Terms and Conditions

Terms and Conditions of the Work Without Borders Platform 1. General Information These Terms and Conditions (hereinafter: "Terms") govern the use of the Work Without Borders platform (the "Platform"), an online service that connects job seekers with employers. The Platform is operated by Stowarzyszenie Humaneo, an association based in Nowy Sącz, Poland (address: ul. Nawojowska 12, 33-300 Nowy Sącz), registered under KRS 0000249088. All services provided via the Platform are subject to these Terms and applicable EU laws. By registering an account or using the Platform, you (the "User") acknowledge that you have read, understand, and agree to abide by these Terms. 2. Definitions o User: Any individual using the Platform, whether as a Job Seeker (an individual looking for employment) or as an Employer (an entity or representative posting job offers and searching for candidates). Users must be adults under the law of their country (generally 18 years or older). If you are under the age of majority (e.g., 16–17 years old in some jurisdictions), you may use the Platform only with the consent of a parent or legal guardian and to the extent permitted by applicable law. o Job Seeker Profile: The account profile of a job-seeking User, containing personal data and information such as a CV/resumé (education, work experience, skills), contact details (address, email), and optionally the results of a personality test (MYPS) if the User chooses to complete it. o Employer Profile: The account profile of an employer User, including company/organization details (name, address, registration number if applicable) and contact information of the representative using the Platform. Employer accounts allow posting job offers and managing recruitment activities. o Job Offer: A job advertisement posted on the Platform by an Employer, including information about the position, requirements, location, offered salary, and other relevant details. o Services: The electronic services provided by the Platform Operator to Users, including account registration, hosting of Job Seeker Profiles and CVs, posting and browsing of Job Offers, automatic matching of candidates to job offers using AI algorithms, and communication tools between Job Seekers and Employers. All services on the Platform are provided free of charge to both job seekers and employers. 3. Account Registration Registration on the Platform is voluntary and free. To access full functionality, the User must create an account by completing the registration form with accurate and complete information. The User agrees to keep their login credentials secure and not share them with others. Each User may create only one account on the Platform (either as a Job Seeker or an Employer, or both roles if applicable through separate profile sections). o Job Seeker Account: To register as a Job Seeker, you will provide your name, email address, and a password. You will then be able to create your Job Seeker Profile by adding details such as your education, employment history, skills, and other CV information. You may also upload a profile photo and complete the MYPS personality test if you choose; the test is optional and meant to enhance job matching. By creating a profile, you consent to the Platform processing the provided data for job matching purposes. o Employer Account: To register as an Employer, you (the registering individual) must provide your name, company or organization name, business contact details (including a valid business email and address), and a password. You must have the authority to represent the company in using the Platform. The Employer Profile will typically show the company name and basic information to Job Seekers. As an Employer, you agree to use information obtained through the Platform (such as candidate data) solely for recruitment purposes and in compliance with privacy laws. Account Security: Users are responsible for maintaining the confidentiality of their account login information. If you suspect any unauthorized use of your account, you should notify the Operator immediately. The Platform may implement verification steps (such as email confirmation) to ensure accounts are genuine. 4. Platform Usage Rules By using the Platform, you agree to use it only for its intended purpose of facilitating employment connections, and to refrain from any illegal or abusive activities. Specifically, you agree not to: o Provide false or misleading information: All information in your profile or job postings must be truthful and factually correct. Job Seekers should not misrepresent their qualifications, and Employers should not misrepresent job terms or company details. o Post unlawful or inappropriate content: You must not post any content that is defamatory, obscene, harassing, discriminatory, or otherwise violates any law or rights of others. This includes refraining from posting job ads that violate labor laws or equal opportunity laws, and refraining from including any sensitive personal data (e.g., health information, religious or political beliefs, racial or ethnic origin) in profiles or applications, as such data is not required for recruitment and is not processed by the Platform. o Misuse personal data: If you obtain personal information about another User through the Platform (for example, an Employer receiving a candidate’s CV or a Job Seeker seeing a recruiter’s contact information), you must use it solely for the purposes of the hiring process for which it was provided. Any other use (such as marketing or sharing data with third parties) is strictly prohibited without the data subject’s explicit consent. o Engage in spamming, commercial solicitation, or advertising unrelated services: The Platform is to be used only for job search and recruitment related communication. You may not send unrelated commercial offers or promotions to other Users via contact information obtained from the Platform. o Interfere with Platform security or operations: You must not attempt to circumvent security measures, probe or test system vulnerabilities, introduce malware, perform automated data scraping (unless authorized via an API), or otherwise disrupt or attempt to gain unauthorized access to the Platform or its Users’ data. The Operator reserves the right to monitor public areas of the Platform (such as job postings) and remove or edit content that violates these Terms or applicable laws. Users who violate the rules may have their content removed and/or account suspended or terminated (see Section 8 below). 5. Job Matching and AI Assistance One of the Platform’s features is an AI-driven matching system that suggests suitable candidates to employers and job offers to job seekers. By using the Platform, Job Seekers acknowledge that their profile information may be analyzed and matched to job criteria, and Employers acknowledge that their posted job requirements may be used to search for potential candidates. o Automated Recommendations: The Platform’s algorithm will automatically compare Job Seeker Profiles with Job Offers to highlight potential matches. For Job Seekers, this means you might see recommended jobs that fit your profile, and for Employers, you might see suggested candidate profiles that match your job requirements. These recommendations are intended to streamline the recruitment process but are not decisions that have legal effect – they are for informational purposes and the initiation of contact. Any hiring decision is made by humans (the Employer and Job Seeker) outside the Platform. o No Guarantee: While we strive to improve the accuracy of our matching algorithm, the Platform does not guarantee that using the service will result in a job offer or a hire. The matching suggestions are based on the information provided and algorithmic logic, which may not account for all factors. We do not warrant that the suggested candidates will fully meet an Employer’s expectations or that suggested jobs will fully meet a Job Seeker’s expectations. o User Control and Transparency: We aim to make the matching process transparent. Job Seekers can typically see the jobs they were matched with and decide whether to apply; Employers can review suggested profiles and decide whether to reach out. If you as a Job Seeker prefer not to be included in automated matching, you may adjust your profile settings or notify us to opt out of profiling – however, this may limit your ability to be discovered by Employers through the Platform’s recommendations. o Compliance with Profiling Laws: The use of AI for matching constitutes a form of automated processing of personal data. We ensure this is done in compliance with Article 22 of the GDPR, meaning no significant or binding decision about you is made solely by a machine without human involvement. The purpose is to assist, not replace, human decision-making. You have the right to request human intervention or to contest any suggestion if you believe it’s inaccurate. 