GDPR – Privacy statement

This privacy statement (hereinafter the « Privacy Statement ») explains why we collect your data and what we do with it. If you have any questions after reading this Privacy Statement, you are welcome to discuss them with your contact person in our team. We can also be reached as follows:

What is the scope of this Privacy Statement?

This statement only applies to the data that SEEWHY processes as (joint) data controller. This means that we (jointly) determine the purpose and means for the processing of your data.

However, we can already clarify that this Privacy Statement applies to processing the data of (1) customers who purchase services from us, (2) candidates in the context of our recruitment and selection services or in connection with direct services that these candidates purchase from us and (3) business partners who assist us in providing our services to our customers and candidates, or whom we assist in providing services to their customers, for example by providing them with suitable, consenting candidates where appropriate (e.g., within the framework of an assignment of an international nature). The data of former and potential future customers, candidates and business partners is also handled with the greatest possible care and security, in accordance with this Privacy Statement.

We understand ‘processing of data’ as meaning any processing of data that could identify you as a natural person. Which specific data this concerns will be explained below in this Privacy Statement. The concept of ‘processing’ is broad and includes the collection, storage, use or distribution of your data.

When do we collect your data as (joint) data controller?

We may process your data if:

  • You contact us, or have contacted us:
  • We provide or have provided one of our services to you, as a customer, candidate or business partner;
  • We may provide services to you in the future, as a customer, candidate or business partner;
  • We optimise our services and business processes;
  • You are our contact for one of our customers, candidates or business partners.
  • To provide information about our activities and services, via electronic channels or otherwise, that we believe may be of interest to you based on the existing relationship you have with us

What data can we process about you?

Below, we will clarify which data we can process about you, depending on your relationship with SEEWHY. This does not mean that in all cases we will have all the data about you as listed below. After all, this will always depend on the specific situation and your preferences.

Visitors to our website

If you visit our website, we may process the following data from you through the use of cookies and through your use of functions that we have provided on the website (e.g., the contact form).

Customers and business partners

We may process the following data from our (contact persons at our) current, former and potential future customers and business partners. Which data we effectively process about you will of course depend on the specific recruitment and selection services that you, as our customer, purchase from us, have purchased or may wish to purchase from us, or on the way in which you assist us as our business partner in providing the aforementioned services to our customers. 

Candidates and applicants

We may process the following data from our (contact persons at our) current, former and potential future candidates for positions that we are trying to fill on behalf of our customers. The same applies to candidates who purchase services directly from us, persons who rely on us to provide services outside the standard recruitment and selection services (e.g., CEO training), and persons who apply for a position within SEEWHY itself. Naturally, the data processed in this case depends to a large extent on the data that you yourself provide to us in the context of your application, this specific service or application.

Special categories of data

In principle, we will not process special categories of data (e.g., medical data, political views, religious or philosophical beliefs, trade union membership) unless you provide it to us with your explicit consent.

For the fulfilment of the agreement (e.g., the submission or assessment of your application), it may be necessary for us to ask to view your certificate of good conduct or other information regarding criminal convictions and offenses. However, we will not process this data in any way, and we will therefore not ask you to provide us with a copy. In the event that other parties request such information, we ask that you provide this information – if feasible – directly to the requesting party. 

What are the legal grounds that we apply for processing your data?

We only process your data for legitimate purposes, and it will always be processed according to the grounds for processing as listed in the General Data Protection Regulation (GDPR).

In general, we process your data because it is necessary for the performance or termination of the agreement with our customers, candidates and business partners and in order to provide you with our services, or to allow you to provide your services to us.

In addition, we may process your data on the basis of our legitimate interests which, in specific cases, may outweigh any potential harm to your rights. In such cases, to this end, we will have made a careful assessment, thoroughly balancing our interests against your interests, with a view to the valid application of this legal basis. In addition, you retain the right at all times to object to the processing of your data based on our legitimate interests. When we rely on the legal basis of our legitimate interests, depending on the case, this will concern one of the specific interests listed below:

In addition, we may process your data on the basis of your (explicit) consent. In particular, we rely on consent as a legal basis, regarding our candidates, to include them in our database and to submit their application to organisations that have suitable positions available. If you have granted us verbal permission to process your data, we will always send you an e-mail confirming your consent. You may withdraw your consent at any time by contacting us. We ask that you confirm a verbal withdrawal of your consent in writing, or that you withdraw your consent by e-mail or letter.

Finally, we process your data for legal purposes in order to fulfil the legal obligations incumbent upon us. For example, we are legally required to comply with your requests based on data protection laws and regulations, and we as a company must keep the relevant accounting documents for the legally required term.

If we further process your data for purposes other than those for which it was collected, we will contact you and, if necessary, offer our services and/or ask for your consent. If this contact is made by telephone, we will subsequently send you an e-mail stating that we will process your data in accordance with this statement.

