If you happen to be left with even more questions after reading our policy – or already have some – do not hesitate to contact us.
“Applicable laws” means all the laws and regulations relevant to the collection, processing and storage of data, especially all the data protection laws and the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
“Commerce Media Tech” or “we” or “us” or „our” means Commerce Media Tech Sp. z o.o. with a registered office at Lubicz 17G, 31-503 Kraków, Poland.
“Cookies” means small text files stored in a web browser by a website (here specifically: Site) or by an ad server. By storing certain information in a cookie, those web browsers, ad servers, and explicitly our Site are able to remember your preferences and recognize websites visited and/or web browsers used from one visit to another.
“Data Protection Officer” means a Data Protection Officer as defined in article 37 – 39 of GDPR appointed by Commerce Media Tech to watch the security of your Data (as defined below).
“Group of undertakings” means a group of undertakings affiliated to a central body in the meaning of Recital 48 of the GDPR.
“Legal Grounds” means the legal basis for the collection, processing and storage of your Personal Information.
“Log Data” means information that is automatically reported by your browser each time you access our Site and which is sent by your web browser that our servers automatically record. Log Data may include information such as your IP address, browser type, web requests, domain names or pages viewed.
“Personal Information” or “Information” or “Data” means any Information relating to an identified or identifiable person as defined in article 4.1 of the GDPR.
“Site” means the Commerce Media Tech’s website – www.cm.tech.
“You” means an individual that uses the Site.
II. Personal Information we collect about you
We collect Information about you through:
- your use of our contact or job application forms
- your use of our newsletter form
- your use of Site
- you contacting us, for example via email
- your use of our social media profiles
The categories of your Data that we collect may include:
- your contact details (your name, surname and e-mail address)
- your LinkedIn profile (optionally for job applicants – only if you want to tell us your LinkedIn profile)
- data included in the job application documents attached by you, like your CV or a cover letter (e.g. your employment and education history) as well as your correspondence with us with regard to job application,
- other information you provide us with in the correspondence
III. Log Data, Cookies and similar technologies
When you interact with our Site, we may also automatically collect information from your Site activities through the usage of Cookies, Log Data and similar technologies.
By using those technologies we aim to personalize our Site to better meet your needs, as well as to provide you with customized Site content and to act within our advertising purposes. We may also use this information for the purposes of analytics and monitoring of the effectiveness of our performance, including the collection of the aggregate Site usage data (such as the overall number of Site visitors or pages viewed).
The information mentioned above may include:
- information about your interactions with the Site;
- technical information about your computer hardware and software that may include URL information, cookie data, your IP address, the types of devices you are using to access our Site and/or use the services, device ID, device attributes, network connection type, browser type, language, internet service provider, clickstream data, access times, the files viewed on our Site;
- demographic information such as your ZIP code, age, gender and preferences by using Log Files; such information is not associated with your name or other Personal Information.
Please see our Cookies Policy for more details about our collecting and using of this Data.
IV. Purposes and Legal Grounds for Data processing
Your local law may require setting out the Legal Grounds on which we rely in order to process your Data. Below you will find an outline of the purposes for which we may process your Data accompanied by an indication of a relevant Legal Grounds for such processing pursuant to GDPR:
In this case, with regard to the employment agreement, the legal basis on which we process your Data is:
On the other hand, the legal basis on which we process your Data concerning civil law contract is:
In this case the legal basis on which we process your Data is your separate voluntary consent (article 6.1. point a) of GDPR).
The legal basis on which we process your Data in these circumstances is our legitimate interest (article 6.1. point f) of GDPR) to: respond to your inquiries or pursue claims or defend against claims.
The legal basis on which we process your Data in these circumstances is our legitimate interest (article 6.1. point f) of GDPR) to promote our products and services.
Sometimes we also ask you for your voluntary consent to specific form of marketing, i.e. sending commercial information via e-mail (newsletter) or contacting you by phone or skype for our commercial purposes in accordance with applicable law (telecommunication law, act on providing services by electronic means).
In order to ensure that we are able to send you our newsletter, we may process your name, surname and email address (which is necessary in order to provide you such services).
Your consent is voluntary and it is expressed by clicking in the subscription button (legal basis – Article 6 (1) (a) of the GDPR). If you do not provide us with relevant information we will not be able to perform such services for you.
