In accordance with Articles 13 and 14 of Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (hereinafter the “GDPR”) and Section 16 of Act No. 18/2018 Coll. on Personal Data Protection (hereinafter the “Personal Data Protection Act”), we would like to briefly inform you about the processing of your personal data (hereinafter the “Policy”).
The controller of your personal data
The controller of your personal data is:
Koderia, s. r. o., with its registered office at Dúbravská cesta 1793/2 Bratislava - mestská časť Karlova Ves 841 04, Slovakia, Company ID: 47 975 890, registered in the Commercial Register of the District Court Bratislava I, Section: Sro, Insert No. 101669/B (hereinafter the “Controller”)
Contact: kontakt@koderia.sk
Should you have any questions regarding the protection of your personal data, you can contact us at any time using the contact details above.
The Controller operates the website www.koderia.sk (hereinafter the “Website”).
Why do we process your personal data?
Our Website is publicly accessible without you having to provide any personal data. However, if you decide to use any of the services listed below on our site, we will need your personal data.
The “Adequate salary” feature
On our Website you can use the “Adequate salary” feature, which makes it possible to estimate an approximate adequate salary level on the labour market. In order for us to evaluate the adequate level of your salary, you can provide us with:
- your CV, which you upload as a file by clicking the “Upload CV” option, or
- your input data, namely: the selected position, first name and surname, e-mail address, work experience, specific technologies, years of experience (both overall and with specific technologies).
The personal data you provide in your CV or fill in through the form will be processed solely for the purpose of evaluating the adequate salary and will be deleted once you have been informed of the result.
By ticking the checkbox “I agree to the processing of personal data in accordance with the current Privacy Policy” you grant the Controller consent to process your personal data. The purpose of collecting your personal data is to provide you, upon your request, with information about the adequate salary level for the specific position selected. You grant your consent to the processing of personal data for a period of 3 years and you have the right to withdraw it at any time at the e-mail address kontakt@koderia.sk. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
The “Jobs” feature
The “Jobs” feature available on our Website allows you to upload your CV to our database for the purpose of being placed on the specific project you applied for or on another project in the future. Your data will be stored in our internal database and we will send you project offers that could be of interest to you.
By ticking the checkbox “I agree to the processing of personal data in accordance with the current Privacy Policy” you grant the Controller consent to store your CV in our internal database. The purpose of processing your personal data is to assign you to a specific project, or to be able to offer you other interesting projects in the future. You grant your consent to the processing of personal data for a period of 5 years and you have the right to withdraw it at any time on our Website via the e-mail address kontakt@koderia.sk. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
The “Refer a friend” feature
The “Refer a friend” feature available on our Website allows you to refer another person for one of our open job offers. The purpose of processing the referrer’s personal data is to refer a job position to another person and to pay out the commission. The purpose of processing the referred person’s personal data is to mediate an open job position.
To successfully start this process, the referrer’s personal data is required, namely: first name, surname and e-mail, along with the referred person’s personal data, namely: first name, surname, e-mail, phone number and current position.
We keep the data of the person who was referred to us only on the basis of that data subject’s consent. If consent is not given to us, the referred person’s data will be automatically deleted upon the expiry of 30 days from the day it was provided by the referrer.
By ticking the checkbox “I agree to the processing of personal data in accordance with the current Privacy Policy”, you as the referrer grant the Controller consent to process your personal data for this purpose and to store it in our internal database. The purpose of processing your personal data as the referrer is to find a suitable job position for another person and to pay out the commission to you as the referrer. You grant your consent to the processing of personal data until the job is mediated, for a maximum of 3 years. You have the right to withdraw your consent to the processing of personal data at any time at the e-mail address kontakt@koderia.sk. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
The “None of the positions caught your eye?” feature
The “None of the positions caught your eye?” feature available on our Website allows you to create a request to search for a job position matching your requirements as closely as possible. To create this request, the following input data must be entered: first name, surname, e-mail, phone number (optional), work location, project start date and preferred technologies.
