PRIVACY POLICY of INTRODUCE

1. Your privacy is important
   Your privacy is important to us. We want to process your data in an ethical, lawful, correct and transparent manner. In this document, our privacy policy, we explain how the processing takes place and which personal data are involved. The processing starts at the moment we receive your data. We refer here to you as a candidate, (future) customer, supplier or a person at another organisation who is in contact with us.

1.1 Prior notice
We recommend that you read this document carefully so that you know why and for what purposes we process your personal data. You will also find your rights and how you can exercise them.

We also explain which personal data we process when you, for example:
• use our services
• ask questions via our website
• hand over your business card

We may amend our privacy policy. The most recent version can be found on our website: https://www.introduce.be

If you would like more information about privacy legislation in Belgium, you can consult the website of the Belgian Data Protection Authority www.gegevensbeschermingsautoriteit.be.

1.2 Who processes your data? Who are we?
INTRODUCE operates in Belgium and has its registered office at Grote Baan 96, 9920 Lievegem and is the controller responsible for processing your personal data.

1.3. How can you contact us?
If you have questions about your privacy, wish to adjust your privacy settings or exercise your rights, you can contact us in the following ways:
• By mail at the address: Grote Baan 96, 9920 Lievegem
• By email at: privacy@introduce.be

INTRODUCE has appointed a Data Protection Officer (DPO). You can always contact our DPO via the above address or email address.

1.4. The lead supervisory authority of Introduce
For Introduce, the Belgian supervisory authority is the lead authority:
Data Protection Authority
Drukpersstraat 35, 1000 Brussels
+32 (0)2 274 48 00 / Contact@apd-gba.be

2. Your right to privacy
   You have many rights regarding the processing of your personal data.

The execution of your rights in our systems and procedures takes place no later than 30 days after we have received your request. If, for any reason, this period cannot be met, we will inform you before the expiration of the original period.

2.1. You may access your personal data
You have the right to access the personal data we process about you, the purpose of the processing, where we obtained the data from and who receives the data.

You may also learn how long we retain the data or whether we intend to transfer the data to a country outside the European Union.

The requested information will be provided to you in writing or electronically within a reasonable period.

2.2. You may have your data corrected/completed
It may occur that the data we process about you are no longer correct. You can always request that incorrect data be corrected or completed with missing data.

2.3. Right to erasure
If you believe that we are processing personal data unlawfully, you may request that such personal data be erased. This request may be refused by INTRODUCE where justified. Examples include exercising or substantiating a legal claim or due to a legal obligation to retain certain data.

2.4. Right to restriction of processing
You may request that we restrict the processing of your personal data if you suspect that the data are incorrect, the processing is unlawful, or if you do not agree that we process the data under our legitimate interest (see article 3.3). We will comply with this objection unless there are compelling reasons not to do so, such as the prevention of fraud or non-payment.

2.5. Right to object
You have the right to object to the processing of your personal data. Processing will then be stopped unless processing is necessary for compliance with social and tax legislation, to safeguard the interests of a third party, or for the establishment, exercise or defence of legal claims.

2.6. Right to data portability
You may ask us to transfer the personal data you have provided to us to a third party.

2.7. Right to lodge a complaint
If you do not agree with our position, you may contact the Belgian Data Protection Authority. You can also lodge a complaint there. The contact details can be found above in section 1.4.

2.8. Identification of the applicant
You may exercise your rights regarding the processing of your personal data by submitting a written request:
• by letter to: Grote Baan 96, 9920 Lievegem
• by email to: privacy@introduce.be

Always be as specific as possible when exercising your rights so that we can process your request correctly.

To prevent someone else from exercising your rights, we want to verify your identity as accurately as possible. Therefore, your request must always be accompanied by a document proving that the identity of the applicant corresponds with your identity. This can be done by adding a copy of your identity card to the request. Please black out your photo and identity card number (etc.) to protect your privacy.

If we consider that the provided document does not constitute sufficient proof, we will inform you. We reserve the right not to comply with the request until sufficient proof is provided.

3. Why do we want to process your personal data?

3.1. INTRODUCE must comply with legal obligations
In some cases, we are legally obliged to process the personal data of our customers and suppliers. The main obligations include:
• tax law
• commercial law
• it is possible that we are required to provide personal data to authorities or other third parties, for example if this is necessary in connection with a legal obligation or for the performance of a task in the public interest.

3.2. INTRODUCE must be able to perform its contract with you
Introduce must be able to fulfil its agreements with you as a customer or supplier. To ensure correct performance of our agreement, we must administratively, financially and operationally process and manage these agreements.

