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Privacy Policy

Last updated: 07-06-2024

Privacy Policy for LusoDutch Employer Branding and Recruitment

Publication date: 07-06-2024

At LusoDutch, we manage our employer branding and recruitment process through our career site (the "Career Site") and using a related candidate tracking system.

In this privacy policy, we explain how we process your personal data if you:

  • Visit our Career Site (as a "Visitor")
  • Connect with us through our Career Site, to create a profile with us and receive information about current or future vacancies with us (as a "Connecting Candidate")
  • Apply for a position with us, through our Career Site or a third-party service (as an "Applying Candidate")
  • We collect information about you from other parties, sites and services, as we believe your profile is of interest for our current or future vacancies (as an "Obtained Candidate")
  • We receive information about you from our employees or partners, as they believe your profile is of interest for our current or future vacancies (as a "Recommended Candidate")
  • We receive information about you from a Candidate, who indicates you as their reference (as a "Reference")

This privacy policy also describes the rights you have when we process your personal data and how you can exercise those rights.

When we use the term "Candidate" in this privacy policy, we are referring to each of the Connecting Candidates, Applying Candidates, Recruited Candidates and Recommended Candidates, unless otherwise indicated.


1. About the processing of personal data

Personal data is all information that can be directly or indirectly associated with a living, physical person. Examples of personal data are: name, email address, telephone number and IP address. The processing of personal data is any automated use of personal data, such as the collection, creation, analysis, sharing and deletion of personal data.

There are laws and regulations about how companies may process personal data, so-called data protection laws. Different data protection laws apply to different types of use of personal data and in different parts of the world. An example of a data protection law that is relevant for our use of your personal data as described in this privacy policy is the EU General Data Protection Regulation (2016/679, "GDPR").

Most obligations under the GDPR apply to the so-called data controller. A data controller is the entity that decides for what purposes personal data will be processed and how the processing will be executed. The data controller may use a so-called data processor. A data processor is an entity that is only allowed to process personal data as instructed by the data controller and cannot use the personal data for its own purposes.

We are the data controller when we process your personal data as described in this Privacy Policy.

2. What personal data do we process?

All individuals

  • Device information - If you visit our Career Site, we will collect information about your device, such as IP address, browser type and version, session behaviour, traffic source, screen resolution, preferred language, geographic location, operating system and device settings/usage.
  • Technical and statistical data - If you visit our Career Site, we will collect technical and statistical data about your use of the site, such as information about the URLs you visit and your activity on the site.
  • Communication data - We will collect and store your communication with us, including the information you provided in the communication. This may include the content of e-mails, video recordings, messages on social media, the information you add to your account with us, surveys, etc.
  • Contact details - Such as your name, e-mail address, telephone number and physical address.

Candidates

  • Interview, assessment and other recruitment process information - Such as interview notes with you, assessments and tests taken, salary requirements.
  • Information in your application - Such as your CV, cover letter, work samples, references, letters of recommendation and educational qualifications.
  • Information from your public profile - Means the information we collect about you from public sources related to your professional experience, such as LinkedIn or your current employer's website.
  • Information provided by references - Means the information we receive from our employees or partners who have referred you to us, or from the people you have indicated as your references.

3. Where do we receive your personal data from?

All individuals

  • From the Career Site. If you visit our Career Site, we collect technical and statistical information about how you use the Career Site and information on your device.
  • Directly from you. Most of the information we process about you, we receive directly from you, for example when you apply for a position with us or connect with us. You may always choose not to provide us with certain information. However, some personal data is necessary for us to process your application or provide you with the information you have requested from us.

References

  • From the person for whom you are a reference. If a Candidate indicates you as a reference, we will collect your contact information from the Candidate so we can contact you.

Candidates

  • From public sources. We may collect personal data about you from public sources, such as LinkedIn or your current employer's website.
  • From our references. We may receive information about you from our employees or partners (such as recruitment service providers), when they consider your profile to be of interest for our current or future vacancies.
  • From your references. If you provide us with references, we may collect information about you from them.
  • Data that we create ourselves or in collaboration with you. Information about your application and profile is normally created by us, or by us in collaboration with you, during the recruitment process. They may, for example, include interview notes with you, assessments and tests taken.

4. For what purposes do we process your personal data?

  • Protect and enforce our rights, interests and the interests of third parties, for example in the context of legal proceedings.
  • Share your personal data with other recipients, for the purposes mentioned in Section 5 below.
  • Collect information about your use of the Career Site, using cookies and other tracking technologies, as described in our Cookie Policy.
  • Maintain, develop, test and ensure the security of the Career Site.
  • Analyse how the Career Site and its content are being used and their performance, to obtain statistics and improve operational performance.
  • Provide you with updates on vacancies with us.
  • Review profiles and applications sent to us. This also includes communicating with you about your application and profile.
  • Collect and assess your professional profile on our own initiative. This also includes communicating with you regarding your profile.
  • Contact you directly about specific and future vacancies in our company.
  • Record the interview(s) with you.
  • Contact you to request your participation in surveys.
  • Contact you to ask you to provide information about a Candidate and evaluate the information you provide.

5. Who do we share your personal data with?

  • Our service providers. We share your personal data with our suppliers who provide services and features in our employer branding and recruitment process.
  • Companies in our group. We share your personal data with companies in our group, when they provide us with services and features for our employer branding and recruitment process, such as access to specific systems and software.
  • Companies that provide cookies on the Career Site. If you give your consent, cookies are set by companies other than us, who will use the data collected by these cookies in accordance with their own privacy policy.
  • To authorities and other public actors - when we are ordered to do so. We will share your personal data with authorities and other public actors when we are legally obliged to do so.
  • To parties involved in legal proceedings. If necessary to protect or defend our rights, we share your personal data with public authorities or other parties involved in a potential or existing legal proceeding.
  • Mergers and acquisitions, etc. In the context of a potential merger, sale of company assets, financing or acquisition of all or part of our business by another company, we may share your personal data with other parties involved in the process.

6. On what legal bases do we process your personal data?

In order for us to process your personal data, we need to have a so-called legal basis. A legal basis is a reason for processing personal data that is justified under the GDPR.

When we process your personal data for the purposes described in this Privacy Policy, the legal basis on which we rely is usually that the processing is necessary for our legitimate interest in being able to recruit talent with the relevant competence for us. We have concluded that we have a legitimate interest in being able to carry out the processing of personal data for this purpose; that the processing is necessary to achieve that purpose; and that our interest outweighs your right not to have your data processed for this purpose.

You can contact us for more information about how this assessment was made. See Sections 9 and 10 below for our contact details.

There may be specific circumstances where processing only takes place if and when you give your consent to the processing. This is the case, for example, if we intend to record an interview with you. See Section 9 below for more information on your right to withdraw consent.

7. When do we transfer your personal data outside the EU/EEA and how do we protect it?

We always try to process your personal data within the EU/EEA area.

However, some of our service providers process your personal data outside the EU/EEA. We also use suppliers whose parent company, or the parent company of a subcontractor, is based outside the EU/EEA. In these cases, we have taken into account the risk that personal data may be disclosed in countries outside the EU/EEA, for example due to a request from an authority.

When we, or one of our suppliers, transfer your personal data outside the EU/EEA, we ensure that a safeguard recognised by the GDPR is used to enable the transfer.

8. How long do we keep your personal data?

All individuals

If we process your personal data for the purpose of being able to protect and enforce our rights, we will retain your personal data until the relevant legal issue has been fully and finally resolved.

Visitors

We retain your personal data for one (1) year for security reasons. The retention periods for cookies are set out in our Cookie Policy. We retain your personal data to analyse the performance of the Career Site for the period during which we retain personal data about you for other purposes.

Candidates

If you are a Connecting Candidate (only), we retain your personal data for as long as you remain connected with us.

For other types of Candidates, we retain your personal data to decide whether you are a suitable candidate for the relevant vacancy(ies) in our company.

If you are unsuccessful in the initial recruitment process, we will keep your personal data for as long as necessary to consider, and potentially contact you, for future relevant job vacancies.

9. What rights do you have and how can you exercise them?

If you wish to exercise any of the rights set out here, we suggest that you:

  • Visit the Data and Privacy page on our Career Site, where we provide features that allow you to exercise your rights;
  • Log in to your account with us, where you can use the account settings to exercise your rights; or
  • Contact us directly at recruitment@lusodutch.com.

Right to be informed - You have the right to be informed about how we process your personal data.

Right of access to your personal data - You have the right to know whether we process personal data about you and to receive a copy of the data we process about you.

Right to request the transfer of your personal data to another recipient ("data portability") - You may request a copy of the personal data concerning you that we process for the performance of a contract with you, or based on your consent, in a structured, commonly used and machine-readable format.

Right to have your personal data deleted ("right to be forgotten") - In some cases, you have the right to ask us to delete your personal data.

Right to object to our processing of your personal data - You have the right to object to the processing of your personal data that is based on our legitimate interest, referring to your personal circumstances.

Right to restrict processing - If you consider that the personal data we process about you is inaccurate, that our processing is unlawful, or that we do not need the information for a specific purpose, you have the right to request that we restrict the processing of that personal data.

Right to rectification - You have the right to request that we rectify inaccurate information and complete information about you that you consider incomplete.

Right to withdraw your consent - When we process your personal data on the basis of your consent, you have the right to withdraw that consent at any time.

Right to lodge a complaint - If you have complaints about our processing of your personal data, you may lodge a complaint with the data protection authority in the Netherlands.

10. Who can you contact for comments or questions?

If you wish to contact us to exercise your rights, or if you have any questions, comments or concerns about how we handle your personal data, you can contact us by sending an email to recruitment@lusodutch.com.

11. Updates to this Privacy Policy

We update this privacy policy whenever necessary - for example, because we start processing your personal data in a new way, because we want to make the information even clearer for you, or if it is necessary to do so to comply with applicable data protection laws.

We advise you to check this page regularly for any changes. You can always see at the top of this page when this privacy policy was last updated.