In order to reply to your inquiry sent to us via the contact form and to correspond with you, we may process your name, surname and email address (which is necessary in order to provide you such services). We may also process other information if provided by you.
Providing such information is voluntary and we process it on the basis of our legitimate interest (Article 6 (1) (f) of the GDPR). If you do not provide us with relevant information we will not be able to perform such services for you.
If you give us your voluntary consent on sending commercial information on your email address or contacting you by special means such as phone, SMS or skype, we will be able to perform marketing activities related to you, including direct marketing of our own services, as well as contacting with you for purposes related to permitted marketing activities by aforementioned means (email, phone, SMS, skype etc.).
We can process your Data to perform marketing activities on the basis of our legitimate interest (Article 6 (1) (f) of the GDPR), however your consent on a specific means of contact is required in accordance with applicable law (telecommunication law, act on providing services by electronic means).
The Site uses plugins and other social tools provided by social network administrators such as Facebook, Twitter, Instagram, LinkedIN.
By displaying the Site containing such a plug-in, your browser will establish a direct connection to the servers of social network administrators (service providers). The content of the plugin is transmitted by the respective service provider directly to your browser and integrated with the website. Thanks to this integration, service providers receive information that your browser has viewed the Site, even if you do not have a profile with a given service provider or are not currently logged in to it. This information (along with your IP address) is sent by your browser directly to the server of the given service provider (some servers are located in the USA) and stored there.
If you have logged in to one of the social networking sites, then this service provider will be able to directly assign a visit to the Sites to your profile on the given social networking site.
If you use a given plugin, e.g. by clicking on the "Like" or "Share" button, the relevant information will also be sent directly to the server of the given service provider and stored there.
Facebook - https://www.facebook.com/legal/FB_Work_Privacy,
Twitter - https://twitter.com/en/privacy,
LinkedIN - https://www.linkedin.com/legal/privacy-policy.
If you do not want social networking sites to match the data collected during visits to the Site directly to your profile on a given website, then before visiting our Site you must log out of your social media account. You can also completely prevent the plugins from loading on the page using the appropriate extensions for your browser, e.g. script blocking.
VI. Your rights
Commerce Media Tech will respect your legal rights to your Data. You can manage and control your privacy by contacting our Data Protection Officer: email@example.com.
Below you will find the description of your rights that you have under the law, and what Commerce Media Tech does to protect those rights:
|What Commerce Media Tech does to protect your rights
The right to be informed
The right of access
You have the right to access your Information. You have the right to request a copy of your Data that we hold about you by contacting us.
The right to rectification
We aim to keep your Personal Data accurate and complete. We encourage you to contact us using the contact details provided below to let us know if any of your Personal Data is not accurate or not complete, so that we can keep your Personal Data up-to-date.
The right to erasure
This is sometimes called ‘the right to be forgotten’. In some circumstances you have the right to the erasure of your Data without undue delay. Those circumstances include situations when: the Data is no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the Data has been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
The right to restriction processing
In some circumstances you have the right to restrict the processing of your Data. Those circumstances are the following: you contest the accuracy of the Data; processing is unlawful but you oppose erasure; we no longer need the Data for the purposes of our processing, but you require Data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your Data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
The right to object
In certain circumstances, you have the right to object to the processing of your Personal Data where, for example, your Personal Data is being processed on the basis of legitimate interests and there is no overriding legitimate interest for us to continue to process your Personal Data, or if your Data is being processed for direct marketing purposes.
The right to Data portability
Commerce Media Tech must allow you to obtain and reuse your Personal Data for your own purposes across services in a safe and secure way without it affecting the usability of your Data. This right only applies to Personal Data that you have provided to us as the Data Controller. The Data must be held by us by consent or for the performance of a contract and the processing is carried out by automated means.
The right to withdraw consent
If you have given us your consent to process your Data but changed your mind later, you have the right to withdraw your consent at any time, and Commerce Media Tech has to stop processing your Data unless Commerce Media Tech has other Legal Ground for processing of your Data. The withdrawal of consent does not affect the compliance of the processing which was made on its basis before the withdrawal of consent.
The right to complain to the Supervisory Authority
You have the right to lodge a complaint with the Supervisory Authority in particular if you feel that Commerce Media Tech has not responded to your requests to solve a problem.