6. Communication Features The Platform may provide communication tools to facilitate interactions between Job Seekers and Employers, such as: o Messaging system: A direct messaging or email relay system enabling Employers to contact candidates (and vice versa) through the Platform without revealing personal email addresses, until they choose to do so. o Notifications: Automated email notifications or in-platform alerts to inform Job Seekers of new job matches or responses to their applications, and to inform Employers of new applications or candidate matches. By using these features, you agree to communicate respectfully and only for the intended recruitment purpose. All messages should be professional and relevant to job opportunities. We may review messages if a misuse or abuse is reported, in line with our Privacy Policy and these Terms. 7. Liability and Disclaimers Use at Your Own Risk: The Platform’s role is to facilitate connections between Job Seekers and Employers. While we strive to verify that our Users use the Platform legitimately, we do not thoroughly vet or guarantee the identity, integrity, or statements of each User. You should exercise due diligence when pursuing any employment opportunity or candidate. o Accuracy of User-Provided Content: We do not guarantee the truth or accuracy of information Users post. Profile information (CVs, qualifications, etc.) is provided by Job Seekers themselves, and job descriptions are provided by Employers. The Platform is not responsible for any false, misleading, or outdated information posted by Users. We do not confirm the accuracy or completeness of any Job Offer or User profile, including the identity or trustworthiness of any User. It is the Employer’s responsibility to verify candidate credentials and the Job Seeker’s responsibility to vet job terms and the Employer’s legitimacy. o No Guarantee of Employment: The Platform does not act as an employment agency or guarantee that any User will find a job or fill a vacancy through the Platform. We simply provide tools for information exchange. Any employment or hiring decisions are solely between the Job Seeker and Employer. The Platform is not liable if a Job Seeker is not hired or if an Employer does not find a suitable candidate. o No Involvement in Contracts: Any agreement reached between a Job Seeker and an Employer (such as an employment contract) is outside the scope of the Platform and the Operator is not a party to it. We are not responsible for any obligations arising from such agreements, nor for the conduct of either party during or after the hiring process. o Release in Case of Disputes: Because the Platform is not directly involved in actual employment transactions, Users agree that the Platform Operator will not be held liable for any dispute, claim, or damage arising out of or related to interactions between a Job Seeker and an Employer. In the event of a dispute or conflict (for example, regarding working conditions, salary, discrimination, etc.), that dispute is strictly between the Job Seeker and the Employer. By using this Platform, you agree to release and hold harmless the Operator from any claims or liabilities resulting from any such dispute. Furthermore, you agree to indemnify the Operator for any costs or damages (including legal fees) that may arise from your actions on the Platform or from disputes you have with other Users, to the extent those disputes cause any claim against the Operator. o Platform Availability: We aim to keep the Platform accessible and functional at all times, but we do not warrant that the service will be uninterrupted or error-free. Scheduled maintenance, technical issues, or factors beyond our control (force majeure) may occasionally prevent access to the Platform or cause functionality to malfunction. We will try to give advance notice of significant downtime, but in no event shall the Operator be liable for any loss of data, opportunities, or any damages resulting from Platform unavailability or technical malfunctions. o Third-Party Links and Content: The Platform may contain links to third-party websites or resources (for example, a link to an Employer’s company site or external application form). Such links are provided for convenience only. We do not endorse and are not responsible for the content, security, or practices of third-party sites. If you choose to visit or use any third-party resources, you do so at your own risk and should review their terms and policies. o Legal Compliance: The Platform Operator is not responsible for ensuring that Users actually comply with labor laws or other regulations in the hiring process. For instance, we cannot guarantee that an Employer will adhere to all employment laws in a given jurisdiction, or that a Job Seeker is eligible to work. Users are responsible for their own legal compliance. However, if we are notified of serious violations (e.g., job postings that are evidently illegal or discriminatory), we reserve the right to remove such content and take appropriate action on the User’s account. Disclaimer: Except where prohibited by law, the Operator’s total liability to any User for any claims arising out of the use of the Platform is limited to the amount of fees (if any) paid by that User for the service, or $0 in the case of free services. We do not exclude liability for gross negligence or willful misconduct, and nothing in these Terms affects any rights you may have under applicable consumer protection laws. 8. Account Suspension or Termination The Operator reserves the right to suspend or terminate your account in the following circumstances: (a) if you violate these Terms or any applicable law; (b) if you provide false information during registration or in your profile; (c) if you engage in misconduct or actions that could harm other Users, the Platform’s integrity, or the Operator’s reputation; or (d) for other substantial reasons, such as extended periods of inactivity (which might indicate abandonment of the account) or at your own request. o User-Initiated Deletion: You have the ability to delete your account at any time through your account settings. Deleting your account will remove your profile and personal data from the active database of the Platform (see Privacy Policy for details on data retention after deletion). Once deleted, you will no longer have access to the Platform unless you register again. o Operator-Initiated Suspension/Termination: If we determine that a User has violated the Terms or engaged in improper conduct, we may suspend the account (making it temporarily inaccessible) or terminate it (permanent removal). Normally, we will provide notice to the email on file for the account, informing the User of the suspension/termination and the reason, unless the severity of violation warrants immediate action without notice. Suspended Users may contact us to appeal or clarify the issue. o Effect of Termination: Upon termination of an account (whether by the User or by us), the agreement between the User and the Operator as set out in these Terms is considered terminated. The User will lose access to any features requiring login. However, certain provisions of the Terms that by their nature should survive termination (such as sections on Liability, Governing Law, etc.) shall continue to apply. If an Employer account is terminated, the Operator may remove or anonymize any active job postings from that account. If a Job Seeker account is terminated while there are active job applications in process, we recommend notifying the respective Employers separately, as they will no longer be able to reach you through the Platform. 