- categories of personal data that we collect and process in the context of the services we provide through our platform (accessible in Software-as-a-Service (SaaS) mode via our website), its sub-domains and directories (the " Platform "),
- the purposes for which we collect and process your personal data, and the legal basis on which we rely,
- how long we keep your personal data,
- whether we disclose your personal data to third parties,
- whether we transfer your data outside the European Union or to international organizations,
- the rights you may exercise with respect to your personal data or their processing, and
- the security measures we put in place to ensure the protection and confidentiality of your personal data.
Article 1 : General information
You also have the right to file a complaint with the competent data protection authority or to request further information from it. You will find all the information you need to do this in article 12 below. If you have any questions or remarks, or if you wish to lodge a complaint, we invite you to contact us first so that we can resolve any problems you may encounter.
Article 2: Personal data collected and processed
The information we collect and process about you may be different depending on the capacity you are in when you contact us. You can contact us...:
- as a mere visitor to the Platform or to any of the social networks on which we are active;
- when you create an account on our Platform as a Talent or Company.
Talent " means any natural person seeking employment opportunities with a Flexible Company.
By " Flexible Company " is meant any company that has a Flexibility Policy.
By " Flexibility Policy" is meant the policy implemented within Enterprises to ensure maximum flexibility at work, e.g. in terms of working hours, working place etc.
" Company" means any legal entity wishing to promote its Flexibility Policy and to recruit Talents as part of its recruitment activities.
Note that we may receive your personal data directly from you, either:
- via our Platform, for example when you create your account, when you log in, or when you chat with us via the chatbot included on each of the Platform's pages,
- by any other means related to information and communication technologies, including when you interact with us via email or telephone, or
- through any personal interaction we may have with you.
We may also receive your personal data from third parties, as described below in Article 6.
Below we set out in more detail the different categories of personal data that we collect and process about you.
- Basic contact and identification data
We collect basic identity-related data (such as your last name and first name), as well as contact data such as your e-mail address and telephone number.
We may also collect demographic information such as your mailing address (but only on a voluntary basis, i.e., if you wish to provide us with such information), as well as information about certain preferences and interests you may have.
Specifically, as a Talent, we collect your first and last name, phone number and email address. As a Company, we collect the identifying information of the legal entity, i.e. its name, e-mail address and telephone number, as well as the first and last name of the contact person.
- Account/Profile Data on the Platform
To use our Platform, you must first create a free account or login to our Platform. We collect a set of information related to the account you create and to your profile.
We also collect data specific to our services, i.e. any information that you communicate to us and that we collect as part of the services that we offer via the Platform.
If you are a Talent, this data may include (this list is illustrative and by no means exhaustive):
- the contact data listed under A; see above;
- your social network profiles, if any, in particular the information included in your LinkedIn profile;
- the recruitment information you provide in the context of the services we offer via our Platform, including your academic background, the job you currently hold and your function, an estimate of your current salary and salary aspirations, your professional experience, demographic information (always on a voluntary basis), information relating to your psychological profile that is revealed at the end of the psychometric tests carried out on the Platform (e.g., your professional aspirations, your management style (leadership), etc.);
- any other information that may be useful in the context of the services we offer via our Platform.
Please note that the above-mentioned data that you share as a Talent in the context of your use of our Platform are only shared in the event of a "match" of your Talent profile with the matching criteria of the Company(ies) concerned and subject to your validation of the match. This data is therefore not shared with the Companies in the event that your Talent profile does not correspond ("match") with the matching criteria of this Company and without prior validation on your part. In any event, this data is not shared with the other categories of third parties listed in Article 6 below.
If you are a Company, this data may include (this list is illustrative and not exhaustive):
- the contact data listed under A; see above;
- your profiles on social networks, in particular the information made public on the Company’s LinkedIn profile
- the name, first name and function of the contact person within the Company;
- information relating to your Company (legal status, ECB number, ...) and the services you provide as a Company;
- the information you provide as part of the services we offer via our Platform. It is possible that your Company provides, on this occasion, data such as turnover or size of the Company, but also information relating to the gender balance or age groups within the Company;
- information necessary for the billing of the services provided;
- any other information that may be useful in the context of the services we offer via our Platform.
- Financial Data
If you create an account as a Company on the Platform, we collect a set of financial information (e.g., your bank account information, as well as the transaction information listed in point B., above) necessary to bill you for our services. We also need to collect this information to comply with applicable law (including anti-fraud laws).
- Compliance Data
As a Company, you are sometimes bound by legal and/or ethical obligations specific to your profession. When you wish to create an account on our Platform, we may ask you to communicate certain data to us (for example, financial or accounting data).
