PRIVACY POLICY

In this document, we inform you about the legal basis for the processing of personal data, the methods of collecting and processing them, as well as the rights of persons using the services of the Heads Here Professional Resume Services Platform (hereinafter referred to: “Platform”), managed by Heads Here LLC (hereinafter: “HEADS HERE” or “Controller”).

This Privacy Policy applies in cases where HEADS HERE processes personal data as a Controller. We know that you care about the security of your data, so we will process it carefully, in accordance with the law and in the manner described in this Privacy Policy. Please read the data protection notice contained in this document.

PERSONAL DATA AND THEIR PROCESSING

Personal data is any information about an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly.

Processing of personal data means an operation or set of operations which is performed on personal data, whether or not by automated means.

In connection with your use of HEADS HERE services, we will process the following data:
– name and surname;
– email address;
– data contained in resume/CV and in cover letters;
– data contained in accounting documents;
– cookies.

HEADS HERE is based in the Europen Economic Area and is obliged to apply the provisions of Regulation (EU) 2016/679 of the European Paliament 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, and repealing Directive 95/46/EC (General Data Protection Regulation, hereinafter referred to: “GDPR” ) and national laws on the protection of personal data, in particular the Act of 10 May 2018 on the protection of personal data. The registered office of the Controller is located at Zygmunta Hubnera 1/282, 01-756 Warsaw, Poland.

CONTACT WITH THE CONTROLLER

The Controller can be contacted by sending an e-mail to the following address: office@headshere.com.

FOR WHAT PURPOSES DO WE USE YOUR PERSONAL DATA?

We use your data for the following purposes and on the indicated legal grounds:

1. To register and service an account on the Platform and to accept and provide services through the Platform – based on Article 6(1)(b) of the GDPR – in connection with the concluded agreement;
   
2. To handle inquiries directed through the contact form – based on the ligitimate interest of the Controller (Article 6(1)(f) of the GDPR); our ligitimate interest is to respond to received messages and conduct correspondence;
   
3. To manage social media profiles (Facebook, Instagram, LinkedIn, TikTok, YouTube) and enable the person whose data data is being processed to be active on these profiles – based on the legitimate interest of the Controller (Article 6(1)(f) of the GDPR); our legitimate interest is to promote the brand and pursue claims (this information pertains to data processing by HEADS HERE and not by the owners of individual social media platforms);
   
4. to handle the complaint process – on the basis of the legitimate interest of the Controller (Article 6(1)(f) of the GDPR); our legitimate interest is to consider the complaint and defend against potential claims;
   
5. to conduct marketing activities – on the basis of the consent expressed by the Website Users (Article 6(1)(a) of the GDPR);
   
6. to send the newsletter – on the basis of the consent expressed by the Website Users (Article 6(1)(a) of the GDPR);
   
7. for the purpose of keeping accounting books – pursuant to Article 6(1)(c) of the GDPR in connection with our obligation under the accounting regulations;
   
8. to pursue and defend claims – pursuant to Article 6(1)(c) of the GDPR in connection with the national regulations on the pursuit and defence of claims.

DATA RECIPIENTS

Your personal data may be disclosed to other recipients, and we do so in accordance with the law. The recipients may be entities authorized to receive data on the basis of applicable law or entities to which we entrust data processing on the basis of concluded contracts, in particular external suppliers supporting our activities, for example, in the field of IT suppliers, payment processing, providing marketing assistance, or providing services. We do not sell personal data to other entities. The data is stored within the European Economic Area. Personal data is transferred outside the European Economic Area to our subcontractors in countries from which the European Commission has found an adequate level of protection of personal data.

