· What personal data we collect from you (section 2);
· For which purpose we collect your Personal data (section 3);
· The measures to safeguard the access to and the security of your Personal Data (section 4); and
· Your rights in relation to your Personal Data and the conditions under which you can exercise these rights (section 7).
Last updated on: Mei 2022
Van Luppenstraat 57
T: +32 16 31 91 34
Registered with the Crossroads Bank of Enterprises under company number 0840.164.411.
Crossbridge is an independent pioneer in coaching, recruitment and HR consulting, focusing on last-year students and young graduates. Crossbridge has developed the myCareerCompanion Platform, which is an online platform aimed at youngsters who are seeking guidance towards the job market. As part of its myCareerCompanion Platform, Crossbridge also provides TalentScan services to companies, which consists of allowing companies to objectively test potential talents through other application processes against the algorithms of the Platform (the “Employers”).
As controller, Crossbridge is committed to protecting the privacy of its Users and their Personal Data and providing a secure, user-controlled environment for the Platform in accordance with the applicable data protection law, and specifically with the General Data Protection Regulation (GDPR). At the same time, we also ask you to take your responsibility for maintaining privacy and security— for example, by not allowing any third party to use or access your Account. If you suspect any unauthorized use of your Account or your Personal Data or any other confidential information, please notify us promptly in writing.
- Categories of Personal Data we collect
We may collect and process several types of Personal Data from the Users of our Platform, and store it on our servers located in the European Economic Area, such as:
- Contact information (e. your name, e-mail address, and mobile or other telephone number and postal address);
- The profile data provided by you on your Account (e. password, date of birth, picture);
- Information related to your education (e. university, study program, graduation year);
- Information related to your professional background;
- Information provided by you on your resume uploaded on the Platform;
- Data linked to or resulting from Coaching Services provided by Crossbridge to you (including but not limited to the results of the tests performed by you on the Platform);
- Information provided in helpdesk support inquiries;
- Information provided by you in any User Content;
- Financial information (in case you purchase certain services on our Platform);
- Web behaviour information such as information related to how the Users use the Platform (e.g. browser type, domains, page views) collected through cookies and other automated technology (cfr. section 5 “Cookies”).
At the time of collection of your Personal Data, we will indicate to you whether you are obliged to provide certain Personal Data in order to use our services and / or the App. Please note that if you do not wish to provide us with such mandatory Personal Data (contractually required or by law), you will not be able to use the Platform or our services. Other Personal Data that is not mandatory may be provided by you voluntarily and is optional. If you do not wish to share this optional Personal Data, this will not affect your ability to use our services or the Platform.
- How your Personal Data is processed – Purpose of the processing
Crossbridge collects, uses, and maintains your Personal Data for all purposes necessary to ensure the proper functioning and operation of your Account and/or the proper provision of the services via the Platform. Crossbridge may process your Personal Data provided by you or collected by us for all purposes necessary to provide or maintain the Licensed Technology.
When you provide us with your Personal Data, we use it as indicated hereunder (collectively the “Purpose”):
- Creating and managing your Account to allow you to use the Platform;
- Providing information and allowing the Users to have access to the Platform and their Account;
- Diagnosing technical problems and managing technical support and processing inquiries concerning the Platform;
- Performing data analyses (including anonymisation and aggregation of Personal Data) to obtain information on how the Licensed Technology is used and its performance. Data analyses may also be performed for scientific research and publications in cooperation with academic partners but only in an aggregate and anonymized manner;
- The operation, evaluation and improvement of the Licensed Technology (including the development of additional products and/or services, enhancing and improving the Licensed Technology, analysis of our Platform, quality control activities and performing internal business functions such as accounting and auditing);
- Protection against, identify and prevent fraud and other unlawful activity, claims and other liabilities;
- In order to be in compliance with any applicable legislation or regulations or where required by a law enforcement authority or other government official request;
- Coaching services: Crossbridge may contact you to discuss your myCareerCompanion results and help you to orient yourself. If you wish, Crossbridge can bring you in contact with employers that have your preferred company culture and matching job opportunities. Only when you explicitly confirm your interest in an opportunity, Crossbridge may disclose your Personal Data to the concerned Employer;
- The provision of other services in connection with the Platform to third parties (such as the Employers).
