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We take your privacy very seriously. We comply with the new General Data Protection Regulation (“GDPR”) which will replace the different privacy laws in European member states as per 25 May 2018. This legislation will hereinafter be referred to as the “Relevant Legislation”.
Personal Data refers to all the information that could allow you to be directly or indirectly identified. This definition is in accordance with the Relevant Legislation. This is a broad definition: even dynamic IP addresses are considered to be personal data in some circumstances.
We collect and process most personal data on behalf of our customers within the context of our Services. Our customers define the purpose and the means of such processing of personal data, which means they act as “Data Controller” within the meaning of the Relevant Legislation. We only process such personal data following the instructions of our customers and not for our own purposes. Within this context we therefore act as “Data Processor” within the meaning of the Relevant Legislation.
Apart from the processing of personal data for the sake of our customers, we also collect and process some personal data for our own purposes. Within this context we act as Data Controller ourselves within the meaning of the Relevant Legislation.
As Data Processor we collect and process the following personal data on behalf of our customers:
As Data Controller we collect and process the following personal data:
We process the personal data on behalf of our customers exclusively for the sake of transferring the data of a job applicant to the customer. This implies inter alia that we will never view these personal data for our own purposes or will store a copy for ourselves. Furthermore, we will also delete the personal data, as soon as our customers ask for this. These and other commitments have been laid down in the Data Processing Agreement we enter into with our customers.
We process the data of potential job applicants on behalf of our customers exclusively to provide our Services to them. This means, for example, that we can show the potential job applicants personalised advertisements (also known as ‘advertisements based on interests’ or ‘retargeting’) and to measure the conversion of an online campaign, by using trackers. We will delete the personal data as soon as our customers ask for this. These and other commitments have been laid down in the Data Processing Agreement [link] we enter into with our customers.
We use the personal data as Data Controller for the following purposes:
As Data Processor we store the personal data for our customers as long as the customer in question uses our Services and uses the personal data within such context. If the cooperation with the customer ends, then we will still store the data for 2 months. After this term we will remove or destroy the personal data and all their copies, save we are held by law to store the data for a longer period.
As Data Controller, we remove the personal data as soon as they are no longer necessary for the purposes stated above. In no event will the personal data be stored for more than five years following the date on which they have been changed for the last time. We keep the personal data of our own employees as long as required by the applicable laws.
As Data Processor, we process the personal data on behalf of our customers only according to their instructions. We will never share these personal data with someone else, save our customers order us to do so.
However, it is possible that we use the services of “Sub Data Processors” (by order of our customers), for instance for storing the data and monitoring recruitment campaigns. Within this context such Sub Data Processors will receive personal data. The Sub Data Processors must strictly follow our instructions and those of our customers regarding the processing of such personal data. Therefore, they will not use the personal data for their own purposes. We will ensure that all Sub Data Processors comply with the requirements of the Relevant Legislation.
The Sub Data Processors we may use as Data Processor, with the consent of our customers, are for instance: Amazon, Google, Dropbox and Exact Online. It is also possible that we use the services of Sub Data Processors for personalized advertisements (also known as ‘interest-based ads’ or ‘retargeting’). The Sub Data Processors we may use for this as Data Processor, with the consent of our customers, are for instance: Google, Facebook, Twitter and LinkedIn. These external providers can post your ads on sites on the internet.
We also use the services of Sub Data Processors for the personal data we process for our own purposes.
The The Sub Data Processors we may use as Data Controller are for instance: Amazon Web Services, MailChimp and Salesforce.
Apart from the above, we will not share your data with third parties – unless we are legally obliged to do so.
We may transfer personal data to parties outside the EU, if our customers ask for this or if one of our Sub Data Processors is established outside the EU. The personal data will only be transmitted to countries and/or parties offering an adequate level of protection which meets the European standards. We will check inter alia whether an organization outside the EU is listed in the Privacy Shield List and whether the level of protection of the third country has been approved by the European Commission.
If we use Sub Data Processors established outside the EU on behalf of our customers and the Sub Data Processor does not offer an adequate level of protection in accordance with the European standards, then we will record this in the agreements with our customer. De customer, being Data Controller, will ensure that the required permission is obtained from the data subjects for the use of these parties.
Transfer of data outside the EU will always be in accordance with the Relevant Legislation (such as Article 76(1) of the Dutch Data Protection Act – replaced as per 25 May 2018 by Chapter 5 of the GDPR).
We may convert your personal data in non-personal data. This means that the data will be fully and irreversibly anonymized and aggregated: in that case they do not include any personal data anymore, because no identification can take place on the basis of the data. We may share such aggregated data with business partners for analytical purposes, demographic profiling and improving our services.
We protect all the personal data we process from unauthorized or unlawful access, change, disclosure, use and destruction. We take the following technical and organizational measures to protect the data:
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If you have any questions, comments or concerns regarding the way in which we process your personal data, please contact us through the contact data below.
3012 KC Rotterdam
T: 010 737 15 21
KvK nummer: 57298890
BTW nummer: NL852521480