Personal data protection

I. Introductory provisions

Zoznam, s.r.o., registered seat Svätoplukova II. 18892/2 A, 821 08 Bratislava - mestská časť Ružinov, CRN: 36 029 076, a company registered at Commercial register of Municipal Court Bratislava III., section Sro, insert no. 24598/B and Kariera.sk, s.r.o., registered seat Svätoplukova II. 18892/2A, 821 08 Bratislava - mestská časť Ružinov, CRN: 36 615 242, a company registered at Commercial register of Municipal Court Bratislava III., section Sro, insert no. 41278/B are based on the agreement joint operators of services at the website Kariera.sk for Jobseekers (hereinafter also referred to as "Joint Operators"). Fundamental elements of the agreement of Joint Operators form a part of these conditions in part V.

The Operator of services for Employers and other visitors of the Website is Zoznam, s.r.o., registered seat Svätoplukova II. 18892/2 A, 821 08 Bratislava - mestská časť Ružinov, CRN: 36 029 076, registered at Commercial register of Municipal Court Bratislava III, section Sro, insert no. 24598/ B.

II. Definitions

Personal Data are any information related to identified or identifiable natural person, whereas an identifiable natural person is a person that can be identified directly or indirectly, in particular, concerning identifiers as name, ID number, location data, online identifier, or concerning various elements specific for the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person; in case of using the services at the Website, personal data are considered data specified in the CV and motivation letter, contact details and registration details.

Website is a publicly available webpage Kariera.sk.

Data subject is considered a person related to personal data.

Operator s a natural or legal person, public authority, agency, or other entity that determines purposes and means of personal data processing.

Agent is a natural or legal person, public authority, agency, or other entity processing personal data on behalf of the operator.

Joint Operators are two or more operators that upon agreement determine purposes and means of processing personal data, and also determine individual responsibilities for compliance according to law. Joint Operators are, when processing personal data upon provision of the Service at the Website, Zoznam, s.r.o., registered seat Svätoplukova II. 18892/2 A, 821 08 Bratislava - mestská časť Ružinov, CRN: 36 029 076, a company registered at Commercial register of Municipal Court Bratislava III., section Sro, insert no. 24598/B and Kariera.sk, s.r.o., registered seat Svätoplukova II. 18892/2A, 821 08 Bratislava - mestská časť Ružinov, CRN: 36 615 242, registered at Commercial register of Municipal Court Bratislava III, section Sro, insert no. 41278/ B.

Jobseeker is a natural person that uses services provided at the Website, in particular, to find a suitable employment or other work.

Employer is a natural person, contractor, or legal person that uses services provided at the Website upon registration.

CV is a document that includes a summary of personal data including relevant work experience of the Jobseeker.

CV database is a database consisting of Jobseekers’ CVs.

Processing of personal data means an action or set of actions with personal data or with files containing personal data, in particular, their acquisition, recording, arrangement, rewriting, changing, gathering, collecting, disseminating, searching, browsing, reorganizing, combining, transferring, using, storing, blocking, disposal, provision, disclosure or publishing.

Provision of personal data means transferring personal data to a third party for further processing.

Disclosure of personal data means the communication of personal data or allowing the recipient access for further processing.

Consent of data subject means a freely given, specific, informed, and explicit indication of data subject's wishes, by which the data subject signifies its agreement to personal data processing relating to the data subject. The Consent is established at the Website, especially by the information system record, and the consent shall indicate clearly who granted it, who was it granted to, for what purpose, list or scope of personal data, and validity of the Consent.

Anonymisation is an activity during which are personal data modified into such a form that prevents connection of the Data subject it relates to.

Services refer to the offer of functions at the Website available to both Jobseekers and Employers. Services for Jobseekers are provided free of charge and services for Employers are provided for consideration. Characteristics of individual Services are specified in the Terms and Conditions for Jobseekers and for Employers.

