PRIVACY POLICY - PAYLAB

This Privacy Policy explains how Alma Career companies as joint controllers, as defined below, process the personal data of Users and Clients in connection with the provision of the Paylab Service ("Data Subjects"). 

The personal data of Data Subjects are processed in accordance with the applicable and effective legal regulations, in particular General Data Protection Regulation (EU) 2016/679 (“GDPR”).  

Alma Career includes/represents companies that act as joint controllers for the purposes of the GDPR, unless otherwise specified below (see point 2 below).  

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

Alma Career Slovakia s. r. o., registered office: Bratislava - Staré Město, Pribinova 19, ZIP code 811 09, Slovak Republic, ID No.: 35800861, registered in the Commercial Register maintained by the Bratislava III District Court, section Sro, insert 22949/B, 

Alma Career Poland Sp. z o.o., registered office: BL Astoria, Przeskok 2, 00-032 Warsaw, Republic of Poland, registered in the Commercial Register maintained by the District Court for the capital city of Warsaw in Warsaw, XII Commercial Division of the National Court Register, under entry number KRS 0000988078, NIP 5252920122, REGON: 522873400, with a share capital of 300,000 PLN, 

(hereinafter referred to as "we", "us", "our", "Joint Controllers" or "Alma Carrer"). 

Terms used in the Privacy Policy that are not specified herein shall have the meanings defined in the terms and conditions at https://www.almacareer.com/legal. 

JOINT CONTROLLERS 

All of the aforementioned Alma Career companies are so-called joint controllers of personal data as per Article 26 GDPR, unless they are in the position of a separate controller. The companies have entered into an agreement that defines the individual shares of responsibility for compliance with the obligations set out in Article 26 of the GDPR. 

INDEPENDENT CONTROLLER 

Alma Career acts as an independent data controller when it processes Client data for the performance of contractual or legal obligations related to the provision of the Paylab Service in a given country.  

Personal data and information provided by the Data Subject 

USERS 

The scope of the data corresponds to the form the User fills in on the Paylab website. This includes the following categories of data: job title, experience in the position, salary/wage and job information, and other information indicated in the form. E-mail is optional, it serves for sending salary reports based on the specified criteria and is not mandatory.  

The purpose of the data processing is to create a salary report based on the criteria entered by the User, even without providing an e-mail address.  

If the e-mail address is provided, an updated salary comparison is sent to the User every three months for a period of one year. After one year, an invitation is sent to the User to join the salary survey, however, if the User does not respond to the invitation, her/his e-mail is deleted from the Alma Career database within one week.  

If the User agrees to the use of her/his e-mail address for salary tracking, a message with the salary trend and an invitation to participate in the salary survey will be sent to the User in the following year.  

CLIENTS 

The scope of the data follows from the relevant form that the Client fills in on the Paylab website. These are the following categories of data: company name, ID number, name, referral, e-mail, phone number, target country for which the client wants to try Paylab, or other information as specified in the form.  

The purpose of the data processing is the provision of the Service, i.e. the testing of the salary tool and/or the provision of Salary Analyses in accordance with the Alma Career Product Terms and Conditions.  

USERS 

The legal ground for the processing is consent to the processing of personal data pursuant to Article 6(1)(a) GDPR in the case of an e-mail. Salary information (anonymous data) is processed on the basis of Article 6(1)(b) for the provision of the service and Article 6(1)(f) GDPR for statistical purposes, i.e. monitoring and comparison of salary development.    

The e-mail is retained for one year for the purpose of sending salary reports.  

If the User gives consent to the use of the e-mail address for salary progress monitoring, the e-mail is stored for the period of the consent given, with the possibility of its revocation, and therefore deletion, via the link provided in the footer of the message. 

CLIENTS 

The legal basis for processing is pre-contractual and/or contractual negotiations according to Article 6(1)(b) GDPR. If the Data Subject acts on behalf of the Client as an employee, the personal data, including contact data, is processed on the basis of legitimate interest pursuant to Article 6(1)(f) GDPR. 

The data is processed for a period of one year and, in the case of ordering paid Services, for the period required by accounting and tax regulations.  

The personal data of Data Subjects is only disclosed to authorised personnel of Alma Career or individual contracted processors or other recipients as separate controllers, such as public authorities.  

Most processors have only limited access to the personal data of Data Subjects. Although personal data are transmitted by the processor, this is only to a minimal extent. No processor is entitled to use the personal data provided for its own purposes (marketing or otherwise). 

We use the cloud provider Amazon Web Services for Paylab Services. Information on other potential processors is available at  https://www.almacareer.com/gdpr.   

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 - we do not transfer all data, only the data that are necessary for the purpose, for example, for sending out e-mail communication, it's just e-mails. With regard to data transfers outside the EU/EEA, Alma Career undertakes that any transfer of personal data to third countries will only take place under the conditions set out in Articles 44-49 of the GDPR. If the tools for the transfer of personal data to a third country are modified, revoked or invalidated, Alma Career undertakes to take such measures as are equivalent to those required by EU law.  

In the cases provided by law, the Controller may, and sometimes must, disclose certain personal data to public authorities or law enforcement authorities in accordance with applicable law. For this reason, we are sometimes as well obliged to "comply" with the relevant public authorities. 

We use the contact details (e-mail, phone number) of our Clients for marketing purposes relating to our own Services. We may use this data to send marketing messages only if the Client has not opted out of receiving these messages and unless otherwise required by law (such as in Poland or Hungary). 

Anyone is entitled to unsubscribe from receiving marketing messages via the link provided in the footer of the email message or by sending a STOP message (even in advance) to  

The conditions for sending marketing messages are governed by the e-privacy directive and local regulations. We would also like to emphasize that not every message you receive from us is a marketing / commercial message. While providing a given Service, sometimes it is necessary to communicate with Clients and Users of Alma Career 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 are not commercial communication – an example is a notification that the general terms and conditions or product terms have changed or information about a password change or a notification of an incomplete action, e.g. when filling in information in an posting form. 

