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Privacy Policy For The Recruitment Process

About this policy

The service of handling recruitments and simplifying the hiring process (the "Service") is powered by Recruitee on behalf of NOVA Consulting Group Sp. z o.o. ("Controller" “We” “Us”).

It is important that the persons using the Service ("Users”) are informed about, how we handle User's personal data in the recruitment process.

We respect the personal data of the User and meet the conditions resulting from the law, in particular from Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of personal data relating to the processing personal data and the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

We ensure that our employees and subcontractors have been trained in the protection of personal data.

We process, manage, use, and protect User's Personal Data in accordance with this Privacy Policy ("Privacy Policy”).

We are the Controller in accordance with current privacy legislation. The Users’ personal data is processed with the purpose of managing the recruitment of employees to our company.

About collecting the personal data

We are responsible for the processing of the personal data that the Users contribute to the Service, or for the personal data that we in other ways collect with regards to the Service.

When and how we collect personal data

We collect personal data about Users from Users when Users;

  • make an application through the Service or otherwise, adding personal data about themselves either personally or by using a third-party source such as LinkedIn; and

  • use the Service to connect with our staff, adding personal data about themselves either personally or by using a third-party source such as LinkedIn.

We collect data from third parties, such as LinkedIn and through other public sources. This is referred to as “Sourcing” and be manually performed by our employees or automatically in the Service.

The types of personal data collected and processed

The categories of personal data that can be collected through the Service can be used to identify natural persons from names, e-mails, pictures, and videos, information from LinkedIn-account, answers to questions asked through the recruiting, titles, education, and other information that the User or others have provided through the Service. Only data that is relevant to the recruitment process is collected and processed.

Purpose and lawfulness of processing

The purpose of the collecting and processing of personal data is to manage recruitment. The lawfulness of the processing of personal data is our legitimate interest to facilitate recruitment.

The consent of the data subject

The User consents to the processing of its personal data with the purpose of the Controller’s handling recruiting. The User consents that personal data is collected through the Service, when Users;

  • make an application through the Service, adding personal data about themselves either personally or by using a third-party source such as LinkedIn, and that Controller may use external sourcing-tools to add additional information; and

  • when they use the Service to connect to Controller’s recruitment department, adding personal data about themselves either personally or by using a third-party source such as LinkedIn.

The User also consents to the Controller collecting publically available information about the User and compiling them for use in recruitment purposes.

The User consents to the personal data being collected in accordance with the above and will be processed according to the below sections.

The User has the right to withdraw the consent at any time, by contacting Controller using the contact details. Using this right may, however, mean that the User can not apply for a specific job or otherwise use the Service.

Storage and transfers

The personal data collected through the Service is stored and processed inside the EU/EEA, or such third country that is considered by the European Commission to have an adequate level of protection, or processed by such suppliers that have entered into such binding agreements that fully comply with the lawfulness of third country transfers or to other supplies where adequate safeguards are in place to protect the rights of the data subjects whose data is transferred. To obtain documentation regarding such adequate safeguards, contact us.

We inform you that the personal data provided via the Service and during the recruitment process are transferred to a third country - Germany. This is because the Recruitee's servers are located at the AWS hub in Frankfurt, Germany.

Duration of personal data processing

We shall process your personal data in order to contact and invite you, carry out and decide on the recruitment process, no longer than it is necessary for protection against claims and only as long as such claims may be made against the employer, for 24 months.

During that time we may also contact you and ask you to participate in other future recruitment processes. If you as a User wish not to have your Personal Data processed for this purpose (future recruitment) please contact us.

After sending us a message requesting the deletion of all personal information provided when contacting a User, we may take up to 14 days to comply with this request.

Exceeding the 2 years period is allowed only in order to perform the obligations arising from the provisions of the law, e.g. for accounting purposes or to defend our interests in case of complaints.

Users’ rights

The User has the right to request from us access to personal data concerning the user and to obtain information about the purposes of their processing, categories of processed data, data recipients, and data storage period.

The User has the right to rectify personal data if they are incorrect and the right to request completion of incomplete personal data.

The User has the right to request the erasure of personal data without undue delay if:

  • The personal data are no longer necessary for the purposes for which they were collected or otherwise processed;

  • Consent to the processing of personal data has been effectively withdrawn;

Using this right may, however, mean that the User can not apply for a specific job or otherwise use the Service.

The User has under certain circumstances a right to data portability, which means a right to get personal data and transfer these to another controller as long as this does not negatively affect the rights and freedoms of others.

The User has the right to request the restriction of the processing of personal data when:

  • The User questions the correctness of personal data - for a period enabling the administrator to check the correctness of personal data;

  • According to the User, the processing is unlawful, and the User opposes the deletion of personal data, requesting the restriction of their use instead;

  • The Administrator no longer needs personal data for processing purposes, but they are needed by the User to establish, pursue or defend claims;

  • The User has objected to the processing until it is verified whether the legitimate grounds of the administrator override those of the User.