III. General principles for processing personal data

Processing of personal data is lawful if carried out in compliance with at least one of the following legal basis:

the Data subject granted consent with personal data processing for at least one specific purpose,
processing of personal data is required for the performance of the agreement to which the Data subject is a contracting party, or to carry out a measure before concluding the agreement upon request of the data subject,
processing of personal data is required under a special regulation or an international agreement binding the Slovak Republic,
processing of personal data is required for the protection of safety of life, health, or property of the Data subject or other natural person,
processing of personal data is required to accomplish tasks carried out as public service or exercising official authority vested into the operator, or
processing of personal data is required to ensure legitimate interests of the operator or a third party, unless interests and rights of the Data subject or rights of the data subject requiring personal data protection prevail, especially in case the data subject is a minor; Such legal basis shall not apply to the processing of personal data by public authorities upon the discharge of their responsibilities.

Following principles shall apply when processing personal data:

principle of legality: Personal data may only be processed legally, so as not to infringe fundamental rights of the Data subject.
purpose limitation principle: Personal data may only be collected for a particularly designated, expressly stated, and eligible purposes and not further processed in a way incompatible with those purposes, whereas further processing for the purposes of archiving or statistics shall not be considered incompatible with the original purpose.
principle of data minimization: personal data processed must be adequate, relevant, and not excessive concerning the purposes for which they are processed.
principle of accuracy: Processed personal data shall be accurate and, where necessary, kept up to date; every reasonable and effective step must be taken to ensure that inaccurate personal data, having regard to the purposes for which they are processed, are erased or rectified without delay.
principle of storage limitation: Personal data shall be kept in a form which permits identification of the Data subject for no longer than is necessary for the purposes for which the personal data are processed
principle of integrity and confidentiality: Personal data shall be processed in a manner that ensures appropriate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.
principle of accountability: the operator shall be responsible for the compliance with fundamental principles of personal data processing, for the compliance of the processing of personal data with principles of personal data processing, and shall be able to demonstrate compliance with principles of personal data processing upon official request.

The Operator is obliged in particular:

to define the purpose of Personal data processing before the commencement thereof,
to determine conditions of processing
to ensure processing only Personal data that correspond with the purpose of the processing in both content and extent, and are crucial in reaching it.
to ensure processing of personal data solely in a way that corresponds to the purpose for which it was collected; It is unacceptable to combine personal data collected specifically for different purposes.
to ensure collected data are processed in a form allowing the identification of Data subjects for a period for no longer than necessary for the purposes for which the data were collected,
to erase Personal data, if the purpose of processing ended; once the purpose of processing is completed Personal data shall be further processed only anonymized, to the extent necessary, for historical research, scientific research and development or for statistics.

If the processing of Personal data is based on the data subject's consent, the Operator shall be obliged to prove anytime that the data subject granted consent with the processing of personal data. If the operator requests the Consent of the Data subject with the processing of personal data, this consent has to be distinguished from other circumstances and has to be expressed clearly and in an intelligible and easily accessible form. The Data subject has the right to withdraw the consent at any time. The Data subject may withdraw the consent in the same way it was granted. When assessing whether consent is freely given, utmost account shall be taken of whether the performance of a contract, including the provision of a service, is conditional on consent with the processing of personal data that is not necessary for the performance of that contract.

IV. Processing of personal data at the Website

Website visitors may use the following services:

sending notifications on job offers according to the criteria set by the Jobseeker (hereinafter also referred to as „Agent”)
browsing through Job offers advertised by Employers at the Website
replying to Job offers using the Website

Registered visitors of the Website may also use the following Services:

creating a template CV and its listing in the Jobseeker database
making a CV available and providing it to Employers
delivering labor market information, job offers of Employers and Services by the Website (hereinafter also referred to as „Infomail”)

Personal data in the Registration at the Website, when entered into Database, and when creating a CV. What personal data are processed:
Joint Operators process Personal data of Jobseekers to the extent of name, surname, title, date of birth, sex, address, email, phone, age, economic identity data (desired category of work, employment relationship, expected wage), expected date of start, language skills and other qualifications, courses, as well as data on previous employments. Stating additional information in the CV shall be an exclusive decision of the Jobseeker and Joint Operators shall not require stating additional information that may be considered a specific category of personal data, i.e. data revealing racial or ethnic origin, political views, religious and philosophical beliefs, trade union membership, genetic data, biometric data, or data concerning health, sex life or sexual orientation.

