Privacy Policy
Who we are and how we process your personal data
If you data is processed in connection with your use of Brightman recruitment services, the Data Controller is: Bright Agency sp. z o.o. with its registered office in Minsk, Belarus, address: avenue POBEDITELEY 7A, 14 (hereinafter referred to as: "Brightman", "we" or "us").
The protection of personal data relating to you is important to us. This Privacy Policy informs you about what categories of personal data we collect, the purposes for which we use it and how we process your data when you visit our website, when you apply for a job, when we introduce ourselves to you, when we provide recruitment and employment services to you, when we maintain a relationship with you after providing services to you, or when you provide services to us.
The following information is addressed to you if you fall into any of the following categories of individuals:
- candidates to whom we provide employment services or who apply to us for a vacancy and contact us through our website, notice boards, social media pages or other sources;
- clients and their contacts with whom we have a business relationship and whom we assist in filling vacancies;
- prospective candidates and potential clients and their contacts with whom we come into contact to present our products and services;
- users of our website https://brightmanclub.com (hereinafter: "you" or "your").
Details of data processing
Below you will find an overview of what kind of personal data we process about you, for which purposes, on which legal basis and where we collect this data.
If you do not provide us with your personal data, even though we need to collect it in order to process an order from you or fulfil a contract with you, or because we are required to do so by law, we may have to refuse your order or be unable to fulfil our contractual obligations to you.
Purpose
When you visit our website, we process your data for the following purposes:
- Calling up the website/app;
- Ensuring smooth connection establishment;
- Ensuring and optimising the performance of our website and the user-friendliness of our website;
In this context, we also use various cookies and other technologies.
For further information, see our Cookie Policy
Data categories
In this context, we process the following data:
- IP address of the requesting Internet-enabled device;
- Date and time of access;
- Name and URL of the retrieved file;
- Website/application from which the access was made (referrer URL), the browser you use and, if applicable, the operating system of your Internet-enabled computer;
- Name of your access provider.
Legal basis
The data processing is based on the following legal basis:
Art. 6 (1) (f) of the GDPR, stating that processing personal data is allowed when it is necessary for the purposes of the legitimate interests pursued by the controller. Our legitimate interest is connected with the need to control the traffic on our website, prevent technical errors and bugs, ensure site security, collect statistical data or prevent abuse and violations of law within the application.
When you will enter our website for the first time, we will inform you about our usage of cookie files and ask you for your explicit consent concerning storing these files.
Collection of your Data
We collect the data directly from you.
Purpose
We process your data to provide you with personalised advertising on the website based on your browsing behaviour. To do this, we use various cookies and other technologies.
For further information, see our Cookie Policy
Data categories
In this context, we process the following data:
- IP address of the requesting Internet-enabled device;
- Date and time of access;
- Name and URL of the retrieved file;
- Website/application from which the access was made (referrer URL), the browser you use and, if applicable, the operating system of your Internet-enabled computer;
- Name of your access provider.
Legal basis
The data processing is based on the following legal basis:
Art. 6 (1) (a) GDPR - your consent.
Collection of your Data
We collect the data directly from you.
Purpose
We process your data in order to provide you to potential employers as a candidate for a vacancy.
Data categories
In this context, we may process the following data:
- Name and address;
- Telephone number;
- Email address;
- Information in your CV
- Information about your educational path;
- References
- Professional experience;
- Job references;
- Salary expectation;
- Career aspirations;
In scenarios where potential employers would require such data to move forward with the recruitment proceedings, they might ask us about information on your previous professional relationships and possible conflicts of interests, if you were to carry out work on behalf of such potential employer.
In certain cases, special categories of data on such as:
- Disability;
- Health information.
Legal basis
The data processing is based on the following legal bases:
Art. 6 (1) (b) GDPR - establishment, performance, or termination of the user contract with you for the provision of our candidate registration service and provision of further recruitment services for you.
In case of special categories of data, we only process such data on the basis of your explicit consent pursuant to Art. 6 (1) (a), Art. 9 (2) (a) GDPR.
Collection of your Data
We collect the data directly from you.
Purpose
We process your data to send you promotional information, newsletters, and other electronic promotional information, to keep you informed about job opportunities, industry reports and insights, events, happenings and other content.
Data categories
In this context, we may process the following data:
- Name;
- Email address;
- Telephone number;
- Your marketing information and job preferences.
Legal basis
The data processing is based on the following legal bases:
Art. 6 (1) (f) GDPR of the GDPR, stating that processing personal data is allowed when it is necessary for the purposes of the legitimate interests pursued by the controller. Our legitimate interest is connected with carrying out marketing activities.
However, if specific legal provisions require us to obtain prior consent before sending marketing messages, we do not send any, if such a consent has not been given by you.
Collection of your Data
We collect the data directly from you.