How long do we store your data?

We do not store your data for longer than is necessary in order to achieve the purpose for which the data has been collected or processed. 

When it is no longer necessary to process your data, we will delete or anonymise your data. If this is not (technically) possible, for example because your data is stored in backup archives, then we will retain your data, but we will not further process it and will remove it when this becomes possible.

From whom do we receive your data?

We may obtain your information from you directly, from our customers, from public sources or from third parties. 

If we obtain your data from our customers (e.g., as our contact person or potential candidate), and when we are not acting merely as a processor (e.g., when we only conduct an assessment, test or specific evaluation of the person concerned), we will take all reasonable measures to verify whether the data has been lawfully collected and further processed by our customer, and whether the data can be passed on to us by virtue of the legal basis used. If this is not the case, we will refuse the processing of the data concerned.

If we obtain your data from external (public or other) sources and we process your data in our systems as data controller, we will notify you, at the latest at the time of our first contact with you, about the processing of your data. 

In addition to consulting public sources, such as the Crossroads Bank for Enterprises, press articles, your profile on professional social networks and other publicly available information, we have joint operating agreements with various partners such as companies specialised in collecting business information, companies specialised in providing prospect lists and other data suppliers. 

If we further process data from external sources for other purposes than those for which they were collected, we will contact you and offer you our services and/or request your permission for the processing of your data, so that you will be aware of the processing of your data. If this contact is made by telephone, we will send you an e-mail stating that we will process your data in accordance with this Privacy Statement.

Where do we store your data?

We store your data chiefly on IT systems in Belgium. However, the management of some of our IT systems is outsourced to third parties, whereby the data is stored within the European Economic Area (EEA). We have also engaged IT service providers located outside of the EEA, which means that your data may also be stored outside the aforementioned countries. In this case, however, we will meet the requirements of the GDPR to ensure the adequate protection of your data in these third countries. These external service providers (e.g., the company hosting our website) act as data processors on our behalf (see also below).

We only share your data with the aforementioned external service providers to the extent that this is necessary for the relevant purpose. They may not use the data for other purposes. Moreover, these service providers are contractually bound to guarantee the confidentiality of your data by means of a so-called « processor agreement » concluded with these parties.

We and our processors have taken the necessary physical and appropriate technical and organisational (precautionary) measures in order to secure your data against any form of unlawful processing. Access to your data is restricted to personnel and third parties where such access is necessary for legitimate, relevant business purposes.

