Privacy Policy

1. general information.

We would like to inform you that in practice we apply Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016. on the protection of individuals with regard to the processing of personal data and on the free movement of such data and the repeal of Directive 95/46/EC (hereinafter: RODO). As a Company dedicated to maintaining high standards in the protection of personal data of our Customers, Contractors and Users of our service, we provide below important information regarding the processing of your personal data, of which we are the Administrator.

Taking care of the security of the personal data entrusted to us, internal procedures have been developed and implemented to prevent the release of data to unauthorized persons. This documentation is periodically reviewed for compliance with the RODO, as well as other legislation.

2 Who is the Administrator of your data?

3. where was the data obtained from?

The data of which we are the administrator was obtained directly from you, through the contact form on , provided during a telephone conversation or email correspondence in the recruitment process (Job Candidates), provided in the process of offering / negotiating contracts for the provision of services offered by us (Clients / Contractors), as well as in the process of selecting / establishing cooperation with Entities providing services to STALWART MANACUS.

4 To what extent STALWART MANACUS processes data

Depending on the purpose for which they were obtained, your personal data as:

a. Data of Service Users / Job Candidates (in connection with the recruitment service provided by Stalwart Manacus): Personal data will be processed to the extent that voluntarily the data subjects provide us with their data.

This may include the following categories of personal data: name, place of residence, province, telephone, e-mail, gender, date of birth (year, month, day), image, amount of current earnings, financial expectations, education.

Additional information included in the resume forms, such as:

  • SCHOOLS – name of school / start date and graduation date,
  • EXPERIENCE – place of work / start date and end date, – position, – responsibilities,
  • EMPLOYMENT – industry, – place of structure,
  • LANGUAGE KNOWLEDGE – language, – level: basic / intermediate / advanced,
  • COURSES AND TRAININGS Course / training – knowledge of programs, – program.

b. Data of Customers / Contractors / Suppliers of services performed for STALWART MANACUS will be processed in the scope of identification data, contact details, company name, NIP, REGON, PESEL, bank account number, identification data of your designated employees / representatives, billing history, data concerning the concluded agreement and history of performed services. Provision of data is voluntary, but necessary for the conclusion of the contract and implementation of cooperation between the Administrator and the Provider / Recipient of the service.

5 For what purpose will your personal data be processed?

Your personal data will be processed for:

a. Implementation of services in the field of HR, including HR consulting, Assessment Centre, Development Centre, recruitment service for Candidates and Clients, i.e. Supporting Candidates in finding a job by providing their personal data to potential employers and implementing recruitment projects for Stalwart Manacus Clients),
b. Implementation of training, auditing and consulting services,
c. transfer of commercial information concerning the activities of Stalwart Manacus,
d. conducting correspondence,
e. Presentation of the offer of services provided by STALWART MANACUS,
f. to take action to conclude an agreement,
g. implementation of the contract,
h. marketing of products and services offered by the Administrator,
i. accounting services (e.g., billing for services rendered may involve the processing of personal data, etc.),
j. establish, assert and defend against potential business claims or damages,
k. complaint handling,
l. conducting statistical analysis,
m. storage for archival (evidentiary) purposes, in order to secure information in case of legal need to prove facts,
n. other activities for which your, voluntary consent will be obtained.

6 On what basis will we process your personal data?

Your personal data, depending on the purpose for which it was obtained, will be processed on the basis of Art. 6 paragraph. 1 lit. a) b) (c) and (f) of the General Data Protection Regulation of April 27, 2016 (RODO):

(a) Art. 6 paragraph. 1(a) RODO, i.e.. activities for which your voluntary consent has been obtained, such as consent for recruitment or acceptance of Cookies on the website

If you respond to an advertisement for active recruitment, Stalwart Manacus assumes that the basis for the processing of the data contained in the application you send is the candidate’s consent, which is manifested by an action such as sending Stalwart Manacus application documents containing your personal data. Consent obtained in this way does not apply to future recruitment, for which the Candidate must actively give consent, which we record in the system.

(b) Art. 6 paragraph. 1(b) RODO, i.e.. processing is necessary for the preparation and execution of the contract of cooperation with STALWART MANACUS.

(c) Art. 6 paragraph. 1(c) RODO – i.e.. processing is necessary for the fulfillment of obligations incumbent on the Company, such as keeping financial accounts, including tax accounts.

