Privacy

I. Who are we?

2024/10/09

CVWarehouse NV (hereafter “CVWarehouse”), operates CVWarehouse candidate portal and the company portal on the CVWarehouse website and is the data controller or processor (see further) for the processing of personal data.

You are able to contact us through following coordinates:

CVWAREHOUSE NV
Ternesselei 330
2160 Wommelgem
Belgium
Tel: +32 3 202 42 20
E-mail: info@cvwarehouse.com

We have appointed a Data Protection Officer ('DPO') that oversees all privacy related matters within CVWarehouse. The contact details for our DPO are:

Mrs. Lieve Van de Loo
Tel: +32 3 202 42 20
E-mail: dpo@cvwarehouse.com

II. Which personal data do we process and for which reasons?

A. Anonymous aggregated information

This is information about all our visitors combined, such as the sections of our website visitors most frequently go to, and the services that they prefer to use, as well the browser and operating system used by a visitor. To protect our visitors' rights to privacy, this information is anonymous and aggregated. Therefore, no individual CVWarehouse visitor can be identified on the basis of this information. We may use such information to generate anonymous traffic numbers which we may disclose to our clients and the public.

B. Personal data

- Internet Protocol addresses

In our log files (which are files that contain data about events for future reference), we may collect and store Internet Protocol addresses of candidates and customers for data safety reasons (to prevent and/or detect fraud, malicious intent or cyber-attacks). We may also collect Internet Protocol addresses, anonymize them and draw up anonymous statistics, in order to measure the number of people on our website (traffic) and load balance our systems accordingly to provide optimal response times. We may use these anonymous statistics for accounting purposes to calculate the number of clicks received via our own or websites of our business partners, but we will not use this information to identify visitors of the website (legal basis: legitimate interest).

- Contact details of our customers/suppliers

As we need to be able to process the contact details of our customers/suppliers and persons working for them/acting on behalf of them, we process such personal data with the sole purpose of executing the agreement we have with our customers/suppliers (legal basis: executing agreement).

- Contact details of prospects

For prospecting purposes, we process contact details of potential customers. This could mean we process personal data if such contact details refer to a natural person working for a potential customer (legal basis: legitimate interest).

- Contact form

When you contact us through the contact form on our website, we will process the personal data you provide us with in order to process your request (legal basis: consent)

- Candidate data

Providing us (through registering for a profile) or our customers (companies you may apply with) with your personal data will lead to the processing of such data by CVWarehouse.

By registering on our website you can create and use a CVWarehouse profile. Potential employers may allow you to use your profile to apply for a job, in which case you decide to disclose the personal data in your profile to that potential employer. We will process all the personal data you provide us with, such as (but not limited to) identity and contact details (name, address, tel. number, e-mail address, date and place of birth, marital status, nationality, sex,…), profession, education, memberships and possibly also sensitive information (such as health data) if such data is provided by you. We as CVWarehouse will only save the personal data for you when you add such personal data in your profile and will not further process your personal data ourselves for other purposes unless we would ask your consent to do so. In this case we qualify as a data controller (legal basis: executing agreement). If a potential employer has opted for the creation of a profile to apply for a job, but you do not wish to do so, we advise you to send your application by other means, such as e-mail, to that potential employer. Creating a profile may be needed to use a jobsite of a potential employer, but is in no way necessary to apply with such a potential employer.

Once you disclose the personal data in your profile to a potential employer, the further processing of your personal data by that potential employer will be entirely and solely the responsibility of that potential employer. We will not qualify as a data controller anymore for this act of processing, but only as a processor because we provide that potential employer, the data controller, with a platform in order to process data of the application process in their search for the right candidates for their vacancies.

Our customers are also solely responsible as data controller for the information that they add to a candidate profile themselves following a job interview or information they would ask from candidates in an application form or in the course of the application process. Although our customers contractually agree to use your data for their own company recruitment needs only, non-compliance by such companies with this contractual obligation can be notified to our Support Department.

- Personal mailings (‘job alerts’)

We will also process personal data of candidates for personal mailings (called ‘job alerts’) if the candidate signs up for mailings relating to job opportunities of a certain customer or customers. Consenting to this will allow us to send mailings basing ourselves on which job alerts the candidate has signed up for. Again, personal data will only be passed on to a customer after the candidate itself decides that it wishes to share its personal data when it is interested in a job opportunity (legal basis: consent). In some cases, our customers themselves will manage these job alert mailings and therefore process the data of candidates directly themselves when candidates are signing up for job alerts. In this case not CVWarehouse but the customer is the controller. This situation will be indicated by the privacy policy of the customer being referenced on the subscription page and not the privacy policy of CVWarehouse.

