Privacy Protection Principles of LMC

Valid from 1.1.2023

Privacy Policy of LMC s.r.o.

We keep your personal data private and secure and give you full control over it.

When you use LMC services, you provide us with a variety of information, including your personal data. This Privacy Policy will primarily introduce you to the services we provide, which personal data we process, and how we use and protect such data.

We take the protection of your privacy seriously and would like to ask you to take the time to learn about our processes. If you have any questions, please feel free to contact us.

PROVIDED SERVICES

All LMC services are in some way related to job-searching, recruitment, and personal development:

a) in the Czech Republic we currently provide the following services: Jobs.cz, Prace.cz, Práce za rohem, Atmoskop.cz, Jobote, Seduo.cz, Teamio, Techloop and Robot Arnold.

b) In the Republic of Poland we currently only provide the Praca za rogiem service, which is the Polish version of the Práce za rohem service, Teamio and Seduo.pl.

c) In the Slovak Republic, we only provide Seduo.sk, which is the Slovak version of Seduo.cz, Teamio and Robot Arnold.

These services are provided by the following LMC group companies operating in the countries listed below:

a) in the case of the provision of LMC services in the form designated by LMC for the Czech Republic, as well as in the case where it is designated as a provider in the contract:

LMC s.r.o., registered office: Menclova 2538/2, Libeň, 180 00 Prague 8, ID No.: 264 41 381, registered in the Commercial Register kept by the Municipal Court in Prague, Section C, Insert 82484

b) in the case of the provision of LMC services in the form specified by LMC for the Republic of Poland, as well as in the case where it is named as a provider in the contract:

LMC POLAND SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, with its registered office at BL Astoria, Przeskok 2, 00-032 Warszawa, Republic of Poland, entered in the Commercial Register kept by the District Court for the Capital City of Warsaw in Warsaw, XII Commercial Department of the National Registry Court, under entry number KRS 0000988078, NIP 5252920122, REGON: 522873400, with a share capital of PLN 300,000. (Please note that all rights and obligations are being transferred to this company as of 1.1.2023) by transferring the business plant from the organizational unit LMC S.R.O. (SPÓŁKA Z OGRANICZONA ODPOWIEDZIALNOSCIA) ODDZIAŁ W POLSCE), address: BL Astoria, Przeskok 2, 00-032 Warszawa, Republic of Poland, KRS number 0000714295, REGON: 369317811.

c) in the case of the provision of LMC services in the form designated by LMC for the Slovak Republic, as well as in the case where it is designated as a provider in the contract:

Profesia spol. s r.o., with its registered office at Bratislava - Staré Město, Pribinova 19, Postal Code 811 09, Slovak Republic, ID No.: 35 800 861, registered in the Commercial Register kept by the District Court in Bratislava, Section Sro, Insert 22949/B

We take the protection of your privacy seriously, so please take the time to familiarize yourself with our practices. If you have any questions, you can contact us at:

a) https://www.lmc.eu/cs/kontakty if your personal data are processed in connection with LMC services provided by LMC, a company based in the Czech Republic.

b) https://www.lmc.eu/pl/kontakt, if the processing of personal data is in connection with LMC services provided by an organizational unit of LMC based in the Republic of Poland.

c) https://www.lmc.eu/cs/kontakty, if the processing of personal data is in connection with LMC services provided by an LMC company based in the Slovak Republic.

You may also contact our Data Protection Officer, whose contact details are set out below.

POSITION OF LMC COMPANIES

All of the above LMC companies are so-called joint controllers of personal data under Article 26 of the GDPR. In this document, when we write "we" or refer to "LMC", "LMC companies", etc., we mean all of these companies at the same time, unless explicitly stated otherwise.

However, it is always the case that the user of the services is primarily in a relationship with the company whose service he/she uses, e.g. for www.jobs.cz it is LMC based in the Czech Republic, for Praca za Rogiem or Seduo.pl it is LMC based in the Republic of Poland, for Seduo.sk it is LMC (or Profesia spol. s r.o.) based in the Slovak Republic. Technologically and in terms of personnel, however, the three companies cannot be separated.

LMC's services are primarily developed and operated in the Czech Republic and LMC, based in the Czech Republic, is the owner of these services.