(d) Art. 6 paragraph. 1(f) RODO – i.e.. processing is necessary for the realization of purposes arising from the legitimate interests of STALWART MANACUS, such as:

  • handling correspondence,
  • complaint handling,
  • the possible need to establish, assert possible civil law claims, damages and defend against such claims,
  • conducting statistical analysis,
  • storage for archival (evidentiary) purposes, to safeguard information in case of legal need to prove facts.

7 Rights of data subjects.

As the Controller of your personal data, STALWART MANACUS provides you with the right to:

  • Request from the Administrator to access, rectify, erase or restrict the processing of your personal data,
  • to object to the processing,
  • data portability,
  • lodge a complaint with a supervisory authority (i.e. the President of the Office for Personal Data Protection) if you believe that the processing of personal data concerning you violates the provisions of the RODO,
  • if the processing is carried out on the basis of your consent, the Administrator provides the right to withdraw consent to the processing of personal data for a specific purpose. Withdrawal of consent does not affect the lawfulness of processing that took place before the withdrawal of consent.

8 How long will we process your personal data?

  • Personal data processed on the basis of a contract, will be processed for the period necessary for the execution of the contract, and after its termination for the period required by law.
  • Personal data may also be processed after the purpose for which it was obtained has been fulfilled, if there is a legal basis for further processing, for example:
    • processing is necessary for the fulfillment of a legal obligation incumbent on the Administrator – e.g., processing of data for bookkeeping purposes, which is based on accounting regulations,
    • processing is necessary for the purposes of legitimate interests pursued by the Administrator – e.g., for the purpose of establishing, asserting or defending business claims,
  • Personal data processed on the basis of consent will be processed until it is revoked.

9. Do we process data automatically?

Your personal data will be processed in computer systems. This may result in automatic processing of personal data.

10. To whom may we share your personal information?

Personal data may be transferred mainly to external entities providing and supporting Stalwart Manacus ICT systems to providers of legal, consulting, insurance, auditing or accounting services, etc. These entities will process your data only on our behalf, based on the necessary data processing entrustment agreements, and with these entities providing adequate measures to protect your data. Recipients of your personal data can only be institutions authorized by law (e.g., police, prosecutor’s office, court, etc.). We do not transfer your data outside the European Union.

11. How to contact us about the processing of your personal data?

12. Use of cookies and similar technologies

We may use the following types of cookies on the website:

  • “necessary” cookies to enable the use of services available on the website, such as authentication cookies used for services that require authentication on the website,
  • cookies that allow collecting information about the use of the website’s pages,
  • “functional” cookies, which allow “remembering” the user’s selected settings and personalizing the user’s interface, e.g. with regard to the user’s chosen language or region of origin, font size, website design, etc,

The following cookie technologies may be used on our site:

Google Analytics – this tool provides the creation of statistics and their analysis in order to optimize our websites, the data collected prevents the identification of a specific person. More information about the tool is available at the following link: In addition, using the following link: you can disable activities measured by Google Analytics.

Facebook Pixel – an analytics tool that helps measure the effectiveness of ads based on analysis of users’ actions on the site. Information on. you can find advertising preference settings at the following link:

Social tools – our website uses plug-ins, buttons and other social tools, collectively referred to as “plug-ins”, provided by social networks such as Facebook, LinkedIn. When you view our website containing a plug-in of a particular social network, your browser sends information about your visit to the administrator of that social network. The plug-ins collect certain information about you, such as your user ID, the site you visited, the date and time, and other browser information. For details related to the processing by social networks of information collected by plug-ins, please refer to the privacy policies of individual service providers:

– Instagram –,

– Facebook –,

– LinkedIn – ,

It is possible to independently disable or configure Cookies in your browser of the option to notify you of receiving cookies – then you will not receive cookies from our site or the cookies will be collected to the extent you prefer. How to do it in practice? You can find many guides to cookie management on the Internet. Below are instructions for the most popular browsers:, for example.

1. chrome:

2. Firefox:,

3. Internet Explorer:,

4 Opera:,

5. Safari:

You can also use our site in a mode that blocks the collection of data about your visit, the so-called “visit mode”. incognito mode. Using our website without changing your browser settings, i.e., accepting cookies and the technologies used by default, implies your consent to their use as specified in this Policy

13 Final Information.

Links to other websites may appear on Such websites operate independently of the Service and are not supervised in any way by the Service. These sites may have their own privacy policies and regulations, with which we recommend that you familiarize yourself.

STALWART MANACUS reserves the right to make changes to the privacy policy of the website, which may be affected by the development of Internet technology, possible changes in the law on the protection of personal data and the development of our website. We will inform about any changes in a visible and understandable way.