If you refuse to provide us with this information, we may refuse to create your account on the Platform. If you are asked for this information after you have registered on the Platform, refusal to provide this information may result in the deletion of your account on the Platform. We will clearly inform you of the importance of this information if and when we ask you to provide it.
- Technical and Usage Data
We also collect usage data such as the pages you visit on our Platform or other actions related to your use of the Platform.
- Sensitive Data
No sensitive data (e.g. data relating to health status, sexual, political, trade union or religious affiliation, etc.) is collected or processed by us in connection with the services we offer via our Platform. However, there may be situations in which we collect such data without having been able to anticipate it. This would be the case, for example, if you transmit sensitive data to us when you communicate with us via the chatbot.
In these circumstances, we take great care to treat such data with caution and put in place appropriate mechanisms to limit the risks of infringement of your rights and freedoms with regard to the protection of personal data.
Article 3: Collection of personal data
We use a variety of methods to collect your personal data. Personal data is collected both in an online and offline environment. This data may be collected when you visit our Platform as a visitor, when you use our Platform as a Talent or Company, when you send us an e-mail or contact us by phone, but also, for example, when you give us your business card.
You may provide us with your personal data directly, as well as we may obtain it from third party sources (see below, section 6). We may also receive and collect personal data from public sources, such as public registers for individuals and public registers for companies (e.g., the Crossroads Bank of Enterprises).
Article 4: Personal Data Processing
Below, we explain the specific purposes for which your personal data is collected and processed, the manner in which it is processed and the legal basis for processing your personal data.
We may collect and process personal data about you when you interact with us, whether or not our communications are related to the services we offer on our Platform. This personal data includes all contact and basic identification data, which may be necessary for the proper exchange of information.
We may interact with you by postal mail, e-mail, telephone, via our social networks, or any other means of communication or telecommunication technology available to you. Our interactions may also occur directly on the Platform, or when you create an account on the Platform or register for an event we are hosting.
The processing in this section also includes interactions in an offline environment. For example, we will process information such as personal data on a business card given to us.
For the collection and processing of your personal data in relation to our interactions, we rely on our legitimate interest in providing you with the best possible interactions, among other things, in the context of the services we offer, by responding to your requests in a timely manner.
- Provision of Services via the Platform
When providing our services through the Platform, we collect a range of information. The information collected allows us, among other things, to improve or customize our services based on your preferences or profile information. This information may include contact and basic identification data, data related to your account/profile on the Platform, as well as financial and compliance data.
The personal data collected and processed will vary depending on whether you access and use our Platform as a visitor or as a Talent or Company. We may also collect such data in connection with our chatbot support.
For example, we may collect and process a range of information about you :
- as a Company, to offer you Talent profiles that comply with the matching criteria you have previously filled in on your profile;
- as a Talent, to match your profile to the matching criteria of the Companies, to notify you in case of a match with a Company, to notify you when a Company wishes to contact you, etc.
You are free not to share the Personal Data required to provide our services. Please note, however, that this choice may affect your access to and use of the Platform, and may in some circumstances result in your inability to create an account on the Platform and/or to access our services.
We collect and process personal data from Businesses in connection with the provision of services via the Platform on the basis of the performance of the contract you enter into with us when you access and use the Platform.
For the collection and processing of personal data of Talents in the context of the provision of services via the Platform, we will in principle ask for your consent explicitly. If we consider that the request for consent is not appropriate to your particular situation, we will rely on the performance of the contract you enter into with us when you access and use the Platform.
In general, where particular categories of information are processed for the provision of services via the Platform, we will normally seek your explicit consent. If we consider that the request for consent is not appropriate to your particular situation, we will rely on our right to process such personal data for the purpose of establishing, exercising or defending a right.
- Marketing Communications and Promotional Messages
We may use your personal data, such as contact and basic identification data, as well as account/profile data on the Platform, to send you commercial communications related to the services we offer, promotional messages, etc.
For the collection and processing of your personal data in connection with commercial communications and promotional messages, we rely on your consent to receive such communications and messages.
As a Talent or Company, we may send you marketing communications based on the services provided via the Platform. This is based on our legitimate interest in keeping you informed about the services we provide and their improvements, as well as the evolution of our activities and services.When you receive marketing communications and promotional messages from us, either on the basis of your consent or on the basis of our legitimate interest, you retain the right to remove yourself from our mailing list at any time by sending us an e-mail to firstname.lastname@example.org by clicking on the unsubscribe button at the bottom of a specific marketing communication or promotional message
- Compliance and Enforcement
We use your contact and basic identification data, compliance data specific to your legal and/or ethical obligations, and technical and usage data for our own compliance with legal and regulatory obligations imposed on us. These obligations include, but are not limited to, any tax obligations with which we are required to comply.