3.3. INTRODUCE processes your personal data as a candidate with your consent
The mission of Introduce is to match the right person (the so-called candidate) with the appropriate employer and to guide our candidates throughout their entire professional career, as long as they wish. Examples include:
• communicating with you about open positions that may interest you
• informing you about general trends in the job market
• requesting feedback from you regarding our services

We always store the personal data of you as a candidate in our database for candidate management in the context of recruitment, selection and aftercare. We follow an ethical strategy and transparent communication. For these reasons, we aim to request and obtain your consent for these same purposes.

3.4. INTRODUCE requests your consent
When subscribing to our newsletter, you give implicit consent to receive information about our services. Every newsletter always contains an option to unsubscribe.

When you visit our website for the first time, we ask for your consent via our cookie banner to place our statistical, marketing and social media cookies. More information can be found in our cookie policy.

You may withdraw your consent at any time. Our contact details can be found in section 2.8.

3.5. INTRODUCE collects indirect personal data of a job applicant based on its legitimate interest
You have posted your CV and contact details on platforms specifically designed for finding a suitable job (for example VDAB; Stepstone, …) (see more details in 4.2). Introduce may process this personal data and make initial contact with you based on its legitimate interest.

If, after initial contact, you express further interest in participating in a selection procedure with us today or in the future, we will include your personal data in our database with your consent.

3.6. Introduce and assessments
Introduce may ask candidates to complete an assessment during the selection procedure. Through this globally recognised method, Introduce gains insight into a person’s knowledge, skills and character traits, allowing a better assessment of suitability for a particular role.

For participants, this offers a unique opportunity for greater self-insight. Both development areas and strengths come to the surface. Based on this assessment, the candidate can enhance their professional capabilities and improve their chances on the labour market.

The processing of personal data during these assessments therefore falls under the legitimate interest of Introduce.

4. Which personal data do we process and for what purposes?

4.1. Of our business relations
Our business relations are our customers and suppliers. Introduce processes the personal data of individuals working for companies with which business is conducted. The purpose of this processing is to provide information about our services and to maintain business relationships.

To contact and identify you for customer and supplier management, we process name, first name, email address, mobile number, telephone number, date of birth, interests and hobbies, title, VAT number and financial information.

4.2. Of our candidates
For our candidates, we process name, first name, address, email address, gender, date of birth, nationality, language, photo, private and/or mobile phone number, marital status, education level, languages and IT skills, professional experience, obtained diplomas, hobbies, interests, memberships, current salary package.

We may also process personal data collected via other channels such as references, LinkedIn profiles, etc. If you wish to know our sources, you can always contact us to request this information.

Through this processing, we identify you, communicate with you and optimally guide you throughout your professional career.

4.3. Of our active prospects
Our potential new customers are interested in our services. We therefore wish to keep them informed about these services. To communicate with and identify them, we process name, first name, telephone and/or mobile number, email address, interests and hobbies, gender.

4.4. Cookies
INTRODUCE uses cookies on the website www.introduce.be. These are small information files stored on the device you use to visit our website, such as a computer, tablet or smartphone. When we refer to “cookies” below, we also mean other similar technologies. Cookies make it possible to recognise your web browser. This is convenient, as you do not need to repeatedly enter your details, indicate preferences or adjust settings. In this way, we can also improve the functioning of our website, gain insight into visitor behaviour, and allow other parties to gain insight into your browsing behaviour so they can show personalised advertisements across multiple websites and exclude irrelevant ads.

Cookies do not compromise the security of your computer.

We use functional, analytical, marketing and social media cookies. With the exception of functional cookies (necessary for the proper functioning of our website), we ask for your consent before placing these information files. More information can be found in our cookie policy.

5. About sharing and retaining your personal data

5.1. With whom do we share your personal data
We only share your data with persons who have explicitly received permission from us and who need this data to perform their tasks. These persons will process your data on the same legal basis as we received it from you.

As we act as an HR service provider, your personal data are only consulted by and/or passed on to our customers and your potential new employer with your consent.

For the proper functioning of our IT systems, we rely on external service providers. INTRODUCE works only with service providers who ensure the same technical and operational safeguards.

We only share your data further if required by law or a government order.

We do not sell or rent your personal data to third parties for their own use.

5.2. We do not retain your data indefinitely
INTRODUCE uses your personal data with a clear purpose in mind. Once this purpose has been achieved, the data are deleted. The guiding principle for retaining personal data is the statutory retention period.

We initially retain the personal data of our candidates for 5 years. If contact has taken place between the candidate and INTRODUCE during this period, a new 5-year period starts from that contact.

We initially retain the personal data of prospects for 5 years. If contact has taken place between the prospect and Introduce during this period, a new 5-year period starts from that contact.

We initially retain the personal data of existing customers, suppliers, subcontractors, … for 10 years. If new contact takes place during this period, a new 10-year period starts from that contact.