By ticking the checkbox “I agree to the processing of personal data in accordance with the current Privacy Policy” you grant the Controller consent to process your personal data and to store it in our internal database. The purpose of processing your personal data is to find a suitable job position. You grant your consent to the processing of personal data for 5 years and you have the right to withdraw it at any time at the e-mail address kontakt@koderia.sk. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Registration and sign-in
Registration and subsequent sign-in on our Website allows you to create an account for greater convenience when browsing the website and using individual services. Through registration, the user gains the ability to save job offers and posts, as well as to add posts. Registration is possible by entering your first name and surname, e-mail address and password or through the services Google or Github. The purpose of processing your personal data is the creation and existence of your account.
As part of registration, by ticking the checkbox “I agree to the processing of personal data in accordance with the current Privacy Policy” you grant consent to the processing of personal data and to its storage for the duration of the account. You may request the cancellation of your account at any time and withdraw your consent to the processing of personal data at the e-mail address kontakt@koderia.sk. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. On the legal basis of legitimate interest, in connection with the creation of your account we will send you our newsletter with open job positions and other information that could be of interest to you. If you do not wish to receive the newsletter, you can cancel it at any time in your account settings, in the e-mail settings section.
The “CV” feature
The “CV” feature is available on our Website and, after signing in to your user account, allows you to create your CV online and subsequently generate it in pdf format. The personal data you state in your CV will be stored in our internal database so that we can contact you if we have a suitable job offer for you. As part of the “CV” feature you can provide us with the following personal data: photo, first name, surname, permanent address, profession, technologies you know, bio, contact details (namely: e-mail, phone, link to a website or social network), employment data (namely: position, company name, duration of employment, technologies, a more detailed description of the job position), experience (namely: education attained, name of the school/university, city, country, duration, more detailed description), references (namely: name, link, short description), certificates (namely: name, short description, foreign languages in the scope of language known, level attained).
By ticking the checkbox “I agree to the processing of personal data in accordance with the current Privacy Policy” you grant the Controller consent to process the personal data stated in your CV and to store it in our internal database. The purpose of processing and storing your personal data is to ensure that you can update your CV at any time, and at the same time our ability to offer you suitable job positions. You grant your consent to the processing of personal data for a period of 5 years and you have the right to withdraw it at any time on our Website via the e-mail address kontakt@koderia.sk. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. After the consent period expires or after the consent to the processing of personal data is withdrawn, your CV will be deleted.
The “Newsletter” feature
You have the option to subscribe to our newsletter, through which we will inform you about suitable job positions and about news that may be of interest to you.
You can subscribe to the newsletter at the end of the forms of the services listed above, where there is a checkbox with the option to subscribe to the newsletter. The system then adds your e-mail address to MailChimp and stores it in the corresponding list according to the type of applicant (Analyst, IT Specialist, IT Tester, Developer, Project Manager).
For the purpose of sending the newsletter, we will process the following data about you: first name and surname, e-mail address and the applicant’s experience in the form of technologies known.
By ticking the checkbox “I agree that Koderia may contact me in the future and send me interesting news” you grant the Controller consent to store your personal data in our internal database for the purpose of sending marketing offers. The purpose of processing and storing your personal data is to send you marketing offers that could be of interest to you. You grant your consent to the processing of personal data relating to the newsletter subscription for a period of 5 years and you have the right to withdraw it at any time on our Website via the e-mail address kontakt@koderia.sk. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. After the consent period expires or after the consent to the processing of personal data is withdrawn, your CV will be deleted.
We carry out automated individual decision-making, including profiling.
Mailchimp
MailChimp serves us to build a database of contacts of persons who have expressed interest in receiving the newsletter. Consent to the processing of personal data for the purpose of sending the newsletter is recorded using the MailChimp application. We use the MailChimp application to send electronic newsletters.