Please note that we may collect this information from you or from third parties, such as official bodies in charge of these documents, on the basis of their competence or your instructions. In particular, we may collect and process personal data about you by accessing online registers (such as the Crossroads Bank for Enterprises) or after requests to do so from official governmental authorities and registers.
We may process your personal data under this section to establish legal, administrative or judicial claims or defences.
When collecting and processing your personal data to comply with specific legal or regulatory obligations, we base our decision on the need to comply with the legal obligations to which we are subject..
When we process personal data for the purpose of establishing or enforcing our own claims or defences, we rely on our legitimate interest in protecting our business, financial and legal interests as permitted by law
- Overview and analysis of Platform users
For the collection and processing of your personal data for the purpose of knowledge and analysis of the users of our Platform, we rely on our legitimate interest to use your personal data for the continuous improvement of the services we offer via the Platform, in order to provide you with the best possible experience, including on our Platform and on our social networking pages.
- Security and IT management
In collecting and processing your personal data for the purpose of securing and ensuring the efficient operation of our online environments, we rely on our legitimate interest à monitor how our Platform is used and to detect and prevent fraudulent behaviour, criminal activity and general abuse of our services.
Article 5: Duration of storage of personal data
It is our policy to retain your personal data only for as long as is necessary to fulfil the purposes for which we collected it or for which you provided it to us. Where processing is based on your consent, we will process personal data for as long as you have not withdrawn your consent.
In the following, we seek to provide you with the tools necessary to enable you to assess how long we may retain your personal data.
In general, we will de-identify or delete any personal data that is no longer considered necessary for the purposes described above or when the retention period described below is exceeded. This deletion will be done without further notice or liability on our part. However, your personal data will never be de-identified or deleted where we are required to retain it by a legal, administrative or judicial obligation. Such an obligation would prohibit or prevent us from effectively deleting your personal data. However, such data will only be retained for the purpose of complying with that obligation and will not be further processed for other purposes.
We distinguish between the following retention periods:
- All contact and basic identification data will be retained and stored for as long as it isneeded for the purposes of our communications with you and for building up a history ofour past communications. The storage of this information is particularly important for ourfuture interactions, as it allows us to refer back to past communications should you sendus new questions, requests, comments or the like;
- All Financial Data and les Compliance Data will be retained for the duration of thecontractual relationship we have with you (e.g., as long as you have an account on ourPlatform) as well as for a period of one (1) year following the end of the contractual relationship, or for the statute of limitations imposed by applicable laws and regulations,with a maximum retention period of ten (10) years following the end of the contractualrelationship;;
- As a Talent, your account/profile data on the Platform will be retained for the duration ofthe contractual relationship we have with you (e.g., as long as you have an account onour Platform). After this period, all your data will be automatically deleted;
- As a Company, your account/profile data on the Platform will be kept for the duration ofthe contractual relationship we have with you (e.g. as long as you have an account onour Platform) as well as for a period of one (1) month after the end of the contractual relationship;
- Technical and usage data is kept for a period of three (3) months after its initialcollection. After this period, it will be de-identified or deleted
Article 6: Sharing of personal data
In order to provide our services to you and to make our Platform and social networking pages available to you, we may share your personal data with third party processors and/or other data controllers.
We have identified below the main categories of third party recipients with whom your personaldata may be shared. Where applicable, we also provide you with links to the privacy policies ofthese various third parties:
- As a Talent, we share your data in case of a match of your Talent profile with thematching criteria of the relevant Company(ies) and only after you have validated thematch. In other words, even if your Talent profile matches the matching criteria of aCompany, this data is only shared with the Company(ies) concerned after validation ofthe match. In any case, this data is not shared with any of the third parties listed below.
- Third party service providers who help us to better understand and analyze ourcustomers, such as Google Analytics and HubSpot;
- Third-party service providers that help us to promote ourselves to our customers, suchas Google Ads and Facebook Ads;
- Third party service providers that allow us to connect with Users, such as Crisp Chat;
- Remarketing and behavioral targeting services that allow us to distribute, optimize andpresent advertisements based on the use of the Platform, such as FacebookRemarketing Services;
- Third parties to whom we outsource certain services such as, but not limited to,computer system or software vendors, computer support service providers andinformation storage service providers;
- Third-party hosting and backend service providers, such as Amazon Web Services, Microsoft Azure and OVH;
- Third party providers of traffic optimisation and distribution services;
- Third-party postal or courier service providers who help us send you our postalmarketing campaigns or deliver materials related to our services;
Some of the above-mentioned third parties act as data processors on our instructions, while others should be considered as processors of your personal data. Our data processors include computer system or software providers, IT support service providers, information storage service providers, who will process your personal data on our behalf and in accordance with our instructions. We have put in place the necessary documentation and security measures to ensure that your personal data is processed securely by our contractors.
