PRIVACY POLICY

COREVIST spółka z ograniczoną odpowiedzialnością with its registered seat in Warsaw (address: Szańcowa Street 44, 01-458 Warszawa), entered into the registry of entrepreneurs of the National Court Register by the District Court for the capital city of Warsaw, XIII Commercial Department of the National Court Register, under the number: 0000905908, having Tax Identification Number (NIP): 5272961213 and Statistical Number (REGON): 389209939 (hereinafter referred to as: „Corevist” or “We”) is a controller of job aplicants’ personal data obtained within recruitment process. You can contact us by phone: +1 919-424-2120, and also via e-mail to the address: hr@corevist.com

2. Why do we process your personal data

If we consider you a suitable candidate to work at Corevist, we process your personal data in order to ensure your participation in the recruitment process. We will process your data in order to:

• contact you & conduct the recruitment process,
• evaluate your qualifications for work at the position you are applying for,
• evaluate your abilities and skills necessary to work at the position you are applying for,
• ensure your participation in future recruitment processes (depending on your separate consent).

We process the following data of job applicants:

1. name(s) and surname;
2. date of birth;
3. contact details indicated by such a person (e.g. correspondence address, e-mail address, telephone number);
4. education;
5. professional qualifications;
6. employment history;
7. other personal data contained in your application documents (e.g. your image) such as CV, motivation letter, letter of reference or others;
8. personal data made publicly available on business or professional social media (LinkedIn, candidate’s organisation’s website);
9. other personal data acquired during an interview to the extent permitted by law;
10. other personal data that you made available to our recruitment services provider who then passed it on to

According to Polish law, personal data of job applicants indicated in points d) – f) above may be asked for only when required to perform work of a specific type or in a specific position. At Corevist, we need to analyze your education, professional qualifications and employment history to understand if you will be able to perform your future responsibilities successfully. It applies to all job applicants since each position at Corevist requires specific skills and abilities.

We may ask for other data than those mentioned in points a) – f) above only if it is necessary to exercise rights or to fulfil an obligation arising from the law provision. However, they still can be processed under your consent.

The legal basis for the processing of your personal data is:

• in relation to personal data mentioned under points a) – f) above – a provision of law [Article 22¹ of the Polish Labour Law] and the necessity of processing to take steps at your request prior to entering into a contract [Article 6 1 point b) 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, hereinafter referred to as: the “GDPR”];
• in relation to personal data mentioned under point g) above (not applicable to personal data relating to criminal convictions and offences should you include them in your application documents) – your consent [Article 6 par. 1 point a) of the GDPR]. You can withdraw your consent at any time by contacting us at hr@corevist.com. Note that such withdrawal will not affect the lawfulness of processing based on consent before its withdrawal;
• in relation to personal data mentioned under point h) above – the necessity of processing for the purposes of pursuing our legitimate interests [Article 6 par. 1 point f) of the GDPR]. We have a legitimate interest in actively searching for potential job candidates by looking through their publicly available profiles on business or professional social media (eg. LinkedIn, your organization’s website), otherwise we would not be able to judge whether you might be interested in a given position. Prior to our evaluation, our recruitment services provider probably also already browsed such public activity of yours and perhaps even contacted you that way in order to match you with us. We hope that you do not consider our activities as violating your rights and freedoms. We make every effort to ensure that our activities do not include unnecessary data and do not surprise you. After all, creating a profile in social media of a business or professional nature, taking part in events of this type and engaging in online discussions on topics related to us, you can expect that recruitment agencies or potential employers will contact you!

• in relation to personal data mentioned under point i) above – the necessity of processing for the purposes of pursuing our legitimate interests [Article 6 par. 1 point f) of the GDPR]. We have a legitimate interest in verifying your skills and abilities – it is necessary to assess whether you are the right person for the position we are recruiting for;
• in relation to personal data mentioned under point j) above – any legal basis that was relevant towards our recruitment services provider should be valid in relation with us; if not, we will not process such data or inform you about relevant legal basis separately.

If the data you provide to us includes sensitive data, we will process it only on the basis of your express and separate consent. The consent may be withdraw at any time by contacting us at hr@corevist.com. Note that such withdrawal will not affect the lawfulness of processing based on consent before its withdrawal. In the absence of the consent data will be deleted immediately.

