BRILL AV MEDIA PRIVACY POLICY

PRIVACY POLICY

 

1. OUR APPROACH TO THE PROTECTION OF YOUR PRIVACY

• We pay close attention to the protection of all personal data you provide to us in the course of our cooperation.
• You may decide which data you provide to us and how detailed they should be – while using our online services, it is up to you whether you provide us only with the minimum necessary information or tell us more about you so you can access all the benefits connected with our services.
• We only require the data we need to provide our services and process them for purposes stated below. We do not give your information to anyone who is not entitled to process it.
• As a business entity, we cooperate with various trustworthy partners who provide important services to us, such as technology and infrastructure, data storage, data backup, and so on. These partners may have access to your data, but only within the scope of the service they provide to us. See below for more information.

 

2.  BRILL AV MEDIA AS A CONTROLLER OF YOUR PERSONAL DATA

• The controller is responsible for the lawfulness of the processing of your personal data - it is the person or an entity who determines for what purpose and by what means your data will be processed and protected. The controller also handles any of your privacy issues and helps you exercise your rights.
• The controller of your personal data processed in connection with using the app BRILL AV MEDIA on OnSinch is:
  • BRILL AV MEDIA SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, identification no.: NIP 1070003205, registered office ul. Ojca Aniceta 7, 03-264 Warszawa, Mazowieckie, registered in the Commercial Register kept with the District Court for the Capital City of Warsaw, reg. no.: KRS 0000246063.
  • Website: https://bavm.onsinch.com
  • E-mail: it@brill.pl
     

 

3. THE SCOPE OF THE PROCESSING OF PERSONAL DATA

• The scope of your personal data we process depends on which services you decide to use and what settings you apply on them. Your data is processed by us in the following situations:

 

• 01: When you browse our website https://bavm.onsinch.com
  • Purpose of processing: Customization of the website to your needs and collecting visitors’ data for improvement of our services.
  • Legal basis for processing: Our legitimate interests in shaping our professional online identity and your consent to the collection of cookies (you can change your cookie settings at any time in your browser - for more information please refer to section "Cookies settings").
  • Processed data: Cookies, data about the use of our website (e.g. device data, browser, time of access).
  • Duration of processing: Session Cookies are processed only while the browser is in use (i.e., until the browser is closed). Processing of Persistent Cookies lasts until the expiration date specified in their code, this period shall not exceed 12 months.
• 02: When you contact us via form or e-mail
  • Purpose of processing: Communication with the public and handling your inquiries or requests.
  • Legal basis for processing: Your consent by sending a message, our legitimate interests in developing good public relations.
  • Processed data: E-mail or other personal data voluntarily included in your message.
  • Duration of processing: Usually for the duration of our communication. Archiving communication related to claims and requests for up to 3 years from the end of the communication.
• 03: When you sign up for BRILL AV MEDIA on OnSinch app
  • Purpose of processing: Setting up and maintaining your user account, enabling performance of work tasks, scheduling and organizing them. The app allows us to offer you specific job opportunities and register for jobs, track your work history, evaluations, and reports that can help you achieve higher hourly wages.
  • Legal basis for processing: Performance of the contract concluded between you and BRILL AV MEDIA.
  • Processed data: Name, surname, e-mail address, phone number, date of birth, gender, job preferences, evaluations, work history, and scheduling data.
  • Duration of processing: Until the termination of the user account.
• 04: When you use BRILL AV MEDIA on OnSinch app and enter information about yourself
  • Purpose of processing: Maintaining your user account, tracking work-related data, adjusting work conditions to your needs, evaluating your eligibility for tasks.
  • Legal basis for processing: Performance of the contract and performance of obligations as an employer.
  • Processed data: Employment data, job history, preferences, certifications, evaluations. If certain data is mandatory (e.g., for employment contracts), this will be indicated in the app.
  • Duration of processing: Until the termination of the user account. Certain personal data (e.g., employment documentation) may be processed after account termination if required by law or necessary to protect claims and interests.
• 05: When you work for us as an employee
  • Purpose of processing: Performance of the obligations between employer and employee. After successful registration, an employment-related contract will be concluded, serving as the basis for cooperation under labour law.
  • Legal basis for processing: Performance of the contract and legal obligations of BRILL AV MEDIA as an employer.
  • Processed data: Name, surname, contact details, employment details, tax and accounting information.
  • Duration of processing: The duration varies by legislation. For example, accounting data is processed for 5 years after the accounting period, while tax documentation may be retained for 10 years.
• 06: When you attend our events
  • Purpose of processing: Organization of events, communication related to events, reporting for PR purposes.
  • Legal basis for processing: Performance of the contract (event participation), our legitimate interests in promoting our activities, or your consent.
  • Processed data: First name, surname, contact details, photos.
  • Duration of processing: Personal data related to event participation is processed for 3 years after the event. If consent is the legal basis, processing continues until consent is withdrawn.
• 07: When you subscribe to e-mail newsletters
  • Purpose of processing: Sending e-mail newsletters with information about BRILL AV MEDIA and its services.
  • Legal basis for processing: Your consent.
  • Processed data: E-mail address.
  • Duration of processing: Until consent is withdrawn.
     

4. VOLUNTARY PROVISION OF PERSONAL DATA

• The provision of your personal data for our services is voluntary. This means that it is exclusively at your discretion whether you provide us with your data.
• However, please note that the provision of your personal data is in some cases necessary for certain services to be successfully performed or received by you. For instance, we are unable to conclude an employment-related contract with you or assign work tasks unless you provide us with the data we are required to process as an employer. Similarly, we are unable to set up and maintain a user account for you unless you provide the necessary information during registration.
• The voluntary element remains in your decision whether to use our services or establish cooperation with us. By choosing to proceed with registration or signing an employment contract, you acknowledge the need for providing the required data.