HOW LONG WILL WE KEEP YOUR DATA? (RETENTION)

The retention of your data depends on the purpose and legal basis of their processing. Personal data processed:

1. for the purpose of registering and servicing your account, as well as the execution of your order – we will use for the duration of the contract, and then for the period of pursuing claims;
   
2. for the purpose of handling inquiries sent via the contact form – we will use for the period necessary to handle the inquiry, and then for the period of pursuing claims;
   
3. for the purpose of maintaining social profiles (Facebook, Instagram, LinkedIn, TikTok, YouTube) and enabling you to conduct activity on these profiles – we will use for the period of our profiles on social networks, then this period may be extended until claims are pursued;
   
4. for the purpose of handling complaints – we will use them for the period necessary to handle the complaint, and then for the period of pursuing claims;
   
5. for the purpose of conducting marketing activities – we will use until the purpose for which it was collected is achieved or until you withdraw your consent (you can revoke your consent by unsubscribing or following the instructions in each email and by contacting us);
   
6. for the purpose of sending the newsletter – we will use until the purpose for which it was collected is achieved or until you withdraw your consent (you can revoke your consent by unsubscribing or following the instructions in each email and by contacting us);
   
7. for the purpose of bookkeeping – we will use it for the period required by accounting regulations;
   
8. for the purpose of pursuing and defending claims – we will use for the period of pursuing claims, resulting from national regulations.

RIGHTS OF DATA SUBJECTS

In connection with the processing of your data, you have the right to access your data, obtain a copy of your data, rectify your data, delete your data, limit the processing of your data, object to the processing of your data, withdraw your consent, as well as the right to lodge a complaint with the supervisory authority. Before responding to such requests, we may ask you for information that will enable us to identify you.

The right to access data – on this basis, the Controller provides you with information on whether it processes your data and what are the purposes of data processing, categories of processed data, data recipients, data storage period, whether the data is processed in an automated manner, about your right to lodge a complaint with the supervisory authority and – if the data was obtained from a source other than you – about the source of the data.

The right to obtain a copy of the data – on this basis, the Controller will provide you with a copy of the data processed by the Controller.

The right to rectify data – on this basis, the Controller changes/rectifies the data at your request, if you report that they are incorrect.

The right to delete data – on this basis, you can request the deletion of personal data, provided that all the purposes for which the data was collected have already been achieved.

The right to restrict processing – on this basis, you can request the Controller to cease performing operations on your data, and the Controller will then cease to process the data and store them in accordance with the adopted retention periods until the reasons for limiting the storage of data cease. This does not apply if the data subject consents to the processing of data.

The right to transfer data – on this basis, the Controller, at your request, will provide you with data in a format that can be read on a computer.

The right to object – on this basis, you have the right to object to the processing of your data by the Controller for marketing purposes or to other purposes of processing, related to your particular situation.

The right to withdraw consent – you have the right to withdraw your consent to the processing of your personal data at any time, which, however, does not affect the lawfulness of the processing before the withdrawal of this consent.

The right to lodge a complaint with the supervisory authority – if you believe that the Controller processes your data in violation of the provisions on the protection of personal data, you have the right to lodge a complaint with the supervisory office, which in Poland is the Office for Personal Data Protection.

In order to exercise your rights, please contact the Controller electronically, in accordance with the data provided in the paragraph entitled “Contact with the Controller”. Responses to the submitted requests are provided within one month from the date of their receipt by the Controller. If it is necessary to extend this period, the Controller will inform you about it.

COOKIES

The Platform uses the technology of cookies, which are used to ensure the proper use of the Platform by the user and to ensure security (session cookies). HEADS HERE may also use analytical and marketing cookies with your explicit consent. Cookies do not enable the identification of the customer visiting the Platform. You can delete or block cookies at any time by using the options available in your web browsers.

HOW WE KEEP YOUR DATA SAFE

To ensure the security of your personal data, we have taken privacy protection into account when designing the Platform. We regularly improve our security solutions. We have implemented internal procedures to ensure proper operational operation. Access to your data is granted only to persons whom we have authorized to use the Controller’s personal data. Our devices have functions that protect against unauthorized access to the personal database.

CHILDREN’S PRIVACY

Our services are not directed to people under the age of 18.

FINAL PROVISIONS

The content of Privacy Policy is subject to regular reviews and, if necessary, may be changed, in particular in the event of changes in the law, changes in the processing operation or the scope of the data processed.

The current Privacy Policy is available on the Controller’s website.

Last updated and effective May 15, 2025.