions which are based solely on automated processing, including profiling.

Each of these rights is executed at the request of the User. Dynaminds examines each request and provides a response within 1 month of the date of receipt of the respective application.

In the framework of these rights the User may at any time withdraw consent to the further processing of Personal Data for purposes that require consent, provided that the withdrawal of consent does not affect the legal use of personal data in activities conducted based on consent before the withdrawal thereof.

As a part of the right to access Personal Data, the User is entitled to obtain the following information in the form of copies:

  • Information on the purposes of processing of Personal Data;
  • Information on the categories of Personal Data − what types of data are processed, e.g. name, telephone number, etc.;
  • Information on the recipients or categories of recipients − to whom (a person, company, or institution) data can be transmitted;
  • Information on the right to request that Dynaminds rectify or delete Personal Data or limit the processing of Personal Data, and information on the right to object to certain data processing;
  • Information on the ability to file a complaint to the Office for Personal Data Protection;
  • Information on the source of the data if it was not obtained directly from the User − an indication of the person, company or institution that provided the Personal Data;
  • Information on the use of profiling: on what basis it is taken, what would be the consequences of profiling for the User.

Dynaminds also advises that each subsequent copy of Personal Data is subject to a fee resulting from costs incurred in connection with the creation of another copy of Personal Data.

Dynaminds reserves the right both not to respond to a request and to respond later than indicated above (by up to two months) due to the number of requests sent or the complex nature of the respective inquiry. Complex nature is understood as the need to prepare a summary of Personal Data from multiple systems, the need to consult with more than one person from one or more departments in order to obtain the information requested.

In both of these situations Dynaminds undertakes to inform the User of such fact each time, providing the reasons therefor.

VIII. PROCESSING OF PESONAL DARA FOR RECRUITMENT PURPOSER AND WITHIN THE CANDIDATE RECOMMENDATION SYSTEM.
Dynaminds conducts recruitment for its own needs and for its clients to whom, among others, Dynaminds provides access to Specialists. Therefore we advise that your.  Personal Data may also be processed by clients of Dynaminds, which is indicated in job advertisements that specify that the recruitment process is conducted on behalf of the client. Please also note that consenting to a recruitment process means recruiting for the specific position contained in the advertisement as well as to the future recruitment. This means that we will store Personal Data in our database in order to send information on positions tailored to the profile and professional experience of the User.
In accordance with Chapter VII of this Policy, the User may withdraw consent to the further processing of Personal Data, provided that the withdrawal of consent does not affect the legal use of personal data in the activities conducted basing on consent before the withdrawal thereof.

Personal Data may also be processed if the User has been recommended by another person. In this situation, the recommending person enters his/her data and the data of the person recommended and attaches a CV under the form with the recommended person’s data. Dynaminds verifies the CV of the recommended person as received from the recommending person in terms of the consent of the recommended person to the processing of Personal Data meeting the requirements of the GDPR. If such consent has been granted, Dynaminds has permission to use the data for recruitment processes.

IX. PROCESSING OF PERSONAL DATA FOR MARKETING PURPOSES.
By submitting an inquiry or subscribing to training sessions, conferences, or other events organized by Dynaminds, the User may consent to the processing of Personal Data for the direct transfer of marketing information on products and services offered by Dynaminds, including newsletters. Consent may be withdrawn at any time, subject to the rules set out in Chapter VII of this Policy.

X. PROCESSING OF PERSONAL DATA IN ORGANIZING AND CONDUCTING TRAINING
Dynaminds provides open and dedicated training sessions organized for its clients and any interested persons. Therefore, Dynaminds processes the Personal Data of Users subscribing for such sessions to the extent necessary for the purposes of organizing the said training sessions.

XI. PROCESSING OF PERSONAL DATA AND PROFILING
In Dynaminds, profiling is understood as a form of automated processing of personal data consisting of the use of certain data about the User. The obtained data include information from social media profiles, location, data provided by Users using forms on the Dynaminds website.

It allows us to:

  • ensure a more conscious and better-suited selection of job offers to correspond to Users’ skills and experience (in the case of candidates for a job in Dynaminds),
  • match marketing and advertising materials sent to Users’ interests and needs.

The User may object to profiling at any time in accordance with Chapter VII of this Policy, but it entails the inability to send marketing and commercial information or to receive new job offers tailored to the profile and professional experience.

XII. SECURITY
Dynaminds has implemented appropriate (organizational and technical) security measures to protect Personal Data from loss, misuse, unauthorized processing or modification. The Personal Data controller undertakes to protect any information disclosed by Users in accordance with security and confidentiality standards.Access to Users’ Personal Data is limited: such information is not made available to unauthorized persons. Access to Personal Data is limited to the number of eligible employees of Dynaminds.

Dynaminds is authorized to provide Personal Data to entities authorized under the relevant provisions of the law.

XIII. COOKIES
Dynaminds declares that www.dynaminds.pl and other websites belonging to Dynaminds use cookies. By using this website, the User agrees to the storage of cookies on his/her device as explained below. Settings regarding the cookies used on the www.dynaminds.pl website and other websites belonging to Dynaminds may be modified via our website or via a third-party website.

Cookies are used to:

  • Customize the content of web pages to User preferences and to optimize the use of websites; in particular, these files allow for the identification of the User’s device and the proper display of the web page tailored to their individual needs,
  • Create statistics that help to understand how Users use the websites, which leads to improving the structure and content thereof,
  • Deliver advertising content tailored to Users’ interests.

Types of cookies used by Dynaminds:

  • “Essential” cookies, enabling the use of the services available through the site, e.g. allowing the use of sessions;
  • “Functional” cookies, allowing the website to “remember” the settings chosen by the User and personalize the User interface, e.g. in terms of the selected mobile/desktop version, the last phrases typed by the User, the appearance of the website, etc.;
  • “Analytical” cookies, allowing us to monitor the activity of Users on the site.

The User may block the saving of cookies by changing his/her browser settings. Disabling cookies may affect the functioning of the site. No change in the User’s browser settings means acceptance of the use of cookies.

XIV. 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.dynaminds.pl/cookie-policy website.