Privacy Statement

Privacy Statement Platform and Website

sympl NV – Privacy Statement Platform and Website

Privacy Statement Platform and Website

This privacy statement (“Statement”) applies to the interactive recruitment platform (“Platform”) and the website www.gosympl.com (“Website”), owned and managed by:

sympl NV
Broederminstraat 36D 2018 Antwerpen
Belgium
Company registration number:
0644.814.329
hereinafter “sympl”, “we” or “us”

sympl highly values the protection of privacy and intends to inform and respect you – as the user of its Platform and Website – as much as possible by giving you control over what happens with your Personal Data and your privacy.

All capitalized names which are not defined in this Statement have the meaning as defined in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 regarding the protection of individuals in relation to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC (“General Data Protection Regulation” or “AVG” or “GDPR”).

Your Personal Data (“Personal Data”) and your privacy are protected by sympl in accordance with the Belgian and European regulations on the protection of privacy.

Please be advised to read this Statement very carefully. Below you will not only find your rights described, but also the way in which you can exercise these rights.

By using our Platform and our Website and communicating your Personal Data and agreeing to this Statement, you expressly agree on how sympl collects and processes your Personal Data as described in this Statement.

Who Processes your Personal Data?

sympl is responsible for the Processing of your Personal Data which you provide via the Platform or the Website.

sympl has appointed a data protection officer (Data Protection Officer or DPO) who always can be contacted for questions regarding your privacy and the Processing of your Personal Data:

sympl NV
Attn. Data Protection Officer
Broederminstraat 36D 2018 Antwerpen
Belgium
E-mail: mark@sympl.be 
Tel.: 03-294.73.59

Which information is collected and Processed?

sympl Processes different types of Personal Data, depending on the services you use on the Platform or on the Website. Personal data in this Statement has the same meaning as in the GDPR. The following Personal Data may be Processed by sympl:

• Information available on social media and Internet in general
  Personal data such as your name, email address, mobile phone number, address, date of birth etc.

• Contact details
  Personal data such as your name, email address, mobile phone number, address, date of birth, etc.

• Profession and/or education
  Personal data regarding all possible information related to (i) your current and previous professional occupation, such as information about previous employers, your skills, tasks performed, responsibilities, reasons for dismissal, salary and packages, etc. and (ii) academic experiences and education, such as information about your obtained degrees, timeline of your studies, results achieved, information about success rates, details about your studies, details about your degree, dismissals, etc.

• Personal details
  Personal data about your personal characteristics such as the images and sound recordings of the video interviews, written representations and reviews about conversations and/or video interviews, data which emerge from conversations and/or video interviews, answers during these conversations and video interviews, etc.

• Technical information
  Personal data such as data about computers, phones or other devices on which you use our Platform or our Website, IP address, browser type, location information

• History and logs
  Personal data such as data on search history on the Platform or on the Website, information about your surfing history, date and time the Platform or Website was visited, information about which of our emails you open, on which links in our e mails you click and when you do this, information about the time of chat sessions and the response time therein, etc.

• Cookies
  Visit our Cookie Policy

What is the purpose of this data usage and what is it based upon?

The purpose and basis of the Processing of your Personal Data mainly depends on the category of Personal Data involved. Below you will find an overview of the purpose and basis regarding the various Personal Data we Process.

• Information available on social media and the Internet in general
  Purpose: Your information available on social media (and the Internet in general) is collected to enable sympl to offer you the best possible and personalised service, for communication and marketing purposes, etc.
  Basis: Legitimate interest

• Contact details
  Purpose: Your contact details will be used by sympl for communication and marketing purposes, for personalised services (e.g. personalised emails, matching and targeting of your location and age with any of our job offers), etc.
  Basis: Implementation of the agreement and legitimate interest

• Profession and/or education
  Purpose: Your Personal Data about your profession and education are collected to enable sympl to provide its services such as assessment of a candidate, applying screening to find employment, matching your profile with possible job offers, and all other (personalised) services related to recruitment and for analysing, optimising and personalising our Platform or Website, for marketing purposes, etc.
  Basis: Implementation of the agreement and legitimate interest.

• Personal details
  Purpose: This data is collected to enable sympl to offer you a more personalised service through the Platform or the Website in the context of recruitment such as for example a more personal assessment of you as a candidate and matching with possible job offers, for your personal use of the Platform or the Website, etc.
  Basis: Implementation of the agreement and legitimate interest

• Technical information
  Purpose: Your technical information is collected to enable sympl to optimise its Platform and Website, to further match its Platform and Website to your personal use, to ensure a better user experience and all other ways to further improve its Platform and Website, for marketing purposes, etc.
  Basis: Legitimate interest

• History and logs
  Purpose: Your history and logs are collected to enable sympl to optimise its Platform and Website, to further match with your use, to ensure a better user experience and all other ways to improve its Platform and Website in the future for marketing purposes, to enable sympl to screen you for a job offer and for targeting.
  Basis: Legitimate interest.
  

