Privacy Policy

Who we are

The controller of your personal data is:

• Alexandru Morari, conducting business as PropertyTalents Alexandru Morari, entered in the Polish Central Register and Information on Economic Activity (CEIDG)
• ul. Chłodna 51, 22nd floor, 00-867 Warsaw, Poland
• NIP (tax identification number): 9462460717
• REGON (statistical number): 142094347

In this policy, "PropertyTalents", "we" and "us" refer to this controller.

You can contact us about anything in this policy:

• by email: contact@propertytalents.com
• by telephone: +48 22 243 77 53
• by post: at the address above, marked "Personal data"

We have not appointed a Data Protection Officer. You can contact us directly with any question about your personal data.

What this policy covers

This policy applies to personal data we process:

• on this website, www.propertytalents.com;
• on our career site, jobs.propertytalents.com;
• in emails, calls and meetings with us;
• in the course of our executive search, recruitment, new market entry and career advisory services.

It covers:

• website visitors;
• candidates;
• clients and prospective clients;
• other business contacts.

Websites we link to, such as LinkedIn, are run by other organisations under their own privacy policies.

We process personal data in line with Regulation (EU) 2016/679 (the General Data Protection Regulation, "GDPR") and Polish law.

Visiting this website

You do not need to tell us who you are to browse this website. This website is hosted by Vercel Inc. When your browser requests a page, Vercel automatically processes the technical data needed to deliver it:

• your IP address;
• the date and time of the request;
• the page requested and the page you came from;
• your browser and device type;
• the response status.

How we use this data:

• Purpose: to deliver the website, keep it secure and investigate faults.
• Legal basis: our legitimate interest in running a secure, working website (Article 6(1)(f) GDPR).
• How long: on our current hosting plan, the request logs available to us are kept for one hour.

Vercel also processes technical data, such as IP addresses and traffic information, for its own purposes, including the security and operation of its platform, as described in Vercel's privacy notice.

The website's server functions run in Frankfurt, Germany, and its pages are delivered through Vercel's global network. Section 9 explains transfers outside the European Economic Area.

Current job listings are loaded from our recruitment system by the website's server. Browsing jobs does not send your personal data to Zoho.

Contacting us

Our enquiry forms and "Email your CV" links do not send anything to our website. They open a draft email in your own email app, addressed to contact@propertytalents.com, for you to review and send. A form draft contains:

• the details you typed: your name, telephone number, email address and message;
• the address of the page you started from.

If you do not send the email, we receive nothing.

When you email or call us, we process:

• your name and contact details;
• the content of your message and any attachments, such as a CV;
• our replies and any follow-up.

How we use this data:

• Purpose: to answer your enquiry and continue the conversation you started.
• Legal basis: our legitimate interest in responding to you (Article 6(1)(f) GDPR), or steps you ask us to take before entering into a contract with us (Article 6(1)(b) GDPR).
• How long: for as long as needed to deal with your enquiry, then for three years from our last contact, in line with the limitation period for claims connected with business activity under Article 118 of the Polish Civil Code.

Emails we receive are processed in Zoho Mail. If you send us a CV, section 5 also applies.

Applying for a role or sharing your CV

When you select "Apply Now", you leave this website for our career site, jobs.propertytalents.com. The career site runs on Zoho Recruit, our recruitment system. You enter your details and upload your CV there, and your application is stored in Zoho Recruit.

We process:

• your name, contact details and location;
• your CV, education, professional qualifications and employment history;
• information you share with us during the process, such as availability, notice period, salary expectations and career goals;
• our notes and the roles we have discussed with you.

Please do not send us:

• special category data, such as information about your health, ethnic origin, religious beliefs, political opinions, trade union membership or sexual orientation;
• information about criminal convictions.

If you choose to include special category data, we process it only with your explicit consent (Article 9(2)(a) GDPR and, for applications to join our own team, Article 22¹b of the Polish Labour Code). We do not process criminal conviction data on the basis of consent.

How we use this data:

• For roles we fill for our clients, to assess your suitability and manage your application: our legitimate interest in providing recruitment services and in considering you for the role you applied for (Article 6(1)(f) GDPR). Any additional information you choose to give us is processed with your consent (Article 6(1)(a) GDPR).
• For roles in our own team: steps you ask us to take before entering into a contract (Article 6(1)(b) GDPR) and, for the data listed in Article 22¹ of the Polish Labour Code, our legal obligation (Article 6(1)(c) GDPR). Any other data you choose to give us is processed with your consent (Article 6(1)(a) GDPR and Article 22¹a of the Polish Labour Code).
• To present your profile to the hiring client: only for a role you applied for or agreed to be considered for.
• To consider you for future roles: only with your consent (Article 6(1)(a) GDPR).
• To establish, exercise or defend legal claims: our legitimate interest (Article 6(1)(f) GDPR).