9. Complaints and Dispute Resolution We value our Users and aim for a positive experience. If you have a complaint about the Platform or believe we have not met your expectations, please contact us at biuro@humaneo.pl (email) or via the contact form on our website. Provide as much detail as possible about the issue. We will acknowledge receipt of your complaint and do our best to resolve it promptly, typically within 14 days. If a dispute arises between you and the Operator that cannot be resolved amicably, refer to Section 11 for governing law and jurisdiction. Note that disputes between Job Seekers and Employers are outside our direct responsibility (per Section 7), but we encourage Users to notify us of any misuse of the Platform. 10. Intellectual Property The Platform and all of its components (including text, graphics, logos, software code, and overall design) are protected by intellectual property laws. The Operator (or its licensors) retains all rights, title, and interest in the Platform’s software and content, except for content provided by Users themselves. You are granted a limited, revocable, non-exclusive, non-transferable license to use the Platform for its intended purpose. You may not copy, modify, distribute, sell, or lease any part of our services or included software, nor may you reverse engineer or attempt to extract the source code of that software, unless laws prohibit those restrictions or you have our written permission. User Content: By submitting or posting any content (such as CV information, job descriptions, or messages) on the Platform, you grant us a worldwide, royalty-free license to use, host, store, reproduce, and display that content for the purpose of operating and improving the Platform and providing the services (for example, displaying your CV to interested Employers, or translating your job posting to other languages if needed for candidates). We will not use your content for any unrelated purposes. You represent that you have the rights to any content you post (for example, you have permission to use a company’s logo in a job ad, or you own the rights to your CV details). We may remove or delete User content if we receive notice of intellectual property infringement or if it violates these Terms. 11. Final Provisions o Changes to Terms: The Operator reserves the right to modify these Terms and Conditions if necessary (for example, to reflect changes in the law, new features, or business practices). Users will be notified of material changes at least 7 days before the new terms become effective, via email or a prominent notice on the Platform. If you do not agree with the revised Terms, you must discontinue using the Platform and may delete your account. Your continued use of the Platform after the effective date of the updated Terms will constitute acceptance of the changes. o Governing Law: These Terms, and any disputes arising from or relating to them or the use of the Platform, shall be governed by the laws of Poland, without regard to its conflict of law principles. We operate from Poland and currently target Users in the EU; we thus adhere to EU and Polish regulations for online services. o Jurisdiction: Any legal actions or proceedings arising out of or related to these Terms or the use of the Platform that cannot be settled amicably shall be brought exclusively in the competent courts of Poland. By agreeing to these Terms, you consent to the jurisdiction of Polish courts. If you are using the Platform as a consumer and your local mandatory laws provide for different jurisdiction, those provisions may take precedence. o Severability: If any provision of these Terms is held to be invalid or unenforceable by a competent court, the remaining provisions shall remain in full force and effect. Any invalid/unenforceable provision will be interpreted or replaced in such a way as to fulfill its intended purpose to the maximum extent permitted. o No Waiver: The failure of the Operator to enforce any right or provision of these Terms shall not constitute a waiver of such right or provision. Any waiver must be explicit and in writing to be effective. o Entire Agreement: These Terms, along with the Privacy Policy and any other policies or guidelines posted on the Platform, constitute the entire agreement between the Operator and the User regarding the use of the Platform, superseding any prior agreements or understandings (oral or written) relating to the same subject matter. If you have any questions or concerns about these Terms, please contact us before using the Platform. Thank you for reading our Terms and Conditions and for using Work Without Borders!   Privacy Policy of the Work Without Borders Platform 1. Introduction – Who We Are and Scope of Policy This Privacy Policy explains how Work Without Borders (the "Platform") collects, uses, shares, and protects your personal data, in accordance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR). The Platform is committed to respecting your privacy and safeguarding your personal information. By using our services, you agree to the collection and use of information in accordance with this policy. • Data Controller: The data controller for the Platform is Stowarzyszenie Humaneo, located at ul. Nawojowska 12, 33-300 Nowy Sącz, Poland. In this document, "we" or "us" refers to Humaneo. As data controller, we determine the purposes and means of processing personal data on the Platform. • Contact Information: If you have any questions or requests regarding your personal data or this Privacy Policy, you can contact us at biuro@humaneo.pl or by mail at the above address (Attn: Data Protection). We may have appointed a Data Protection Officer; if so, you may reach the DPO via the same contact details (please mention "For the attention of DPO" in your request). • Services Covered: This Privacy Policy applies to data we collect through the Platform’s website and related services where this policy is referenced. It covers personal data of Platform Users (job seekers, employers) as well as visitors to our site. For clarity, "personal data" means any information relating to an identified or identifiable natural person (as defined by GDPR). • Updates: We may update this Privacy Policy from time to time to reflect changes in our practices or for legal reasons. We will notify you of significant changes by posting a notice on our site or emailing registered users. The "last updated" date at the end of this document indicates the latest revision. 