- Applications for a job opportunity from CVWarehouse itself

When someone applies for a vacancy for CVWarehouse as an organization itself (not one of our customers), that personal data will be processed by CVWarehouse for these application purposes (legal basis: consent).

III. With whom is the collected personal data shared?

A. Candidate data

Contrary to other recruitment sites, CVWarehouse never gives any third party access to the personal data of candidates that they have transferred directly to CVWarehouse, without the candidate itself deciding thereto (see above section). This way we assure more privacy and safety of use of such personal information than commonly available in this market space. All information provided remains private and is solely used for the purposes described in this policy. Therefore, the bulk of collected personal data is only available to employees of CVWarehouse, who have signed a specific non-disclosure agreement concerning the processing of such data.

In case you create a free profile on the CVWarehouse website and enter data, your data is submitted only to CVWarehouse and will be saved in your profile. Your data will only be passed on to a potential employer after you explicitly decide thereto by disclosing your data. Every customer that uses the company portal on our websites enters into a non-disclosure agreement with us and can only view the details of candidates who have decided to disclose their data to these specific companies or the candidates that have applied directly with them.

Possibly your personal data will be shared with other external parties by the companies themselves during the application process, which however will be covered by data processing agreements and/or other agreements concluded by our customers themselves, as they are the sole responsible party for such transfers to third parties.

Today, a candidate’s profile is only accessible on the CVWarehouse site in the company login section, by employers who have entered into a contractual relationship with CVWarehouse. A CV may, however, be made accessible in the future via other websites of CVWarehouse subsidiaries or branches in other EU countries and possibly the US and Asia Pacific countries. In such case, a candidate will be notified in a timely fashion and will be asked to consent to this through the profile login or by e-mail.

B. General

In addition to the above, all personal data processed by CVWarehouse can also be shared with our technical partners, in order to be able to provide customers and candidates with our services.

Our website is hosted on a server in the EU that is being maintained by CEGEKA NV (Belgium) which has access to our databases to ensure the contractual maintenance, but cannot access login and password protected areas. As technical support for our business activities we also work with companies that supply the following services or tools for such services: accountancy, hosting of corporate email addresses, internal file sharing, internal task manager, customer support, email campaign, phone management and CRM software.

We also work with a limited amount of external technical parties to provide our customers and candidates with some of the functionalities on our website or that support us technically. Currently, we work with the following parties, who act as processor and with whom we have signed a data processing agreement:

• FLIPBASE BV (the Netherlands): optional video functionalities
• TEXTKERNEL LLC US/SOVREN (US and EEA servers): optional cv parsing functionality
• ALTICE (Portugal): optional cv parsing e-mail hosting functionality

For compliance with our legal or statutory obligations, e.g. (the prevention of) fraud and abuse, we also may choose to share certain personal data if we deem such action necessary or when we are obligated to do so.

Whenever we would work with processors based outside of the EEA, we will make sure that appropriate safeguards are in place to protect the personal data.

IV. How long do we store personal data?

For candidate data in CVWarehouse-profiles, including IP-addresses linked to candidates, we maintain a retention policy whereby we delete data after 10 years inactivity. For the personal mailings we maintain the same policy given that those mailings are linked to the profile, however you may unsubscribe at any moment for these mailings.

Your personal data as a candidate will also not be kept in our database when you are not making use of our services anymore by deleting your profile, using the option in your personal profile.  We will also delete personal data if you request us to do so when using the delete option in your profile is not possible. Any delete request (automated or manual) will also result in our customers (who you may have applied with for a job) not being able to consult your personal data anymore as your profile will be deleted.

For information on how long your personal data is stored by our customers who you applied with, we refer to the privacy policy of the customer(s) in question.

For data referring to customers/suppliers/prospects or received through our contact form we maintain a retention policy of 10 years after the end of the contract with a customer or last contact, whichever applies.

V. Your rights and how to exercise them?

You have several rights concerning the personal data you provide us with, which you may exercise by notifying us or our DPO directly by using the contact details mentioned above.

• the right to obtain information regarding the processing and access to copies of the personal data that are processed by CVWarehouse and if these personal data are inaccurate or incomplete, the rectification or completion of these data;
• the right to have your personal data deleted, or – in certain cases – to have the processing limited/to object to the processing.

Please note that when you exercise your right of deletion of your personal profile data, we will only delete the profile to which the e-mail address is linked that you use to exercise your right of deletion. If you have multiple profiles with multiple e-mail addresses and wish for all of your information to be deleted, you need to exercise this right for every profile and you will need to specify this upon your request to us;

• the transfer of your personal data that you provided us with, either by providing you with a copy in a readable format or by transferring the data directly to another entity if requested so by you;
• the right to withdraw your consent for personal mailings;
• the right to object to the processing of your personal data for reasons of direct marketing.

We do not make use of automated decision making (incl. profiling) when processing your personal data.

When we are not the data controller of your personal data but merely processor (see section III), we will forward your questions or complaints to the actual data controller, the customer, that controls your personal data and is as such responsible for facilitating you in exercising your rights and answering any questions you may have.

If you wish to do so, for instance when you would feel that your inquiry with us has not been addressed in a satisfactory manner, you always have the right to lodge a complaint with the data protection supervisory authority, which is the competent authority for us (or with a supervisory authority of your choice):

Autorité de protection des données – Gegevensbeschermingsautoriteit
Drukpersstraat 35 Rue de la Presse
1000 Brussels
Tel: +32 (0)2 274 48 00
E-mail: contact@apd-gba.be

VI. Links to other websites

CVWarehouse websites may contain hyperlinks to other websites which are outside the control, influence or responsibility of CVWarehouse. CVWarehouse is not responsible for the protection of personal data or data security practices of other websites or companies operating them. We therefore strongly recommend you to read the privacy policies of such other websites in order to enable you to find out how they may process your personal data. CVWarehouse is not responsible for the use they may make of your personal data. Although we screen the companies and the opportunities, CVWarehouse has no control over, and is hence not responsible for the legality, reliability, quality, truth or accuracy of the job offers posted on its website. We encourage you to promptly inform us if you would obtain knowledge of improper or fraudulent practices through websites linked to the sites of CVWarehouse and/or by companies or persons responsible for or contributing to such practices. The same holds for websites of third-parties that link into our websites.

The links to social media and the social media share buttons on our website will lead you to the external website of the social medium, over which CVWarehouse has not control (as you will have left the CVWarehouse website) We do not allow third party websites to trace you by using our website or its functionalities.

VII. Data Safety

To access your private data, you will need to login and submit a password or other kinds of exclusive authentication. The authentication security is enabled through various security methods like intrusion detection, firewalls, encryption, manual procedures and others. Additionally, passwords or any other authentication information will never be communicated by email, as we cannot ensure conclusive safety measures on all browser and email platforms where such information would pass through. Please refer to the FAQ section for further details on loss of authentication details and unlocking blocked accounts.

VIII. Cookie Policy

- What are cookies?

Cookies are small files placed on your computer or your mobile phone browser by websites that you visit. Cookies are used widespread for websites to function, to enhance the user experience as well as to share certain information with the owner of a website.

Visitors have the choice to configure their browser to either accept all cookies, to reject them or to inform them when a cookie is used. Rejecting cookies can however have the consequence that certain personalised services cannot be offered to the visitor or that the website will not function properly anymore, which can result in not being able to use all features of the website.

If you wish to reject all or certain cookies, you need to adapt your browser settings. Given that every browser is different, we advise you to check the ‘Help’-menu of your browser to see how you can change your preferences regarding cookies.

- Which cookies do we use on this website?

CVWarehouse currently only uses the following cookies:

Technically necessary cookies:

These cookies are required to enable core site functionality and cannot be disabled or rejected. These cookies only stay active during your session on our website and are deleted by your browser as soon as you log out.

We use the following technically necessary cookies:

- Cookies placed by our customers:

Besides the cookies that CVWarehouse uses, customers using our CVWarehouse hosted jobsites can also place their own cookies on their jobsite.

As this is different for every customer and it is the customer itself that places the cookies, we kindly refer you to the cookie policy/website of the customer that is linked under the name of the customer in the cookie banner for more information about these cookies.