Apart from the processing of personal data, users using the services of the LMC company based in the Czech Republic have no legal or factual relationship with the LMC company based in the Slovak Republic or the LMC company based in the Republic of Poland, unless he/she uses one of the LMC services provided by these entities. In other words, the processing, in particular the storage of personal data, takes place to a large extent in the Czech Republic and partly in Slovakia - of course, with certain exceptions for some types of processing, as can be seen from the list of processors. However, in the case of Polish and Slovak users, when using LMC's services, the processing of personal data will take place to the greatest extent in the Czech Republic through LMC, a company based in the Czech Republic, with similar exceptions as mentioned in this Policy. It is precisely because of the joint data control that the LMC companies have entered into an agreement that defines the respective shares of responsibility of each LMC company for compliance with the obligations as set out in Article 26(1) of the GDPR.

LMC, based in the Czech Republic, holds a valid employment agency permit issued by the General Directorate of the Labor Office of the Czech Republic under No. UPCR-2022/15058/13 pursuant to Article 60(1) and Article 14(1)(a) and (c) of Act No. 435/2004 Coll, Employment Act, as amended, and in this respect, within the Techloop platform (Techloop Sourcer service), we help companies to find and match applicants to vacancies and we help applicants to find and match applicants to job opportunities, including related consulting and information activities."

PROCESSING OF PERSONAL DATA

The vast majority of our processing of personal data occurs in the recruitment process, i.e., when you use our services such as Jobs.cz, Prace.cz, Práce za rohem, and its Polish version Praca za rogiem. Providing certain data is mandatory – specifically, data used for basic identification of a person (name, surname, e-mail, and telephone number (optional)), while other data is provided by applicants in their CVs and profiles without us explicitly requesting them. It is not possible to provide a complete list of all personal data that we process since there is no single uniform template for CVs, and hence each job applicant may provide completely different data.

As a general rule, we usually process the following data: name and surname, title, date of birth, photograph, e-mail, telephone number, area of work, experience, education, citizenship, language skills, completed courses/training seminars/certificates awarded, know-how and skills, and personal interests.

We never request personal data not necessary for the specific goal of the applicant (e.g., personal ID no., ID card no., copies of documents, etc.).

Our other services, i.e. those not directly related to the recruitment process, in particular Seduo.cz, Seduo.sk and Seduo.pl, usually only use basic identification and contact data (name, surname, e-mail, possibly telephone number). The reason for the collection of such data is to ensure that services work correctly and to provide users with a history of their actions in the given service. The specific scope of the personal data is evident from the relevant form or registration.

The personal data of applicants provided for the purpose of job placement within the Techloop platform (Techloop Sourcer service) are provided and processed in accordance with Section 17(2) or Act No. 435/2004 Coll., Employment Act, as amended, on the basis of the applicant's consent. The applicant gives his/her consent by ticking the appropriate box when registering or when completing the response to a specific job advertisement.

HOW WE USE PERSONAL DATA

Within our provided services, we only use personal data for the purpose for which they were given to us and we also transparently inform users of their purpose.

Here, it is important to emphasize that we are not always the controllers of the provided personal data. For example, if a user of LMC services responds to a job advertisement on Jobs.cz, Prace.cz, or Práce za rohem, then the administrator of the personal data is the employer who is advertising the position. In such a case, LMC is the processor of the personal data.

If an applicant does not provide the employer with consent to the processing of personal data above thebeyond the scope of the given purpose (i.e. participation in a selection procedure), then the data of the user are deleted after the end of the selection procedure (or at most after six months).

If the user of LMC services provides LMC with consent to the processing of personal data beyond the scope of the given purpose, then LMC shall be in the position of the controller of the data, or the LMC companies are in the position of joint controllers, as mentioned above, but the respective LMC company is also in the position of processor or further processor for the client. The purpose is always stated in the personal protection data notice or in the text of the processing consent.

Both the LMC service users and the clients acknowledge that the client is not authorized to transfer the personal data of the LMC service user to other employers unless the LMC service users are transparently informed of this fact. If the client is an HR agency that provides the personal data of applicants to its clients, i.e. employers, then applicants are informed of this fact in the personal protection data notice at the end of each advertisement. Similarly, if the client is a group of companies with a joint recruitment procedure (a common situation for holdings and groups of companies), users of LMC services are once again informed of this fact in the guidance.

