Privacy Policy

Welcome to our homepage and thank you for your interest in intive group companies, i.e. intive GmbH, intive automotive GmbH, intive Inc., intive Ltd. (UK), intive Ltd. (Ireland), intive S.A.U., intive LLC,Ammeon UK Ltd,  intive SRL, SimtLix LLC, Infintity Technology SAS, SimTLiX SRL, DevSpark LLC, DevSpark Argentina LLC, DevSpark S.A. As part of this policy, each and everyone of the above mentioned intive group companies is referred to as an "intive", a "controller" or a „Company”. This name will also be used to intive GmbH Spółka z ograniczoną odpowiedzialnoscią Oddział w Polsce (Limited liability company Branch in Poland, hereunder referred to as: “intive GmbH Sp. z o.o. Branch in Poland” or “Branch Office in Poland”) in relation to processes where it is a separate controller. If there are any deviations from this rule, the name of a specific company will be used in relation to its specific situation.

Since it is necessary to process personal data for the purposes of our business and intive makes every effort to secure the processing of personal data to the highest degree, ensuring their full security, it has become reasonable to prepare this document in order to describe what actions we take on personal data and how we do it. However, the unchanging principle of intive is that all actions taken by us are in compliance with applicable laws on the protection of personal data, including, where applicable, the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (hereinafter referred to as "GDPR"). Below we will inform you about what data we collect and how this data can be processed.

As we give the highest priority to the protection of your personal data at intive, we will inform you in this document on the means and purposes of processing your data. It is very important for us that you feel safe browsing our websites, using the functionalities available on them, as well as establishing and cooperating with us or taking other actions. 

Responding to issues presented using the contact form

The controller of your personal data is intive GmbH or intive GmbH Sp. z o.o. Branch Office in Poland, with respect to requests and queries concerning processes in which the Branch Office in Poland is the sole controller.

Your personal data is processed on the basis of a legitimate interest (art. 6 pp. 1 p. f GDPR) in correspondence in relation to messages sent using a contact form (as well as social networking sites) and in answering questions sent.

The data will be processed for the duration of the communication or until an objection is made, which is deemed reasonable by the controller; in the case of intive GmbH and intive Automotive GmbH, for a maximum of 1 year.

The provision of personal data is voluntary, but necessary to answer to message sent.

Analysis of website traffic in order to optimize available functionalities

The controller of your personal data is intive GmbH.

Your personal data is processed on the basis of a legitimate interest (art. 6 pp. 1 p. f GDPR) in the need to analyze the traffic on a website in order to optimize the functionality available on it.

The data will be processed until such time as an objection as the controller deems reasonable; in the case of intive GmbH and intive automotive GmbH, for a maximum period of 3 years.

The provision of personal data is voluntary, but necessary in order to optimize the functionality of our website.

Answering questions and requests from data subjects

The controller of your personal data is:

• If you have any questions regarding the processes administered by intive GmbH, the company will be the data controller of the process-related data;

• If you have any questions regarding the processes administered by intive GmbH Sp. z o.o. Branch in Poland as a separate controller, intive GmbH Sp. z o.o. Branch in Poland will be the controller of the process-related data; 

• If you have any questions regarding the processes administered by any other Company, the particular company will be the data controller of the process-related data.

Depending on the nature of your request, your personal data can be processed on the basis of a legitimate interest (art. 6 pp. 1 p. f GDPR) which is the necessity to answer questions sent, as well as, when processing is necessary for the performance of a contract to which the data subject is party (art. 6 pp. 1 p. b GDPR) or on the basis of legal obligation incumbent on us as a controller (art. 6 pp. 1 p. c GDPR).

Your personal data will be processed for no longer than necessary, however:

• If the request for withdrawal of consent to the processing of personal data is justified and the controller has no other legal grounds for data processing, the personal data shall be deleted immediately; for intive GmbH and intive automotive GmbH provided that there are no contradictory statutory periods for data storage;

• Where a request for erasure is considered unjustified, the data shall be processed for the time necessary for the purpose for which they were obtained, where detailed information on the purpose and time of the processing was provided at the time of their acquisition. Detailed information in this respect may be obtained by contacting the Data Protection Officer again at the contact address below or, if not appointed, at the address: dpo@intive.com;

• Where requests other than for deletion are made, data will be processed for the purpose of responding to the request for information for the time necessary to respond and then for the time necessary to observe the principle of accountability, including the defense against claims, i.e. in the case of intive GmbH, intive GmbH sp. z o.o. Office in Poland, intive automotive GmbH, intive Ltd. (Ireland), and intive SRL for 3 years; in the case of intive S.A.U., SimTLiX SRL and DevSpark S.A., for 5 years.

The provision of personal data is voluntary, but necessary to answer to message sent, and – in case question concerns the contract – in order to perform a contract, or on the basis of legal obligation incumbent on us as a controller.

Conducting recruitment activities

The controller of your personal data is:

• In the case of recruitment procedures conducted by intive GmbH in Germany, this company will be the controller of data related to the process;

• In the case of recruitment procedures conducted in Poland by intive GmbH, the Branch Office in Poland remains the controller of data related to the process;

• In the case of recruitments done by other companies from the intive group, the controller of personal data related to the process is the company that is recruiting;

• In relation to the Referral Program, the controller of personal data is intiveGmbHsp. z o.o.  Branch Office in Poland.

Your personal data is processed in compliance with the following legal basis:

• Legal obligation incumbent on the controller to the extent that the person joining the recruitment process provides the data indicated in the provisions of law (art. 6 pp. 1 p. c GDPR);

• Processing for the performance of a contract to the extent that, within the recruitment process, the CV applicant seeks to conclude a contract of employment or cooperation with intive (art. 6 pp. 1 p. b GDPR);

• Candidate's consent to the processing of other data voluntarily provided;

• The legitimate interests of a controller – in respect of e-mail address provided in the recruitment form on the website - in the form of conducting recruitment activities by electronic means;

• Candidate's consent to the processing of data for participation in future recruitment processes or consent given in case of an application without indicating a specific position (art. 6 pp. 1 p. a GDPR);

• Candidate's consent to make the CV data available to the intive client for whom the recruitment is being conducted (art. 6 pp. 1 p. a GDPR);

• Candidate's consent to make the CV data available as a part of intive’s GmbH sp. z o.o. branch in Poland referral program (art. 6 pp. 1 p. a GDPR)

• The explicit consent of the candidate, if he or she voluntarily submits to intive data of a special category (art. 6 pp. 1 p. a GDPR);

• Legal obligation imposed on the future employer under the Aliens Act and the Act on employment promotion and labor market institutions (in Poland) (art. 6 pp. 1 p. c GDPR);

• The legitimate interests of a controller – in respect of providing support in obtaining other documents allowing the foreigner to stay and work, and the obtaining of which is not the employer's responsibility (art. 6 pp. 1 p. f GDPR);

• The legitimate interests of a controller – in respect of providing support in obtaining residence permit for a foreigner who is a family member of the future employee, on the basis of the power of attorney granted to the Controller’s employee (art. 6 pp. 1 p. f GDPR)

Your personal data will be processed for no longer than necessary, however:

• Personal data collected for the purpose of an ongoing recruitment process will be processed for the duration of the recruitment process or until the withdrawal of consent to the processing of data (in the case of data processed on the basis of consent), depending on which event occurs first; in the case of intive GmbH sp. z o.o. Branch Office in Poland not longer than 6 months from the date of commencement of recruitment and 6 months from the end of recruitment in case of intive GmbH and intive Automotive GmbH.

• If you agree to participate in future recruitment processes, in the case of the Referral Program of intive GmbH sp. z o.o. Branch Office in Poland or application submitted without indicating the position, until the withdrawal of consent, unless the controller previously considers the deletion of data to be justified depending on which event occurs first; however, no longer than 3 years from the date of receipt of the CV in the case of intive GmbH, intive GmbH Branch Office in Poland, intive Automotive GmbH and intive S.A.U.

• In case of consent to transfer the CV to an intive client for whom the recruitment project is to be carried out, until the withdrawal of consent or for the duration of the recruitment process, depending on which event occurs first ; in the case of intive GmbH and intive Automotive GmbH for a maximum period of 3 years.