The User has the right to withdraw consent to the processing of personal data at any time, however, the withdrawal does not affect the lawfulness of the processing, which was made on the basis of consent before its withdrawal.

The User has the right to lodge a complaint to the supervisory authority regarding the processing of personal data relating to the User if the User considers that the processing of personal data infringes the legal framework of privacy law.

Data Security

We take the measures that can be reasonably expected to make sure that the personal data of Users are processed safely and in accordance with this Privacy Policy and the GDPR regulation.

However, transfers of information over the Internet and mobile networks can never occur without any risk, so all transfers are made at the own risk of the person transferring the data.

Transfer of personal data to third party

The Administrator of personal data provided when using the Service is:

NOVA Consulting Group Sp. z o.o.

Lubicz 4, 31-075 Kraków, Polska

KRS 0000998715, NIP 5252929040, REGON 523490367

We will not sell The User's personal data to third parties. We may transfer User’s Personal Data to;

  • our contractors and sub-contractors, acting as our Processors and Sub-Processors in accordance with our instructions, for the provision of the Service;

  • our sister companies who are owned by NOVA Consulting Group AS (Karl Johans gate 16, 0154 Oslo, company number 995 113 058), acting as our Processors and Sub-Processors in accordance with our instructions, for the provision of the Service;

  • authorities or legal advisors in case criminal or improper behavior is suspected; and

  • authorities, legal advisors, or other actors, if required by us according to law or authority’s injunction.

We transfer Users' personal data to companies that provide services enabling the implementation of The Service:

  • Recruitee (Keizersgracht 313 1016 EE Amsterdam The Netherlands, Registration No. 63881829) who supplies the Service,

  • Microsoft Ltd., provider of cloud services including our corporate e-mail

  • Comarch S.A. (al. Jana Pawła II 39, 31-864 Kraków, NIP: 6770065406), provider of invoicing platform “Comarch ERP XT Faktury”

In the event of sending data from the EU area to other countries, we comply with the law regulations that ensure an analogical level of security to that of the European Union’s regulations.

Aggregated data (non-identifiable personal data)

We may share aggregated data with third parties. The aggregated data has in such instances been compiled from information that has been collected through the Service and can, for example, consist of statistics of internet traffic or the geological location for the use of the Service. The aggregated data does not contain any information that can be used to identify individual persons and is thus not personal data.


When Users use the Service, information about the usage may be stored as cookies. We use cookies to improve the User’s usage of the Service and to gather information about, for example, statistics about the usage of the Service. This is done to secure, maintain and improve the Service. This site is provided by the Recruitee platform. For information on how Recruitee processes personal data, please visit Recruitee’s Privacy Policy

What are cookies?

Cookies are passive text files that are stored in the internet browser on the User’s device, such as a computer, mobile phone, or tablet, when using the Service. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the site again, the cookie allows that site to recognize your browser. This way, the information you previously provided can be retrieved, so you can easily use customized features. Cookies may store user preferences and other information to enhance your experience on the career site or be used to track you when you navigate to other sites that also use services from third-party cookies.

Types of cookies used on this career site

Strictly necessary cookies: These cookies are necessary to provide you with services available through the career site.

Analytics cookies: These cookies collect information that is used either in aggregate form to help us understand how the career site is being used or how effective marketing campaigns are, or to help us customize the career site for you.

Preference cookies: These cookies allow the career site to remember information that changes the way the career site behaves or looks, such as your preferred language or the region you are in. Loss of information stored in a preference cookie may make the experience less functional but should not prevent it from working.

Social cookies: This career site may integrate with the following social platforms which independently may set marketing cookies on your computer. Please note that we do not have any control over how the information in these cookies is used nor do we have access to it.

Your control of cookies: You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by indicating your preference on the cookie banner that appears when you enter this career site.

Aside from exercising your cookie preferences through the cookie banner, you can restrict (block or delete) cookies by altering your browser settings. If you restrict the use of cookies, you will not be able to use all the interactive features on this career site. The way in which you can restrict cookies varies from browser to browser. You should therefore visit your web browser's help menu for more information.

Users can at any time disable the use of cookies by changing the local settings in their devices. Disabling cookies can affect the experience of the Service, for example disabling some functions in the Service.

Below are links to guides on disabling the option of accepting cookies in the most popular browsers:

Changes in Privacy Policy

We have the right to, at any time, make changes or additions to the Privacy Policy. The latest version of the Privacy Policy will always be available through the Service.


For questions or further information about our handling of personal data, please contact us via e-mail: