WayToTech Privacy Policy

Effective from: September 18, 2024

1. Data Controller

The controller of users' personal data on the WayToTech portal is:

Palapa Sp. z o.o.
Address: ul. Młynarska 42/115, 01-171, Warsaw, Poland
Tax ID (NIP): 5272934529
Contact email: hello@wayto.tech

2. Types of Personal Data Collected

The WayToTech portal processes the following personal data:

For candidates:

Email address
Phone number
Curriculum Vitae (CV)
Candidate profile (including name, surname, education, professional interests, and others)
Work experience
Job application history
Recruitment test results (if applicable)
Skill test monitoring data (webcam photos, interaction logs - if applicable)
Recruitment-related correspondence

For recruiters and companies:

Contact details of the company representative
Company name and Tax ID
Invoice details (if applicable)
Published job posting history
Candidate notes and ratings in the ATS system

This data is collected solely to enable user registration and use of the portal's services, including sharing it with recruiters as part of the recruitment process.

3. Purposes of Data Processing

Personal data is processed for the following purposes:

Creating and managing user accounts on the WayToTech portal
Enabling candidates to apply for job positions
Enabling recruiters to manage recruitment processes
Automatic evaluation and scoring of candidate applications using artificial intelligence
Storing application history in accordance with legal requirements
Supporting recruitment processes for IT positions
Error monitoring and service operation prevention (Sentry)
Analyzing visit statistics and user behavior for optimization purposes (SimpleAnalytics)
Fulfilling legal obligations arising from accounting regulations

4. Legal Basis for Data Processing

Users' personal data is processed based on:

User consent (Article 6(1)(a) GDPR) for processing data in the recruitment process, including sharing data with the recruiting company, and for using data in future recruitment processes (if such consent was given)
Contract performance necessity (Article 6(1)(b) GDPR) – user account registration and management, and ATS service provision
Administrator's legitimate interests (Article 6(1)(f) GDPR) – error prevention and statistics analysis
Legal obligations (Article 6(1)(c) GDPR) – retention of accounting documents

5. Data Retention Period

For candidates:

User account data: stored until account deletion or consent withdrawal
Job applications:
- 6 months from the end of the recruitment process – if the candidate did not consent to processing for future recruitments
- Until consent withdrawal or account deletion – if the candidate consented to data use in future recruitment processes
CVs and application documents: in accordance with application retention period

For recruiters and companies:

Account data: until service agreement termination
Accounting documents: 5 years from the end of the tax year
Recruitment process history: 3 years from process completion

6. Data Sharing

Users' personal data may be shared with:

Recruiting companies - when a candidate applies for a job, their data (CV, profile, test results) is shared with the company that posted the offer. The company only receives access to data of candidates who applied for their offers
Recruiters acting on behalf of companies - persons authorized by recruiting companies receive access to candidate data to the extent necessary to conduct the recruitment process
Data processors acting on our behalf:
- OpenAI – artificial intelligence service provider used for automatic application evaluation (based in USA, security measures applied: data encryption, data processing agreement)
- DigitalOcean – server and database provider (based in USA, Privacy Shield certified)
- SimpleAnalytics – statistics analysis tool (GDPR compliant)
- Sentry – application error monitoring tool
- Google Analytics – traffic and user behavior analysis tool

Recruiting companies are obligated to process data in accordance with GDPR regulations and data processing agreements concluded with them.

7. User Rights

WayToTech portal users have the following rights regarding their personal data processing:

Right to access data – users have the right to obtain information about what data is processed and for what purpose
Right to rectification – users have the right to request correction of their personal data if it is outdated or incorrect
Right to erasure ("right to be forgotten") – users can request deletion of their personal data at any time
Right to restriction of processing – in certain cases, users can request restriction of their data processing
Right to data portability – users have the right to receive their data in a structured format
Right to object – users can object to their data processing for specific purposes
Right to withdraw consent – if processing is based on consent, users can withdraw it at any time

8. Data Download and Deletion

Data Download

Users can download all data we store about them at any time:

Through the user panel: the "Download my data" option is available in account settings
By email: by sending a request to hello@wayto.tech

Data will be provided in JSON or CSV format within 30 days of the request.

Account and Data Deletion

Users can delete their account and all associated data:

Through the user panel: the "Delete account" option is available in account settings
By email: by sending a request to hello@wayto.tech

After account deletion:

All personal data will be permanently deleted within 30 days
Exceptions are data we must retain due to legal obligations (e.g., accounting documents)
It will not be possible to recover a deleted account

9. Data Security

To ensure personal data security, we apply:

SSL/TLS connection encryption
Data encryption at rest
Regular backups
Limited data access (authorized persons only)
System monitoring for security breaches
Regular security audits

10. Cookies

The WayToTech portal uses cookies for:

Maintaining user sessions
Remembering user preferences
Site traffic analysis (anonymously)

Users can manage cookie settings in their browser.

11. Data Protection Contact

For matters related to personal data protection, please contact:

Email: hello@wayto.tech
Address: Palapa Sp. z o.o., ul. Młynarska 42/115, 01-171 Warsaw, Poland

We respond to all inquiries within 30 days.

12. Complaint to Supervisory Authority

Users have the right to lodge a complaint with the President of the Personal Data Protection Office if they believe that the processing of their personal data violates GDPR regulations.

Personal Data Protection Office
ul. Stawki 2
00-193 Warsaw, Poland

13. Privacy Policy Changes

The privacy policy may be updated. We will inform users of significant changes:

Through a notification on the portal's main page
By email (in case of significant changes)

The date of the last update will always be visible at the top of the document.

14. Automated Decision-Making and Profiling

AI Scoring in Recruitment Process

The WayToTech portal uses artificial intelligence (AI) for preliminary evaluation of candidate applications:

Purpose: Supporting recruiters in efficient candidate selection through automatic CV analysis and matching to job requirements
Scope: AI analyzes work experience, technical skills, education, and other information contained in the application
Transparency: Candidates are informed about the use of AI in the application evaluation process
Decisions: AI does not make automatic decisions about rejecting candidatures – scoring results are only recommendations for recruiters
Candidate rights:
- Right to obtain information about the AI system's logic
- Right to challenge the scoring result
- Right to request human intervention in the evaluation process

Safeguards

We regularly monitor the AI system for potential errors and discrimination
We apply mechanisms to prevent unjustified discrimination
The recruiter always makes the final evaluation of applications

To exercise rights related to automated proces sing, please contact: hello@wayto.tech

15. Skill Test Monitoring

Monitoring Scope

During technical skill tests, we may collect:

Webcam photos - taken periodically for identity verification
Interaction logs - information about window minimization, leaving the test area, copying text

Processing Purpose

This data is collected solely to ensure test fairness and verify independent test completion.

Legal Basis

Candidate consent given before starting the test (Article 6(1)(a) GDPR).

Retention Period

Test monitoring data is stored for 6 months from the test date, after which it is automatically deleted.

Candidate Rights

Test data is not linked to the user account in the system
To request deletion of test monitoring data, send an email to hello@wayto.tech containing:
- Test completion date
- Company/position name applied for
- Email address used during application

Monitoring Information

Candidates are informed about monitoring before starting the test and must consent to recording to proceed with the test.

16. Final Provisions

This privacy policy constitutes an integral part of the WayToTech portal terms of service. In matters not regulated by this policy, GDPR provisions and Polish personal data protection laws apply.