Purpose
We process your data to send you satisfaction surveys to find out whether you are satisfied with our services, to improve our existing services and to develop new services.
Data categories
In this context, we may process the following data:
- Name;
- Email address;
- Previous placements and services provided;
- Your information in the satisfaction questionnaire.
Legal basis
The data processing is based on the following legal bases:
Art. 6 (1) (f) GDPR of the GDPR, stating that processing personal data is allowed when it is necessary for the purposes of the legitimate interests pursued by the controller. Our legitimate interest is connected with carrying out marketing activities.
However, if specific legal provisions require us to obtain prior consent before sending marketing messages, we do not send any, if such a consent has not been given by you.
Collection of your Data
We collect the data directly from you.
Purpose
When we are obliged to do so by our partners (that is, entities on behalf of which we provide recruitment services and which might be interested in recruiting you), and there are sufficient legal bases to do so, we might process personal data relating to your criminal convictions, offences, and related security measures.
We can also process personal data relating to Money-Laundering (AML) procedures, in accordance with appropriate regulations , and in scope envisioned by them, if it is necessary and is carried out on behalf of covered entities under AML regulations – these activities are mainly connected with establishing your identity, as per provisions of AML regulations.
In some cases we also may process personal data related to job references and work assessments made by your previous employer.
Data categories
In this context, we may process the following data:
- Information on criminal convictions, offences, and related security measures - including general information on being convicted or not, as well as information indicated within specific proceedings;
- Information stored within identification documents - name, surname;
- Email address;
- Information in your CV;
- Information about your educational path, professional experience, job references, if provided by you;
- Nationality;
- Date and place of birth;
- Address, identification numbers (such as PESEL);
- Date of issuing and validity of the documents;
- Residence and work permit;
- Photos.
Legal basis
The data processing is based on the following legal bases:
Art. 6 (1) (a) GDPR - your consent – in case of job references or general background checks.
Art. 6 (1) (c) GDPR – if there is a legal obligation of entities on behalf of which we provide services, which are interested in recruiting you, where legal obligations demand that such entity verifies criminal convictions, permission to work in a given country, sanction lists or AML compliance.
Collection of your Data
We collect the data directly from you.
In addition, we may also collect your data from other sources, incluuding third parties, namely:
- Reference providers, such as previous employers or former customers of you to check your details – after obtaining your consent;
- Sanction lists and other public lists and registers, including terror and embargo lists as well as PEP lists, beneficiary registries;
- Public sources: newspapers, websites, social media, online articles.
Purpose
Conducting surveys on talent trends.
In order to continuously improve our services and keep them up to date, we will selectively invite you to participate in surveys on talent trends.
Data categories
In this context, we may process the following data:
- Name;
- Previous placements and services provided;
- Email address
- Information in the survey questionnaire.
Legal basis
The data processing is based on the following legal bases:
Art. 6 (1) (f) GDPR of the GDPR, stating that processing personal data is allowed when it is necessary for the purposes of the legitimate interests pursued by the controller. Our legitimate interest is connected with carrying out marketing activities.
However, if specific legal provisions require us to obtain prior consent before sending marketing messages, we do not send any, if such a consent has not been given by you.
Collection of your Data
We collect the data directly from you.
Purpose
In order to present our services and to be able to contact you and answer your enquiries, we process your personal data. We process the personal data about you that you provide to us when you contact us and make an enquiry.
In addition, we may have been made aware of you through recommendation from another candidate or client and contact you.
If you are acting as a business contact on behalf of a company, we will process your professional contact details.
Data categories
In this context, we may process the following data:
- Name and address;
- Position in the company;
- Telephone number;
- Email address;
- Professional contact details;
- Name of the company you work for;
- Information in your CV, job profile, company profile;
- Information about your educational path;
- Professional experience;
- Salary expectations;
- Career aspirations;
- Open job advertisements;
- Nationality;
- Photos;
- Language skills;
- Status in professional networks, e.g., open for job.
Legal basis
The data processing is based on the following legal bases:
Art. 6 (1) (f) of the GDPR, stating that processing personal data is allowed when it is necessary for the purposes of the legitimate interests pursued by the controller. Our legitimate interest is connected with contacting you, providing you with an offer or proposition of work or answering your enquiries.
Art. 6 (1) (b) GDPR - establishment, performance, or termination of the contract with you – if you contact us in order to start a business cooperation with you.
Collection of your Data
We collect the data directly from you.
In addition, we may also collect your data from third parties, namely:
- Publicly accessible professional sources, homepages;
- Professional networks, such as LinkedIn, StepStone, Freeslance.de, Xing, etc.;
- Your job or company profiles published in public databases.
Purpose
We process your data in order to provide our recruiting services to you. In this context, we process your data and those of your business contacts in order to communicate with you and find suitable candidates for your vacancies.