You can withdraw consent at any time. Withdrawal does not affect processing carried out before it. Refusing or withdrawing consent will not lead to unfavourable treatment; for candidates for employment, Article 22¹a § 2 of the Polish Labour Code expressly prohibits it.

How long we keep this data:

• For a specific role: until the recruitment process for that role ends.
• For future roles: until you withdraw consent, and no longer than three years from our last contact with you.
• For legal claims: only the minimum data needed, for the limitation period under Polish law.

Article 22¹ of the Polish Labour Code limits what an employer in Poland may request from a candidate:

• name and surname, date of birth and the contact details you choose to give;
• where necessary for the role, education, professional qualifications and employment history, excluding pay in current and previous employment.

Other data may be processed only with your consent (Article 22¹a § 1 of the Polish Labour Code).

When we approach you about a role

Executive search means identifying professionals who may suit a client's role, including people who have not applied to us. For this purpose we may process:

• your name, current and previous positions and employers;
• your professional background and qualifications;
• your business contact details.

We obtain this data from:

• professional networking sites, such as LinkedIn;
• company websites, press and industry publications;
• industry events;
• recommendations from people in our professional network;
• business contact databases (such as Lusha).

How we use this data:

• Purpose: to identify and approach suitable candidates for our clients' roles.
• Legal basis: our legitimate interest in providing executive search services and in offering relevant career opportunities (Article 6(1)(f) GDPR).
• How long: while the data remains relevant to our search work. We review each profile at least every 24 months and delete data we no longer need.

We tell you that we hold your data, and where it came from, when we first contact you and in any case within one month of obtaining it (Article 14(3) GDPR). You can object at any time. If you do, we stop using your data for this purpose and keep only a minimal do-not-contact record: your name and the contact details needed to recognise you, so that we do not contact you again. The legal basis for that record is our legitimate interest in respecting your objection (Article 6(1)(f) GDPR).

Clients and business contacts

If you work for a client, a prospective client or another business we deal with, we process:

• your name, job title and employer;
• your business contact details;
• our correspondence and meeting notes;
• contract and billing details.

How we use this data:

• To deliver our services and manage our relationship: performance of a contract where you contract with us personally (Article 6(1)(b) GDPR), otherwise our legitimate interest in working with your organisation (Article 6(1)(f) GDPR).
• To issue invoices and meet accounting and tax obligations: legal obligation (Article 6(1)(c) GDPR).
• To establish, exercise or defend legal claims: our legitimate interest (Article 6(1)(f) GDPR).
• To send you market updates by email: only if you have given your prior consent, as required by Article 398 of the Polish Electronic Communications Law of 12 July 2024 (Prawo komunikacji elektronicznej). The legal basis is your consent (Article 6(1)(a) GDPR). You can withdraw it at any time, using the unsubscribe link in each update or by writing to us, and we will stop sending updates.

How long we keep this data:

• Relationship data: for the duration of the relationship, then until the limitation period for claims expires. Under Article 118 of the Polish Civil Code this is generally six years, or three years for claims connected with business activity, and the period ends on the last day of a calendar year unless it is shorter than two years.
• Accounting and tax records: five years from the end of the calendar year in which the tax payment deadline expired (Articles 70 § 1 and 86 § 1 of the Polish Tax Ordinance).
• Market updates: until you withdraw your consent. We keep a record of your consent and of its withdrawal for as long as we may need to demonstrate it.

Who receives your data

We do not sell personal data. We share it only as described below.

• Hiring clients receive candidate profiles as described in sections 5 and 6. They use them as separate controllers under their own privacy policies.
• Zoho Corporation and its group companies provide Zoho Recruit, Zoho Mail and related tools we use, and process data on our behalf under Zoho's data processing addendum.
• Vercel Inc., 440 N Barranca Avenue #4133, Covina, CA 91723, United States, hosts this website and processes the technical data described in section 3 under Vercel's terms and privacy notice.
• Providers of cloud office and file storage, and AI assistants used under business terms, process data on our behalf.
• Our accounting office, banks and legal or professional advisers receive data where they need it to provide their services.
• Public authorities receive data when the law requires us to disclose it.

Providers that process data on our behalf under data processing terms act only on our documented instructions and are bound by confidentiality. Within PropertyTalents, only team members who need personal data for their work can access it, and they are bound by confidentiality.

Transfers outside the European Economic Area

Some of our service providers process data outside the European Economic Area (EEA). When they do, we rely on a safeguard recognised by the GDPR.

