PRIVACYVERKLARING

Please read our Privacy Policy carefully as it contains important information on the following: ·       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: May 2022

All capitalized terms not otherwise defined in this Privacy Policy shall have the same meaning as ascribed to them in the Terms of Use, available on www.myCareerCompanion.com/terms-of-use.

If you do not understand or have any questions relating to any of the provisions of this Privacy Policy, please contact us before using the Platform (info@crossbridge.be).

For the purpose of this Privacy Policy, the following entity acts as controller in relation to any Personal Data processed via the Platform:

Crossbridge BV
Van Luppenstraat 57
B-2018 Antwerp
E: info@crossbridge.be
T: +32 16 31 91 34

Registered with the Crossroads Bank of Enterprises under company number 0840.164.411.

1. General

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”).

This Privacy Policy explains how Crossbridge (“we”, “us”) collects, shares and uses any information that, alone or in combination with other information, relates to you (“Personal Data“) when you (“you” and “your“) use our Platform as a User.

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. 

2. 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.

3. 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;
• Compliance with and enforcing any applicable legal obligations and our Terms of Use and Privacy Policy;
• 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: This is not applicable to the employees of our customers, except in case of mutual agreement with our customer. 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).

In general, we will use the Personal Data we collect from you only for the purposes described in this Privacy Policy or for purposes that we explain to you at the time we collect your Personal Data. However, we may also use your Personal Data for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.

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.

4. Security

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. 

5. Cookies

When using the Platform, we may collect certain information using automated technology, such as cookies (i.e. small data files that are placed on your device when you visit a website) and similar technologies, including mobile application identifiers, to improve your experience of the Platform, to increase security, measure use and effectiveness of the Platform, to identify and resolve technical issues. We may also use cookies and other automated means for purposes such as management of our Platform and other aspects of the commercialization of our business. Please note that we shall only process and collect information via cookies and similar technologies to the extent necessary for the purpose of the specific cookie or similar technology.

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.

You can control our use of cookies through the cookie consent tool available on  https://www.mycareercompanion.com/cookie-policy/ where you may choose to refuse the use of any cookies at any time.. Please note, however, that without cookies the Platform may not work properly or you may not be able to use all of its features.

Cookies set by the website owner (in this case, Crossbridge) are called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”. Third parties may use cookies to collect information about your activities on the Platform to understand and continue improving the performance of the Platform. Please check the relevant third party’s website for more information about their use of cookies. Where this third-party website allows such cookies to be set or you access other websites from the Platform using the links provided, the operators of these websites will use cookies in accordance with their own cookies policy, which may differ from ours.

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.

For more information on our use of cookies, you can consult our Cookie Policy, which is available on https://www.mycareercompanion.com/cookie-policy/.

6. Disclosure to third parties

We may disclose your Personal Data to the following categories of recipients:

• in the event of a full or partial merger, or acquisition of all or a part of Crossbridge, we may transfer your Personal Data to a potential buyer In such event, Crossbridge shall inform this third party to use any Personal Data strictly consistent with this Privacy Policy;
• to our group companies for purposes consistent with this Privacy Policy;
• to third party service providers, vendors or partners who provide data processing services to us, or who otherwise process Personal Data for purposes that are described in this Privacy Policy or notified to you when we collect your Personal Data. This may include disclosures to third party vendors and other service providers we use in connection with services they provide to us such as IT platform management or support services, infrastructure and application services, marketing, data analytics;
• 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.

Other than as set out in this Privacy Policy, we shall not sell or otherwise disclose your Personal Data to third parties without obtaining your prior explicit consent, unless this is necessary for the purposes set out in this Privacy Policy or unless we are required to do so by law.

7. 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.

To exercise your abovementioned rights or if you have any other questions concerning this Privacy Policy, please contact us by e-mail at privacy@crossbridge.be or by writing us: Crossbridge BV, Van Luppenstraat 57, B-2018 Antwerp. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

• 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.

8. 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 privacy@crossbridge.be 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.

9. Complaints

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.)

10. 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.

11. Updates or changes to our Privacy Policy

Occasionally, we may change or update this Privacy Policy in response to changing, legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material changes to this Privacy Policy if and where this is required by applicable data protection laws. You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Policy.