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GDPR – Privacy statement

This privacy statement (hereinafter the "Privacy Statement") explains why we collect your data and what we do with it. If you have any questions after reading this Privacy Statement, you are welcome to discuss them with your contact person in our team. We can also be reached as follows: What is the scope of this Privacy Statement? This statement only applies to the data that SEEWHY processes as (joint) data controller. This means that we (jointly) determine the purpose and means for the processing of your data. However, we can already clarify that this Privacy Statement applies to processing the data of (1) customers who purchase services from us, (2) candidates in the context of our recruitment and selection services or in connection with direct services that these candidates purchase from us and (3) business partners who assist us in providing our services to our customers and candidates, or whom we assist in providing services to their customers, for example by providing them with suitable, consenting candidates where appropriate (e.g., within the framework of an assignment of an international nature). The data of former and potential future customers, candidates and business partners is also handled with the greatest possible care and security, in accordance with this Privacy Statement. We understand 'processing of data' as meaning any processing of data that could identify you as a natural person. Which specific data this concerns will be explained below in this Privacy Statement. The concept of 'processing' is broad and includes the collection, storage, use or distribution of your data. When do we collect your data as (joint) data controller? We may process your data if:
  • You contact us, or have contacted us:
  • We provide or have provided one of our services to you, as a customer, candidate or business partner;
  • We may provide services to you in the future, as a customer, candidate or business partner;
  • We optimise our services and business processes;
  • You are our contact for one of our customers, candidates or business partners.
  • To provide information about our activities and services, via electronic channels or otherwise, that we believe may be of interest to you based on the existing relationship you have with us
What data can we process about you? Below, we will clarify which data we can process about you, depending on your relationship with SEEWHY. This does not mean that in all cases we will have all the data about you as listed below. After all, this will always depend on the specific situation and your preferences. Visitors to our website If you visit our website, we may process the following data from you through the use of cookies and through your use of functions that we have provided on the website (e.g., the contact form). Customers and business partners We may process the following data from our (contact persons at our) current, former and potential future customers and business partners. Which data we effectively process about you will of course depend on the specific recruitment and selection services that you, as our customer, purchase from us, have purchased or may wish to purchase from us, or on the way in which you assist us as our business partner in providing the aforementioned services to our customers. Candidates and applicants We may process the following data from our (contact persons at our) current, former and potential future candidates for positions that we are trying to fill on behalf of our customers. The same applies to candidates who purchase services directly from us, persons who rely on us to provide services outside the standard recruitment and selection services (e.g., CEO training), and persons who apply for a position within SEEWHY itself. Naturally, the data processed in this case depends to a large extent on the data that you yourself provide to us in the context of your application, this specific service or application. Special categories of data In principle, we will not process special categories of data (e.g., medical data, political views, religious or philosophical beliefs, trade union membership) unless you provide it to us with your explicit consent. For the fulfilment of the agreement (e.g., the submission or assessment of your application), it may be necessary for us to ask to view your certificate of good conduct or other information regarding criminal convictions and offenses. However, we will not process this data in any way, and we will therefore not ask you to provide us with a copy. In the event that other parties request such information, we ask that you provide this information – if feasible – directly to the requesting party. What are the legal grounds that we apply for processing your data? We only process your data for legitimate purposes, and it will always be processed according to the grounds for processing as listed in the General Data Protection Regulation (GDPR). In general, we process your data because it is necessary for the performance or termination of the agreement with our customers, candidates and business partners and in order to provide you with our services, or to allow you to provide your services to us. In addition, we may process your data on the basis of our legitimate interests which, in specific cases, may outweigh any potential harm to your rights. In such cases, to this end, we will have made a careful assessment, thoroughly balancing our interests against your interests, with a view to the valid application of this legal basis. In addition, you retain the right at all times to object to the processing of your data based on our legitimate interests. When we rely on the legal basis of our legitimate interests, depending on the case, this will concern one of the specific interests listed below: In addition, we may process your data on the basis of your (explicit) consent. In particular, we rely on consent as a legal basis, regarding our candidates, to include them in our database and to submit their application to organisations that have suitable positions available. If you have granted us verbal permission to process your data, we will always send you an e-mail confirming your consent. You may withdraw your consent at any time by contacting us. We ask that you confirm a verbal withdrawal of your consent in writing, or that you withdraw your consent by e-mail or letter. Finally, we process your data for legal purposes in order to fulfil the legal obligations incumbent upon us. For example, we are legally required to comply with your requests based on data protection laws and regulations, and we as a company must keep the relevant accounting documents for the legally required term. If we further process your data for purposes other than those for which it was collected, we will contact you and, if necessary, offer our services and/or ask for your consent. If this contact is made by telephone, we will subsequently send you an e-mail stating that we will process your data in accordance with this statement. How long do we store your data? We do not store your data for longer than is necessary in order to achieve the purpose for which the data has been collected or processed. When it is no longer necessary to process your data, we will delete or anonymise your data. If this is not (technically) possible, for example because your data is stored in backup archives, then we will retain your data, but we will not further process it and will remove it when this becomes possible. From whom do we receive your data? We may obtain your information from you directly, from our customers, from public sources or from third parties. If we obtain your data from our customers (e.g., as our contact person or potential candidate), and when we are not acting merely as a processor (e.g., when we only conduct an assessment, test or specific evaluation of the person concerned), we will take all reasonable measures to verify whether the data has been lawfully collected and further processed by our customer, and whether the data can be passed on to us by virtue of the legal basis used. If this is not the case, we will refuse the processing of the data concerned. If we obtain your data from external (public or other) sources and we process your data in our systems as data controller, we will notify you, at the latest at the time of our first contact with you, about the processing of your data. In addition to consulting public sources, such as the Crossroads Bank for Enterprises, press articles, your profile on professional social networks and other publicly available information, we have joint operating agreements with various partners such as companies specialised in collecting business information, companies specialised in providing prospect lists and other data suppliers. If we further process data from external sources for other purposes than those for which they were collected, we will contact you and offer you our services and/or request your permission for the processing of your data, so that you will be aware of the processing of your data. If this contact is made by telephone, we will send you an e-mail stating that we will process your data in accordance with this Privacy Statement. Where do we store your data? We store your data chiefly on IT systems in Belgium. However, the management of some of our IT systems is outsourced to third parties, whereby the data is stored within the European Economic Area (EEA). We have also engaged IT service providers located outside of the EEA, which means that your data may also be stored outside the aforementioned countries. In this case, however, we will meet the requirements of the GDPR to ensure the adequate protection of your data in these third countries. These external service providers (e.g., the company hosting our website) act as data processors on our behalf (see also below). We only share your data with the aforementioned external service providers to the extent that this is necessary for the relevant purpose. They may not use the data for other purposes. Moreover, these service providers are contractually bound to guarantee the confidentiality of your data by means of a so-called "processor agreement" concluded with these parties. We and our processors have taken the necessary physical and appropriate technical and organisational (precautionary) measures in order to secure your data against any form of unlawful processing. Access to your data is restricted to personnel and third parties where such access is necessary for legitimate, relevant business purposes.
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