5. LEGAL BASIS FOR OUR PROCESSING

The processing of your personal data is lawful only if at least one of the lawful bases for processing under the General Data Protection Regulation (GDPR) is applicable. We have identified the following legal bases:
 

Performance of the contract

• This applies to the processing of your personal data in connection with maintaining a user account in the BRILL AV MEDIA on OnSinch app, assignment of work under an agreement to complete a job or other contract, arrangement of your participation in events, or other activities based on a contract to which you are a party.

Performance of legal obligations by BRILL AV MEDIA

• This basis applies where the obligation to process certain personal data is imposed on BRILL AV MEDIA directly by law or other binding legislation – for instance, the Labour Code, the Act on Accounting, or other relevant regulations. This is especially applicable in situations where BRILL AV MEDIA acts as an employer or an accounting unit.

Legitimate interests of the controller

• For example, we pursue legitimate interests in:
  • Collecting data about the online traffic and usage of our online services for quality improvements.
  • Utilizing data for our branding campaigns (e.g., reporting from events).
  • Retaining certain data for the purpose of the enforcement of claims, including those made by third-party entities.

Consent of the data subject

• Your consent is necessary in situations where none of the above-mentioned legal bases applies. For instance:
  • If we want to use your personal data for self-promotion, we need your consent.
  • If we want to send you our e-mail newsletters, we require your consent.
• You can easily withdraw the consent you previously gave to us. To do so, send an email to it@brill.pl and inform us of your decision to withdraw your consent.

 

6. THE PROCESSORS

• We are not alone in what we do. We use services of third parties (our partners) to help us function properly and provide professional and reliable services. These are mainly partners providing technical infrastructure for our services or specialized services that we find necessary to outsource.
• These processors may have access to your personal data, provided that legal conditions are met. This applies in situations where the provision of your data is necessary for the performance of the obligations we agreed on. The processing of data by the processors shall only occur to the minimum necessary extent in relation to the purpose for which the data is provided.
• We use services of the following processors:

1. OnSinch, s.r.o., reg. no.: 242 74 330, registered office: Příběnická 939/20, 130 00 Prague 3, The Czech Republic – the provider of the BRILL AV MEDIA on OnSinch app where work is assigned and shifts are selected.
2. Microsoft Ireland Operations Limited, reg. no.: 256796, registered office: One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland – provider of cloud services for data storage and email communication.
3. Google Ireland Limited, reg. no.: 368047, registered office: Gordon House, Barrow Street, Dublin 4, Ireland – provider of analytical tools and advertising services (e.g., Google Analytics).
4. AWS (Amazon Web Services) Europe, registered office: 38 Avenue John F. Kennedy, L-1855, Luxembourg – provider of server hosting and data backup services.

• Other processors of your personal data may also include our clients who upload events and request staff in the app. They have access to a limited amount of personal information necessary for organizing events or obtaining security permissions.

 BRILL AV MEDIA does not transfer personal data to a third country (i.e., outside the EU).

7. YOUR RIGHTS AND HOW TO EXERCISE THEM

In relation to your personal data, you may exercise the following rights:

• Right of access to personal data – the right to obtain information about the processing carried out by the controller.
• Right to correction of inaccurate data (right to rectification) – you can correct the data directly in the app.
• Right to erasure of your personal data from our databases (right to be forgotten) in case the data is no longer necessary for the purpose for which it has been collected.
• Right to restriction of processing – e.g., the right to require that we temporarily process data only by deposition.
• Right to data portability – the transfer of data to another controller, if technically possible.
• Right to object at any time to processing of personal data based on our legitimate interests as described above.
• Right to revoke your consent to the processing of personal data where consent is the legal basis of such processing without any sanction. You can revoke consent either by unchecking the respective box in the app or by sending an e-mail to it@brill.pl.

You can send your request to exercise a privacy-related right to it@brill.pl or address a letter to our registered office (see Article 2). Please note that all requests must be made in writing.

It is important that we verify who is exercising the right and what exactly is requested. We may therefore require verification of your credentials to ensure we can process the request securely and prevent unauthorized access or deletion of data.

We aim to resolve all questions or requests promptly to your satisfaction. However, if you believe our processing violates your rights, you have the right to submit a complaint to the supervisory authority: President of the Personal Data Protection Office (UODO), Poland.

 

8. COOKIES SETTINGS

Cookies, as described above, are small data files stored on your computer that carry information related to your online preferences and use of our online services. They allow our website to load faster or adapt to your browser preferences.

We process cookies based on your consent, which you grant through your browser settings. If you do not want our website to store and use cookies, you can disable them in your browser.

To change your browser's cookie settings, visit the following links:

• Google Chrome
• Internet Explorer
• Microsoft Edge
• Mozilla Firefox
• Opera

 

9. MAILING POLICY

• You can subscribe to and unsubscribe from our newsletters in your profile settings. By subscribing, you agree to receive newsletters to your e-mail. You can unsubscribe anytime by clicking the link at the bottom of the newsletter.
• When you unsubscribe, we will terminate the processing of your personal data for mailing purposes.
• We send newsletters approximately once a month.
• For any questions regarding mailing, please contact us at it@brill.pl.

10. EFFECT OF THIS POLICY

• In the future, we may adapt this privacy policy to reflect new data processing activities. We will notify you about any substantial changes. Even so, we recommend checking back from time to time for updated versions of this policy.
• This policy becomes effective on 2.12.2024.