Mailchimp is a service provided by The Rocket Science Group, LLC, 512 Means Street, Suite 404, Atlanta, GA 30318, USA. The data stored during registration will be stored on a server operated by The Rocket Science Group, LLC in accordance with the GDPR rules and the EU-US Privacy Shield agreement. Further information about the personal data protection provided by the MailChimp application is available on this website: https://mailchimp.com/legal/privacy/.
MailChimp is integrated into every form on our site, but joining it is voluntary.
Processing of cookies
Cookies are small text files that a website stores on your computer or mobile device and that improve the use of the website, e.g. by making it possible to recognise previous visitors by remembering the visitor’s choice when opening a new window, by measuring website traffic or the way it is used for user improvements. Our Website uses cookies for this purpose.
The Website uses various types of cookies, namely necessary, analytical (Google Analytics) and marketing (Facebook Pixel) cookies. Personal data within the scope of essential cookies is necessary for the functioning of the website and is processed on the basis of the legitimate interest of the Controller for the purpose of ensuring the proper functioning of our site.
Personal data within the scope of analytical and marketing cookies is processed on the basis of consent, until the cookies are deleted in the internet browser, but no later than until the consent to the processing of personal data for this purpose is withdrawn.
This information is in accordance with the legal framework under Section 55(5) of Act No. 351/2011 Coll. on Electronic Communications, as amended, which stipulates that anyone who stores or gains access to information stored in a user’s terminal equipment is entitled to do so only if the user concerned has given consent on the basis of clear and complete information about the purpose of its processing; the use of the relevant setting of a web browser or another computer program is also considered consent for this purpose.
You can prevent these files from being stored on your device at any time by adjusting the settings of your web browser. Instructions on how to limit the use of cookies for the following web browsers can be found here:
Use of Google Analytics
On our Website we use the Google Analytics service, a web analytics service provided by Google Inc., 1600 Amphitheater Parkway Mountain View, CA 94043, USA (hereinafter “Google”). The Google Analytics service uses cookies, which are text files placed on your computer, to allow websites to analyse how you use the site.
Our Website uses the IP anonymisation feature provided by the Google Analytics service. Your IP address will therefore be shortened/anonymised by Google immediately upon receipt. On our behalf, Google will use this information for the purpose of evaluating your use of our websites, compiling summary reports on website activity for website operators and providing services related to website activity and internet use. Google will not associate your IP address, transmitted by your browser, with any other data held by Google.
A natural person (a user of the Website) can prevent cookies from being downloaded to their computer or other technical device by adjusting the settings of their internet browser.
The information stated in this section of the Policy corresponds to the framework in Section 55(5) of Act No. 351/2011 Coll. on Electronic Communications, as amended, which stipulates that anyone who stores or gains access to information stored in a user’s terminal equipment is entitled to do so only if the user concerned has given consent on the basis of clear and complete information about the purpose of its processing; the use of the relevant setting of a web browser or another computer program is also considered consent for this purpose.
More detailed information on how to secure and protect your personal data can be found here.
You can refuse these cookies using the Google Analytics opt-out tool.
Hotjar
Our Website uses a web analytics service, the Hotjar tool, from Hotjar Ltd., Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Malta, Tel.: +1 (855) 464-6788 (hereinafter “Hotjar”). This tool makes it possible to collect the opinions or feedback of website visitors and to track movements on all pages where Hotjar is integrated. Hotjar helps us find out how users scroll or which links or buttons users click. In this way we learn valuable information so that we can create even faster and more convenient pages for users. The above analysis takes place on the basis of our legitimate interest for the purposes of optimisation and marketing, as well as for the purpose of creating a site that corresponds to users’ interests in accordance with Article 6(1)(f) of the GDPR. When using this tool, we pay particular attention to protecting your personal data. In this way we can only find out which buttons you click and how you scroll. Areas of the website where your personal data or the personal data of third parties is displayed are automatically hidden by Hotjar, so that it can never be identified. Hotjar offers every user the option to deactivate tracking through this tool, thanks to which no data about the visit to a particular website is recorded. This is a setting supported by all current versions of common browsers. For this purpose, your browser sends information to the Hotjar tool with a request to disable the tracking of that user. If you use our Website in different browsers/computers, you must activate the “Do Not Track” header for each of these browsers/computers.
