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Policy of processing and protection of personal data (PD)

Information on the processing of PD subjects

This privacy policy ("Policy") regulate the conditions under which the company LeConte s.r.o., registered office Prague 7 - Holešovice, Františka Křížka 460/13, ZIP Code 17000, ID: 28992407, registered in the commercial register maintained at the Municipal Court in Prague under sp. C 158442 (hereinafter referred to as the "Company") processes personal data ("Personal Data" or “PD”) in connection with activities and services in the course of its business activity, which is mainly employment mediation and the provision of services in the field of IT.

We take the protection of your personal data seriously and we respect the confidentiality of your personal data and act in accordance with the provisions of the legal regulations on the protection of personal data, in particular with Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation) (hereinafter referred to as "Regulation") and with Act No. 110/2019 Coll. and we follow this Policy.

With this Policy, the Company also informs you about how, for what purposes and to what extent the Company uses your personal data, and what information about you as a candidate for a job position, as an applicant for another type of cooperation or as a business partner – agent - the Company can process.

We always process your personal data on the basis of a legal title, correctly, transparently, for specific, explicitly stated and legitimate purposes, to the minimum extent necessary, and we store them in a form that enables your identification for the necessary time in relation to the purpose of processing.

 

A. Legal reasons, purposes and extent of processing of PD according to categories of PD subjects:

1) Candidate (job applicant):

a) What data do we process?

We may process the following personal data or categories of personal data. This does not mean that we process all the personal data listed below for every candidate. For example, we cannot list all personal information that job applicants submit to us in their resumes and other related documents. Please note that the examples below may not be exhaustive. We only process data that you voluntarily provide us for the purpose of arranging a job position with our Clients. These are in particular:

  • Name and surname
  • Academic title
  • Permanent address
  • Contact address
  • Nationality
  • Date and place of birth
  • Telephone number
  • Email address
  • Educational
  • Salary requirements
  • Qualifications, skills, knowledge, professional history
  • Photograph (if you provide it to us as an attachment to your CV)
  • Link to your profile on social networks and its content
  • Information on the start of employment, the salary, termination of employment
  • Knowledge of languages, special skills/knowledge and professional qualifications
  • Your job preferences
  • Other information listed in your CV

 

b) Why do we process your data?

You provide us with your data either for the purpose of applying for a specific job position, or to find you a job position according to your ideas. You provide us with this information in the form of your CV and communication with our agents. We process the personal data during the process of filling job positions and providing our services (these services are always related to the search, recruitment and filling of job positions). The processing of personal data helps us in our activity as an employment broker.

 

c) On what legal basis do we process your data?

We only process your personal data for legitimate reasons.

Art. 6 paragraph 1 letter b) GDPR - in order to implement measures before concluding an employment contract:

Unless otherwise stated, we process the personal data of job applicants on the basis of interest in a specific job position and the sent request in accordance with Article 6 paragraph 1 letter b) GDPR, i.e. for the purpose of implementing measures before concluding an employment contract.

Art. 6 paragraph 1 letter f) GDPR - for the purposes of the legitimate interests pursued by the Company

We may subsequently store your personal data if this is necessary for the determination, exercise or defense of our legal claims, and this is due to our legitimate interest.

Art. 6 paragraph 1 letter a) GDPR – based on your written consent to the processing of personal data

Based on your consent, we send you other suitable job offers, or we process your personal data for marketing and statistical purposes, based on your express permission we will publish some data on our website www.leconte.cz , all within the scope of the consent granted. You can withdraw your consent at any time by sending an e-mail to the address GDPR@leconte.cz However, the withdrawal of consent does not affect the legality of processing based on such consent.

Art. 6 paragraph 1 letter c) GDPR – in order to comply with a legal obligation

This is the processing of data necessary for proper accounting and other similar legal obligations of the Company.

 

d) Where do we get the data from?

We only process data that you provide us yourself (CV, e-mail communication, etc.) as part of communication aimed at finding a job position you are interested in.

 

e) For how long do we process the data?

We keep personal data only for a period that is absolutely necessary, but no longer than 2 years. After the specified period, personal data will be deleted. Personal data provided on the basis of consent to processing are kept for the period for which the consent was granted, or until its revocation. If we find that your data is no longer necessary for any of the purposes for which it was processed, we delete such data.