If you give your consent to this, Corevist will also store and process your personal data for the purposes of future recruitment processes. You can withdraw your consent at any time by contacting us at hr@corevist.com. Note that such withdrawal will not affect the lawfulness of processing based on consent before its withdrawal.

We may entrust your personal data to our suppliers of services or different tools that are very useful and make our everyday work far easier. Therefore in this case the transfer of data is based on the legitimate interest that we have in optimizing our internal processes in order to provide our services more efficiently [Article 6 par. 1 point f) of the GDPR]. These entities act either as controllers who manage your data independently or as processors who process your data on behalf of and for the purposes set by us on the basis of relevant entrustment agreement of personal data processing.

• Corevist Inc., (address: 2711 Centerville Road, Suite 400, Wilmington, New Castle County, Delaware 19808, USA) – our mother company who runs general and administrative functions for us;
• Google Ireland Limited (address: Gordon House, Barrow Street, Dublin 4, Irlandia, Fax: +353 436 1001) and Google LLC (address: 1600 Amphitheatre Parkway, Mountain View, California 94043 USA) – we use Google services to handle our e-mail correspondence, as well as store and manage data in the cloud (Google Workspace);
• Atlassian. Pty Ltd (addres: Level 6, 341 George Street, Sydney NSW 2000, Australia) and Atlassian B.V. c/o Atlassian, Inc. (address: 350 Bush Street, Floor 13, San Francisco, CA 94104, USA) – we use Atlassian product Jira Software for project management; Using Jira Software involves transmission of your data to so-called third countries (outside the European Economic Area), where the GDPR is not applicable – namely United States, Singapore, and Australia (according to: https://www.atlassian.com/trust/reliability/infrastructure). However, the transfer is made on the basis of legal instruments provided for in the GDPR, guaranteeing adequate protection of your rights and freedoms.According to the privacy policy available at https://www.atlassian.com/pl/legal/privacy- policy Atlassian. Pty Ltd transfers data outside the EEA on the basis of decisions of the European Commission stating an adequate level of protection, namely EU-US Privacy Shield Framework, i.e. pursuant to Art. 45 sec. 1 GDPR, as well as on the basis of standard contractual clauses approved by the European Commission, i.e. pursuant to art. 46 sec. 2 lit. d GDPR.Atlassian, Inc. (address: 350 Bush Street, Level 13, San Francisco, California 94104, USA) has certified to the US Department of Commerce that it adheres to the Privacy Shield Principles. You can find Dropbox’s Privacy Shield certification at https://www.privacyshield.gov.

• Slack Technologies Limited (address: 4th Floor, One Park Place, Hatch Street Upper, Dublin 2, Ireland) – we use Slack Technologies product named Slack for team management;Using Slack involves transmission of your data to so-called third countries (outside the European Economic Area), where the GDPR is not applicable – namely United States, (according to: https://slack.com/intl/en-pl/help/articles/360035633934-Data-residency- for-Slack, https://slack.com/intl/en-pl/trust/privacy/privacy-faq). However, the transfer is made on the basis of legal instruments provided for in the GDPR, guaranteeing adequate protection of your rights and freedoms.According to the privacy policy available at https://slack.com/intl/en- pl/trust/privacy/privacy-policy#international Slack Technologies Limited transfers data outside the EEA on the basis of standard contractual clauses approved by the European Commission, i.e. pursuant to art. 46 sec. 2 lit. d GDPR.Slack Technologies, LLC (address: 500 Howard Street, San Francisco, CA, 94105, United States) has certified to the US Department of Commerce that it adheres to the Privacy Shield Principles. You can find Dropbox’s Privacy Shield certification at https://www.privacyshield.gov.

• external IT services provider – when providing services to us, it may have access to your personal data;

• state administration bodies authorised to do so by law (e.g. tax authorities, self- government bodies of legal advisers, offices, courts).

Your personal data is processed until the end of the recruitment process related to the position for which you are applying. After this time they are delated, unless you expressed your consent for processing your personal data for the purposes of future recruitment processes. In such case you data will be stored for up to 12 months.

