PRIVACY STATEMENT

The below Privacy Policy (also Privacy Statement) applies to Clouds On Mars sp. z o.o. as well as Clouds On Mars Services sp. z o.o, (together as “Clouds On Mars”) and constitutes principles of your personal data processing by Clouds On Mars. We are obliged to protect your privacy and will process your personal data in compliance with this Privacy Statement which is based on binding legislation regarding data processing, i.e. REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) („GDPR”), which came into force on May 25, 2018 as well as Polish legislation in this respect.

1. Information on data controllers

Clouds On Mars Sp. z o.o

Bukowińska 22/13B, 02-703 Warsaw, Poland

KRS no. 0000670382

VAT no. 5213773786

Phone no. (+48) 512 624 266 e-mail: info@CloudsOnMars.com

The Administrator has appointed a Data Protection Officer who can be contacted at the address indicated above or by email at IOD@cloudsonmars.com

2. Definition of personal data, special categories of personal data and personal data processing

Data controller means the authority, organizational unit, entity or person deciding on the purposes and means of processing personal data.

Personal data means any information relatied to an identified or identifiable natural person (“data subject”), such as first and last name, identification number, location, internet identifier, telephone number, email address. Special categories of personal data, also known as sensitive personal data, are a subset of personal data and may include information such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying an individual, health data, or data concerning an individual’s sex life or sexual orientation.

Processing of personal data means an operation or set of operations performed on personal data or sets of personal data in an automated or non-automated manner, such as collecting, recording, organizing, structuring, storing, adapting or modifying, retrieving, viewing, using, disclosing by transmission, dissemination or otherwise making available, matching or linking, limiting, erasing or destroying.

3. The purpose of personal data processing and the time frames of processing

3.1 Recruitment

We process your personal for the purpose of recruitment.

a) in order to carry out the recruitment process, based on the entitlement under Article 22¹ of the Labor Code, in terms of: name and surname, date of birth, contact details, education, professional qualifications and history of previous employment. The basis for the processing of the aforementioned personal data is a legal obligation (GDPR, Article 6(1)(c)),

b) in order to carry out the recruitment process, on the basis of your consent to process your personal data, i.e. personal data other than indicated in the paragraph above, provided in your resume, application form, cover letter and other documents. The basis for processing is the aforementioned consent (GDPR, Article 6(1)(a)),

c) in order to fulfill the legitimate interest of the administrator in the data obtained from you during the recruitment process in connection with the verification of your skills and abilities needed for the position specified in the job offer. The basis for processing this data is our legitimate interest (GDPR, Article 6(1)(f)),

d) in order to fulfill the legitimate interest of the administrator in the event of a legal need to prove facts, to demonstrate the fulfillment of obligations (GDPR, Article 6(1)(f)),

e) for future recruitment processes, based on your consent to process personal data provided in your resume, form, cover letter and other documents. The basis for processing is the aforementioned consent (GDPR, Article 6(1)(a))

Period of storage of personal data

a) to the extent indicated in paragraph 4 (a), (b), (c), your data will be stored for the time necessary to carry out the recruitment, but no longer than 12 months from the moment of hiring the selected candidate.

b) to the extent indicated in paragraph 4(d), your data will be kept for the period of the statute of limitations for claims arising from legal provisions, as well as for the period of time for which regulations require that we store the data,

c) to the extent indicated in paragraph 4(e), your personal data will be stored for a period of 12 months from the date of your consent.

3.2 Concluding and execution of the agreement

We process your personal data in order to provide services for you and to obtain goods and services from you. The data in this process is processed for the purpose of performing a contract with Clouds of Mars to which you are a party, i.e. on the basis of GDPR Article 6(1)(b).

Data collected in this process will be stored for the duration of this contract and for the period of limitation of claims arising from this contract. When collecting data belonging to a special category of personal data, we will ask for explicit consent and inform you of the purpose of processing.

3.3 Marketing
We process your personal data for the purpose of marketing activities. We process data for this purpose on the basis of your consent, i.e. under GDPR Article 6(1)(a). Data collected for the purpose of marketing activities will be stored for a period of 5 years from the date of granting such consent.

3.4 Execution of legal obligations of Clouds on Mars

We will process your personal data when such processing is necessary for the execution of Clouds on Mars’ legal obligations, i.e. on the basis of GDPR Article 6(1)(c). Such legal obligations may include obligations under accounting regulations, tax regulations, civil law (e.g. responding to a complaint), etc.

Data collected for the above purpose will be stored for the period of execution of the above duties and for the period in which the law requires their storage.

3.5 Processing necessary for the purposes deriving from legally reasoned interests of Clouds on Mars

We will process your personal data when such processing is necessary for purposes arising from the legitimate interest of Clouds on Mars, i.e. on the basis of GDPR Article 6(1)(f), such as, for example: the need to establish and defend our rights or claims asserted against the other party to the legal relationship, or to undertake ongoing business activities by Clouds on Mars, except situations where the interests or fundamental rights and freedoms of the data subject are superior.

Data collected in this process will be stored for the duration of the contract and for the period of the statute of limitations for claims under the contract.

3.6 Preparing databases, record sheets, statistics and analysis

We will process your personal data in order to prepare databases, compilations, statistics and analyses for our internal use, i.e. on the basis of GDPR Article 6(1)(f).