• In the case of special categories of data, until the withdrawal of consent, unless the controller deems it necessary to delete the data beforehand; in the case of intive GmbH and intive Automotive GmbH for 3 years.

• In the case of processing foreigners' data for the purpose of obtaining applicable work permits and statements on the entrust work to a foreigner, the data will be stored in accordance with the rules of keeping employees' personal files.

• In case of receiving a decision on refusal to issue a work permit to a foreigner, the data will be processed until an objection is raised, which will be considered justified by the Controller.

• No longer, than necessary for the Controller to provide support in obtaining other documents allowing a foreigner to stay and work.

• To the extent that the Controller provides support in obtaining residence permit for a foreigner who is a family member of the future employee, on the basis of the power of attorney granted to the Controller’s employee, the data will be processed for the duration such proceedings. 

• Your provision of the following personal data: name, surname, date of birth, contact information, education, professional qualifications, and previous employment history, is required by law. Other data is provided voluntary. If you fail to provide personal data required by law, your application may be rejected.

Marketing and sales of in-house services

The Controller of your data will be intive GmbH or another intive group company conducting marketing and sales activities.

Your data will be processed for the purpose of the Controller's legitimate interest, i.e. marketing of the Controller's in-house services based on the sales leads obtained (Article 6(1)(f) GDPR).

We have obtained your data in the form of name, position, place of employment, email address from a professional sales lead generation service provider (e.g. Lusha Systems Inc.).

Your personal data will be processed by us:

- in the event you or your company has become our customer - for the period of limitation of claims, which is - for claims for periodic benefits and claims related to the conduct of business activity- 3 years for the Branch Office in Poland, 6 years for intive GmbH, intive Automotive GmbH and intive S.A.U;

- in case you are our potential customer or represent them:

o if we have contacted you, but not concluded a contract - your personal data will be processed by us for two years counted from the first contact;

o if we have sent an offer - your data will be processed for 5 years calculated from the date of sending the offer;

o In a situation where we have not received a response from you to our inquiry - we will process your data for a period of 2 years counted from the date of sending our message.

In any case, however, we will not process the data in the event of an effective objection or withdrawal of consent.

Provision of personal data is voluntary, but necessary for the purposes of processing. Failure to provide personal data will result in not receiving our marketing content.

Video monitoring

The Controller of your personal data is the Company in which the monitoring is carried out.

Information about the personal data administrator is available on the boards located in the monitored area.

The legal basis for processing is legitimate interest in ensuring the safety of persons staying on the premises of the controller, including employees, protection of property, production control understood as the creation of software and the confidentiality of confidential information (Article 6(1)(f) GDPR).

The Controller processes image recordings for a period not exceeding: intive GmbH spółka z ograniczoną odpowiedzialnością oddział w Polsce - 3 months, intive GmbH and intive automotive – 72 hours, intive Ltd. and intive SRL – 1 month, from the date of their creation. After the expiry of the period referred to in the previous sentence, video recordings shall be destroyed unless otherwise provided by law or they may constitute evidence in legal proceedings unless, before the expiry of those periods, an objection is raised against the processing which the controller deems justified.

The provision of your personal data is voluntary, but for the purpose of staying on the Administrator's premises.

Social media, including in particular Facebook and Instagram profiles

The controller of your personal data is intive GmbH or another intive group company using social media profiles for its own purposes.

In the case of Facebook profile, the Controller or co-Controllers (e.g. for Facebook Page Insights) of your personal data is also Meta Platforms Ireland Ltd. based in Dublin (address: 4 Grand Canal Square Grand Canal Harbour Dublin 2, Ireland). The co-management agreement may be found at this address: https://www.facebook.com/legal/controller_addendum.

Facebook has applicable regulations and privacy policies. To review Facebook's privacy policy, we encourage you to visit this page: https://www.facebook.com/privacy/explanation.