• Zoho: our Zoho account is hosted in Zoho's United States data centre. Zoho states that it also processes data in the EEA and in other countries where it operates. Zoho processes our data under its data processing addendum, which includes the European Commission's standard contractual clauses (Commission Implementing Decision (EU) 2021/914). Zoho Corporation is not currently certified under the EU-U.S. Data Privacy Framework.
• Vercel: this website's server functions run in Frankfurt, Germany, and its pages are delivered through Vercel's global network, so technical data may be processed in the United States and other countries where Vercel operates. Vercel states in its privacy notice that it participates in the EU-U.S. Data Privacy Framework, which the European Commission recognised as providing an adequate level of protection in Implementing Decision (EU) 2023/1795.
• Cloud office, file storage and AI providers: where they process data outside the EEA, we use only services whose business terms include the European Commission's standard contractual clauses or that are certified under the EU-U.S. Data Privacy Framework.

You can ask us for a copy of these safeguards using the contact details in section 1.

Your rights

Under the GDPR you have the right to:

• access your personal data and receive a copy (Article 15);
• have inaccurate data corrected and incomplete data completed (Article 16);
• have your data erased, for example when we no longer need it or you withdraw consent (Article 17);
• restrict how we use your data, for example while we check its accuracy (Article 18);
• receive data you gave us in a structured, machine-readable format, or have it sent to another controller, where we process it by automated means on the basis of your consent or a contract (Article 20);
• withdraw consent at any time, without affecting processing carried out before withdrawal (Article 7(3)).

Your right to object

• You can object at any time to processing based on our legitimate interests, for reasons relating to your particular situation (Article 21(1) GDPR).
• You can object at any time to the use of your data for direct marketing, after which we will stop (Article 21(2) and (3) GDPR).

How to exercise your rights

Write to contact@propertytalents.com or to our postal address. We may ask you to confirm your identity before acting on a request. We respond without undue delay and in any event within one month. Where a request is complex, we may extend this by up to two further months and will tell you why (Article 12(3) GDPR). Exercising your rights is free of charge.

If you believe we are processing your data unlawfully, you can lodge a complaint with the Polish supervisory authority:

• President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych)
• ul. Stanisława Moniuszki 1A, 00-014 Warsaw, Poland
• uodo.gov.pl

You may also complain to the supervisory authority in the EU country where you live or work. We would welcome the chance to address your concern first.

Cookies and similar technologies

This website does not set cookies. It stores a small amount of information in your browser's local storage only where this is strictly necessary to run the site or to remember a setting:

• pt_privacy_consent_v1 records your privacy choices: whether analytics and marketing technologies are allowed, the version of the choices and when you made them. It stays until you clear your browser storage. If we change the available choices, we ask you again.
• pt_site_intro_seen_v2 remembers that the opening animation has played, so it is not shown on every visit. It contains no identifier and stays until you clear your browser storage.
• The website's offline support stores one generic offline page on your device, so you see a message instead of an error when you lose your connection. It contains no personal data.

Analytics and marketing technologies are switched off. If we enable them in the future, they will run only after you allow them, and we will update this policy first. You can review or change your choices at any time through "Cookies" at the foot of every page.

Our career site at jobs.propertytalents.com runs on Zoho's platform and sets its own cookies, including technical cookies that keep your session and route your connection. Zoho's own cookie and privacy information applies there.

You can also delete stored data and block cookies in your browser settings.

Do you have to give us your data?

Browsing this website does not require you to give us any personal data. Contacting us or applying for a role is voluntary. To consider you for a role, we need at least your name, contact details and CV. Without them we cannot take your application forward. Clients need to provide the details required for a contract and for invoicing under tax law.

Automated decisions

We do not make decisions based solely on automated processing, including profiling, that produce legal effects for you or similarly significantly affect you. People at PropertyTalents decide whom we introduce to a client, and the client makes the hiring decision.

Security

We protect personal data with technical and organisational measures appropriate to the risk:

• this website is served only over encrypted connections (HTTPS);
• access to personal data is limited to team members who need it;
• our team is bound by confidentiality;
• our recruitment and email systems are provided under data processing terms.

Children

Our services are for working professionals and organisations. This website is not directed at children, and we do not knowingly collect personal data from anyone under 16.

Changes to this policy

We review this policy regularly and update it when our services, tools or legal obligations change. The effective date at the top shows when it last changed. If a change significantly affects how we use your data, we will make it clear on this website.

Contact

For any question about this policy or your personal data, contact us:

• by email: contact@propertytalents.com
• by telephone: +48 22 243 77 53
• by post: PropertyTalents Alexandru Morari, ul. Chłodna 51, 22nd floor, 00-867 Warsaw, Poland