Privacy Policy v1 January 1st 2020

MyNextCompany, is committed to protecting your privacy and providing you with a positive experience on our Platform. We appreciate that you trust us with your information, and we intend to keep that trust. This Privacy Policy describes our privacy practices.

Topics:

  1. Who are we?
  2. Where does this Privacy Policy apply?
  3. What information do we collect?
  4. Cookies
  5. How do we use information?
  6. How do we share information?
  7. Cross-border transfers
  8. Your rights
  9. How do we protect information?
  10. How long do we retain information?
  11. Children’s information
  12. Privacy Policy changes
  13. How to contact us?

Who are we?

MyNextCompany, the tradename of ClearSource SPRL, having its registered office at 94 Gulledelle, 1200 Brussels, is registered with the Central Database for Enterprises as number 876.098.555 (Belgium Legal Persons Register) (hereinafter referred to as “MyNextCompany”). MyNextCompany is the data controller of your personal data.

Where does this Privacy Policy apply?

This Privacy Policy applies to the use of the Platform.

What information do we collect?

We collect information about you directly from you when you create an account on the Platform. We also collect information when you voluntarily upload a resume, complete surveys or forms or when you provide feedback.

Additionally, we collect information generated as you use the Platform, for example access logs, as well as information from third parties, like when you access Platform through a social media account like LinkedIn. Please find below details:

Information you give us

You choose to give us certain information when using the Platform. This includes:

  • When you create an account, you provide us with at least your login credentials, as well as some basic details necessary for the Platform to work, such as your name, email address etc..
  • When you complete your profile, you can share with us additional information, such as details on your personality, lifestyle, interests and other details about you, as well as content such as photos. Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions. By choosing to provide this information, you consent to our processing of that information.
  • When you participate in surveys or focus groups, you give us your insights into our Platform, responses to our questions and testimonials.
  • If you contact us, we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of the Platform.
  • Of course, we also process the content you publish, as part of the operation of the Platform.

Information we receive from others

In addition to the information you provide us directly, we receive information about you from others, including:

Social Media
You may be able to use your social media login (such as LinkedIn Login) to create and log into your Platform account. This saves you from having to remember yet another username and password and allows you to share some information from your social media account with us.

Information collected when you use the Platform

When you use the Platform, we collect information about which features you’ve used, how you’ve used them and the devices you use to access our Platform. See below for more details:

Usage Information
We collect information about your activity on our Platform, for instance how you use it (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive).

Device information
We collect information from and about the device(s) you use to access our Platform, including:

  • hardware and software information such as IP address, device ID and type, device-specific settings and characteristics, app crashes, , browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address);
  • information on your wireless and mobile network connection, like your service provider and signal strength;

Other information with your consent
If you give us explicit permission, we can collect your precise geolocation (latitude and longitude) through various means, including GPS, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the Platform if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it.

Cookies

We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s). You may read our Cookie Policy for more information on why we use them (such as authenticating you, remembering your preferences and settings, analyzing site traffic and trends, , allowing you to use social features) and how you can better control their use, through your browser settings and other tools.

How do we use information?

The main reason we use your information is to deliver and improve our Platform. Additionally, we use your information to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.

To administer your account and provide the Platform services to you

  • Create and manage your account
  • Provide you with customer support and respond to your requests
  • Complete your transactions
  • Communicate with you about the Platform, including subscription related matters

To help you connect with potential employers or candidates

  • Analyse your profile, activity on the Platform, and preferences to recommend meaningful connections to you and recommend you to others
  • Show users’ profiles to one another

To ensure a consistent experience across your devices

  • Link the various devices you use so that you can enjoy a consistent experience of our Platform on all of them. We do this by linking devices and browser data, such as when you log into your account on different devices or by using partial or full IP address, browser version and similar data about your devices to help identify and link them.

