W3Global Privacy Policy | How We Protect Your Personal Information

1. Introduction and Scope

W3Global, its affiliates, subsidiaries, and related entities (collectively referred to as "W3Global," "we," "us," or "our") are committed to protecting the privacy and security of your Personal Data.

This Privacy Policy describes how we collect, use, share, and protect the personal information of individuals who interact with our website at w3global.pl (the "Site"), and utilize our recruitment, staffing, and related services, including our candidates, temporary workers, client contacts, and website visitors (collectively, "Users" or "you").

As a global staffing and recruitment agency with a US Headquarters and operations in Poland (EU/EEA), we comply with, but are not limited to, the following key data protection regulations:

General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679)
California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA)
Other relevant US federal and state laws, and Polish national data protection laws.

2. Data Controllers and Contact Information

Region	Entity (Data Controller)	Contact Details
Global/US (HQ)	W3Global, Inc.	Address: 1701 Legacy Dr, Suite 1000, Frisco, Texas – 75034 Email: info@w3global.com Phone: +44 (20) 38841111
Poland/EU	W3Global Poland	Address: ul. Cicha 5/4, 00-353 Warszawa, Polska Email: info@w3global.com

3. Personal Data We Collect

We collect personal data to fulfill our role as a recruitment and staffing agency. The specific data collected will depend on your relationship with us (e.g., candidate, client, website visitor).

Category of Data Subject	Types of Personal Data Collected
Candidates / Job Applicants	Identification: Name, photograph, date of birth, nationality, immigration status, IDs/passport (where legally required). Contact: Email address, phone number, physical address. Professional: CV/Resume, employment history, job titles, qualifications, education, skills, professional references, salary expectations. Application Data: Interview notes, assessment results, job preferences. Special Categories (Sensitive Data): Race/ethnic origin, health/disability information (only where necessary for equal opportunities monitoring or reasonable adjustments, and with explicit consent or legal basis). Criminal Data: Details of convictions (only where legally required for specific roles).
Clients / Vendors	Business Contact: Name, job title, company name, business address, work email, work phone number. Relationship Data: Details of services requested/provided, contract information.
Website Visitors	Technical: IP address, browser type, operating system, device information, cookies and tracking data, pages viewed, and access times.

4. Legal Bases and Purposes for Processing (GDPR Requirement)

For individuals in Poland and the European Economic Area (EEA), we must have a lawful basis to process your Personal Data.

Purpose of Processing	Lawful Basis (GDPR Art. 6)
Recruitment & Placement	Legitimate Interest: Matching candidates with client vacancies; assessing suitability for roles; performing background checks (where legally permissible). Performance of a Contract: Fulfilling the terms of a service contract (e.g., employment contract, temporary work assignment, client service agreement).
Legal Compliance	Legal Obligation: Compliance with anti-discrimination laws, tax and employment reporting obligations, and health/safety requirements.
Marketing	Consent: Sending marketing communications (e.g., newsletters, event invitations). Legitimate Interest: Informing candidates of suitable vacancies or clients of relevant services based on their profile (subject to opt-out rights).
Website Operation	Legitimate Interest: Improving our website, system maintenance, ensuring network security.

5. Sharing and Disclosure of Personal Data

We only share your Personal Data with third parties as necessary to perform our services, with appropriate safeguards, or as required by law:

Clients/Employers: We share Candidate Data with our clients (User Employers) for the purpose of recruitment and placement.
Affiliates: With W3Global subsidiary companies globally, including our US HQ and Polish entity, for internal administration and staffing purposes.
Service Providers: Third-party vendors who perform services on our behalf, such as IT hosting, application tracking systems (ATS), payment processing, and background checking providers.
Legal & Regulatory Authorities: When required by law, such as in response to a subpoena, court order, or governmental request (including Polish and US authorities).
Corporate Transactions: In connection with a sale, merger, or acquisition of all or a portion of our business.

6. International Data Transfers (GDPR/EU Requirement)

As our US HQ is outside the European Economic Area (EEA), the transfer of Personal Data from Poland (an EEA member state) to the US or any other non-EEA country constitutes an international transfer.

We ensure such transfers comply with GDPR by implementing appropriate safeguards, which may include:

Standard Contractual Clauses (SCCs): Executing the EU Commission's Standard Contractual Clauses with the US HQ and other non-EEA recipients.
Binding Corporate Rules (BCRs): [If applicable, mention BCRs].
Adequacy Decisions: Relying on the European Commission's adequacy decisions, if available (e.g., the EU-US Data Privacy Framework).

7. Data Subject Rights (GDPR & CCPA/CPRA)

You have specific rights regarding your personal data. To exercise these rights, please contact us using the details in Section 2.

Right	Description (Applicable to EU/Poland)	Description (Applicable to US/California)
Right to Know/Access	Access to your Personal Data and certain supplementary information.	Right to request the categories and specific pieces of Personal Information collected.
Right to Rectification/Correction	To have inaccurate Personal Data corrected.	To request the correction of inaccurate Personal Information.
Right to Erasure ("Right to be Forgotten")	To request the deletion of your Personal Data in certain circumstances (e.g., data is no longer necessary for the purposes for which it was collected).	To request the deletion of your Personal Information, subject to certain exceptions.
Right to Object	To object to processing based on legitimate interests, including profiling and direct marketing.	Right to Opt-Out of Sale/Sharing: To direct us not to "sell" or "share" your Personal Information for cross-context behavioral advertising. W3Global does not sell or share personal data for these purposes.
Right to Portability	To receive your Personal Data in a structured, commonly used, and machine-readable format and to transmit those data to a third party.
Right to Limit		Right to Limit Use of Sensitive Personal Information: To limit the use and disclosure of Sensitive Personal Information to what is necessary.
Right to Withdraw Consent	To withdraw consent at any time where processing is based on consent. Withdrawal does not affect the lawfulness of processing before the withdrawal.

8. Data Security and Retention

Security Measures

We implement technical and organizational security measures designed to protect your Personal Data from accidental loss, unauthorized access, misuse, disclosure, or alteration. These measures include data encryption, firewalls, and access controls to limit access to those with a genuine business need.

Data Retention

We retain your Personal Data only for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

GDPR/Poland requirement: Recruitment documentation is typically retained for the duration of the recruitment process and a further period (e.g., 10 years for employment records or as required by Polish Labour Code).
US requirement: We maintain records as required by federal and state equal employment opportunity (EEO) laws.

9. Cookies and Tracking Technologies

The Site uses cookies and similar tracking technologies to track the activity on our Site and hold certain information.

Types of Cookies: We use strictly necessary, functional, performance, and targeting cookies.
Consent: For all non-essential cookies, we obtain your clear and affirmative consent, particularly for EEA/Polish users, in compliance with GDPR and the e-Privacy Directive.
Cookie Management: You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.

10. Children's Privacy

Our Site and services are not intended for children under the age of sixteen (16). We do not knowingly collect personal information from children under 16. If we learn that we have collected Personal Data from a child under 16, we will take steps to delete that information promptly.

11. Lodging a Complaint (GDPR)

If you are a resident of Poland or the EEA and have a complaint regarding our processing of your Personal Data, you have the right to lodge a complaint with the Polish supervisory authority:

Prezes Urzędu Ochrony Danych Osobowych (President of the Personal Data Protection Office - UODO)

Address: Stawki 2, 00-193 Warszawa, Poland
Phone: +48 22 531 03 00 (UODO General Contact)
Website: https://uodo.gov.pl/

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the bottom of this policy indicates when the latest revisions were made. We will notify you of any material changes by posting the new Policy on this page or via other communication channels.

Last Updated: November 2025