 

f) To whom do we pass on your personal data?

Due to the fact that we process your personal data for the purpose of our activities as an employment broker, and in order to provide related services, we transfer your personal data to employers looking for employees for the offered positions, always after expressing your interest in such positions. In case of your written consent for such processing of specific data, we also advertise this data publicly on our website www.leconte.cz Your personal data may also be provided to authorized state authorities, institutions or other entities subject to the fulfillment of the relevant legal conditions. Where required by the purpose of the processing, your personal data may be transferred to our external suppliers who provide us with support during the recruitment process. These external suppliers may be in the position of processors of your personal data, in which case a processing contract is always concluded with these suppliers.

 

g) Profiling

We collect personal data to facilitate the recruitment process for candidates and for clients to evaluate your skills, experience, qualifications and suitability for current and future job positions in which you may be interested. In particular, we then evaluate whether you are fitting as a candidate for the given position and also that your education, experience and abilities meet the requirements of the given position, and whether the offered remuneration is in accordance with your requirements. This evaluation process can be categorized as personal data profiling within the meaning of Article 4(4) of the GDPR.

 

2) Business partner (cooperating natural person, agent):

a) What data do we process?

We may process the following personal data or categories of personal data. Please note that the examples below may not be exhaustive. We only process data that you voluntarily provide to us for the purposes defined below. These are in particular:

  • Name and surname
  • Academic title
  • Permanent address
  • Contact address
  • Nationality
  • Birthdate
  • Telephone number
  • Email address
  • Educational
  • Qualifications, skills, knowledge, professional history
  • Photograph (if provided)

 

b) Why do we process your data?

You provide us with your data for the purpose of concluding a contract establishing your business relationship with our company and for the purpose of fulfilling mutual obligations from this contract.

 

c) On what legal basis do we process your data?

We only process your personal data for legitimate reasons.

Art. 6 paragraph 1 letter b) GDPR - for the purpose of concluding and fulfilling the contract:

We collect and process personal data for the purpose of selecting a partner for contractual cooperation, i.e. determining the suitability of concluding a contract, for its conclusion and fulfillment of obligations arising from it. PD are needed to identify a person and to fulfill the terms of the contract, for communication with our Company, with clients and business partners, presentation of the Company on websites, etc.

Art. 6 paragraph 1 letter f) GDPR - for the purpose of fulfilling the legitimate interests of the Company

We may subsequently store your personal data if this is necessary for the determination, exercise or defense of our legal claims, and this is due to our legitimate interest.

Art. 6 paragraph 1 letter c) GDPR - in order to comply with a legal obligation

This is the processing of data necessary for proper accounting and other similar legal obligations of the Company.

 

d) Where do we get the data from?

We only process data that you provide to us during pre-contractual negotiations, negotiating the contract and during its duration for the purposes of its fulfillment.

 

e) For how long do we process the data?

We process personal data during the contractual relationship and for the period necessary for the exercise or defense of our legal claims, for the period resulting from accounting regulations in the case of accounting documents and for a period of 5 years in the case of contracts and similar documents, which must be kept for at least the period when it is possible to exercise rights from such relationships (contract archiving, rights from defects and liability for damage).

Personal data provided on the basis of consent to processing are kept for the period for which the consent was granted, or until its withdrawal.

If we find that your data is no longer necessary for any of the purposes for which it was processed, we will delete such data.

If a contractual relationship is not concluded, we will delete your data obtained within 30 days after the end of the negotiations, unless you give us written consent to their further processing (e.g. keeping it in a database for possible future offers, etc.)

 

f) To whom do we pass on your personal data?

Your personal data may also be provided to authorized state authorities, institutions or other entities subject to the fulfillment of the relevant legal conditions.

Where the purpose of the processing requires it, your personal data may be transferred to our external suppliers, e.g. an accounting firm, etc. These external suppliers may be in the position of processors of your personal data, in which case a processing contract is always concluded with these suppliers.

 

3) Website visitor:

If you are a visitor to our website www.leconte.cz , then we process your personal data listed below necessary for the legitimate interests of our Company in accordance with Article 6 paragraph 1 letter f) Regulations:

Using the contact form or email

If you use the contact form on our website for your questions addressed to our Company or if you send our company an e-mail to our published e-mail address, we use the personal data provided by you, including your contact information, only to process the question.