Your Personal Data is processed for the purpose of fulfilling the contractual obligations of Crossbridge related to the services offered in connection with the Platform, as well as for the legitimate interests pursued by Crossbridge in relation to the management of its business and the provision of its core business activities or similar interests pursued by any third party (including any Employers). In addition, we may also process certain Personal Data with your prior consent.
Crossbridge shall process your Personal Data in a manner that ensures appropriate security of your Personal Data, including unauthorized or unlawful processing of any Personal Data or its accidental loss, destruction or damage, access, disclosure or use, implementing all appropriate administrative, technical and organizational measures.
The information we collect in this manner includes IP address, browser characteristics, device characteristics, operating system version, information on actions taken on our Platform (such as usage, activity logs and click-throughs), and dates and times of visits. Log data is promptly deleted on a regular basis.
Cookies can remain on your computer or mobile device for different periods of time. Some cookies are ‘session cookies’, which means they only exist when your browser is open and are automatically deleted when you close your browser or quit the app. Other cookies are ‘persistent cookies’, meaning they survive after your browser or app is closed and can be used by websites or apps to recognize your computer when you re-open your browser or app later.
If you have disabled one or more cookies, we can always use information collected by these cookies before the deactivation. However, we cease to collect information via the opted-out cookie.
- Disclosure to third parties
We may disclose your Personal Data to the following categories of recipients:
- to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
- to our auditors, advisors, legal representatives and similar agents in connection with the advisory services they provide to us for legitimate business purposes and under contractual prohibition of using the Personal Data for any other purpose.
- Your rights
You have the following data protection rights in relation to your Personal Data:
- Right of access
If you are concerned or have any questions about (the processing of) your Personal Data, you have the right to request access to the Personal Data which we hold or process about you. We will then provide you with information about the Personal Data that are being processed and on the source of those Personal Data.
- Right to rectification and right of erasure
You have the right to obtain from Crossbridge without undue delay the rectification of inaccurate Personal Data concerning you. Taking into account the purposes of the processing, you shall have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.
Furthermore, you have the right to request us free of charge to erase your Personal Data without undue delay if such Personal Data would be no longer be necessary in relation to the purposes for which they have been collected or processed or processed unlawfully.
Please note that you can change or update your Account information at any time on the following page www.myCareerCompanion.com/profile.
- Right to restriction of processing/ right to object to data processing
You shall have the right to obtain from Crossbridge restriction of the processing of Personal Data or to object to the processing of your Personal Data in accordance with the GDPR.
- Right to withdraw your consent
If we have collected and process your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
- Right to data portability
You shall have the right to receive your Personal Data that you have provided to Crossbridge, in a structured, commonly used and machine-readable format and have the right to transmit those Personal Data to another controller without hindrance from Crossbridge. In exercising your right to data portability, you shall have the right to have your Personal Data transmitted directly from one data controller to another, where technically feasible.
- Right to opt-out of marketing communication
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided above.
- Data retention
We retain Personal Data we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested in relation to the Platform or to comply with applicable legal, tax or accounting requirements). When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.
Please note that you can permanently delete your Account at any time on the following page www.myCareerCompanion.com/profile or by sending an e-mail to firstname.lastname@example.org or by writing us: Crossbridge BV, Van Luppenstraat 57, B-2018 Antwerp. Your Account information will be deleted from our database upon your request, unless there would be another legal ground requiring Crossbridge to further process any Personal Data linked to your Account.
If you have a complaint or concern about how we are processing your Personal Data, then we will endeavour to address such concern(s). If you feel we have not sufficiently addressed your complaint or concern, you have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area are available here.)
- Third Party websites or applications
You acknowledge and understand that certain content or services provided by third parties may be made available to you through the Platform or your Account. Such third-party content or services have their own privacy policies and we urge you to review them before using them as they will govern the use of your Personal Data whilst visiting/using this third-party content or service. Crossbridge cannot be held responsible for the privacy practices of such third parties and your use of such third party content or services is at your own risk. Crossbridge does not in any way review or endorse the privacy practices of such third parties.