ARTICLE 7 : INTERNATIONAL DATA TRANSFERS
Our offices are located in Belgium and France. Your personal data will normally be processed in these two territories. However, for the purposes set out in Article 4, we may need to transfer personal data to other jurisdictions outside the European Economic Area (EEA), and therefore not bound by the GDPR. Your data may also be hosted on servers outside the EEA.
When we transfer your personal data to third parties residing in these jurisdictions, we implement appropriate safeguards in our agreement with these third parties to provide your personal data with an adequate level of data protection and at least equivalent to the level to which you are entitled under the GDPR. To this end, we assess the level of data protection in the country of transit or destination, taking into account, among other things, relevant decisions made by the European Commission. We may use the Standard Contractual Clauses adopted by the European Commission and any other appropriate solution, as required or permitted by the Applicable Data Protection Legislation.
If you have any questions about international transfers of your personal data and the safeguards we have put in place, please contact us using the contact details in section 11 below.
ARTICLE 8 : YOUR DATA PROTECTION RIGHTS
Under the Applicable Data Protection Legislation, you have certain rights with respect to your personal data that we collect and process.
If you would like more information about your rights as listed below or if you wish to exercise them, please feel free to send us an email to email@example.com. When exercising your data protection rights, we simply ask that you identify yourself correctly so that we can respond to your request within the time limits indicated below.
The exercise of your rights is free of charge and will be carried out within one (1) month from the receipt of your request. We may extend this period by two (2) additional months for a total of three (3) months if your request is particularly complex. If we decide to extend the initial deadline, we will inform you of this decision in a timely manner.
In cases where we believe that your request is manifestly unfounded or excessive, we reserve the right to charge you an administrative fee for fulfilling your request or to refuse to fulfill your request. You will be informed of our decision within the above-mentioned timeframe
Below is a brief overview of the rights you can exercise in relation to your personal data:
- Withdrawal of consent: you have the right to withdraw your consent for all processingactivities that are subject to it;
- Right of access: you have the right to request a copy of the data we process and storeabout you, in a comprehensible format;
- Right of rectification: you have the right to ask us to correct, modify or complete your personal data;
- Right to erasure: you have the right to request the deletion of the personal data weprocess or store about you;
- Right to restrict processing: in certain circumstances, you have the right to request us torestrict the processing of your personal data. By exercising this right, the relevantpersonal data will remain in our possession, but we will not be able to process it further;
- Right to object to processing: where we process and collect your personal data on the basis of our legitimate interest, you have the right to object to the processing of that data;
- Right to portability of your data: this implies that Jobgether can, at the request of the data subject, provide him/her with his/her personal data and/or supply it to third parties in a structured and machine-readable form.
Article 9: Security of your personal data
We use generally accepted and reasonable technical and organisational methods, consistent with current technological developments in operational security, to provide protection against the loss, misuse, alteration or destruction of any personal data we store and process.
Our technical and organisational measures are frequently updated in order to adapt these measures to new technical and organisational procedures and to guarantee the permanent security of your personal data.
Our Platform and social media accounts may contain links to other websites or Internet resources (collectively, " Third Party Sites "), which may also collect personal data, including through cookies or other technologies. We are not responsible for or control these Third Party Sites or their collection, use or disclosure of your personal information. We encourage you to review the privacy policies of these Third Party Sites to understand how they collect and process your personal data.
ARTICLE 11 : QUESTIONS AND REQUESTS
You agree to provide us with accurate personal data. You can change your personal data at any time by sending us an e-mail to firstname.lastname@example.org. We cannot be held responsible for any failure of our services due to incorrect information provided by you.
ARTICLE 12 : DISPUTE RESOLUTION
You have the right to file a complaint with the competent data protection authority, namely theauthority of the Member State of your habitual residence, your place of work or the place of thealleged breach of the Applicable Data Protection Legislation.
The main data protection authority is the Belgian Data Protection Authority(ou Gegevensbeschermingsautoriteit), which can be reached by the following means ofcommunication:
- By following the instructions and filling in the form accessible via this link;
- By sending a letter to the following address: rue de la presse 35, 1000 Brussels,Belgium;
- By calling the following telephone number: +32 (0)2 274 48 00
- By sending an email to the following address email@example.com.