We also process your data as a part of our Facebook and Instagram profiles. The legal basis for this processing is our legitimate interest (Article 6(1)(f) GDPR), in relation to:

- responding to private messages you send to us through the relevant Facebook or Instagram functionality,

- reaching out to you as an exchange of comments under our posts,

- sharing our posts with you as a follower of our Fan page/profile,

- informing you about our services by sharing posts on our Fan page/profile,

- obtaining anonymized analytical and statistical data obtained by the service in question based on the parameters we set in advance based on the nature of our clientele, as well as our promotional and marketing purposes

We process your personal data for the period of time necessary to resolve your case or to respond to your inquiry directed by our profile. Depending on the subject matter of your case, we may process your data in the future in order to demonstrate that we have resolved your case, i.e. until the statute of limitations for claims.

Provision of personal data is voluntary, but necessary for the purposes of processing.

Every data subject shall have the following rights:

• the right of access to data content;

• the right to rectify them;

• the right to remove data;

• the right to limit the processing;

• the right to transfer data;

• the right of objection;

• the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal – to withdraw your consent please contact the DPO of the Controller to which you gave your consent at the e-mail address: consentwithdrawal@intive.com or dpo@intive.com.

• the right to lodge a complaint with the supervisory authorities:

In the course of processing your personal data, we may share your personal data with different recipients in different situations. The recipients of personal data may be organisations supporting the Controller in the course of their business activities, in particular: banks, courier and transport companies, external entities providing IT support, personal data protection, legal protection, companies conducting internal controls/audits on behalf of the Controller, customers, contractors, entities responsible for the functioning of social networking sites, providing services that we use on the website, the Tax Office and the Police or other authorities on the basis of applicable laws. Moreover, the recipients may be companies within the intive capital group and entities to which intive provides space on its website.

The following entities that provide services to intive may also be recipients of personal data:

• LinkedIn Corporation

• Meta Platforms

• Salesforce

• Google

• Usercentrics

intive does not make automated decisions, including profiling, which would result in legal consequences for the users of the website or otherwise significantly affect the users of the influencing website. Notwithstanding the above, intive takes measures to analyze traffic on the website and to collect data about the users through the use of cookies as well as to collect data about the users of the website by means of cookies for other service providers. This profiling does not result in a decision that has legal effects or similarly affects data subjects.

None of our services is directed to children, i.e. to people under 16 years of age. 

Due to the international nature of our business, we may need to transfer your personal data within the intive group or in the context of the provision of services by service providers to third countries within the meaning of GDPR. Personal data may be transferred to third countries on the basis of Article 45 or 46 of the GDPR or when any of the exceptions provided for in Article 49(1) of the GDPR apply. In particular, data may be transferred to the United States of America and Ukraine, on the basis of standard contractual clauses and additional guarantees. Data may be transferred also to the Argentine Republic and United Kingdom (for which the European Commission has concluded an adequate level of protection of personal data). Information on the safeguards applied in the case of transfer of data to a third country and a copy of these safeguards can be obtained from the above mentioned e-mail addresses of the data protection officers or, in case of their absence, by contacting the above mentioned contact details.

Personal data may also be transferred from Argentina to another country, i.e. a country belonging to the European Union, the United States of America, the United Kingdom, or Ukraine. Argentina considers the following countries as providing adequate data protection standards to ensure the free flow of data within them: EU Member States, EEA Member States, Switzerland, Guernsey, Isle of Man, Faeroe Islands, Canada (for the public sector only), Andorra, New Zealand, Uruguay and Israel (for automated processing only) and the United Kingdom. For the transfer to the United States and Ukraine, it is carried out using appropriate safeguards, i.e. standard contractual clauses approved by the AIPP.

According to the GDPR we inform you that:

1. With respect to the contract between any third party and intive (hereinafter referred to as the “Contract”), the controller of the personal data of the party to the Contract or those party’s employees, co-workers and other representatives, designated to represent the party or perform on behalf of the party the Contract, is the Company with which the Contract was concluded, that is one of the companies listed in the section “Controller of personal data” of this Privacy Policy.

2. Some of the Companies have designated a data protection officer (DPO) who can be contacted in various ways described in the section “Controller of personal data” of this Privacy Policy.

