Privacy statement
Version 1.0 – 01/09/2023
The protection of your personal data is important to us. This privacy statement sets out how we process your personal data.
In a world that's always changing with new technology, we might need to update this privacy statement every now and then. We invite you to visit this webpage regularly, to remain up to date on how we process personal data.
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1. Who are we?
We are Prosatt BV, with registered office at Excelsiorlaan 43, 1930 Zaventem and with company number 0805.337.847. We are the data controller when we process the personal data for our own purposes. This is the case, for example, when we process data about our website users and (potential) customers or team members.
We comply with the regulations applicable to data protection such as European Regulation 2016/679 (the General Data Protection Regulation or “GDPR”) and the Belgian Data Protection Act.
On any matters related to your personal data, you can reach us at privacy@prosatt.be.
2. Processing of personal data: key information
2.1 In this section, we explain why we process your personal data, which categories of personal data we process, how we obtain the data, on which legal basis we process them and how long we keep them.
- We only process your personal data with a specific purpose in mind (why).
- Depending on this purpose, we collect and process different categories of data (which). We may collect, among other things, (a) identification data (your name, address, date and place of birth, picture, phone number, e-mail address or IP address), (b) career data (CV, LinkedIn profile, references) and (c) financial data (salary, bank account number).
- We inform you on how we obtain the data. We usually receive the information from yourself, when you submit it to us through our website, by e-mail or otherwise. We may also obtain information from other sources, such as your LinkedIn profile or a recruiting company. In this case, we will inform you thereof in all transparency. We will do so as soon as possible, and in any event within one month.
- For each processing, we make sure that a specific legal basis applies. There is a legal basis, among other things, if you have given consent, if the processing is done as part of taking pre-contractual or contractual steps, if we process to comply with a legal obligation, or if the processing is necessary for purposes of our legitimate interests.
- Finally, we also inform you how long we will keep your data.
2.2 We collect your personal data for the following specific purposes:
Why do we process personal data? | Which data do we collect for this purpose? | How do we obtain the data? | On which legal basis do we collect the data? | How long do we keep the data? |
To process your job application | Identification data Career data | From yourself, when you submit your job application through our website or by mail or e-mail | Pre-contractual steps Legal obligation | If we decide not to work together: until six months after your application. We may need to retain certain data for longer in order to comply with specific legal obligations. |
To manage our collaboration (if we decide to work together after your application) | Identification data Career data Financial data | From yourself | Performing a contract Legal obligation | As long as necessary to comply with specific legal obligations, or to defend ourselves in any disputes after the end of our collaboration. |
To present you with the most interesting job opportunities (1) | Identification data Career data | From yourself, when you submit your job application to us. | Our legitimate interest as a service provider who seeks to match the best opportunities with the best talents | Until 18 months after your application, or when you object to us processing your data in this way (see section 6 below about your rights). |
To send you our newsletter | Identification data (email address) | From yourself, when you subscribe to our newsletter | Your consent | Until you withdraw your consent |
Direct marketing | Identification data
| From yourself, when you register on our website | Our legitimate interest as a commercial company | Until the time that you object to us processing your data in this way (see section 6 below about your rights). |
To manage our relationship with you as a customer | Identification data Position | From yourself, during the course of our commercial relationship | Part of taking contractual steps (i.e. processing is necessary for the execution of the agreement) | Ten years after the termination of our commercial relationship |
(1) For clarity: if you apply with us and we do not immediately have a job opportunity for you, we want to retain your profile for other interesting job opportunities. We encourage you to give us additional relevant information about yourself, even after your application process has been completed, so that we can present you with the best possible job opportunities, based on accurate and up-to-date information. For the same reason, we may also retain information that you provide publicly (e.g. through updates of your LinkedIn profile). You have the right to object to us processing your personal data in this way, by sending an e-mail to privacy@prosatt.be.