Data categories
In this context, we may process the following data:
- Company name;
- Name and address;
- Contact details of the business contacts;
- Telephone number;
- Your feedback on candidates;
- Contract data and accounting data;
- Information on vacancies and requirement profiles;
- Registry data;
- Tax numbers;
- Financial data.
Legal basis
Art. 6 (1) (b) GDPR - Establishment, performance, or termination of the contract with you.
Art. 6 (1) (f) GDPR - our legitimate interest in connection with performance of contracts between our clients and us – if you are a client’s representative or a contact person.
Art. 6 (1) (c) GDPR - additionally, we may process your personal data basing on the necessity to perform legal obligations imposed on us, especially connected with tax obligations.
Collection of your Data
We collect the data directly from you or from your employer.
Purpose
We process your data to send you satisfaction surveys to find out whether you are satisfied with our services, to improve our existing services and to develop new services.
Data categories
In this context, we may process the following data:
- Company name;
- Name and address;
- Contact details of the business contacts;
- Telephone number;
- Previous placements and services provided.
Legal basis
The data processing is based on the following legal bases:
Art. 6 (1) (f) GDPR of the GDPR, stating that processing personal data is allowed when it is necessary for the purposes of the legitimate interests pursued by the controller. Our legitimate interest relates to carrying out marketing activities.
However, if specific legal provisions require us to obtain prior consent before sending marketing messages, we do not send any, if such a consent has not been given by you.
Collection of your Data
We collect the data directly from you or from your employer.
Purpose
We process your data to send you promotional information, newsletters, and other electronic promotional information, to keep you informed about job opportunities, industry reports and insights, events, happenings and other content.
Data categories
In this context, we may process the following data:
- Name
- Email address;
- Telephone number;
- Your marketing information and job preferences.
Legal basis
The data processing is based on the following legal bases:
Art. 6 (1) (f) GDPR of the GDPR, stating that processing personal data is allowed when it is necessary for the purposes of the legitimate interests pursued by the controller. Our legitimate interest relates to carrying out marketing activities.
However, if specific legal provisions require us to obtain prior consent before sending marketing messages, we do not send any, if such a consent has not been given by you.
Collection of your Data
We collect the data directly from you or from your employer.
We use social media and employ various cookies and other analysis technologies on our website.
For further information, see our Cookie Policy.
We do not make decisions based solely on automated data processing; there is always human intervention before a decision is made.
We may provide your personal data to some third-party IT service providers, such as:
- A provider of hosting and cloud services: Amazon Web Services EMEA SARL with its registered office in Luxembourg.
- Within our website we also use Google Analytics to monitor and analyse traffic. This means that we transfer some of users’ personal data to Google Ireland Ltd. and Google LLC – a company based in Mountain View, California. Therefore, we may save Google Analytics’ cookies on your device in accordance with the rules on cookie files set out in our documents.
- In some cases, if this is necessary for the provisions of services by us, we may use services of other cloud providers, such as Microsoft Ireland Operation Limited with its registered office in Dublin or Google Ireland Limited with its registered office in Dublin. In each of these cases, the data may also be transferred outside of the European Economic Area, to other companies from the Microsoft or Google groups.
- Additionally, in connection with visiting our fanpages on social media platforms, we may provide your personal information to:
— Meta Platforms Ireland Limited — this entity processes personal data in connection with visiting our fanpage on Facebook, Instagram or contacting us via Messenger. This entity is a subsidiary of Meta Platforms Inc with headquarters in California, USA.
— Google Ireland Limited - this entity processes personal data in connection with visiting our fanpage on Youtube. This entity is a subsidiary of Google LLC with headquarters in California, USA.
— LinkedIn Corp. based in San Francisco, California, USA - this entity processes personal data in connection with visiting our fanpage on LinkedIn.
— New Work SE based in Hamburg, Germany - this entity processes personal data in connection with visiting our fanpage on Xing.
- Due to the fact that your personal data can be processed by entities such as Google, Amazon, Microsoft or Meta Platforms, your personal data can be subject to transfer outside of European Economic Area. The legal basis of transferring your personal data to USA is EU-U.S. Data Privacy Framework, accepted by the European Commission.
- In case of LinkedIn, your personal data can be subject to transfer outside of European Economic Area on basis of Standard Contractual Clauses, a special agreement, the model of which has been approved by the European Commission.
Intra-group data transfers outside the EEA Brightman is a service provided by Bright Agency sp. z o.o.
Bright Agency is a company. Our recruitment experts and key business people in functions such as recruiting support, payroll management and IT support are located all over the world. For the above-mentioned purposes, in the context of our cooperation in Bright Agency, we transfer your personal data in compliance with Art. 44 et seq. GDPR also to Bright Agency outside the EEA or allow employees who work in Bright Agency outside the EEA to access your personal data for the purpose of our cooperation and fulfillment of our contractual obligations with you.