In any above-mentioned matter please contact our Data Protection Officer: firstname.lastname@example.org. Please include information that will enable us to verify your identity within your request.
VII. How your Data is protected
Commerce Media Tech uses various security technologies and procedures that help protect your Personal Information from unauthorized access, use, disclosure, alteration or destruction.
- Personnel. Only qualified and authorized employees are permitted to access Personal Information, and they may do so only for permitted business functions;
- Data Protection Officer. We appointed a Data Protection Officer who in particular watches over the security of your Data, monitors our compliance with GDPR, and is a point of contact for you in all matters regarding Data protection; here you have contact to our Data Protection Officer: email@example.com;
- Security Measures. We use encryption in the transmission of your Personal Information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your Personal Information;
- Additional Safeguards. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your Information. Our security procedures mean that we may request proof of your identity before we disclose Personal Information to you;
VIII. International transfer of Data
We may transfer Data to a country outside of the European Economic Area (EEA) based on a decision of the European Commission, stating that a third country may be considered as providing an adequate level of data protection or based on standard contractual clauses approved by the European Commission (the EU Commission Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council). If you are located in the EEA, you may contact us if you require a copy of the safeguards which we have put in place to protect your Data transferred outside of the EEA and your privacy rights in these circumstances. You may also learn more about EU Commission Decision on standard contractual clauses for the transfer of personal data to entities established in third countries here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.
IX. Retention of your Information
Commerce Media Tech stores your Information for a period of time required for the purposes for which it was collected using generally accepted security standards and in compliance with applicable laws. Commerce Media Tech will not retain your Personal Information for longer than required.
In particular, we store Information about you when you send your enquiry by contact form as well as when you send documents and information through a job application form or when you sign up for a newsletter. Such processing will last only for the period of time necessary to achieve the intended purposes.
Please note, that:
- for our marketing purposes your Data will be processed until such time you object to it;
- where you have consented to marketing communications via e-mail (e.g. you agree to receive our newsletter), you may withdraw your consent at any time by contacting as well as you may unsubscribe from newsletter at any time by clicking the unsubscribe link in an email from us; in these circumstances, your personal data will be processed until your withdrawn of the consent;
- for purposes of performance current recruitment process - your Data will be processed as long as necessary to complete the recruitment processor or until such time that your consent is withdrawn (depending on what event has happened earlier);
- for the needs of the current recruitment process - for the period of recruitment,
- in order to conclude an employment contract in connection with current recruitment (applies only to job applicants with whom Commerce Media Tech decides to conclude such a contract) - until the conclusion of the employment contract,
- in order to pursue claims or defend against claims resulting from the above-mentioned recruitment process (applies only to job applicants with whom a recruitment interview took place) - for a period of 3 (three) years from the moment of completing recruitment,
- for purposes of performance future recruitment process - your Data will be processed for a period of 3 (three) years from the date of granting consent or until you withdraw your consent to process your Data for these purposes (depending on which event occurred earlier).
After the expiration of those periods, the data is deleted without unnecessary delay.
If you need more detailed Information about the retention of your Information, please contact our Data Protection Officer.
We may disclosure your Personal Data only to the following trusted third parties:
- Safety, Legal Purposes and Law Enforcement. We may use and disclose the Data when we believe it is necessary: (i) under applicable law, and (ii) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities.
- Service providers. We may also engage third parties that support the operation of our Services (acting on our behalf), such as analytics providers, IT services providers (e.g. cloud or host services providers), recruitment or advertising agencies.
XI. Children's privacy
Protecting children's privacy is very important to Commerce Media Tech. Our Site is not intended for, designed to be used by, or targeted at children. We do not knowingly collect the Data from any person who is an individual under the age of 13.
We are in compliance with the requirements of EU General Data Protection Regulation 2016/679 as well as COPPA (Children’s Online Privacy Protection Act) and we do not collect any Information from anyone under 13 years of age.
XII. Notice to parents
If you are a parent or a guardian who knows or has otherwise discovered that your child under the age of 13 has submitted his or her Personal Information, or other Information, to us without your consent, permission or authorization, do not hesitate to contact our Data Protection Officer using the following email address: firstname.lastname@example.org.
We will promptly remove your child’s Personal Information or other Information from our system, cease the use of such Information and direct any third party with access to it to do the same.
XIV. Contacting us