2. What Data We Collect We only collect data that is necessary for the Platform’s functionality and the recruitment process. The types of personal data we collect include: • Account Registration Data: When you create an account, we collect basic information such as your name, email address, and a password. For Employers, we additionally collect company/organization details (company name, industry, location) and contact information for the company representative (like name, business email, phone number). • Profile and Resume Data: Job Seekers can create a profile with information typically found on a resume/CV, such as your contact details (address, phone number), professional experience, education, skills, languages, and any other information you choose to include about your qualifications. You may also upload documents (e.g., your CV file) or a profile picture. Please do not include sensitive personal information (e.g., racial or ethnic origin, political opinions, religious beliefs, health data) in your profile or CV, as these are not required for job search purposes and we do not solicit or intentionally process such special categories of data. We also advise against including national identification numbers or financial account details on your resume for security reasons. • Personality Test Results: The Platform may offer a MYPS personality assessment to Job Seekers as an optional tool to enhance the matching process. If you take this test, we collect your responses and the resulting assessment profile. This information is used to better understand your work preferences and strengths. Taking the test is voluntary; you can choose not to complete it, in which case no test data will be stored. • Job Listing Information: Employers provide information when posting job offers, which can include job title, description, requirements, salary range, location, and the contact details for applications. This information (excluding personal contact details beyond what’s necessary) is publicly visible to logged-in Job Seekers. If you are an individual Employer or sole proprietor, some of this information (like contact name or business email) might be considered personal data and is treated as such. • Communication Content: If Users communicate through the Platform (for example, sending messages or application letters through our system), we process the content of those communications. These may include cover letters, interview scheduling messages, or any other information shared between Job Seekers and Employers. • Technical Usage Data: Like most websites, our Platform automatically collects certain technical data when you visit or use it. This includes your IP address, browser type and version, device type, operating system, referral URLs, pages viewed, dates/times of access, and other diagnostic data. We also use cookies and similar technologies – see Section 7 (Cookies) for details. This technical data is used primarily for security, analytics, and improving our service (e.g., ensuring compatibility with different browsers, preventing fraud). Such data is typically not directly linked to your name or contact information, but it could be considered personal data when associated with your account. 3. How We Use Your Data (Purposes and Legal Bases) We process your personal data for the following purposes, as necessary for our legitimate interests, to perform a contract with you, to comply with legal obligations, or based on your consent – all in line with GDPR principles: • Providing Core Services (Matchmaking and Recruitment): We use the personal data Job Seekers and Employers provide to operate the Platform’s core functionalities: enabling Job Seekers to find and apply for jobs, and Employers to find suitable candidates. For Job Seekers, this means your profile information and CV data are stored and can be matched against job criteria and presented to prospective employers (either by you applying or by our algorithm suggesting your profile to an interested employer). For Employers, your provided job listings are displayed to candidates, and your contact info is used for candidate communications. Legal basis: This is generally done to fulfill our service contract with you (GDPR Art. 6(1)(b)) – when you sign up, you agree that we process your data to provide the job matching service. In cases where we highlight candidates to employers or vice versa, it’s also in our legitimate interest (Art. 6(1)(f)) to facilitate connections on the Platform, which is the service’s primary function. • Account Management and Customer Support: We use data such as your name and email to manage your account (e.g., to verify your identity during login, to reset your password upon request, etc.) and to communicate with you for customer support purposes. If you contact us with a support query or feedback, we will use your contact information and any info you provide to respond and resolve issues. Legal basis: performance of contract (Art. 6(1)(b) – we have to use your data to provide support as part of the service) and/or legitimate interest (Art. 6(1)(f) – it benefits both you and us to efficiently resolve problems). • Notifications and Service Communications: We may send you service-related emails or notifications, for example: a welcome email upon registration, notifications of new job matches or messages, changes to our terms or policies, or important security updates. These are not marketing communications, but essential or useful information about the service. Legal basis: legitimate interests (Art. 6(1)(f)) in keeping users informed about their account and the service, or sometimes necessity for contract (if the communication is necessary for using the service). You cannot opt out of certain critical service notifications (like security alerts or legal notices), but you can control some preferences (like whether to receive new job match alerts) in your settings. • Personalized Job Matching (Profiling): To improve your experience, we use algorithms to analyze Job Seeker profiles and job listings in order to recommend relevant opportunities. This involves profiling, meaning we process your data (like skills, experience, possibly personality test results) to assess what jobs might fit you best, or for an Employer, which candidates might fit their job. Legal basis: legitimate interest (Art. 6(1)(f)) – our interest in providing an effective job-matching service. We have balanced this against your rights and freedoms, and provide safeguards: see Section 5 (Automated Decision-Making) for more on how we use profiling and your rights in that context. Note: these automated suggestions do not have legal or significant effects by themselves – they merely assist you. • Facilitating Communication Between Users: If our Platform allows you to contact an Employer or vice versa through a messaging system or via email relay, we will process the data needed to facilitate that (like sending your message content and profile info to the Employer you choose to contact). We may also monitor or scan messages for compliance (e.g., to prevent spam or malicious content). Legal basis: performance of contract (facilitating communication you initiate is part of using the service) and legitimate interest (keeping the platform safe from misuse). • Analytics and Improvements: We use aggregated and anonymized data to understand Platform usage and improve our services. For instance, we might track how many Job Seekers clicked on a particular job offer, or what percentage of users fill in the profile entirely, etc., to identify trends or pain points. We use Google Analytics or similar tools that collect usage data in an anonymized fashion. Legal basis: legitimate interest (Art. 6(1)(f)) – to improve our platform’s functionality and user experience. Wherever feasible, we use data that does not directly identify individuals for analytics. • Security and Fraud Prevention: We process certain data to maintain the security of our Platform and users. This includes using IP addresses, device information, and activity logs to detect and prevent fraudulent or malicious activity (such as fake accounts, bot usage, scraping, or hacking attempts). We may block certain IP