In the case of Registration on the Website via a Google account, data is provided from the Applicant in the scope of name, surname and email in the wording as stated by the Applicant in the Google account. In the case of a subsequent login to the Website via a Google account, only that data is verified.

Data required for the performance of the Services are mandatory and marked by an asterisk
How are Personal data processed:
Personal data specified in the registration at the Website and in the CV are stored in the system of Joint Operators, and are processed by one or combination of several following methods selected by the Jobseeker:
1. upon the listing into the Database, personal details of the Jobseeker are anonymized and used exclusively for statistics after 2 years following the last login at the Website.
2. making a CV available and providing it to Employers - the CV shall be made available and provided to Employers only upon the decision of the Jobseeker authorizing sharing the CV and providing it for a period scheduled in advance (usually from 4 months to two years). The Jobseeker may change /i.e. deactivate/ sharing and provision, or change the scheduled period, and the CV shall remain stored in the profile of the Jobseeker for later use. The Jobseeker determines, changes and sets sharing or provision of Personal data at the Website, as well as the sharing period for Employers, and determines the duration of the sharing period by using settings in the registration profile.
3. certified Employers registered at the Website are allowed to browse CVs and download or use them as a separate operator for the purposes of selecting the most suitable candidate for the position published, if during the period of sharing they had a specific offer published, as well as for the purposes of selection procedure with the particular Employer also for other job positions filled by the Employer for a year as of the CV was saved or provided. Personal data shall be provided to third parties for the purposes of administrative and technical service.
What is the legal basis and purpose of processing:
the legal basis for processing is the consent of the Jobseeker with the status of Data subject.

the purpose of Personal data processing by Joint Operators is to provide assistance to the Jobseeker with finding a suitable job position.
the Jobseeker may withdraw the consent with Personal data processing at any time according to the request in writing or by email specified in part VII. Contacts.

the purpose of Personal data processing by the Employer is a hiring process with the particular Employer of a suitable candidate for the job position published, as well as other job positions filled by the Employer, for a year following the acquisition of Jobseeker’s data.

the Employer, that acquired Personal data of the Jobseeker has the position of a separate Operator acting towards the Data subject individually and on their own account, shall be obliged to comply with reporting obligation towards the Data subject to the extent pursuant to Sec. 20 of the Data Protection Act No. 18/2018.

this shall not affect the right of the Jobseeker as Data subject to assert the rights with and against every operator.
Personal data in the Reply to a Job offer of the Employer What personal data are processed:
Joint Operators process Personal Data of Jobseekers to the extent they were disclosed by the Jobseeker in the Reply to the published job offer at the Website, in the CV, motivation letter, and other documents that the Jobseeker annexed to the Reply to a job offer.

Specified data to a similar extent are also processed by the Employer, whose job offer is being replied to by the Jobseeker.

Personal data of Jobseekers in the Reply and its annexes include mainly name, surname, title, name, surname, title, date of birth, sex, address, email, phone, age, expected wage, expected date of start, data on education, language skills, and other qualifications, courses, as well as data on previous employments. Stating additional information should remain a decision solely made by the Jobseeker. The Reply does not require stating additional information that may be considered a specific category of personal data, i.e. data revealing racial or ethnic origin, political views, religious and philosophical beliefs, trade union membership, genetic data, biometric data, or data concerning health, sex life or sexual orientation.
How are Personal data processed:
The Jobseeker that submitted a Reply to a Job offer published at the Website agrees to provide Personal data specified in the Reply to the specific Employer that published the offer, as well as with storing of the Personal data specified in the Reply by Joint Operators in the database containing the report of the selection process for the particular Employer which is stored in the Database at the Website.

Consent is granted for 1 year and personal data of the Jobseeker shall be subsequently anonymized and used exclusively for statistics.