Data collected in this process will be stored for the duration of the contract and for the period of the statute of limitations for claims under the contract.

4. How we collect your personal data

As a rule, we collect personal information directly from you. We collect it through our website, during telephone conversations, when providing our services or obtaining goods and services from you, on forms and in other correspondence, whether written or electronic.

In the event we collect your personal data from third parties, we will inform you, providing all necessary information in accordance with GDPR Article 14, and if required, we will obtain your consent for such processing.

4.1 Cookies

Browser cookies, or tracking cookies are small, often encrypted text files found in browser directories. They are used by website developers to help users efficiently navigate their websites and perform certain functions.

Due to their primary role in enhancing / improving usability or site processes, disabling cookies may prevent users from using certain websites.

Cookies are created when a user’s browser loads a specific web page. The page sends information to the browser, which then creates a text file.

Every time a user returns to the same website, the browser downloads and sends this file to the site’s server.

You will be informed about this upon visiting our website and we will be presented with a choice to reject cookies, agree to all cookies or agree to their selection. Withdrawal of consent for the use of cookies is also possible via your browser settings. Each browser allows personalized settings. Please research this with your particular browser provider.

The Administrator uses so-called service cookies primarily to provide the User with services provided electronically and to improve the quality of such services. In this regard, the Administrator and other entities providing analytical and statistical services to the Administrator use cookies to store

information or access information already stored in the User’s telecommunications end device (computer, phone, tablet, etc.).

Necessary cookies:

These are necessary for the operation of the site and cannot be turned off. They are saved primarily in response to actions you take, such as setting privacy preferences, logging in or filling out forms. You can set your browser to block or alert you about these cookies, but some parts of the site may then not work properly. These cookies do not store any personal information.

Analytical cookies:

These help us better understand how users use our site and improve its performance. They help determine the number of visits and traffic sources, which pages are the most and least popular, and how visitors navigate the site. All information collected by these cookies is anonymous and treated collectively – they do not allow us to track the actions of an individual user. If you do not allow the use of these cookies it will be more difficult for us to adjust the website to your needs.

4.2 Links on our websites
Our website may contain links to third-party websites. We hereby inform you that the terms of this privacy statement do not apply to external websites. If you wish to learn how a third party protects your personal information, we recommend reviewing their privacy statement.

5. How we use your personal data

Your personal information is collected and used only in accordance with the law and only for the purposes described above. We will not use the personal data obtained for purposes other than those specified in this privacy statement or for purposes that have been disclosed to you and for which we have obtained your express consent.

Your personal data will not be subject to profiling.

6. What happens if you do not give us your personal data

Providing us with personal data is not a statutory obligation. You have the right not to provide us with your personal data. However, if you choose not to provide us with your personal data, we may not be able to conduct a recruitment process with you, provide you with services, obtain goods and services from you or undertake marketing activities.

7. Who do we transfer your data to

7.1 Other data controllers

We may transfer your personal data to other entities that will process it on their own behalf and for their own benefit, to the extent that they become an independent data controller, such as

– banks and financial institutions for payment processing,

– administrative and state authorities, courts and any judicial and law enforcement institutions,

– Clouds on Mars group companies.

7.2 Parties processing the personal data on behalf of Clouds on Mars

We may transfer your personal information to parties who will process it on behalf of Clouds on Mars, such as:

– vendors’ computer systems and cloud services,

– our subcontractors,

– agents and sales agencies or other parties that act as intermediaries in selling our services and organize marketing campaigns,

– entities that provide Clouds on Mars with outsourcing and consulting services (such as tax or legal consulting, – accounting and payroll services, – HR and payroll services, auditing services, etc.,)

– Clouds on Mars group companies.

8. Do we disclose your personal data to parties outside EU/EEA

As a rule, your personal data will not be transferred to countries outside the EU/EEA. However, if we decide to make such a transfer in the future, we will not do so without your written consent and only after we have complied with all the GDPR conditions, unless such transfer is otherwise permitted or legally necessary.

9. Storage and security of personal data

Your personal data is stored in a paper or electronic form. We use security measures required by law to protect the personal information we store from misuse, interference and loss, unauthorized access, modification or disclosure. Clouds on Mars uses technical security measures such as hard drive encryption or file passwords. In addition, access to personal data stored in an electronic or paper form will be limited to those properly authorized to access and only to those for whom access is necessary.

10. Your rights connected with processing of personal data

You are entitled to the following rights related to our processing of your personal data. Their scope, and whether and in which situations you can exercise them, is determined by law and depends on the legal basis on which we process your personal data:

– The right to access and receive a copy of your personal data,

– The right to rectify your personal data

– The right to erasure or restriction of processing of personal data,

– The right to transfer your data to another data controller,

– The right to object to the processing of your personal data,

– The right to withdraw your consent to data processing at any time (without affecting the legality of processing carried out on the basis of consent before its withdrawal).

If you have any questions about this Policy or to exercise your rights related to data processing, please contact us using the contact information provided in this Privacy Statement.

11. Complaint about the breach of privacy

If you believe that our processing of your personal data violates the law, you may file a complaint with the President of the Office for Personal Data Protection, Stawki 2 street, 00-193 Warsaw,

To exercise your rights, please contact the Data Protection Officer at IOD@cloudsonmars.com.

This privacy statement is effective as of 01.01.2025

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