1. Data Controller
The controller of your personal data is:
Polaris processes personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR), the Croatian Act on the Implementation of the General Data Protection Regulation and other applicable laws and regulations of the Republic of Croatia.
2. Personal Data We Collect
Depending on how you interact with us and your relationship with Polaris, we may process the following personal data:
Job candidates
- first and last name
- e-mail address
- telephone number
- information contained in your CV
- education, qualifications and employment history
- skills and language abilities
- information about your preferred position and employment conditions
- other information voluntarily provided to us by the candidate.
Candidates identified through publicly available sources
Polaris may identify and contact potential candidates through publicly available professional or social platforms, including LinkedIn, Facebook and similar platforms.
In such cases, we may process information publicly available on a candidate’s profile, such as their name, professional experience, education, qualifications, skills and contact information that they have chosen to make publicly available.
Such information is used solely for the purpose of potential employment mediation and connecting candidates with suitable employment opportunities.
Employers and business contacts
We may process:
- first and last name of the contact person
- employer or business name
- business e-mail address
- business telephone number
- information relating to the employer’s staffing requirements
- other business communications relevant to our services.
Website visitors
Our website contact form allows you to provide:
- first and last name
- e-mail address
- telephone number
- message content.
Information submitted through the contact form is forwarded to our business e-mail address for the purpose of handling your enquiry.
3. Purposes of Processing
We process personal data primarily for:
- employment mediation
- sourcing suitable candidates for employers
- connecting candidates with potential employers
- presenting candidates to employers seeking specific personnel
- communicating with candidates and employers
- handling enquiries submitted through our website
- coordinating communication and selection processes
- administering employment mediation procedures
- complying with legal and regulatory obligations
- protecting our rights and legitimate interests.
4. How We Collect Personal Data
We may obtain personal data:
- directly from candidates, for example when a candidate sends us an e-mail, CV or contacts us through the contact form;
- from publicly available sources, such as professional and social media platforms including LinkedIn and Facebook, when searching for candidates who match the requirements of a specific position;
- from employers, when they provide us with information about their staffing requirements and the requirements of a specific position.
When using information obtained from publicly available sources, we use it only to the extent relevant to employment mediation.
5. Legal Bases for Processing
Depending on the circumstances, we process personal data on the basis of:
- taking steps at the request of the data subject prior to entering into a contract
- performance of a contract, where applicable
- compliance with legal obligations
- legitimate interests, particularly in relation to business contacts and identifying potential candidates for specific employer requirements
- consent, where required by applicable law.
Where processing is based on consent, you may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
7. Retention of CVs and Candidate Data
CVs and other personal data provided directly to Polaris may be retained for a maximum period of 12 months from the date of receipt, unless a longer retention period is required by law or the candidate requests deletion earlier.
After the retention period expires, the data will be deleted or otherwise securely disposed of.
If a candidate is considered for a suitable position during this period, their data may be used and shared with the relevant employer in accordance with this Privacy Policy and applicable law.
8. Storage of Personal Data
CVs and other documentation provided by candidates via e-mail may be stored digitally on a computer device used by Polaris.
Polaris implements appropriate technical and organizational measures to protect such data against unauthorized access, loss, destruction, alteration or unauthorized disclosure.
9. Recipients of Personal Data
Personal data may be accessible to or shared with:
- potential employers as part of the employment mediation process
- e-mail and hosting service providers, to the extent necessary for the operation of our communication and IT systems
- competent authorities and institutions where legally required
- professional advisers or other service providers where necessary for Polaris’s business operations or protection of its rights.
Polaris does not sell personal data to third parties.
12. International Transfers of Personal Data
Due to the international nature of our business, candidate personal data may be shared with employers or other recipients outside the European Economic Area where this is necessary for a specific recruitment process.
Such transfers will be carried out in accordance with the GDPR and other applicable laws, with appropriate safeguards applied where required.
13. Your Rights
Under the GDPR, and subject to applicable legal conditions, you have the right to:
- request access to your personal data
- request correction of inaccurate or incomplete data
- request deletion of your personal data
- request restriction of processing
- object to the processing of your personal data
- request data portability, where applicable
- withdraw consent where processing is based on consent
- lodge a complaint with the competent supervisory authority.
To exercise your rights, you can contact us at:
E-mail: privacy@polaris-recruiting.com
We will respond to requests within the time limits prescribed by the GDPR.
If you believe that your personal data is being processed in violation of applicable law, you may lodge a complaint with the Croatian Personal Data Protection Agency (AZOP).
14. Changes to this Privacy Policy
Polaris may periodically amend this Privacy Policy to reflect changes in our business operations, technology or applicable laws and regulations.
The current version of this Privacy Policy will be published on our website together with the date of the latest update.
10. Social Media
Our website may contain links to Polaris profiles on social media platforms, including LinkedIn and other platforms.
When you click such a link, you leave our website and access a third-party website. The processing of personal data carried out by such platforms is governed by their own privacy policies.