Facebook Pixel
Our Website uses Facebook Pixel to measure the number of conversions using visitor action pixels from Facebook. The Facebook Pixel service is provided by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (hereinafter “Facebook”).
Facebook Pixel allows us to identify Website users as a target group for displaying advertising and to track the behaviour of web visitors after they click on an advertisement on Facebook to get to the Website. This makes it possible to analyse the effectiveness of Facebook advertisements for the purposes of statistical surveys and market research, and their future optimisation.
When the Website is visited, the Facebook Pixel tool creates a direct connection with Facebook’s servers, which notifies the server that the Website has been visited. Facebook then assigns this information to the personal user account on the Facebook platform. Facebook Inc. is certified under the Privacy Shield Framework and therefore guarantees compliance with European personal data protection regulations.
The information stated in this section of the Policy corresponds to the framework in Section 55(5) of Act No. 351/2011 Coll. on Electronic Communications, as amended, which stipulates that anyone who stores or gains access to information stored in a user’s terminal equipment is entitled to do so only if the user concerned has given consent on the basis of clear and complete information about the purpose of its processing; the use of the relevant setting of a web browser or another computer program is also considered consent for this purpose.
More detailed information on how to secure and protect your personal data can be found here.
You can refuse these cookies in your Facebook ad preferences.
Google Tag Manager
On the Website we use Google Tag Manager from Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). Google Tag Manager is used to manage website tags (parts of code). Using the Google Tag Manager system does not create cookies and does not collect any personal data. The tool ensures the activation of other tags, which under certain circumstances collect data. Google Tag Manager does not access this data. When deactivation has been carried out at the domain or cookie level, it remains in place for all tracking tags that will be implemented through Google Tag Manager.
For which purposes and on which legal bases do we process personal data?
| Data subject | Purpose | Legal basis |
|---|---|---|
| If you used the “Adequate salary” service and did not tick the newsletter subscription box | Evaluation of the adequate salary level on the labour market. | Consent to the processing of personal data under Article 6(1)(a) of the GDPR |
| If you used the “Are you earning adequately” service and ticked the newsletter subscription box | Evaluation of the adequate salary level on the labour market and sending the newsletter. | Consent to the processing of personal data under Article 6(1)(a) of the GDPR |
| If you created a customer account | Creation and existence of a personal account for greater convenience when browsing the website and sending the newsletter | Consent to the processing of personal data under Article 6(1)(a) of the GDPR for the creation of the account and legitimate interest under Article 6(1)(f) of the GDPR for sending the newsletter |
| If you requested the newsletter through a form on our Website | Sending the newsletter. | Consent to the processing of personal data under Article 6(1)(a) of the GDPR |
| If you used the “Refer a friend (Koderia Referral)” service and are the person referring another | Referring a position to an acquaintance | Consent to the processing of personal data under Article 6(1)(a) of the GDPR |
| If you used the “Refer a friend (Koderia Referral)” service and are the person who was referred by another person | Being referred for a position by another person | From the time the personal data is provided by a third party until consent is given by the data subject or until 30 days from obtaining the personal data without consent being given, legitimate interest under Article 6(1)(f) of the GDPR |
| If you used the “Refer a friend (Koderia Referral)” service and are the person who was referred by another person | Being referred for a position, confirming interest in the position by e-mail | After consent is given by the data subject, consent to the processing of personal data under Article 6(1)(a) of the GDPR |
| If you used the “None of the positions caught your eye?” service | Finding a suitable open job position for you | Consent to the processing of personal data under Article 6(1)(a) of the GDPR |
| If you used the “Jobs” service | Assignment to a specific project or to another project in the future | Consent to the processing of personal data under Article 6(1)(a) of the GDPR |
| If you used the “CV” service | Creating a CV for your own needs with the option of generating it in pdf format and storing the data in our internal database for the purpose of contacting you in the event of a suitable job position | Consent to the processing of personal data under Article 6(1)(a) of the GDPR |