Sensitive data that we have received from you without an explicit and separate consent for its processing will be deleted immediately.

In the event when we obtain your personal data from publicly available sources (social media of a business or professional nature, like LinkedIn) or from recruitment agency, we contact you no later than 30 days from obtaining the data (in accordance with Article 14 par. 3 of the GDPR).

We strive to make you happy with working with us. Remember, however, that you have many privileges that will allow you to influence the way we process your personal information, and in some cases cause you to stop such processing. These rights are:

1) the right of access by the data subject (regulated in Article 15 of the GDPR)

Article 15

Right of access by the data subject

1. The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
   • the purposes of the processing;
   • the categories of personal data concerned;
   • the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
   • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
   • the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
   • the right to lodge a complaint with a supervisory authority;
   • where the personal data are not collected from the data subject, any available information as to their source;
   • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data
2. Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the
3. The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
4. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of

 2) right to rectification of your data (regulated in Article 16 of the GDPR)

Article 16

Right to rectification

The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

3) right to erase your data (regulated in Article 17 of the GDPR)

Article 17

Right to erasure (‘right to be forgotten’)

1. The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
   • the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
   • the data subject withdraws consent on which the processing is based according to point
     • of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;
   • the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
   • the personal data have been unlawfully processed;
   • the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
   • the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).
2. Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal
3. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
   • for exercising the right of freedom of expression and information;
   • for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
   • for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);
   • for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
   • for the establishment, exercise or defence of legal claims.

4) right to restrict of processing of your data (regulated in Article 18 of the GDPR)

Article 18

Right to restriction of processing

1. The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
   • the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
   • the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
   • the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
   • the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data
2. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
3. A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.

 5) right to data portability of your data (regulated in Article 20 of the GDPR)

Article 20

Right to data portability

1. The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
   • the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and
   • the processing is carried out by automated means.
2. In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically
3. The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
4. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.

 6) right to object to the processing of your data (regulated in Article 21 of the GDPR)

Article 21

Right to object

1. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing. 
3. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
4. At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.
5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.
6. Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

To the extent that your data is processed on the basis of consent you have the right to withdraw your consent for data processing at any time (Article 7 par. 3 of the GDPR). The withdrawal of consent does not affect the lawfulness of the processing that was carried out on the basis of your consent before the withdrawal. You can withdraw your consent by sending a statement of withdrawal to our correspondence address 7474 Creedmoor Road, Suite 108, Raleigh, NC 27613 USA or our e-mail address: hr@corevist.com

To use any of the rights described above, please contact us by e-mail at the address we contacted you or at the address: hr@corevist.com. You can also contact us by phone at the number: +1 919- 424-2120

According to Article 77 of the GDPR you are entitled to submit a complaint to the supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place where the alleged violation is committed, if you believe that the processing of personal data regarding you violates the provisions of the GDPR.

In Poland, the supervisory body is the President of the Office for Personal Data Protection. You can make a complaint, among others by traditional mail to the following address: ul. Stawki 2, 00-913 Warsaw or electronically through portal ePUAP2. You can also get more detailed information on the website: https://uodo.gov.pl/.

At this point we do not conclude any agreement with you. However, in order to participate in the recruitment process you need to provide your personal data at least within the scope resulting from Article 22¹ of the Polish Labour Law, i.e. including name(s) and surname, date of birth, contact details and if it is necessary to perform work of a specific type or in a specific position (it usually is), education, professional experience and employment history. Provision of other data is voluntary.

The recruitment process may be initiated in three different ways.

As in most cases, we probably received your personal data, contact details and files etc. from our recruitment agency. At the point when we receive your data you should already know about the ongoing recruitment process.

Another possibility is that you contacted us on your own via e-mail, social media or in a different way. In such case we may still examine your profile on social media of business or professional nature or your organisation’s website in order to verify your experience, specialization and usefulness for a specific task.

In rare cases, we may have found you on our own and get in touch directly. This may happen if we for example browse on our own through public profiles on social media of business or professional nature or in case where somebody (e.g. our employee, etc.) directly recommended you for a position in our firm.

We do not make decisions in an automated manner or subject any personal data to profiling as understood by the GDPR.