The website does not use cookies or web analytics tools.

 

B. Your rights as a data subject

As a data subject, you have the following rights:

(i) Right to information

(ii) Right of access to personal data

(iii) Right to rectification

(iv) Right to erasure (right to be forgotten)

(v) Right to restriction of processing

(vi) Right to data portability

(vii) The right to object

(viii) The right not to be subject to automated individual decision-making, including profiling

(ix) The right to file a complaint with the Office for the Protection of Personal Data or with another competent supervisory authority in connection with the processing of personal data

You can exercise the above rights (with the exception of the right to file a complaint with the Office for the Protection of Personal Data or with another competent supervisory authority in connection with the processing of personal data) by means of a request in one of the ways set out below. We will inform you about the measures taken on the basis of your request within one month of receiving the request, but no later than three months after receiving the request, if the deadline has been extended in case of justified need.

 

a. Right to information

Through this Policy and possibly other notices about the processing of personal data, we will inform you about the processing of your personal data in a concise, transparent, comprehensible and easily accessible way, at the moment when we receive personal data from you. If we do not obtain personal data directly from you, we will provide you with the information within a reasonable period of time after obtaining it, but within one month at the latest.

 

b. Right of access to personal data

You have the right to receive confirmation from us as to whether or not personal data relating to you is being processed. If we process your personal data, we will provide you with information that you require or that is required by law.

If we process your personal data, we will provide you with a copy of the processed personal data free of charge upon your request. For additional copies at the request of the data subject, we may charge a reasonable fee corresponding to the administrative costs of obtaining these copies. The right to obtain a copy of processed personal data must not adversely affect the rights and freedoms of other persons.

If you submit an application in electronic form, the information will be provided in a commonly used electronic form, unless you indicate in your application that you require another method of providing the information.

 

c. Right to rectification

You have the right to correct inaccurate personal data concerning you and to complete incomplete personal data taking into account the purposes of the processing, including by providing an additional statement. We will notify the individual recipients to whom the personal information has been made available of any corrections to personal information, where possible with reasonable efforts. If you request it, we will inform you about the recipients informed in this way.

 

d. Right to erasure / right to be forgotten

We will delete your personal data without undue delay in cases as follows:

i. Your personal data is no longer needed for the purposes for which it was collected or otherwise processed;

ii. you withdraw the consent on the basis of which your personal data was processed, and there is no other legal reason for their processing;

iii. you object to the processing of your personal data and at the same time there are no overriding legitimate reasons for the processing or you object to the processing of your personal data for direct marketing purposes;

iv. Your personal data has been processed unlawfully;

v. Your personal data must be deleted to comply with a legal obligation established by the law of the European Union or its member state, which applies to the Company;

vi. the child's personal data was collected in connection with the offer of information services made directly to the child.

 

The above does not apply if the processing of personal data is necessary:

i. for the exercise of the right to freedom of expression and information;

ii. for the fulfillment of a legal obligation that requires the processing of personal data according to the law of the European Union or a member state that applies to our Company, or for the fulfillment of a task carried out in the public interest or in the exercise of public authority with which our Company is entrusted;

iii. for reasons of public interest in the field of public health;

iv. for the purposes of archiving in the public interest, for the purposes of scientific or historical research or for statistical purposes, if it is likely that the use of the right to erasure would make it impossible or seriously jeopardize the fulfillment of the objectives of the said processing;

v. for the determination, exercise or defense of legal claims.

 

We will notify the individual recipients to whom the personal information has been made available of all deletions of personal information where possible with reasonable efforts. If you request it, we will inform you about which recipients of personal data have been informed in this way.

If we refuse to delete your personal data on the basis of one of the above-mentioned exceptions, we will inform you about this within one month from the delivery of the request, justify the use of the exception and instruct you in accordance with the requirements of applicable legal regulations.

 

e. Right to restriction of processing

You have the right to restrict the processing of your personal data in any of the following cases:

i. If you dispute the accuracy of the personal data; in this case, the processing will be limited to the time necessary for us to verify the accuracy of the personal data;

ii. the processing of personal data is unlawful, you refuse the deletion of personal data and instead request the restriction of their use;

iii. we no longer need the personal data for processing purposes, but you require them for the determination, exercise or defense of legal claims;

iv. you have exercised the right to object to the processing of personal data; in this case, the processing will be restricted until it is verified whether our legitimate reasons outweigh your legitimate interests.