| Cookies | Improving the use of the website, e.g. by allowing cookies to recognise previous visitors by remembering the visitor’s choice when opening a new window, by measuring website traffic or the way it is used for user improvements | Legitimate interest under Article 6(1)(f) of the GDPR for essential cookies and consent to the processing of personal data under Article 6(1)(a) of the GDPR in conjunction with Section 55(5) of Act No. 351/2011 Coll. on Electronic Communications for analytical and marketing cookies |
| Google Analytics | Analysis of Website traffic and visitors | Consent to the processing of personal data under Article 6(1)(a) of the GDPR in conjunction with Section 55(5) of Act No. 351/2011 Coll. on Electronic Communications |
| Facebook Pixel | Identification of Website users as a target group for displaying advertising and tracking the behaviour of web visitors after clicking on an advertisement on Facebook | Consent to the processing of personal data under Article 6(1)(a) of the GDPR in conjunction with Section 55(5) of Act No. 351/2011 Coll. on Electronic Communications |
| Hotjar | Optimisation, marketing and the purpose of creating a site that corresponds to users’ interests | Legitimate interest under Article 6(1)(f) of the GDPR |
| If you are a visitor to our pages on Facebook or LinkedIn | Creating traffic statistics for our fan pages for the purposes of pursuing our legitimate interest. Our legitimate interest is monitoring the traffic of our fan page and adapting its content based on viewership and interaction statistics | Legitimate interest under Article 6(1)(f) of the GDPR |
To whom do we disclose your personal data?
We disclose your personal data only to the extent necessary and always while maintaining the confidentiality of the data recipient to the following categories of recipients:
- our contractual partners with whom we cooperate in performing the contractual relationship with you,
- our information technology suppliers, providers of outsourcing services, providers of webhosting services (e.g. in operating the Newsletter, the recipient is the operator of the MailChimp application, The Rocket Science Group, LLC, with its registered office at 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA),
- the companies of the ZOHO group (detailed list here: https://www.zoho.com/privacy/zoho-group.html), which provides us with e-mail hosting,
- Google Ireland Limited and its affiliates (a person belonging to the group of Google companies (consisting of Google LLC and its subsidiaries) including the following companies that provide consumer services in the EU: Google Ireland Limited, Google Commerce Ltd and Google Dialer Inc.).
To which countries do we transfer your personal data?
By using the MailChimp service, we also transfer your personal data to third countries, namely to the United States of America. In order to maintain security rules relating to personal data protection, MailChimp has its own certification for the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield regimes and lawfully transfers EU/EEA personal data to the United States of America in accordance with its Privacy Shield certification. MailChimp also undergoes an annual SOC II Type 2 examination in the areas of the Trust Services Criteria, Processing Integrity, Confidentiality and Availability. A transfer of personal data to a third country or an international organisation may take place if the European Commission has decided that the third country, a territory or one or more specified sectors within that third country, or the international organisation in question ensures an adequate level of protection. No specific authorisation is required for such a transfer (Article 45(1) of the GDPR). According to the information available on the website of the Office for Personal Data Protection of the Slovak Republic (dataprotection.gov.sk), companies certified under the Privacy Shield regime with their registered office in the United States of America are among the entities that the European Commission has, in the relevant decision, included in the list of entities established in third countries that ensure an adequate level of personal data protection under the GDPR. The decisions of the European Commission on the adequate protection of personal data, including the list of countries, can be found at the following internet link: ec.europa.eu.
How long do we keep your personal data?
We keep your personal data only for as long as is necessary to fulfil the stated purposes.
If you used the “Adequate salary” service, your personal data is deleted after the service has been provided, at the latest after 3 years from granting consent, unless it can be processed on another legal basis.
If consent to inclusion in the database is granted after using the “Jobs” service, for a period of 5 years from granting consent, or until your consent is withdrawn.
