Privacy Policy of the Smart Jobs Portal

I. Controller of Personal Data

The controller of your personal data processed in connection with your use of the Smartjobs Portal available at thesmartjobs.com is:

II. How the Smartjobs Portal Works – Division of Roles in Data Protection

The Smartjobs Portal is a job posting service operated by TRAFFIT sp. z o.o. Postings are published by entities using the TRAFFIT recruitment system (hereinafter: Advertisers). When you browse the Portal, sign up for notifications about job offers or Smartjobs news, or receive a tracker after applying for a posting – the controller of your data is TRAFFIT sp. z o.o. In the case of application data submitted in response to a specific posting – the controller is the Advertiser.

III. What Data and for What Purposes Does TRAFFIT sp. z o.o. Process

1. Browsing the Portal – technical and analytical data

When you visit the Portal, technical data is automatically collected: IP address, browser and device type, pages visited, and visit duration. This data is collected using cookies (details in Section V).

2. Tracker – tracking recruitment progress

The Tracker is a unique link that you automatically receive after submitting an application for a posting by an Advertiser using the Smartjobs Service. The Tracker is sent to the email address you provided to the Advertiser during the application process. TRAFFIT sp. z o.o. uses this address solely for the purpose described below.

3. Tracker link reminder

If you have applied for a posting and wish to regain access to your Tracker, you may provide your email address on the Portal to receive a reminder with the link.

4. Notifications about new job offers

You may sign up for email notifications about new postings on the Smartjobs Portal tailored to categories you select (e.g. “marketing job offers”). This service is entirely independent of the application process and the Tracker.

Voluntariness: consent is entirely voluntary. You may withdraw it at any time by clicking the unsubscribe link in the email or by contacting [email protected]. Withdrawal of consent does not affect the lawfulness of processing prior to its withdrawal.

5. Notifications about Smartjobs Portal news

You may sign up for email notifications about news and new functionalities of the Smartjobs Portal. This is a separate consent from job offer notifications – you may choose one, both, or neither.

Voluntariness and withdrawal: as in point 4 above. Retention period: until consent is withdrawn, and subsequently no longer than 3 years for the purpose of documenting its granting and withdrawal.

IV. Application Data – TRAFFIT Is Not the Controller

The data you provide to the Advertiser when submitting an application (CV, cover letter, contact details other than the email address used for the Tracker, answers to recruitment questions) are processed by the Advertiser as the controller – not by TRAFFIT sp. z o.o.

For access to, rectification, or deletion of such data, or for withdrawal of consent to participate in the recruitment process, please contact the Advertiser directly. Information about the controller and the rules of data processing should be found in the content of the posting or in the information clause provided by the Advertiser.

V. Cookies and Analytical Tools

1. Cookie consent management

On your first visit to the Portal, we display a cookie banner where you can give or refuse consent to individual categories of cookies. You may change your choice at any time using the consent management panel available on the website.

2. Types of cookies used

Refusing consent to analytical and functional cookies does not affect the ability to use the basic functions of the Portal.

3. Google Analytics 4

The Portal uses the Google Analytics 4 service provided by Google LLC (USA). Data may be transferred to the USA on the basis of Standard Contractual Clauses (SCCs) approved by the European Commission. More information: policies.google.com/privacy.

You can opt out of Google Analytics tracking by installing a browser add-on: tools.google.com/dlpage/gaoptout.

4. PostHog

The Portal also uses PostHog, an open-source product analytics platform, to analyse user behaviour, track events, and improve the Portal. PostHog may process data such as page views, clicks, session recordings, and device/browser information. Data is collected in a pseudonymized manner and processed on the basis of your consent (Art. 6(1)(a) GDPR).

5. Managing cookies in the browser

Regardless of the settings on the Portal, you can manage cookies in your browser settings. Disabling necessary cookies may limit the proper functioning of the Portal.

VI. Data Recipients

Your data processed by TRAFFIT sp. z o.o. as the controller may be disclosed only to:

• hosting and IT infrastructure service providers supporting the Portal – on the basis of data processing agreements;
• Google LLC – with respect to analytical data, after you have consented to analytical cookies;
• PostHog – with respect to analytical data, after you have consented to analytical cookies;
• the email sending service provider – only to the extent necessary for sending notifications and Trackers, on the basis of a data processing agreement;
• public authorities – where disclosure is required by law.

Your data is not sold or transferred to other entities for marketing purposes without your express consent.

VII. Your Rights

In relation to data processed by TRAFFIT sp. z o.o. as the controller, you have:

• the right of access to your data and to obtain a copy;
• the right to rectification of inaccurate or incomplete data;
• the right to erasure of data where there is no legal basis for their further processing;
• the right to restriction of processing in the cases specified in the GDPR;
• the right to data portability for data processed on the basis of consent or contract;
• the right to object to processing based on a legitimate interest;
• the right to withdraw consent – at any time, without affecting the lawfulness of processing prior to its withdrawal;
• the right to lodge a complaint with the President of the Personal Data Protection Office (ul. Stawki 2, 00-193 Warsaw; uodo.gov.pl).

Please direct your requests to: [email protected]. TRAFFIT will respond without undue delay, no later than within 30 days of receiving the request.

VIII. Data Security

TRAFFIT sp. z o.o. applies appropriate technical and organizational measures to protect data against unauthorized access, loss, or destruction. Access to data is limited to authorized persons who are obliged to maintain confidentiality.

Use of the Internet involves the risk of unauthorized access to or modification of data by third parties. We recommend using up-to-date antivirus software and regularly updating your operating system and browser.

IX. Changes to the Privacy Policy

This Privacy Policy may be updated in connection with changes in the law or the way the Portal operates. The current version is always available at thesmartjobs.com. We will notify persons whose email addresses we hold in connection with the services provided (Trackers, notifications) of any significant changes by email.

This Privacy Policy enters into force on the date of its publication on thesmartjobs.com.