Please note that if you have consented to receive commercial communications for our other products and you wish to opt out of a particular Service, but not all of them, you you have to write this information in the e-mail, e.g. unsubscribe only from Seduo. Otherwise, we will unsubscribe you from receiving all commercial communications or from that commercial communication as indicated in the applicable e-mail footer. Unsubscribing from all commercial communication may also affect the sending of Job Advertisement as we classify them as marketing communications. 

Based on your history of use of our Services, you may receive notifications on some websites in the form of promotional communications that we would like to welcome you back on our websites. For these notifications we use the services of Google, Facebook, LinkedIn and Seznam.cz – they use the cookies stored in your browser to detect your previous visit, provided you have given your consent. 

For more information about marketing via web tools, please see the Cookie Policy.   

We use cookies to provide our Users and Clients with the best Services. Cookies are short text files that allow the recording of information when you visit a website and are stored on the User's device.  

Our website may also contain third-party cookies, which are used to obtain anonymous statistics about the traffic and behavior of Users on individual pages. These third parties usually do not store any personal data in relation to the use of cookies since they do not have access to the identity of the Alma Career Service User, provided that the User is not logged into the user account of such third party - e.g. Google. 

The use of cookies can be modified  via the cookie bar or in browser settings.   

Detailed information on the use of cookies is available in Cookie Policy. 

Alma Career has implemented all technical and organizational measures to ensure the protection of personal data in accordance with the GDPR and the relevant (local) data protection legislation.  

These include measures to prevent unauthorized or accidental access, alteration, destruction or loss of personal data, unauthorized transfers, other unauthorized processing and misuse of personal data. This obligation remains in force even after the processing of personal data has ceased, i.e. even after the User stops using our Services.  

Personal data is continuously monitored electronically and physically. We have implemented modern safety and security mechanisms to ensure maximum data security. To protect data from unauthorized access, we use a user access control system to manage user rights and roles. All persons who, in the course of their work or in the performance of their contractual obligations, come into contact with the personal data of Users or Clients of Alma Career Services are bound by a legal and/or contractual duty of confidentiality. 

Data Subjects’ rights can be exercised in writing by sending a letter to Alma Career's registered office or by e-mail to [email protected], [email protected] or [email protected]. 

Please note that in the event of repeated or manifestly unfounded requests to exercise the rights, Alma Career is entitled, in accordance with Article 12(5) of the GDPR, to charge a reasonable fee for the exercise of the right in question, or to refuse to comply with such a right. Alma Career shall inform you of such steps in advance. Please direct your requests primarily to the Alma Career company whose Services you are using. We will promptly acknowledge receipt of your request and process it within the one-month time limit set by the GDPR, or we will inform you of the reasons for the extension.  

You have the right to be informed whether your personal data is being processed and, if so, to have access to it. 

If you consider personal data processed by Alma Career to be inaccurate, incorrect, outdated or incomplete, you have the right (and in certain cases the obligation) to request its rectification or completion. Alma Career will rectify/add the data without undue delay, taking into account technical limitations. 

If you request erasure of your data, we will erase your personal data if (i) they are no longer necessary for the purposes for which it was collected, (ii) you withdraw consent or object to the processing and there are no overriding legitimate grounds for processing, (iii) they were processed unlawfully, or (iv) a legal obligation must be fulfilled, or if it was collected in connection with the offer of services of the information society.  

If you do not wish to delete the data, but only to temporarily restrict the processing, you can exercise your right to restrict the processing of your personal data.   

The data subject has the right to restrict processing if (i) she/he disputes the accuracy of the data - for the time necessary for the controller to verify the accuracy of the personal data, or (ii) the processing is unlawful and the data subject refuses to erase the personal data but requests instead that the use of the data be restricted, or (iii) Alma Career no longer needs the personal data for processing but the Data Subject requires it for the establishment, exercise or defense of legal claims; or (iv) the Data Subject objects to the processing - pending a determination of whether Alma Career's legitimate interests outweigh the Data Subjects' legitimate interests. 

If you wish to transfer your personal data processed based on consent or contract to another controller, you can exercise your right to data portability. If the exercise of this right could adversely affect the rights and freedoms of third parties, Alma Career will not be able to comply with such a request. 

You may object to the processing of personal data that is processed for the purposes of protecting the legitimate interests of Alma Career or third parties, including profiling. Unless we can prove that there are compelling legitimate grounds for the processing that override the interests or rights and freedoms of the Data Subject, we will terminate the processing without undue delay upon objection.  

You can object to the sending of commercial communications via the link provided in the marketing message. You can object to marketing at any time before the data is provided, either by ticking the checkbox - if available - or by writing an e-mail with the subject STOP. 

If personal data is processed based on consent, you can withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent given before its withdrawal. 

You have the right to contact the relevant supervisory authority. Contact details for each supervisory authority can be found at https://www.edpb.europa.eu.  

You can contact the Data Protection Officer at any time at the Alma Career head office (please see point 1) or by e-mail at [email protected], [email protected] or [email protected].  

The terms of processing set out in this Privacy Policy apply to any data or information you provide to us in any written or telephonic communication. 

Alma Career reserves the right to modify this Privacy Policy in response to changes in the Services provided and/or if there is a change in the law that requires us to govern the relationship differently. 

Minor edits, such as formatting, correcting typos or clarifying text, can be made without changing the date of the last update. 

In accordance with the European Data Protection Board's guidelines, we will notify significant or material changes/processes that may be surprising or unexpected, via Alma Career's electronic systems. 

The Privacy Policy