As a result of the limitation of personal data processing, we may continue to store the personal data in question, but they may only be processed with your consent, or for the purpose of determining, exercising or defending legal claims, for the purpose of protecting the rights of another natural or legal person or for reasons of important public interest of the European Union or a member state. In these cases, you will be notified in advance that the restriction of processing will be lifted.

 

f. Right to data portability

You have the right to receive personal data relating to you, which you have provided to us, and which are processed automatically, if one of the following conditions is met:

i. personal data is processed for a specific purpose/s based on your consent;

ii. this is a special category of personal data processed for one or more specified purposes based on your express consent; or

iii. the processing of personal data is necessary for the fulfillment of the contract to which you are a contracting party, or for the implementation of measures taken prior to the conclusion of the contract at your request.

We will transfer your personal data in a structured, commonly used and machine-readable format. You are entitled to transfer the personal data to another personal data controller. In your request, you can choose whether we should provide you with personal data or whether you will use the right to have your personal data transferred by our Company directly to another controller/processor, if this is technically feasible.

 

g. The right to object

In the case of personal data processing based on the legal title of our Company's legitimate interest, you have the right to object to the processing of your personal data for reasons relating to your specific situation, which you will describe in the objection. You can file an objection using the contact details below.

If we receive an objection, we will stop processing your personal data (we will only keep them stored) and we will assess whether we have serious legitimate reasons for processing them that outweigh your interests or rights and freedoms, or whether we need your personal data for determining, performing or defending our legal claims. If we come to the conclusion that we have such reasons, we will inform you about it and we will continue to process personal data. If, on the contrary, we come to the conclusion that we do not have sufficient reasons for the processing of personal data, we will inform you about this, we will end the processing and delete the personal data.

You have the right to object at any time to the processing of your personal data for direct marketing purposes.

 

h. The right not to be subject to automated individual decision-making, including profiling

We process your personal data with respect for your right not to be the subject of any decision based solely on the automated processing of personal data that significantly affects you, including profiling.

However, when managing your personal data, we may make you the subject of an automated decision, if such a decision is necessary for the conclusion or performance of a contract between you and us, or if the decision is permitted by a legal regulation of the European Union or the Czech legal order, at the same time appropriately ensuring the protection of the rights and freedoms and rights of interests of the data subject, or if you give express consent to such a decision.

 

i. The right to file a complaint

If you do not agree with our handling of your request, you can file a complaint against our procedure at the Office for Personal Data Protection:

i. electronically at the e-mail address posta@uoou.cz ;

ii. via databox ID: qkbaa2n;

iii. by phone at +420 234 665 111; or

iv. in writing at the address Plk. Sochora 27, 170 00 Prague 7,

or another competent supervisory authority of a member state of the European Union.

 

C. How to exercise your rights and how to obtain more detailed information about the processing of your personal data

To exercise your above-mentioned rights and in case of any questions regarding this Policy or the processing of your personal data, please contact:

LeConte s.r.o.

Františka Křížka 460/13

170 00, Praha 7 – Holešovice

E-mail: GDPR@leconte.cz

 

D. Security of personal data

Our Company has adopted certain personal data security measures to ensure the full confidentiality and integrity of your personal data. These security measures have been adopted taking into account the state of the art, the costs of implementation, the nature, scope, context and purposes of the processing, as well as the likely and variously serious risks for the rights and freedoms of natural persons, in order to ensure a level of security of personal data corresponding to the given risk, in particular accidental or unlawful destruction, loss, alteration, unauthorized disclosure of transmitted, stored or otherwise processed personal data or unauthorized access to them.

To keep your personal data safe, we use security measures such as firewalls etc. We have implemented adequate physical, electronic and process security and use reliable IT service providers. We have also bound Company employees and other persons entrusted with the handling of personal data in employment contracts and agreements to confidentiality and the obligation to handle personal data exclusively according to our instructions.

Due to the nature of the Internet, however, we would like to draw your attention to the fact that there may be certain security gaps in the transmission of personal data via the Internet (e.g. communication via e-mail) and that complete protection of personal data preventing access by third parties is not possible.

 

 

In Prague on September 13, 2022