To serve you relevant offers and ads

  • Administer contests, discounts or other offers
  • Develop, display and track content and advertising tailored to your interests on our services and other sites
  • Communicate with you by email, phone, social media or mobile device about products or services that we think may interest you

To improve our services and develop new ones

  • Administer focus groups and surveys
  • Conduct research and analysis of users’ behaviour to improve our Platform, its related services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behaviour)
  • Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).

To prevent, detect and fight fraud or other illegal or unauthorized activities

  • Address ongoing or alleged misbehaviour on and off platform
  • Perform data analysis to better understand and design countermeasures against these activities
  • Retain data related to fraudulent activities to prevent against recurrences

To ensure legal compliance

  • Comply with legal requirements
  • Assist law enforcement
  • Enforce or exercise our rights,

To process your information as described above, we rely on the following legal bases:

  • Provide our service to you: Most of the time, the reason we process your information is to perform the contract that you have with us.
  • Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyse users’ behaviour on our Platform to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection and other legal purposes.
  • Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us here.

How do we share information?

We may share your personal information with third parties for the purposes of operating our business, delivering, improving, and customizing our Platform, sending marketing and other communications related to our business, and for other legitimate purposes permitted by applicable law or otherwise with your consent.

With potential employers/candidates

We share your information with potential employers/candidates when you voluntarily disclose information on the Platform (including your public profile). Please be careful with your information and make sure that the content you share is information that you’re comfortable being viewable since neither you nor we can control what others do with your information once you share it.

We may share your information with third party companies/candidates that could potentially be interested in your professional qualifications/job offering. We may also employ a third-party service provider to help us record, store and analyse this information to determine how we might best deliver the engagement.

With our service providers

We use third parties to help us operate and improve our Platform. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations.

We contractually require that our service providers protect such information from unauthorized access, use, and disclosure. The Internet, however, cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any personal information you provide to us.

For corporate transactions

We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.

When required by law

We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

To enforce legal rights

We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

With your consent or at your request

We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.

We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioural data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with third parties (notably advertisers) to develop and deliver targeted advertising on our Platform and on websites or applications of third parties, and to analyse and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources.

Cross border transfers

To the extent that any personal information is provided to third parties outside the European Economic Area (EEA), or who will access the information from outside the EEA, we will ensure that approved safeguards are in place, such as the approved Model Clauses provided by the European Commission or the EU/US Privacy Shield.

Your rights

We want you to be in control of your information, so we have provided you with the following tools:

  • Access / Update tools. Tools and account settings that help you to access, rectify or delete information that you provided to us and that’s associated with your account directly within the Platfrom. If you have any question on those tools and settings, please contact us for help.
  • Deletion. You can delete your account by using the corresponding functionality directly on the Platform.

We want you to be aware of your privacy rights. Here are a few key points to remember:

  • Reviewing your information. Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability or variations of those terms). You can request a copy of your personal information by putting in such a request with us.
  • Updating your information. If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us here.

For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.

Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user.

Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our Platform to you anymore. Accountability. In certain countries, including in the European Union, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established. If you wish to raise a complaint on how we have handled your personal data, you can contact us via this form. If you are not satisfied with our response or believe we are not processing your personal data in accordance with applicable laws you can complain to the Belgian Privacy Commission (https://www.dataprotectionauthority.be/).

How do we protect information?

We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure.

We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.

We may suspend your use of all or part of the Platform without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately here.

How long do we retain information?

We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law.

We delete or anonymize your information upon deletion of your account or after a year of continuous inactivity, unless:

  • we must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations);
  • we must keep it to evidence our compliance with applicable law;
  • there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
  • the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behaviour or security incidents from opening a new account.

Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.

Children’s information

Our Platform is restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our Platform and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please use the reporting mechanism available through the Platform.

Privacy Policy changes

We keep our Privacy Policy under regular review, and we place any updates on this webpage. This Privacy Policy V1 was last updated on January 1st 2020.

How to contact us?

If you have questions about this Privacy Policy or about information that we hold about you, please contact us via this form.