If a user of LMC services creates a profile in the Jobs.cz or Techloop service and publishes it, his/her CV may be forwarded to some employers that are LMC clients. However, we never do this without relation to the user's own activity, i.e. he/she wants his/her profile to be published so that employers can contact him/her with a job offer. By "publish" we do not mean that the profile is publicly available to anyone, it will always be only the employers who have purchased the relevant LMC service, consisting of access to such published CVs. Therefore, it is not possible to say in advance which employers will have access to the published CV, as the list of employers with access to published CVs changes over time.

Besides recruitment services, we also operate other services that are not directly related to recruitment. These include the Atmoskop service, the educational portal Seduo and the Arnold communication robot. In all these services, we respect the general principles described in this document. We protect personal data, process it solely for the purpose of providing our services, and share it only with other processors mentioned below, who are involved in the provision of our services (and do not use our users' personal data for their own purposes).

OTHER PROCESSORS

LMC is authorized to process personal data both manually and automatically and to use designated processors of personal data for this purpose. Personal data are only accessible (or will only be made accessible) to authorized representatives of LMC or of the processor, and only to the extent necessary for processing.

Most processors only have limited access to the personal data of users of LMC services. Processors do sometimes receive personal data, but only in minimal amounts. No other processor is authorized to use the provided personal data for their own purposes ( marketing or otherwise). Our services are continuously developing, which is why we maintain up-to-date lists of other processors:

(a) https://www.lmc.eu/seznam-zpracovatelu, if the processing of personal data is related to LMC services provided by LMC, a company based in the Czech Republic,

(b) https://www.lmc.eu/pl/lista-podprocesorow, if the processing of personal data is in connection with LMC services provided by LMC based in the Republic of Poland,

(c) https://www.lmc.eu/sk/zoznam-spracovatelov, if the processing of personal data is in connection with LMC services provided by LMC based in the Slovak Republic,

(d) https://www.lmc.eu/en/processors-list, representing an informative version of the list of other processors in English (in case of conflict, the respective language version pursuant to (a) to (c) above shall prevail).

Some other processors are located outside of the EU, for instance in the United States of America. For the transfer of personal data to other countries outside of the EU, we uphold the principle that the free transfer of personal data within the EU is neither limited nor forbidden. We have concluded contracts with all suppliers, and these suppliers are obliged to regularly delete transferred personal data and to refrain from using such data for their own purposes. When transferring data to a processor, we fully respect the principles of personal data processing under the GDPR, in particular the principle of data minimization. Aside from these cases, personal data are not transferred from LMC to countries outside of the EU other than those listed in the list of other processors. Please also refer to this list for information regarding data protection safeguards for processors processing data outside the EU/EEA. Users of LMC's services can request further details of processors under Articles 46 or 49 of the GDPR by e-mailing dpo@lmc.eu.

MARKETING

We use contact data (e-mail, telephone number) of our clients and users of LMC services for marketing purposes regarding our own services only. Mostly, this concerns services and products similar to those that the LMC service users/clients have already received from us. We may only use this data to send marketing information if the recipient has not opted out of from receiving such information, unless the law in your country provides otherwise.

Everyone is authorized to unsubscribe from receiving marketing information through the links provided in the respective e-mails or by sending a message to any of the contacts specified in the footer of this Privacy Policy. The conditions for sending marketing information are governed in detail by provision § 7 of Act 480/2004, on certain Information Society Services and on Amendments to certain Acts, as amended.

We would also like to emphasize that not every message you receive from us is a marketing message. While providing a given service, sometimes it is necessary to communicate with clients and users of LMC services directly, and due to the large number of recipients, this cannot be handled by any other means than via bulk e-mail. Such messages do not provide marketing information (an example is a notification that the business terms and conditions have changed).

Based on your previous visit to our services, you may receive reminders on some sites in the form of promotional communications that we would like to welcome you back to our websites. For these reminders we use the services of Google, Facebook, LinkedIn, Seznam.cz and AdForm. They all use the Cookies stored in your browser to detect your previous visit.

To offer our services to other users similar to you, we use the creation of similar audience services offered by Google and Facebook. Both services store a person’s encrypted key (hash ID) as an identifier. In other words, they do not store your e-mail address.

In no case do we pass on your enclosed CVs, or data extracted from them, to advertising companies and social network operators.

COOKIES

We use cookies to provide our users and clients with the best services. Cookies are small files stored by websites on the hard drive of a user's device; these are not used to obtain personal data about users (obtained information could include the user’s IP address or the type of browser used) but rather to distinguish individual users connecting to LMC websites.