If consent is granted after using the “Refer a friend” service, the referrer’s personal data is processed for a period of 3 years from granting consent, or until your consent is withdrawn. The referred person’s data is processed on the basis of consent for a period of 3 years. If the referred person does not give consent to the processing of personal data within 30 days of the day the personal data was obtained, the data is automatically deleted upon the expiry of 30 days from the day it was obtained.
If consent is granted after using the “None of the positions caught your eye?” service, for a period of 5 years from granting consent, or until your consent is withdrawn.
In the case of “Registration and creation of an account”, personal data is kept for the duration of the account.
If consent is granted after using the “CV” service, for a period of 5 years from granting consent, or until your consent is withdrawn.
If consent to receiving “Newsletters” is granted, for a period of 5 years from granting consent, or until your consent is withdrawn.
Google Analytics cookies are kept for a maximum of 2 years.
Facebook Pixel cookies are kept for a maximum of 28 days.
When storing personal data, we follow the specific regulations that set out storage periods for us and/or the basic principles of the GDPR regarding the retention and disposal of personal data.
How do we obtain personal data about you?
We obtain your personal data from you, namely by you providing it to us through one of the forms on our Website.
In the case of the “Refer a friend” service, we obtain the personal data of potential candidates from the referrer. We only process this personal data further on the basis of requesting consent from the referred person. If consent is not given to us within 30 days of obtaining the personal data, it will be automatically deleted upon the expiry of 30 days from the day it was obtained.
What rights do you have as a data subject?
As a data subject you have the following rights:
The right to withdraw consent to the processing of personal data
If we process personal data about you solely on the basis of your consent to the processing of personal data (Article 6(1)(a) of the GDPR), you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. If you withdraw this Consent, the Controller must stop processing the personal data provided in this way without undue delay, unless it has another legal basis for its subsequent processing.
The right to object to the processing of personal data for direct marketing purposes
You have the right to object at any time to the processing of personal data for direct marketing purposes, including profiling, or where we would process personal data on the basis of legitimate interest under Article 6(1)(f) of the GDPR.
The right to rectification
As a data subject you can ask us to rectify inaccurate or incomplete personal data that we process about you.
The right of access
As a data subject you have the right to request access to the personal data that we process about you.
The right to erasure
As a data subject you can ask us to erase your personal data if:
(i) the personal data is no longer necessary for the purposes for which it was obtained,
(ii) we process the personal data solely on the basis of your consent, which you withdraw,
(iii) you object to processing carried out in the specific situations under the GDPR (a task carried out in the public interest, the legitimate interest of the Controller or profiling) and there are no overriding legitimate grounds for the processing over your interests, rights and freedoms, or
(iv) you object to processing for direct marketing purposes;
(v) the personal data was processed unlawfully;
(vi) the personal data must be erased in order to comply with a legal obligation under EU law or the law of a Member State to which the Controller is subject;
(vii) the personal data was obtained in connection with the offer of information society services under the GDPR.
The right to data portability
You have the right to the portability of your personal data if we process your personal data on the basis of:
(i) your consent, or
(ii) it is necessary for the performance of a contract to which you are a party,
and at the same time the processing is carried out by automated means, you have the right to request the transfer of the personal data to another controller. This applies where you have provided the personal data to the Controller in a structured, commonly used and machine-readable format, and this right does not adversely affect the rights and freedoms of others.
The right to lodge a complaint
You have the right to lodge a complaint with the supervisory authority, which is the Office for Personal Data Protection of the Slovak Republic, Hraničná 12, 820 07 Bratislava 27, www.uoou.sk.
Changes to the personal data protection terms
The information that we are obliged to provide to you in view of our processing of personal data may change or cease to be up to date. For this reason, we reserve the option to amend and change this Policy at any time and to any extent. In the event that this Policy changes substantially, we will bring this change to your attention, e.g. by a general notice on our Website or by a separate notice by e-mail.