addresses or accounts if we suspect abuse. Legal basis: legitimate interest (Art. 6(1)(f)) – ensuring the security and integrity of our service; this is a fundamental interest that also benefits all users. In rare cases, processing may be to comply with a legal obligation to maintain security (Art. 6(1)(c)), especially under laws related to personal data protection (GDPR mandates appropriate security measures). • Legal Compliance: We might need to process and retain data to comply with various legal obligations. Examples include retaining business records for tax/audit purposes, complying with lawful requests from authorities, or fulfilling obligations under labor or anti-discrimination laws in our role as a service provider. Legal basis: compliance with a legal obligation (Art. 6(1)(c)). For instance, if law enforcement provides a lawful subpoena, we may need to process (disclose) data accordingly. • Marketing and Newsletters (if applicable): If you explicitly consent, we may use your email to send occasional newsletters or information about new Platform features, project updates, or events. This is completely opt-in. You can decide to receive such emails, and you can opt out at any time. Legal basis: consent (Art. 6(1)(a)), which you can withdraw any time. If you don’t give consent, we will not send you marketing communications. (Note: as of the latest update, we may or may not have such a newsletter; if we introduce one, we will ask your permission first). We will not use your personal data for purposes that are incompatible with the above, unless we obtain your consent or as required/allowed by law. We do not engage in automated decision-making that produces legal effects or similarly significant effects without human involvement, as defined under GDPR Article 22. 4. Disclosure of Data (Who We Share Your Data With) We treat your personal data with care and confidentiality. We do not sell your personal data to third parties. However, in order to provide our services, we may need to share certain data with specific parties, as detailed below: • Sharing between Users: The core function of the Platform involves controlled sharing of data between Job Seekers and Employers. If you are a Job Seeker and you apply to a job or are identified as a match, the Employer will gain access to your application and the personal data you include (usually your name, CV details, and contact info). Similarly, if you are an Employer and a Job Seeker applies to your listing, that Job Seeker sees the information you provided in the job ad and any contact details designated for applicants. We facilitate this transfer of data as part of using the Platform. Important: Once an Employer has a Job Seeker’s data (or vice versa) through the Platform, they become an independent data controller of that information for the purpose of their recruitment process. They are responsible for handling that data lawfully (for example, an Employer should not use a candidate’s CV from our Platform to contact them about unrelated jobs outside the Platform without consent). We urge all Users to use others’ data only for recruitment-related purposes and to keep it secure. • Service Providers (Processors): We employ third-party companies and individuals to support our services – for example, hosting providers, cloud storage providers, email service providers, analytics services (like Google Analytics), and possibly AI algorithm providers. These third parties may have access to your personal data only to perform tasks on our behalf (e.g., storing data on a server, delivering email notifications, or analyzing usage patterns) and are obligated not to disclose or use it for any other purpose. We ensure that all our service providers are bound by data protection agreements (GDPR-compliant processor contracts) to safeguard your data. Examples of processing partners: our web hosting company that stores the Platform’s database, an email delivery service to send notification emails, etc. These providers typically only have access to information as needed for their function (for instance, the email service would handle your email address and message content to send emails, but not other profile data). • Authorities or Legal Obligations: We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court, law enforcement or government regulator). For example, if a court order or subpoena demands certain user information, we will comply after verifying the request’s legitimacy. Additionally, we might disclose data if necessary to exercise, establish, or defend our legal rights (for instance, providing information in a lawsuit involving the Platform), but we will do so in accordance with applicable laws and with respect for your privacy. • Business Transfers: If the Platform or Humaneo’s project is involved in a merger, acquisition, restructuring, or asset sale, your personal data may be transferred to the new entity or third party as part of that transaction. We would ensure that the new owner continues to use your data in line with this Privacy Policy or notify you of any changes. • Project Partners: The “Work Without Borders” platform may be part of a collaborative project (potentially funded by an EU program or partnership). In such case, we might share non-identifiable aggregate data about the platform usage with project partners or sponsors for reporting purposes (e.g., number of users, general outcomes). We will not share identifiable personal data with project partners unless it is explicitly needed and we have appropriate agreements in place or your consent. International Data Transfers: We store and process data on servers located within the European Union. We do not transfer your personal data to countries outside the European Economic Area (EEA). All our main service providers are also within the EEA or in countries deemed adequate by the EU, or otherwise bound by standard contractual clauses to ensure GDPR-level protection. Therefore, your data benefits from the strong protections of EU privacy law wherever it is processed. If in the future we need to transfer data outside the EEA (for example, to a cloud service provider in the U.S.), we will do so only with appropriate safeguards in place (like EU Commission’s Standard Contractual Clauses) and will update this policy accordingly. 5. Automated Decision-Making and Profiling As mentioned, we use automated processing (profiling) to match candidates with jobs. However, this does not constitute an automated decision that produces legal effects or similarly significant effects on you, as per GDPR Article 22. The Platform’s automated suggestions do not by themselves determine the outcome of any job application or employment decision – those decisions are made by human employers and job seekers. The profiling is used simply to sort and recommend opportunities. You have rights regarding automated processing: you can request human intervention in the process, express your point of view, or contest a suggestion. For instance, if you feel the algorithm is not presenting you appropriate matches, you can contact us to review. Also, you are free to not rely on the suggestions and search or post manually. We continually work to improve the fairness and accuracy of our matching algorithm. If we were ever to implement fully automated decision-making with significant impact (which we do not currently do), we would only do so in compliance with GDPR (e.g., with your explicit consent or as otherwise allowed, and with an option to have a human review). 