Our websites may also contain third party cookies. LMC uses these to obtain anonymous usage statistics of individual websites, such as the number of visitors and typical user behavior. These third parties typically do not store any personal data in relation to the use of cookies since they do not have access to the identity of the LMC service user (under the assumption that the user is not a registered user of the products by such a third party – e.g. Google).

The use of Cookies can be modified, i.e. disabled, deleted, etc. in the browser settings or via the cookie bar.

Detailed information about use of cookies in LMC products can be found at: https://www.lmc.eu/en/cookies/.

DEVELOPING AND IMPROVING THE QUALITY OF OUR SERVICES

To improve our services, we make use of the data we receive on how users use our services. The intended result is the optimisationoptimization of the quality of our services, especially in terms of providing the best recommendations of advertised positions to applicants on our portals and optimal recommendation of suitable courses for Seduo users. Data obtained for these purposes are stored at LMC in such a way that that our employees cannot identify the actual personal data of users of LMC services.

HOW WE PROTECT YOUR DATA

LMC implements all technical and organizational measures to ensure the protection of personal data in compliance with the GDPR and the relevant legislation or other binding legislation of the above-mentioned countries. These include measures to prevent unauthorized or random access to personal data, the change, destruction or loss, unauthorized transfer, other unauthorized processing, and misuse of personal data. This obligation remains in effect even after the termination of the processing of personal data.

Personal data are continuously monitored both electronically and physically. We have implemented modern security and safety mechanisms to guarantee the maximum safety of data. We use User Access Control, a system for managing the rights and roles of users, to protect data against unauthorized access. All persons who encounter the personal data of clients or LMC service users during their work or their contractually stipulated obligations are bound by legal and/or contractual non-disclosure obligations.

Upon request, LMC is also obliged to provide your personal data to certain government bodies (such as the Czech Police, public inspection bodies, etc.).

ALWAYS KEEP YOUR DATA UNDER CONTROL

Every user of our services has the following rights, which we at LMC fully respect:

Transparency

Whenever you enter personal data within LMC services, we always transparently inform you of the purpose for which the entered data may be used, who uses these data, and who the controller is. This document is part of any such guidance that refers to it.

Right to access personal data

The owner of the data is authorized to receive a confirmation of whether his/her personal data are being processed, and if so, then he/she is authorized to gain access to such personal data. This means that, upon request, we provide our users with all information about the processing of those personal data where we have the position of controller of personal data (a request can be sent via e-mail to dpo@lmc.eu). If a user of our services wishes to receive information regarding the personal data they provided to a client, in this case, they should contact the client who holds the position of administrator of personal data.

Right to rectification

If an applicant discovers that some of their personalher personal data are incorrect or not being processed correctly, he/she is authorized to have the personal data corrected as soon as possible (the request can be sent by e-mail to dpo@lmc.eu).

Right to be forgotten

If personal data are being processed for a specific purpose and at some point, no longer become necessary for that purpose, we will automatically delete them. If personal data are being processed based on consent and the owner of the data withdraws his/her consent, we also delete them. Here, however, it is necessary to note that we only delete personal data for which we hold the position of controller, including for all joint controllers.. For personal data held by our clients, it is necessary to apply to the clients who are controllers of the given personal data for the right to be forgotten. Furthermore, it is necessary to specify that the right to be forgotten is not absolute, and if we have an objective obligation to maintain the data (e.g. accounting), then we will only delete the personal data that are no longer necessary for the original purposes of processing.

Requests for erasure of personal data can be sent by e-mail to dpo@lmc.eu. You acknowledge that in case the consent to personal data processing is withdrawn, such a withdrawal shall not affect the lawfulness of processing based on consent before its withdrawal.

Right to limit processing

The owners of personal data have the right to limit the processing of his/her personal data (a request can be sent by filling in a contact form or by sending an e-mail to dpo@lmc.eu), if: i) the owner of the data disputes the accuracy of the data – for the period necessary for the controller to verify the accuracy of the personal data; or ii) the processing is illegal and the owner refuses the deletion of personal data but instead requests that their use be limited; or iii) the controller no longer needs the personal data for processing, but the owner requires them for legal reasons; or iv) the owner of the data makes an objection to their processing – until determining whether the justified interests of the controller supersede the justified interests of the owner of the data.