Personal data shall be provided to third parties for the purposes of administrative and technical service
What is the legal basis and purpose of processing:
The legal basis for the processing of Personal data of the Jobseeker is the consent of the Jobseeker with the status of the Data subject. Upon submission of the Reply, the Data subject declares that all Personal data provided are accurate, and grants the consent for processing thereof by Joint Operators and the Employer that published the job offer, under the provisions of these terms and conditions.

The purpose of Personal data processing by Joint Operators is to provide assistance to the Jobseeker with finding a suitable job position. Personal data specified in the Reply at the Website and in annexes of the Reply are stored in the system of Join Operators.

The purpose of Personal data processing by the Employer, granted consent by the Data subject, is a selection process with the particular Employer for a suitable candidate for the job position published, as well as other job positions filled by the Employer for a year.

The Employer has the position of a separate Operator acting towards the Data subject individually and on their own account. This shall not affect the right of the Jobseeker as Data subject to assert the rights with and against every operator.
Personal data in „the Agent for job offers" What personal data are processed:
Joint Operators process email addresses and preferences of a person interested in receiving emails related to job offers for example job title, place of work, etc.
How are personal data processed:
At the Website the Jobseeker may create a so-called agent for sending job offers according to criteria selected such as e.g. job title, place of work, etc., and upon entering the email address the Jobseeker shall receive job offers of Employers that match criteria of the Jobseeker. The consent is granted for 2 years.

Personal data shall be provided to third parties for the purposes of administrative and technical service.
Legal basis and purpose of processing::
The legal basis for the processing of Personal data is the consent of the Jobseeker.
Personal data in the „Send offer to a friend” What personal data are processed:
Joint Operators process the email address which shall receive a one-time link to a job offer published at the Website and the email address of the person that requested submission of the link to the published job offer.
How are personal data processed:
A notification for a job offer published at the Website shall be sent to an email address entered by the visitor of the Website.

Personal data shall be provided to third parties for the purposes of administrative and technical service. Personal data shall not be transferred to third countries.

Email addresses shall be stored for a period necessary to process information, however not exceeding one month.
Legal basis and purpose of processing:
The legal basis for the processing of Personal data is the consent of the person sending the notification. The purpose of processing is to inform about a suitable job offer.
Personal data of contact persons of Employers What personal data are processed:
The Operator Zoznam, s.r.o., registered seat Svätoplukova II. 18892/2 A, 821 08 Bratislava - mestská časť Ružinov, processes personal data of contact persons that were designated by the Employer concerned and to the extent of title, name and surname, position, email, phone number, fax
How are personal data processed:
Employers using Services at the Website may publish contact details of their employees to the extent of name, surname, email address, phone number, job position and specify them also in orders of Services at the Website.

Specified personal data shall be processed for 10 years following the withdrawal from the provision of Services to the Employer at the Website, and shall be erased thereupon.
Legal basis and purpose of processing:
Employers are entitled to provide data of their employees, and to the extent stipulated hereinbefore, if it is necessary with relation to the discharge of work, service or functional duties of a particular employee - Data subject.

V. Agreement of Joint Operators

Pursuant to applicable legislation Joint Operators are obliged to provide Data subjects information on essential provisions of their Agreement of Joint Operators. In case of processing of Jobseeker's data at the Website under Art. IV letters A to D, the Joint Operators are Zoznam, s.r.o., registered seat Svätoplukova II. 18892/2 A, 821 08 Bratislava - mestská časť Ružinov, CRN: 36 029 076, a company registered at Commercial register of Municipal Court Bratislava III., section Sro, insert no. 24598/B and Kariera.sk, s.r.o., registered seat Svätoplukova II. 18892/2A, 821 08 Bratislava - mestská časť Ružinov, CRN: 36 615 242, registered at Commercial register of Municipal Court Bratislava III, section Sro, insert no. 41278/ B. The subject of their cooperation established for an indefinite period is the joint provision of the Website operation.

Zoznam, s.r.o. handles and responds to all requests of Data subjects including the provision of customer support, complies with information obligation related to Data subjects, represents Joint Operators in any proceeding before the Personal data protection supervisory authority or before any other body of public authority (related to personal data processed during the operation of the Website), adopts main documentation for the area of personal data protection and is responsible for the security of personal data outside processing which is carried out by Kariera.sk.