We have an intra-group data transfer agreement containing Standard Contractual Clauses (SCCs) approved by the European Commission that allow for cross-border transfers of personal data from the EEA to third countries outside the EEA, (as data protection laws outside the EEA may not provide an equivalent level of protection to EEA data protection laws).
We have implemented and maintain appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss or alteration or unauthorised disclosure or access. Only authorised personnel and third-party service providers have access to personal data on a need-to-know basis, and these employees and service providers are contractually required to treat this information as confidential.
We do our best to store your personal data only for as long as it is actually necessary, and after that we delete it. The time for which we store your personal data depends on what is the type of our interaction:
- If you are a visitor to our website, we process your personal data for as long as you use the website and for up to fourteen months after your last visit;
- If you are our client (entity which concluded an agreement with us) or its representative – we process your personal data for as long as the agreement between us is binding and for the duration of limitation of claims (up to 3 years from termination or expiration of the agreement);
- If you are a person who has written to us using the contact form on our website, contacted us by telephone or by e-mail - we process your personal data for as long as the contact between you and us lasts. After it ends and 3 months have passed, we delete the personal data we have collected in this way;
- Data processed for purposes of fulfilling accountancy and tax obligations shall be processed for period of 5 years from the end of calendar year in which the deadline for payment of tax obligation has lapsed;
- If you are a person who has visited our social media profile, liked or commented on a social media post or written to us via the Messenger application, we will process your data for as long as our profile exists on such a social media site, however, no longer than for the time that you are a user of such site;
- If you are a person who subscribed to our mailing list - we process your personal data until you unsubscribe our mailing list or after termination of marketing activities, basing on a mailing list.
Request access to your personal data
You can request a confirmation from us that your personal data are processed and request appropriate information in this regard, including information on what types of personal data are processed and for which purposes.
Request rectification of your personal data
You have the right to request immediate rectification of incorrect personal data and supplement incomplete personal data.
Request erasure of your personal data
You have the right to request immediate erasure of your personal data if any of the following criteria apply:
- personal data are no longer necessary to realize purposes for which they were collected or are otherwise processed;
- you have revoked consent (assuming it is the basis of processing) and there are no other legal bases for personal data processing;
- you have filed an objection regarding processing of your personal data and there are no other legally justified legal bases for personal data processing which override the objection;
- personal data have been processed illegally;
- personal data have to be erased in order to fulfil a legal obligation;
- personal data have been collected in connection with providing information society services to a child.
This does not apply to the extent that the processing of personal data is necessary:
- to exercise the right to freedom of expression and information;
- to comply with a legal obligation imposed on the controller requiring data processing;
- to establish, assert or defend claims.
Request restriction of processing your personal data
You have the right to restrict the processing of your personal data if:
- you object the correctness of personal data;
- processing of personal data is illegal but you object erasure of your personal data, requesting a restriction of processing instead;
- we do not need your personal data for processing purposes, but you need them to establish, pursue claims or defend from claims;
- you have filed an objection regarding processing of your personal data.
- until we determine whether the legitimate grounds on our side override the grounds for your objection.
Request transferring your personal data
You have the right to receive the personal data concerning you, which you provided to a me, in a structured, commonly used, and machine-readable format and have the right to transmit those data to another controller. Such request can be fulfilled only where your personal data are processed on basis of consent or an agreement and are processed by automated means.
You also have the right to request from us sending of your personal data directly to another controller, assuming that it is technically possible.
Right to file a complaint to a competent authority
You have the right to file a complaint to an authority competent in matters related to personal data processing – in Poland it is the President of Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych – PUODO), address: Urząd Ochrony Danych Osobowych, Stawki 2, 00-193 Warsaw. where your personal data are processed on basis of consent or an agreement and are processed by automated means.
Right to withdraw your consent for processing
You have the right to withdraw consent for processing of your personal data in a scenario, where the consent is a legal basis of such an activity. You can also withdraw consent where a specific activity undertaken by us is based on consent in understanding of regulations on protection of personal data, especially when it comes to sending marketing messages.
Withdrawing consent does not affect the legality and effectiveness of personal data processing until the consent was withdrawn.
Object to the processing of your personal data
You have the right to object personal data processing in scenarios where the legal basis for processing is our legitimate interest.
If you have any questions about this Privacy Policy or the processing of your personal data, or if you would like to make a complaint, you can send an email to us or to our Data Protection Officer at info@brightmanclub.com
We may update this privacy policy at any time. Any material changes to this privacy policy shall be duly posted on this website and shall be communicated through other communication channels where appropriate.
Get in touch
Contact our recruiter
info@brightmanclub.com
Where we are
12 Dimostheni Severi Str.,
6th floor, office / flat 601,
1080 Nicosia, Cyprus
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