3. The legal bases for the processing are:

a) Art. 6 (1) b of the GDPR – processing of personal data is necessary for the performance of the Contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into the Contract – for the purpose of performing the Contract,

b) art. 6 (1) c of the GDPR - processing is necessary for compliance with a legal obligation to which the Company is subject, i.a. keeping accounts and fulfilling accounting obligations, as well as examining the controller’s financial condition,

c) art. 6 (1) f of the GDPR - processing is necessary for the purposes of the legitimate interests pursued by the controller, where the legitimate interest of the controller is:

• conclusion and performance of the Contract, regarding persons designated to perform the Contract and persons representing the parties to the Contract, i.e., e.g. proxies,

• establishment, exercise or defence of legal claims,

• archiving documents (for the period resulting from legal provisions),

• processing personal data within the corporate group for internal administrative purposes, including keeping statistics and financial statements for Companies.

4. Personal data can be transmitted to external entities that support the controller, in particular: banks, courier and transport companies, external entities providing IT support, personal data protection, legal services, companies conducting internal controls/audits at the request of the controller, governmental authorities or other authorities on the basis of applicable law. In addition, the recipients of the personal data can be other Companies.

5. Data subjects due to the GDPR regulations have the rights described in the “Rights of data subjects” section of this Privacy Policy.

6. Providing personal data is necessary to conclude and perform the Contract, fulfil legal obligations, and perform tasks covered by the controller’s legitimate interest. Where personal data have not been obtained from the data subject, the data originate from the party that employs (or cooperates with) the data subject. In such situations, the controller processes the following data: name, surname, phone number, e-mail address, position, other contact details.

7. Personal data will be processed for the periods indicated below:

- for a duration of time covering the pursuit of a contract, i.e. initiating cooperation and agreeing on its terms, as well as the conclusion and subsequent execution of the contract

- for the Branch Office in Poland billing documents related to the transaction will be stored for 5 yearscounting from the end of the calendar year in which the tax payment deadline has passed; other accounting documents regulated by the provisions of the Tax Ordinance Act or the Accounting A–t - for the periods indicated therein; with respect to intive GmbH, intive automotive GmbH, intive S.A.U.,SimTLiX SRL and DevSpark S.A. accounting documents related to the transaction shall be kept for 10 years.

- the period of limitation for claims shall be 6 years for the branch in Poland, intive GmbH and intive automotive GmbH, for claims for periodical services and claims related to the conduct of business activity for the Branch in Poland – 3 years, and 6 years for intive GmbH, intive automotive GmbH, intive S.A.U., SimTLiX SRL and DevSpark S.A.

- with regard to recovery for the duration of the proceedings, until their final and binding conclusion and, in the case of enforcement proceedings, until the satisfaction of claims in those proceedings;

- in case where the basis for the processing of personal data is the legitimate interest pursued by the controller - until a reasoned objection or the time of expiry of the deadlines indicated above.

8. Personal data may be transferred to third countries pursuant to Article 45, art. 46, art. 49 par. 1 of the GDPR. In particular data may be transferred to the United States of America and Ukraine based on standard contractual clauses and additional guarantees and to the Republic of Argentina (according to the decision of European Commission this third country ensures an adequate level of protection). Information about the applied safeguards and a copy of these safeguards can be obtained at e-mail address of the data protection officer. Personal data may also be transferred from Argentina to another country, i.e. a country belonging to the European Union, or the United States of America or Ukraine. Argentina considers the following countries as providing adequate data protection standards to ensure the free flow of data within them: EU Member States, EEA Member States, Switzerland, Guernsey, Isle of Man, Faeroe Islands, Canada (for the public sector only), Andorra, New Zealand, Uruguay and Israel (for automated processing only), the United Kingdom. For the transfer to the United States and Ukraine, it is carried out using appropriate safeguards, i.e. standard contractual clauses approved by the AIPP.

9. Personal data will not be used for automated decision making, including profiling, which is described in Art. 22(1,4) of the GDPR.

intive continuously updates the applied technical and organizational measures, in particular in order to protect the processed data against unauthorized use or loss. Among the many types of security measures used to protect data security during transmission, we use state-of-the-art encryption techniques (such as SSL) via HTTPS.

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