The legitimate interest as a basis is justified with regard to technical information and history and logs as it is important for sympl to adjust and improve its Platform and Website based on this information and with regard to information collected on social media (and the internet in general) and personal details to be able to further personalise our service in the context of the implementation of the agreement. sympl Processing this information ultimately also benefits the users. In view of the data being collected, there is no possibility of a violation of the fundamental rights and/or fundamental freedom of the users at all.

Your given permission is always voluntarily, and you have the right to withdraw this permission at any time. However, such a revocation does not affect the Processing of Personal Data (i) prior to such revocation, (ii) based on any legitimate reason for Processing Personal Data (iii) in the legitimate interest of the Processing.

The Processing of the above Personal Data by sympl and other information given by you, including any sensitive personal information, is necessary in view of the implementation of the agreement between Parties. In the event that you refuse to provide this Personal Data, sympl will not be able to fulfill its obligations (i.e. making the Platform and/or the Website available and offering its services via the Platform and/or the Website) and you will not be able to use the Platform and/or the Website.

If you enter non-mandatory information as well on the Platform and/or the Website, sympl will also Process this Personal Data based on your granted permission to improve the use of the Platform and/or the Website.

The foregoing reasons may not be exhaustive and sympl is always entitled to Process your Personal Data for any other legitimate reason. In such cases sympl will inform you as soon as possible. An update of this Statement in accordance with Article 9 can thus constitute a notice.

Direct marketing and profiling

sympl will also use your Personal Data for direct marketing purposes, including profiling related to direct marketing. This enables sympl to keep you informed about its products, updates, events, etc. You give explicit permission for this, but you have the option to object at any time to the Processing of your Personal Data for such marketing purposes, including profiling related to direct marketing. Profiling will only occur within the context of services provided by sympl and in view of direct marketing (i.e. recruitment).

In relation to these direct marketing purposes, including profiling in view of direct marketing, you have the right to object, free of charge, by sending an email to privacy@sympl.be.

Receiving and sharing Personal Data

sympl receives certain Personal Data directly from you when:

• you interactively fill in a registration form or another contact form;

• you provide us with data through a chat session with our bot on our Platform or our Website.

• you take a video interview;

• you send us your details (e.g.: via your curriculum vitae);

• you fill in a contact form;

• you register and create an account;

• you use the Platform and/or the Website;

• via chat functions;

•  

• via cookies or when your browser sends certain data;

• ...

sympl receives certain Personal Information from third parties, for example:

• via references we receive from your (former) employers;

• through software suppliers;

• through social media;

• via the Internet in general.

sympl will always share your Personal Data in a minimal manner. However, in order to be able to respond to your question or action on the Platform and/or the Website, it will be sometimes necessary for sympl to share Personal Data with third parties. You therefore give your explicit permission to share your Personal Data as described in this Statement.

Processors and sub-processors of sympl act under the responsibility of sympl. If sympl appeals to Processors or sub-processors, this will always be actioned under a processing agreement which meets the requirements of the GDPR which will protect the Processing of your Personal Data as optimal as possible.

We may share your Personal Data with third parties to:

• introduce you to a potential employer;

• Store and Process your Personal Data;

• answer your questions on the Platform and/or the Website;

• Facilitate transactions on the Platform and/or the Website;

• send you content;

• Optimise the Platform and/or the Website

• …

sympl does not sell your Personal Data to commercial partners but shares your Personal Data to potential employers in the context of recruitment. For example, we send edited versions of video interviews to clients and potential clients of sympl (i.e. potential employers).

If you were referred to another website, platform or application via our Platform and/or the Website, please consider the conditions that apply to that website, platform or application.

Transfer of Personal Data to countries outside the EEA

In principle, sympl does not transfer your Personal Data to countries outside the EEA. However, it is possible that sympl – via its (sub) processors – does transfer your Personal Data to other countries within/outside the EEA. If there is less strict protection policy for Personal Data in a specific country compared with the EEA, sympl ensures that the same level of protection is achieved (e.g. by concluding an agreement on this with the processor located in a country outside the EEA).

Notwithstanding the foregoing, you expressly acknowledge that when indicating your interest in an international career (including job offers in countries outside the EEA), it will be necessary for sympl for the implementation of the agreement, to have the right to transfer your Personal Data to countries outside the EEA.

How is my Personal Data being stored?

sympl uses the following retention periods for your Personal Data:

• Information available on social media and the internet in general
  Retention of the personal data for four (4) years after its collection, or longer if and for so long as a legitimate interest for sympl is present.

• Contact details
  Retention of the Personal Data for four (4) years after its collection, or longer (i) if and as long as is necessary for the implementation of the agreement or (ii) if and for so long a legitimate interest for sympl is present.

• Profession and/or education
  Retention of this Personal Data for four (4) years after its collection, or longer (i) if and as long as is necessary for the implementation of the agreement or (ii) if and for so long a legitimate interest in sympl is present.