3. How do we protect your personal data?
We make every effort to guarantee the security of your data. We have implemented reasonable technical and organisational measures to guarantee your personal data against accidental or unlawful destruction, loss, modification, unauthorised disclosure and/or unauthorised access. Please note that the internet is an open network; we cannot 100% guarantee that unauthorised third parties will not be able to circumvent these measures or use your personal data for inappropriate purposes.
4. Do we transfer your data to third parties?
4.1 First of all, we never sell or lease your personal data to third parties.
4.2 However, we may share your personal data with affiliated companies. We may also share your personal data with third parties that assist us with our products and services, such as cloud hosting service providers. These third parties have access to your personal data but only when this is required to perform their activities; they may not use your data for any other purposes. We have signed data processing agreements with them. We may publish your personal data to enforce our policy, to comply with our legal obligations or in the interest of safety, in the public interest or for the purposes of legal enforcement. We may follow up a request from a law enforcement agency, regulatory authority or government agency. We may also publish data for the purposes of current or scheduled court cases or to protect our property, safety, people or other rights and interests.
4.3 If you apply with us for a job opportunity, we will only disclose your personal data to dedicated members of our HR team and to managers or team members of our relevant departments. If your job involves working directly for our customer, we may also disclose your personal data to the customer. If we do so, we will only disclose personal data that are relevant for the customer’s assessment of your application and only with your consent.
5. Do we transfer your personal data outside the European Economic Area?
We may transfer your personal data to third parties in third countries (outside the European Economic Area (EEA)). Such a transfer is allowed if the recipient of the data resides in a country with a level of protection deemed adequate by the European Commission. Some of these countries may not have enacted equivalent data protection legislation to protect the use of your personal data. In such cases, we have researched whether appropriate preventive measures similar to those implemented within the EU are possible, for example by adopting standard contractual clauses. In specific cases, we will request your prior consent to the transfer of your personal data outside the EEA. Please follow the procedure set out in Rights of the data subject for further information on data transfer.
6. What are your rights and how can you exercise them?
In this section, we set out the rights that you have as a data subject. If you want to exercise these rights, please contact us at privacy@prosatt.be. When you do so, we may ask you verify your identity to ensure that your request is lawful, and that we are sending the reply to a person who has the right to make such a request. Under specific circumstances, we may be legally entitled to deny your request.
6.1 Right of access/inspection. You have the right to ask us whether we process your personal data. If we do, you have the right to access and inspect your personal data.
6.2 Right to rectification. If the personal data we hold on you are incomplete or incorrect, you have the right to ask us to rectify them.
6.3 Right to be forgotten. In certain circumstances, you have the right to ask us to erase your personal data. This is the case, among other things, if the processing is no longer necessary (taking into account the initial purpose for the processing). This is also the case if you withdraw your consent for the processing (if the legal basis for the processing was your consent) or if you object to the processing (if the legal basis for the processing was our legitimate interest). This is also the case if despite our best efforts, we somehow would have processed your data unlawfully.
6.4 Right to restriction of processing. In certain circumstances, you have the right to ask that we limit the processing of your personal data.
6.5 Right to data portability. You have the right to receive your personal data in a structured, standard and machine-readable format. You can request that we transfer your personal data directly to another data controller. You have this right only if the processing is based on your consent and occurs via an automated procedure.
6.6 Right to object. If we process your personal data on the basis of our legitimate interest, you have the right to object on the basis of your specific situation. We will then no longer process your personal data unless we would have compelling legitimate grounds for the processing which outweigh your interests, or unless we would have to pursue or defend legal claims. If we process your personal data for direct marketing purposes (including profiling), you have the right to object to the processing at any time.
6.7 Automated individual decision-making. You have the right not to be subject to any significant decision based solely on automated processing, including profiling, unless the processing is allowed on the basis of a mandatory legal provision. There are exceptions to this right, for example when the decision is required in the context of an agreement between us, or if the decision is based on your explicit consent of the data subject.
6.8 Right to withdraw consent. If you have given your consent to the processing of your personal data for a specific purpose, you can always withdraw your consent. If you opted in to receiving our newsletter from us, you can unsubscribe if you change your mind.