Privacy Policy – Vanguard Group

VANGUARD GROUP SP. Z O.O. PRIVACY POLICY

1. Data controller

The controller of your personal data is Vanguard Group sp. z o.o. based in Łódź, ul. Juliana Tuwima 48/11, 90-021 Łódź, KRS 0001136947, NIP 7272883773, REGON 540113045 (hereinafter: "controller"). For matters concerning personal data, please write to: hr@vanguardgroup.pl. The controller has not appointed a Data Protection Officer.

PART I. WEBSITE

2. Email and phone contact

If you contact us by email or phone, we process the data you provide, in particular your name, email address, phone number, and the content of the message. Purpose and legal basis: response and further correspondence – legitimate interest of the controller (Article 6(1)(f) GDPR). Retention period: until the matter is handled, and then for 12 months from the last contact. If the contact relates to recruitment, we apply the rules from Part II.

3. Cookies

The site uses only cookies necessary for its proper functioning. We apply them without your consent, based on art. 399 of the Act – Electronic Communications Law; we process data from them in our legitimate interest, which is the proper functioning of the site (Article 6(1)(f) GDPR). We do not use analytical or marketing cookies. You can specify the conditions for saving cookies in your browser settings.

4. Facebook

We run a Vanguard Group page on Facebook and publish announcements there, including application forms. Data submitted via the Facebook form are processed like data in recruitment (Part II). Regarding the statistics of our Facebook page, we are joint controllers of data with Meta Platforms Ireland Limited. Data processing rules by Meta: https://www.facebook.com/privacy/policy

The essential content of the agreements between us and Meta regarding joint controllership: https://www.facebook.com/legal/terms/page_controller_addendum

PART II. RECRUITMENT

5. What data do we process

– data from CVs and forms: name and surname, contact details, education, qualifications, and work experience;

– when directing a foreigner to work: citizenship, date of birth, data from the passport, and other information needed for the referral agreement, for the employer's application for a work permit, and for maintaining records required by regulations.
Please do not provide data that we do not ask for, especially photos or information about health, religion, or beliefs.

6. Where we get your data from

Most often directly from you. We may also receive your data from our recruitment partner to whom you provided it. In such a case, we will inform you no later than one month after receiving the data.

7. Purposes and legal bases

a) providing job placement services on your behalf, including presenting your candidacy to the employer and concluding a referral agreement – Article 6(1)(b) GDPR;

b) fulfilling the legal obligations of the employment agency, including concluding and storing the referral agreement, maintaining required records, reporting, and audits – Article 6(1)(c) GDPR in connection with the Act of March 20, 2025, on the labor market and employment services;

c) participating in future recruitments – based on your consent Article 6(1)(a) GDPR;

d) establishing, pursuing, or defending claims – legitimate interest of the Controller (Article 6(1)(f) GDPR).

8. How long do we retain data

– recruitment completed without referral to work: 6 months from its completion;

– future recruitments (with your consent): 24 months from the expression of consent or until its withdrawal;

– referral agreement and records: for the period required by law, and if the law does not specify it – until the statute of limitations for claims from the agreement expires.

9. Who do we share data with

– the employer to whom we present your candidacy – only after your acceptance of that employer; when directing a foreigner, the employer also receives data needed for the work permit application;

– recruitment partner, if they participate in your process;

– IT service providers, hosting, and recruitment systems acting on our behalf;

– entities providing us with accounting and legal services;

– public authorities when required by regulations, for example, the voivode, the provincial labor office, or the National Labor Inspectorate.

10. Transfer of data outside the European Economic Area

If we transfer data outside the European Economic Area – for example, to a recruitment partner in the candidate's country or to a tool provider based in the USA – we apply the safeguards required by the GDPR, in particular the standard contractual clauses approved by the European Commission. You can obtain a copy of the safeguards by writing to hr@vanguardgroup.pl.

10a. Publication of opinions and photos

If you consent, we will publish your opinion, name, and photo on our website and on Facebook (Article 6(1)(a) of the GDPR; regarding image rights – Article 81 of the Copyright and Related Rights Act). You can withdraw your consent at any time by writing to hr@vanguardgroup.pl – we will then remove your opinion and photo.

PART III. YOUR RIGHTS

11. Your rights

Under the provisions of the GDPR, you have the right to:

– access your data and receive a copy of it,

– rectify your data,

– erase your data,

– restrict processing,

– data portability,

– object to processing based on legitimate interests,

– withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

You also have the right to lodge a complaint with the President of the Personal Data Protection Office.

12. Voluntariness of data provision

Providing data is voluntary, but necessary for us to respond to your message and conduct recruitment. Providing data required by law is a condition for being directed to work.

13. Automated decisions

We do not make decisions solely by automated means, including profiling as understood by the GDPR.

14. Policy changes

The current version of the policy is always available at www.vanguardgroup.pl.

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