Right to portability

If you want LMC to transfer your personal data that it processes on the basis of consent or data that are necessary for the performance of a contract to a third party, you can exercise your right to data portability. If the exercise of this right would adversely affect the rights and freedoms of others, LMC will not be able to comply with your request.

Right to protection of privacy

If a user of LMC services discovers or believes that LMC is processing his/her personal data in a way that violates the protection of his/her personal and private life and/or illegally, especially if the personal data are inaccurate with respect to the purpose of their processing, he/she may request that LMC provide an explanation or request that LMC remedy the situation; this may especially refer to blocking, corrections, amendments, or deletion of personal data (the request may be sent by e-mail to dpo@lmc.eu).

In the event of repeated or manifestly unjustified requests to exercise the aforementioned rights, LMC is entitled to charge a reasonable fee for the exercise of the right in question or to refuse to exercise it. We would inform you in advance of such action.

LMC reserves the right to verify the identity of the applicant in a reasonable manner in accordance with Article 12(6) GDPR in relation to the rights exercised.

If LMC does not comply with the LMC service user's request as per the previous sentence, then the LMC service user is authorized to contact the Office for Personal Data Protection.

CONTACTS

The authorized person for the protection of personal data at LMC is:

Ján Jaroš, e-mail: dpo@lmc.eu.

The delivery address is the registered office address of the relevant LMC company as defined in the introduction to this Policy. Please note this does not apply to services provided under the Profesia brand name, which are not covered by this Policy.

If the client is the controller of the personal data, then the client’s contact data are either listed in the notice which is part of the advertisement or on the client’s website. If the user of the LMC service is not aware of the client’s contact information for applying his/her rights, then LMC can provide this information to the user.

CONCLUSION

This Privacy Policy enter into force on 6th April 2018 and are available online on the website of LMC. LMC is authorized to change this Privacy Policy using the procedure used to change the conditions of use of LMC services.

This Privacy Policy was updated on 15. 12. 2023.

Your personal data are kept private and safe and remain fully under your control.

Version valid until 31.12.2022:

Privacy Protection Principles of LMC s.r.o.

We keep your personal data private and secure and give you full control.

When you use LMC services, you provide us with a variety of information, including your personal data. These Personal Data Protection Principles will primarily introduce you to the services we provide, which personal data we process, and how we use and protect such data.

We take the protection of your privacy seriously and would like to ask you to take the time to learn about our processes. If you have any questions, please feel free to contact us.

PROVIDED SERVICES

All LMC services are in some way related to job-searching, recruitment, and personal development. Currently, these services are Jobs.cz, Prace.cz, Práce za rohem, Atmoskop.cz, Jobote, Seduo.cz, Teamio, Techloop and Robot Arnold.

In Poland we provide Praca za rogiem, Atmoskop.pl, Teamio and Seduo.pl services.

These services are provided by LMC s.r.o., address: Menclova 2538/2, Libeň, 180 00 Praha 8, Czech Republic, Company Reg. No.: 264 41 381, listed in the trade register at the Municipal Court in Prague, section C, file no. 82484.

PROCESSED PERSONAL DATA

The vast majority of our processing of personal data occurs in the recruitment process, i.e., when you use services such as Jobs.cz, Prace.cz, Práce za rohem, Teamio, or Jobote. Providing certain data is mandatory – specifically, data used for basic identification of a person (name, surname, email, and phone number (optional)), while other data are provided by applicants in their CVs and profiles without us requiring them. It is not possible to provide a complete list of all personal data that we process since there is no single template for CVs and hence each job applicant can provide completely different data.

On a general level, we usually process the following data: name and surname, title, date of birth, photo, email, phone number, job field, practice, education, citizenship, language skills, completed courses/training seminars/certificates awarded, know-how and skills, and personal interests.

We never request personal data which are not needed for the specific goal of the applicant (e.g., personal ID no., ID card no., copies of documents, etc.).

Our other services, i.e. those not directly related to the recruitment process, usually only use basic identification and contact data (name, surname, email, possibly phone number). The reason for the collection of such data is to ensure that services work correctly and to provide users with a history of their actions in the given service.

HOW WE USE PERSONAL DATA

Within our provided services, we only use personal data for the purpose for which they were given to us and we also transparently inform users of their purpose.

Here, it is important to emphasise that we are not always the administrators of the provided personal data. If a job applicant reacts to a job offer on Jobs.cz, Prace.cz, or Práce za rohem, then the administrator of the personal data is the employer who is advertising the position. In such a case, LMC is the processor of the personal data.