6. Data Retention – How Long We Keep Your Information We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, as outlined in this policy, unless a longer retention period is required or permitted by law. This means: • Active Account Data: If you have an account on the Platform, we will keep your profile information, CV, job postings, and other data you’ve provided for as long as your account is active and you do not request deletion. We consider an account active as long as you log in or use the Platform periodically. If you become inactive for an extended period, we may send you a reminder or, eventually, anonymize or delete your data in line with our data minimization practices. • Closed/Deleted Accounts: If you choose to delete your account (or it’s terminated per Terms of Service), we will remove or anonymize personal data associated with your profile within a reasonable time (typically immediately or within 30 days, save for backups). However, we may retain certain basic information to keep records of your transaction (like the fact that you had an account and it was deleted, associated email for suppression list to not send you emails, etc.) or if required for legal reasons. If you merely deactivate your account, we might retain data in case you reactivate. • Job Applications and Communications: If you, as a Job Seeker, have applied to a job or communicated with an Employer through the Platform, those communications may be retained as part of the Employer’s account records (since they received it) and our system logs, even if you delete your account. But we will no longer link them to your profile in our system. Employers are advised to only retain candidate data for as long as necessary for recruitment. We may anonymize application data after a certain period unless the Employer needs it. • Legal and Backup Retention: We keep server logs and backups that might contain fragments of your data for a limited time. Server logs are generally kept for a short period (a few weeks) unless needed for security analysis. Backups are cycled and encrypted; they are typically retained for disaster recovery purposes for up to a few weeks or months. If your account is deleted, your data may persist in secure backups until those backups expire, but it will not be used or restored unless for a legitimate recovery scenario. • Compliance and Disputes: If we are under a legal obligation to retain data (for example, tax records, compliance with grant requirements, or data involved in a legal dispute), we will retain that specific data for as long as the obligation or dispute lasts. During this period, it will be securely stored and not actively processed for other purposes. • Anonymized Data: We may retain anonymized or aggregated data (which no longer identifies you) indefinitely for research, statistical analysis, or project reporting. For instance, overall platform usage statistics or average time to hire, etc., could be kept without personal identifiers. In summary, we aim to minimize retention. When data is no longer needed, we ensure it is either safely deleted or irreversibly anonymized. If you have specific questions about our retention of your data, you can contact us. 7. Cookies and Tracking Technologies The Platform uses cookies and similar tracking technologies to provide and enhance our service. Cookies are small text files stored on your device (computer or mobile) by your web browser. We use the following types of cookies: • Essential Cookies: These are necessary for the Platform to function properly. For example, session cookies keep you logged in as you navigate through pages, so you don’t have to log in repeatedly. Without these cookies, some services (like account login or posting jobs) may not work correctly. • Preference Cookies: These remember your preferences, such as language selection or other settings, to provide a more personalized experience. • Analytics Cookies: We use these to collect information about how users interact with the Platform, which pages are visited, what actions are taken, etc. This helps us improve the Platform’s design and features. For example, we might use Google Analytics which sets cookies to gather usage data (with IP anonymization enabled). The data collected is aggregated and doesn’t directly identify individuals for analytics purposes. • Security Cookies: These cookies help identify and prevent security risks. They might store information about your session to detect if someone else is attempting to hijack it, or to throttle requests if you attempt to perform actions too rapidly (possibly indicating a bot). You have control over cookies. When you first visit, you may see a cookie consent banner (depending on legal requirements) allowing you to accept or reject certain cookies (other than strictly necessary ones). Additionally, most web browsers allow you to manage or delete cookies through their settings. You can usually find these options under “Privacy” or “Security” settings in the browser. Please note that disabling certain cookies (especially essential ones) may affect the functionality of the Platform – for instance, if you block all cookies, you might not be able to log in or maintain a session. For more detailed information, please refer to our Cookie Policy (if a separate policy is provided on the site) which lists specific cookies and their purposes. By using our Platform, you consent to our use of cookies as described (unless you opt out via your browser or settings). 8. Your Rights (Access, Control, and Choices) As an individual in the European Union (or under equivalent regulations in other regions), you have certain rights regarding your personal data that we hold. We are committed to facilitating the exercise of these rights. Below is a summary of your key rights: • Right to Access: You have the right to request confirmation whether we are processing your personal data, and if so, to obtain a copy of the personal data we hold about you, as well as information about how we use it. Most of the basic data you provided can be viewed by logging into your account (e.g., your profile info). If you need a comprehensive export, you can contact us and we will provide you with a copy of your data in a common format. • Right to Rectification: If any of your personal data is inaccurate or incomplete, you have the right to request that we correct or update it. You can directly edit many details in your account profile. For any data not editable by you (or if you need assistance), you can contact us with the correction request. • Right to Erasure ("Right to be Forgotten"): You have the right to request deletion of your personal data in certain circumstances. This includes situations such as: the data are no longer necessary for the purposes they were collected, you withdraw consent (and we have no other legal basis), you object to processing and we have no overriding interest, or your data was unlawfully processed. In practice, the easiest way to exercise this right is by deleting your account via the Platform interface, which triggers the removal of your data from our systems (subject to the retention policy in section 6). If you want us to delete specific data without deleting your whole account, you can also contact us. We will comply unless an exemption applies (for example, we might retain data if needed for a legal obligation or defense of claims, but we will let you know). • Right to Restrict Processing: You have the right to request that we limit the processing of your data (without deleting it) in certain scenarios: e.g., while you contest the accuracy of data and we are verifying it; if processing is unlawful but you prefer restriction over deletion; if we no longer need the data but you need us to keep it for establishment, exercise or defense of legal claims; or if you have objected to processing (next bullet) pending verification of overriding grounds. When processing is restricted, the data will be just stored by us and not actively processed, except to the extent permitted (like you consent or for legal claims) and we’ll inform you before lifting a restriction. • Right to Object: You have the right to object to certain types of processing of your data at any time, on grounds relating to your particular situation. The right to object applies when we process your data based on legitimate interests (Art. 6(1)(f) GDPR) or for public interest tasks (which we don’t do) or for direct marketing. If you object to direct marketing, we will immediately stop using your data for that purpose. If you object to processing based on legitimate interests (like profiling for matching), we will evaluate your objection and will stop processing the data in question unless we have compelling legitimate grounds to continue that override your interests, rights, and freedoms, or the processing is for the establishment, exercise, or defense of legal claims. In plain terms: if you don’t want us to use your data for matching suggestions or certain analytics, you can object and we’ll consider if we can accommodate that (for example, we could exclude your profile from the AI matching if you request it). • Right to Data Portability: You have the right to receive personal data that you provided to us, in a structured, commonly used, machine-readable format, and you have the right to transmit that data to another controller (or have us do so, where technically feasible). This right applies when the processing is based on your consent or a contract and carried out by automated means. For example, you can ask for an export of all the profile and application data you gave us, to transfer to a different job platform. We will provide this in a CSV or similar format upon request. • Right to Withdraw Consent: Where we process your data based on your consent (e.g., subscription to a newsletter or inclusion in a future candidates talent pool), you have the right to withdraw that consent at any time. Once you withdraw consent, we will stop the processing that was based on consent. Withdrawal does not affect the lawfulness of processing done before the withdrawal. For example, you can unsubscribe from marketing emails by clicking “unsubscribe” in any email or adjusting your account settings (if that option exists), or by contacting us. If you withdraw consent for something like the personality test results being used, we will stop using them for matching and can delete that data if you wish. • Right not to be subject to Automated Decision-Making: As explained, you have the right not to be subject to decisions based solely on automated processing, including profiling, that have legal or similarly significant effects on you. Our Platform does not make such decisions – there is always human judgment involved in hiring. Therefore, this right is respected by design. However, if you ever feel that you have been adversely affected by an automated decision within the Platform, please inform us and we will review it. To exercise any of these rights, please contact us at biuro@humaneo.pl with your request. For security, we may need to verify your identity (for example, by confirming you have access to the email associated with your account or asking for certain information) before executing your request, especially for access, deletion, or portability requests. We will respond to your request as soon as possible, generally within one month as required by GDPR. If your request is complex or we have many requests, we may extend this period by up to two more months, but we will inform you of the delay and the reasons. Note: Certain rights have exceptions. For example, we might not delete data we are required by law to keep, or we might not grant access to data that involves others’ privacy or our trade secrets. If we cannot fulfill a request, we will explain why (subject to legal restrictions). 9. Protecting Minors’ Privacy Our Platform is not directed to children. We require Users to be of legal working age. In general, that means we expect Users to be at least 16 years old (depending on local labor and consent laws; in many cases, 18 is the minimum age to enter employment without parental consent). We do not knowingly collect personal data from anyone under the age of 16 without verifiable parental consent. If you are under 16, please do not use or register on the Platform. If we become aware that we have collected personal data from a child under 16 (or the relevant age of consent in your country) without proper consent, we will take steps to delete that information. Parents or guardians who discover that their minor child has created a profile can contact us to request removal of the account and associated data. 10. Data Security Measures We implement a variety of security measures to ensure the safety of your personal data. These include: • Encryption: Our website uses HTTPS encryption (TLS) to secure data in transit between your browser and our servers. Sensitive data (like passwords) are stored hashed and not in plain text. • Access Controls: Only authorized personnel of Humaneo or our processors who need to access personal data to perform their duties have access to it. They are bound by confidentiality obligations. We restrict admin access to the database and use authentication measures to prevent unauthorized access. • Network Security: Our servers are protected by firewalls and monitored for intrusion. We regularly update software to patch vulnerabilities, and we use anti-malware and monitoring tools to detect suspicious activities. • Backups and Recovery: We maintain secure backups in case of data loss events, but these are protected and accessed under strict controls. • Training and Policies: Our team is informed about data protection principles. We have internal policies in place to handle data securely and deal with any suspected breaches responsibly. Despite our efforts, no system can be 100% secure. Therefore, we cannot guarantee absolute security of information. It’s also important for you as a User to maintain the security of your account credentials and to notify us immediately if you suspect any unauthorized access to your account. In the unlikely event of a data breach that poses a risk to your rights and freedoms, we will notify you and the appropriate supervisory authority (like UODO in Poland) as required by law. 11. Links to Other Sites Our Platform may contain links to external websites or services that are not operated by us (for example, a link to an educational resource or a third-party application form). This Privacy Policy applies only to our Platform. If you click a third-party link, you will be directed to that third party’s site. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites. We encourage you to review the privacy policy of every site you visit. 12. Right to Lodge a Complaint If you believe that we have infringed your data protection rights or processed your personal data in a way that is not in accordance with the law, you have the right to lodge a complaint with a supervisory authority. We would appreciate the chance to address your concerns first, so we invite you to contact us with any complaint. However, you can directly contact the data protection authority in the country of your habitual residence, place of work, or place of the alleged infringement. For instance, in Poland the supervisory authority is the President of the Personal Data Protection Office (UODO). In other EU countries, you can find the relevant authority listed on the European Data Protection Board website. To clarify: This right is in addition to any other administrative or judicial remedies you might have. It means you can report our actions to the regulators if you feel we are not complying with GDPR or other data protection laws. 13. Contact Us If you have any questions about this Privacy Policy, the practices of the Platform, or your dealings with us, you can contact us at: • Email: biuro@humaneo.pl • Postal Mail: Stowarzyszenie Humaneo – Work Without Borders Platform, ul. Nawojowska 12, 33-300 Nowy Sącz, Poland. We will be happy to respond and assist with any concerns or inquiries.   