• Personal details:
  Retention of this Personal Data for up to four (4) years after its collection, or longer (i) submission as long as necessary for the implementation of the agreement, or (ii) if and for so long a legitimate interest in sympl is present.

• Technical information
  Retention of this Personal Data for a maximum of two (2) years from the creation of the technical information, or longer if and for so long a legitimate interest in sympl is present.

• History and logs
  Retention of this Personal Data for a maximum of two (2) years from the creation of the item or log, or longer if and for so long a legitimate interest in sympl is present.

sympl stores your Personal Data in its own databases and/or in the databases of its (sub) processors. A list of these (sub) processors can always be requested from sympl.

How is my Personal Data protected?

sympl has developed appropriate technical, organisational and protection measures and guarantees to Process your Personal Data in accordance with applicable Belgian and European regulations, and in particular, without being limited to, in order to protect your Personal Data against loss, misuse or unauthorised changes. sympl provides security for its back office, among other actions. sympl employs a team of technicians, automated systems and advanced technology in accordance with industry best practices to provide appropriate protection for your Personal Data. sympl ensures that all necessary efforts are taken to protect the confidentiality of your Personal Data.

Despite the aforementioned measures by sympl, you should be aware that there are always risks associated with sending Personal Data over the internet. The safety and protection of your Personal Data can never be fully guaranteed.

Under no circumstances can sympl be held responsible for any direct or indirect damage resulting from an incorrect use or unlawful use of the Personal Data by a third party.

What are my rights?

If and to the extent that the applicable Belgian and European regulations provide, you have the right:

1. to receive confirmation from sympl whether your Personal Data is being Processed and, where applicable, of access to the Personal Data which are being Processed;

2. on corrections being implied by sympl, without unnecessary delay, of inaccurate or incomplete Personal Data;

3. to have your Personal Data deleted by sympl;

4. to obtain your Personal Data and to transfer them to another Controller or Processor;

5. to obtain from sympl the limitation of Processing of your Personal Data, as far as this is possible;

6. to receive your Personal Data in a structured and for general use, machine-readable format, and to be mailed such Personal Data;

7. to oppose the Processing of your Personal Data and to oppose the use of your Personal Data for direct marketing purposes.

You can exercise these rights by sending your request to sympl NV, attn. Data Protection Officer, Broederminstraat 36D, 2018 Antwerpen, mark@sympl.be and 03-294.73.59, with a copy of the front of your identity card (the national register number should not be visible).

If and insofar as the applicable Belgian and European regulations provide, you have the right to file a complaint at the competent supervisory authority if the Processing of your Personal Data violates the applicable regulations. In Belgium the Data Protection Authority is https://www.gegevensbeschermingsautoriteit.be/.

Modifications to this Statement

sympl may modify this Statement at any time. You can find the date of the last modified version at the top of the Statement. Changes are published on the Platform and/or the Website, so that you are always informed on the information collected by sympl, as well as on how this information will be used and shared by sympl.

Modified versions of this Statement will take effect ten (10) days after their publication on the Platform and/or the Website and will be submitted for approval if necessary.

Permission to release

You acknowledge, confirm and expressly authorise sympl to disclose your Personal Data if legally required or if sympl judges in good faith that such disclosure is required to:

1. comply with an ongoing judicial investigation, court order or legal process regarding the Platform and/or the Website;

2. enforce the general terms and conditions of sympl;

3. respond to claims for damages against sympl following your Personal Information violating the rights of third parties;

4. safeguard the rights, property and safety of sympl, its employees, users and the public.

sympl may disclose your Personal Data to the competent police or judicial authorities or other official government agencies if sympl considers it necessary or useful in relation with an investigation of fraud, intellectual property infringement or any other harmful activity, or if sympl may reasonably suspect that such activity may expose sympl or yourself to liability.

Liability

sympl cannot be held liable if third parties unlawfully process or use your Personal Data if sympl legally provided this Personal Data to the third party concerned.

sympl cannot be held liable for direct or indirect damage resulting from the unlawful Processing or use of Personal Data by a third party.

sympl can in any case only held liable for damage caused by Processing if the obligations under the GDPR have not been met during the Processing. sympl can in no way be held liable for any special, incidental, indirect or consequential damage.

Applicable law and jurisdiction clause

This Statement is governed, interpreted and executed in accordance with Belgian law, which shall exclusively be applied to any dispute.

The courts of the Brussels jurisdiction, the Dutch-speaking section, have exclusive jurisdiction to rule on any dispute that may arise from the interpretation or implementation of this Statement, subject to the consumer’s right to submit a dispute to the competent court based on a mandatory legal provision.

Contact?

If you have any questions or comments about the Processing of your Personal Data by sympl, want to have your data removed, or have a complaint regarding the Processing of your Personal Data, please contact sympl NV, attn. Data Protection Officer, Broederminstraat 36D, 2018 Antwerpen, Belgium, mark@sympl.be and 03-294.73.59