INFORMATION REGARDING THE PROCESSING OF PERSONAL DATA ON THE eSourcing S.A. SOCIAL MEDIA PAGE LOCATED ON THE LINKEDIN PLATFORM
Pursuant to Art. 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, hereinafter referred to as “GDPR“), we hereby inform you that:
1. The Controller of your personal data obtained and processed in connection with the operation of the eSourcing S.A. page on LinkedIn (available at: https://www.linkedin.com/company/esourcing-s-a-/) is eSourcing spółka akcyjna with its registered office in Kraków, address: ul. Żeleńskiego 103, 31-353 Kraków, entered into the Register of Entrepreneurs of the National Court Register maintained by the District Court for Kraków-Śródmieście in Kraków, 11th Commercial Division of the National Court Register, under KRS number: 0000333749, NIP: 6792872172, REGON: 120142081, share capital of PLN 350,000.00 (hereinafter referred to as “eSourcing“). You may contact us via e-mail at: info@esourcing.pl or by post at the registered office address.
2. eSourcing has appointed a Data Protection Officer, who can be contacted via e-mail at: iod@dmt.com.pl. You may contact the Data Protection Officer regarding all matters concerning the processing of personal data and the exercise of rights related to data processing.
3. The Joint Controller of your personal data is the LinkedIn platform provider – for users in the European Union, the European Economic Area, and Switzerland: LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland; and for other users: LinkedIn Corporation, 1000 W. Maude Avenue, Sunnyvale, CA 94085, USA. Information regarding the processing of personal data by the joint controllers is available at: https://pl.linkedin.com/legal/privacy-policy and https://www.linkedin.com/legal/privacy/eu.
4. When you visit our page, the joint controllers collect user data via cookies. eSourcing does not have information regarding what specific user data is collected. eSourcing also does not obtain full access to the collected user data. eSourcing may only access public profile information. eSourcing has no influence over how personal data is processed by the joint controllers (including during general interaction with pages on LinkedIn).
5. Within our page, we have access to the following personal data, which becomes visible when a user decides to follow our page and/or interact with its content:
- If a user sends us a message, we have access to their profile, the data contained therein, as well as the content, date, and time of the message;
- If a user comments on a post on our page, we have access to their profile, as well as the content, date, and time of the comment;
- If a user interacts with our page content (adds a reaction, shares), we may view their profile and reaction;
- If a user visits our page, post, or advertisement, we have access to their profile, as well as the date and time of the visit;
- If a user follows our page, we have access to their profile;
- If a user searches for our page, we have access to their profile;
- If a user participates in advertising campaigns organized by us (e.g., contests), we have access to the data provided by them necessary for participation. Further details can be found in the Information Note regarding personal data processing included in the Regulations of the respective campaign.
The aforementioned personal data is processed based on our legitimate interest pursuant to Art. 6(1)(f) GDPR to manage interaction with the user when they voluntarily use our page or send us a private message on LinkedIn. This data is stored for the duration of our page’s existence. You may stop following our page at any time.
If you post photos or other comments/posts containing the personal data of other individuals (profile name, image, etc.), please ensure these individuals have been informed beforehand. If the photos or comments/posts concern minors, we will assume you are acting as their legal representative (parent, guardian, etc.) or have obtained prior consent from their legal representative.
6. Personal data collected and processed by joint controllers for the purpose of personalization is determined by LinkedIn without our involvement and may be processed: a) through advertising technologies using pixels, ad tags, cookies, and other device identifiers; b) via data provided by you (e.g., profile, contact information, job title, industry); c) by collection based on LinkedIn usage (e.g., search history, news feed, followed persons, content feed, read posts); d) based on personal data provided by advertising partners, service providers, and publishers; e) through information provided by you and inferences drawn from it (e.g., determining industry, seniority, or salary range based on job title; determining age based on graduation date; determining gender based on names or pronouns; determining interests based on activity).
We only have access to categories already established by LinkedIn. For more information, visit: LinkedIn Privacy Policy. This data is processed in our legitimate interest to promote our activities and is stored for the duration of our page’s existence.
7. We reserve the right to delete any comments that are: a) unlawful or encouraging illegal activities; b) defamatory, vulgar, racist, or xenophobic; c) infringing on copyrights; d) inciting discrimination based on race, ethnicity, religion, disability, age, or sexual orientation; e) inconsistent with LinkedIn rules.
8. We strive to ensure safety and comfort on our page and expect users to refrain from posting unauthorized commercial advertisements, sending viruses/malicious code, or collecting user information through automated means (bots, spiders, scrapers) without our consent.
9. Data Sharing: Personal data is shared only as described below. We take appropriate measures to ensure data is processed, secured, and transferred in compliance with legal requirements. Regarding LinkedIn’s sharing practices, please refer to their policy. Your data may be shared with: (a) LinkedIn (as Joint Controller); (b) External entities administering our page (e.g., marketing agencies); (c) Public authorities, accountants, auditors, lawyers, and professional advisors if required by law or necessary for their work; (d) Contractors (IT systems, telecommunications, backup, and security providers). Data may also be disclosed if requested by the user, to legally authorized representatives, or in the event of a business transfer/acquisition.
10. International Transfers: As a rule, we do not transfer data outside the EEA. If such a transfer occurs, we will ensure protection via Standard Contractual Clauses or European Commission adequacy decisions. LinkedIn may transfer data outside the EEA; please refer to LinkedIn’s transfer help page.
11. Your Rights: You have the following rights (requests to eSourcing concern only data processed by eSourcing; for LinkedIn-specific processing, contact LinkedIn directly): (a) Right of access: Information about the data we hold and its use. (b) Right to rectification: Correcting inaccurate data. (c) Right to restriction of processing: Limiting use under specific conditions (e.g., contesting accuracy). (d) Right to erasure (“Right to be forgotten”): Deleting data no longer necessary or processed unlawfully, subject to legal exceptions (e.g., defense of claims). (e) Right to object: Objecting to processing based on legitimate interests due to your specific situation.
12. Right to Complain: You have the right to lodge a complaint with the President of the Personal Data Protection Office (ul. Stanisława Moniuszki 1A, 00-014 Warsaw, tel. 22 531-03-00, e-mail: kancelaria@uodo.gov.pl) if you believe the processing violates GDPR. More info at: www.uodo.gov.pl.