If an applicant does not provide the employer with consent to the processing of personal data above the scope of the given purpose (i.e. participation in a selection procedure), then the applicant’s data are deleted after the end of the selection procedure (or at most after six months).

If the applicant provides LMC with consent to the processing of personal data above the scope of the given purpose, then LMC shall be both the administrator of such data and the processor of data for the client. The purpose is always stated in the personal protection data notice or in the text of the processing consent.

Both the applicant and the clients consider that the client is not authorised to transfer the applicants’ personal data to other employers unless the applicants are transparently informed of this fact. If the client is an HR agency which provides the personal data of applicants to its clients, i.e. employers, then applicants are informed of this fact in the personal protection data notice at the end of each ad. Similarly, if the client is a group of companies with a joint recruitment procedure (a common situation for holdings and groups of companies), applicants are once again informed of this fact in the notice.

If a user of LMC services creates a profile in the Jobs.cz or Techloop service and publishes it, his CV can be handed over to some employers - LMC clients. However, we never do this without relation to the user's own activity, who wants his profile to be published so that employers can contact him with a job offer. By "publish" we do not mean that the profile is publicly available to anyone, it will always be only the employers who have purchased the relevant LMC service, consisting in access to such published CVs. Therefore, it is not possible to say in advance which employers will have access to the published CV, as the list of employers with access to the published CVs changes over time.

Besides the recruitment services, we also operate other services that are not directly related to recruitment. These include the service Atmoscop, the educational portal Seduoand the Arnold communication robot. In all these services, we respect the general principles described in this document. We protect personal data, process it solely for the purpose of providing our services, and share it solely with other processors mentioned below, who are involved in providing of our services (and do not use our users' personal data for their own purposes).

OTHER PROCESSORS

LMC is authorised to process personal data both manually and automatically and to use designated processors of personal data for this purpose. Personal data are only accessible (or will only be made accessible) to authorised representatives of LMC or of the processor, and only in the scope necessary for processing.

Most processors only have limited access to the personal data of applicants. Processors do sometimes receive personal data, but only in minimal amounts. No other processor is authorised to use the provided personal data for their own purposes (neither marketing or otherwise). Our services are continuously developing which is why we maintain an up-to-date list of other processors.

MARKETING

We use contact data (email, phone number) of our clients and users for marketing purposes regarding our own services only. Mostly, this concerns services and products which are like those that the applicants/clients have already received from us. We can only use this data to send marketing information if the recipient has not unsubscribed from receiving such information.

Everyone is authorised to unsubscribe from receiving marketing information through the links provided in the respective emails or by sending a message to any of the contacts specified in the footer of these Principles. The conditions for sending marketing information are governed in detail by provision § 7 of Act 480/2004, on certain Information Society Services and on Amendments to certain Acts, as amended.

We would also like to emphasise that not every message you receive from us is a marketing message. While providing a given service, sometimes it is necessary to communicate with clients and users directly, and due to many recipients, this cannot be handled by any other means than via a bulk email. Such messages do not provide marketing information (an example is a notification that the business terms and conditions have changed).

Based on your previous visit of our websites, we may remind you the ad messages that we would be happy to welcome you back to our websites. For these reminders we use the services of Google, Facebook, LinkedIn, Seznam.cz or AdForm. They all use the Cookies stored in your browser to determine your previous visit.

To offer our services to other users like you, we use the creation of similar audience services offered by Google and Facebook. Both services store a person’s encrypted key (hash ID) as the identifier. In other words, they do not store your e-mail address.

We never share your curriculum vitae or its extracts to advertising companies and social network operators.

COOKIES

We use cookies to provide our users and clients with the best services. Cookies are small files stored by websites on the user’s hard drive; these are not used to obtain personal data about users (obtained information could include the user’s IP address or the type of browser used) but rather to distinguish individual users connecting to LMC websites.

Our websites may also contain third party cookies. LMC uses these to obtain anonymous usage statistics of individual websites, such as the number of visitors and typical user behaviour. These third parties typically do not store any personal data in relation to the use of cookies since they do not have access to the user’s identity (under the assumption that the user is not a registered user of the products by such a third party – e.g. Google).

Users can forbid the use of cookies in their browser settings; this will, however, have a negative impact on how the websites are displayed.

Detailed information about use of cookies in LMC products you can find on https://www.lmc.eu/en/cookies/.

DEVELOPING AND IMPROVING THE QUALITY OF OUR SERVICES

To improve our services, we make use of the data we receive on how users use our services. The intended result is the optimisation of the quality of our services, especially in terms of providing the best recommendations of advertised positions to applicants on our portals and optimal recommendation of suitable courses for Seduo users. Data obtained for these purposes are stored at LMC so that our employees cannot identify the actual personal data of users.

HOW WE PROTECT YOUR DATA

LMC implements all technical and organisational measures to ensure the protection of personal data in compliance with the law and other binding legal regulations. These include measures to prevent unauthorised or random access to personal data, the change, destruction or loss, unauthorised transfer, other unauthorised processing, and misuse of personal data. This obligation remains in effect even after the termination of the processing of personal data.

Personal data are continuously monitored both electronically and physically. We have implemented modern security and safety mechanisms to guarantee the maximum safety of data. We use User Access Control, a system for managing the rights and roles of users, to protect data against unauthorised access. All persons who encounter the client’s personal data during their work or their contractually stipulated obligations are bound by legal and/or contractual non-disclosure obligations.

Upon request, LMC is also obliged to provide your personal data to certain government bodies (such as the Czech Police, public inspection bodies, etc.).

ALWAYS KEEP YOUR DATA UNDER CONTROL

Every user of our services has the following rights, which we at LMC fully respect:

Transparency

Whenever you enter personal data within LMC services, we always transparently inform you of the purpose for which the entered data may be used, who uses these data, and who their administrator is. This document is part of each such notice that refers to it.

Right to access personal data

The owner of the data is authorised to receive a confirmation of whether their personal data are being processed, and if so, then they are authorised to gain access to such personal data. This means that, upon request, we provide our users with all information about the processing of those personal data where we have the position of administrator of personal data (a request can be sent via email to dpo@lmc.eu). If a user of our services wishes to receive information regarding the personal data they provided to a client, in this case, they should contact the client who holds the position of administrator of personal data.

Right to correction

If an applicant discovers that some of their personal data are incorrect or not being processed correctly, they are authorised to have their personal data corrected as soon as possible.

Right to be forgotten

If personal data are being processed for a specific purpose and at some point, no longer become necessary for that purpose, we automatically delete them. If personal data are being processed based on consent and the owner of the data withdraws their consent, we also delete them. Here, however, it is necessary to note that we only delete personal data for which we hold the position of administrator. For personal data kept by our clients, it is necessary to apply to the clients who are administrators of the given personal data for the right to be forgotten. Furthermore, it is necessary to specify that the right to be forgotten is not absolute, and if we have an objective obligation to maintain the data (e.g. accounting), then we will only delete the personal data which are no longer necessary and needed.

Right to limit processing

The owners of personal data have the right to limit the processing of their personal data (a request can be sent by filling in a contact form or by sending an email to dpo@lmc.eu), if: i) the owner of the data disputes the accuracy of the data – for the period necessary for the administrator to verify the accuracy of the personal data; or ii) the processing is illegal and the owner refuses the deletion of personal data but instead requests that their use be limited; or iii) the administrator no longer needs the personal data for processing, but the owner requires them for legal reasons; or iv) the owner of the data makes an objection to their processing – until determining whether the justified interests of the administrator supersede the justified interests of the owner of the data.

Right to protection of privacy

If an applicant/customer discovers or believes that LMC is processing their personal data in a way that violates the protection of their personal and private lives and/or illegally, especially if the personal data are inaccurate with respect to the purpose of their processing, they may request that LMC provide an explanation or request that LMC remedy the situation; this may especially refer to blocking, corrections, amendments, or deletion of personal data.

If LMC does not comply with an applicant’s/customer’s request as per the previous sentence, then the applicant/customer is authorised to contact the Office for Personal Data Protection.

CONTACTS

The authorised person for the protection of personal data at LMC is:

Ján Jaroš, email: dpo@lmc.eu.

If the client is the administrator of the personal data, then the client’s contact data are either listed in the notice which is part of the ad or on the client’s website. If the user is not aware of the client’s contact information for applying their rights, then LMC can provide this information to the user.

CONCLUSION

These Principles enter into force on 6 April 2018 and are available online on the website of LMC. LMC is authorised to change these Principles using the procedure used to change the conditions of use of LMC services.

Your personal data are kept private and safe and remain fully under your control.