GDPR Data Protection Policy (Summary of GDPR Information) This section provides a concise summary of how we comply with the EU General Data Protection Regulation (GDPR), addressing key points often referred to as a “Privacy Notice” or “GDPR Information Clause”: 1. Data Controller: The controller of your personal data is Stowarzyszenie Humaneo, located at ul. Nawojowska 12, 33-300 Nowy Sącz, Poland. Contact: biuro@humaneo.pl. We are responsible for deciding how and why your personal data is processed in relation to the Work Without Borders Platform. 2. Purposes and Legal Bases of Processing: We process personal data for the following purposes and on the following legal grounds: o Platform Services (Job Matching and Accounts): To provide our core services – enabling Users to create accounts, post profiles/CVs or job offers, and matching job seekers with jobs. Legal basis: GDPR Art. 6(1)(b) (processing is necessary for the performance of a contract – our Terms of Service – with you as a User). o Profile Recommendations (AI Profiling): To automatically recommend relevant candidates to employers and job offers to job seekers by analyzing provided data. Legal basis: GDPR Art. 6(1)(f) (our legitimate interest in improving recruitment efficiency). Note: These automated recommendations do not amount to decisions with legal effect on you; you have the right to object to profiling. o Communications: To send service communications (account verification, notifications about matches or messages, changes to terms) and to respond to user inquiries or support requests. Legal basis: Art. 6(1)(b) (necessary for service) or Art. 6(1)(f) (legitimate interest in user support). o Consent-based Processing: If we ask for and you give consent for specific processing (e.g., signing up for an optional newsletter or including your profile in a future candidates talent pool beyond the current platform scope), legal basis is Art. 6(1)(a) (consent). You can withdraw consent any time. o Legal Compliance: To comply with obligations under law, e.g., providing data to authorities when required, keeping records. Legal basis: Art. 6(1)(c) (legal obligation). o Security and Anti-Fraud: To monitor, prevent, and address fraudulent or malicious activities on our Platform. Legal basis: Art. 6(1)(f) (legitimate interest in ensuring the security of our service). 3. Categories of Data: We process identification and contact data (name, email, etc.), professional data (CV details like education, work history, skills), account data (username, password), and usage data (IP address, cookies). We do not process special categories of sensitive data (racial/ethnic origin, political opinions, health, etc.), and we ask Users not to submit such data. Any such information, if provided, may be removed. 4. Recipients of Data: Your data may be shared with: o Other Users: Job Seeker data shared with Employers (profile, CV, contact info) when you apply or are matched; Employer data (job info, contact) visible to Job Seekers. This is inherent to using the Platform. o Service Providers: Trusted third-party processors who help us run the service (IT infrastructure, email service, analytics). They act on our instructions and are bound by data protection agreements. o Public Authorities: Entities like courts or regulators if required by law (e.g., responding to a lawful request). We do not sell data to anyone. We also do not transfer your data to unauthorized third parties. 5. International Transfers: We do not transfer personal data outside the EU/EEA. Our servers and service providers are located within the EU. Thus, your data enjoys uniform protection under EU law across all processing. Should we ever need to transfer data internationally, we will ensure appropriate safeguards (e.g., Standard Contractual Clauses) and update our policy accordingly. 6. Retention Period: We retain data only as long as necessary for the purposes of processing. In practice: account data is kept while your account is active; if you delete your account, we delete or anonymize your personal data within about 30 days (except data we must keep for legal reasons). Job application data may be retained by employers independently; however, within our system it will be removed once it’s no longer needed. We periodically review and purge data that is no longer required.See our Privacy Policy for detailed retention practices. 7. Your Rights: You have the following rights regarding your personal data: o Access: To confirm if we process your data and obtain a copy. o Rectification: To have inaccurate data corrected. o Erasure: To have your data deleted in certain cases (e.g., when no longer necessary). o Restriction: To restrict processing under certain conditions. o Objection: To object to processing based on legitimate interests, including profiling for matching. We will honor objections unless we have compelling grounds to continue or it’s needed for legal claims. You can always object to direct marketing. o Data Portability: To receive your data in a machine-readable format and have it transmitted to another controller if applicable. o Withdrawal of Consent: If processing is based on consent, you can withdraw it at any time, without affecting past processing. o Not to be subject to Automated Decisions: While our platform does not make legally significant automated decisions without human involvement, you have the right not to be subject to such decisions. To exercise these rights, contact us (see point 1). We will respond within one month or inform you if more time is needed. Note that some rights may be limited by law (for example, we might retain certain data if required by regulations even if you request deletion). 8. Right to Lodge a Complaint: If you believe your data protection rights have been violated, you have the right to file a complaint with a supervisory authority, particularly in the EU country of your residence, place of work, or where the issue occurred. In Poland, this is the President of the Personal Data Protection Office (UODO). We encourage you to contact us first so we can address your concerns. 9. Requirement to Provide Data: Providing personal data is voluntary, but necessary to use the Platform’s core services. For example, without an email you cannot register, without a CV you cannot effectively find a job through the Platform. If you choose not to provide certain data, you may not be able to use some features. We will indicate required fields versus optional ones. There is no statutory or contractual obligation for you to provide data beyond what is needed for service use, but lack of required data means we cannot create an account or offer the service. 10. Automated Decision-Making: The Platform uses automated processes (profiling) to suggest jobs or candidates; however, this does not equate to automated decision-making with legal or similar significant effect on individuals. There is always human choice involved in proceeding with a suggestion. We do not carry out fully automated decisions that would significantly affect you without your consent or other lawful basis. You have the right to request human intervention or to express your viewpoint in cases of automated processing (profiling). 11. Security Measures: We implement appropriate technical and organizational security measures to protect personal data against unauthorized access, alteration, disclosure, or destruction. For instance, data transmission is encrypted (HTTPS), and we have access controls and monitoring in place. For more detailed information, please refer to our full Privacy Policy (above). This summary is provided for convenience and transparency regarding our GDPR compliance.