Kariera.sk processes personal data to the extent of storing personal data on servers of the Website including domain hosting, ensures contractual relationship with the hosting provider on its own behalf, and is responsible for the security of Personal data stored.

Notwithstanding the conditions of Joint Operators agreement, the Data subject may assert the rights with and against every operator.

VI. Information on the rights of Data subject

The Data subject entitled to:

request access to personal data that is processing i.e. mainly to get confirmation if personal data concerning the Data subject are subject to processing, the Data subject is entitled to access these personal data, information on the purpose of processing, category of personal data, as well as retention period and recipients that were or will be provided personal data, furthermore is entitled to information on the existence of automated decision making including profiling and information on a possible transfer to a third country.

The Data subject may request the provision of a copy of personal data relating to the Data subject that are being processed. Any other copies that the data subject so requests may be charged with a reasonable fee corresponding to administrative costs. Where the data subject submitted a request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
request correction of inaccurate data relating to the Data subject. 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.
request erasure of personal data relating to the Data subject and the operator shall be obliged to erase personal data without undue delay, provided any of the statutory requirements is complied with (e.g. personal data are no longer necessary for the purposes for which they were processed)

The right to erasure is not applicable, when the processing is necessary i.e. for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, provided that the erasure renders impossible or seriously impairs the achievement of the objectives of that processing for the establishment, exercise or defense of legal claims.

The request for erasure should include an email address that serves as a login to the account of the Jobseeker, and in case the request is delivered by email, it should be sent from the email address that serves as a registration login. Personal data shall be subsequently anonymized and used exclusively for statistics.
request processing restrictions provided it is one of the cases laid down by the applicable law
request obtaining personal data, concerning the Data subject, which the Data subject provided to the operator, in a structured, commonly used and machine-readable format and has the right to transfer those data to another operator, if:
1. the processing is based on consent or an agreement concluded with the operator
2. the processing is carried out by automated means
When exercising the portability right under paragraph 1, the Data subject has the right to transfer personal data directly from one operator to another to the extent technically feasible.
right to object automated decision-making, i.e. the right to object, so as not to be subject to a decision, which is based solely on automated processing of personal data and which produces legal effects concerning or significantly affecting the Data subject. Such automated decisions shall only be carried out in exceptional cases, e.g. if the registration for the Service is rejected because there is another user account with an identical name or login.

Upon the request for erasure, it is necessary to enter the name, and upon logging in the registration profile it is possible to cancel the profile and the Personal data shall be subsequently anonymized and used exclusively for statistics.

Requests of Data subjects related to Personal data processing at the Website shall be handled by Zoznam, s.r.o. This shall not affect the right of the Jobseeker to assert the rights with and against every operator. We shall undertake to respond to your requests at the earliest opportunity, but no later than in 30 days following the delivery of the request.

That period may be extended where necessary considering complexity and number of requests. In certain cases, the Operator is not obliged to approve the request in whole or in part, in particular, where the request appears to be unwarranted or unreasonable or redundant. In such cases the operator may require a reasonable payment taking into account administrative costs arising from the provision of information or performance of acts, or the operator may refuse to approve the request.

Should there be any reasonable doubt as to the identity of the Jobseeker, we may request the provision of additional information necessary to confirm the identity of the Jobseeker.

Information on the Data subject exercising their rights and on how was the request handled is stored for the purposes of proving request processing, for statistics, for the purposes of improving services and protecting rights of the operator.

If the data subject considers that the Personal data are unlawfully processed or the rights are otherwise infringed, the data subject may contact the Office for Personal Data Protection or the Court.

VII. Contacts

If you have questions related to storing and using your personal data, please contact Zoznam in this matter

in writing at Zoznam, s.r.o., Svätoplukova II. 18892/2 A, 821 08 Bratislava - mestská časť Ružinov or

by email at ochrana.udajov@firma.zoznam.sk