Privacy & cookie policy | USHR

Who we are

“We”, “us” or “our” means USHR, a division of Dull Consulting NV, with its registered office at Veldkant 33A, 2550 Kontich and with company number BE 0650.716.085. We act as controller for the personal data we gather through your use of our website.

This Privacy Policy is solely intended to provide you with information in relation to the processing of personal data through your use of the website. For our privacy practices in relation to our services, we refer you to the agreement as may be concluded between us.

Your privacy is important to us, so we’ve developed this Privacy Policy that sets out how we collect, disclose, transfer and use (“process”) the personal data that you share with us, and which rights you have. Please take a moment to read through this policy.

If you have any questions, concerns or complaints regarding this Privacy Policy or our processing of your personal data or you wish to submit a request to exercise your rights as set out in article 4, you can contact us:

  • Via-mail: info@ushr.be, to the attention of our founder;
  • By post: to Company management, Veldkant 33A, 2550 Kontich.

This Privacy Policy was revised last on (04/09/2020).

How we use and collect your personal data

Personal data is defined as any information relating to an identified or identifiable natural person. Identifiable refers to identifiers (such as name, identification number, location data, etc.), that can be used to directly or indirectly identify a natural person.

The personal data we collect, is collected and used for the purposes as listed hereunder:

  • In the event you use the contact form on our website, we will use your personal data in order to reply to your query, via e-mail or telephone.
  • In the event you use the contact forms to apply for a vacancy (silhouette), we will use your personal data to track your application progress and keep this no longer than legally required.
  • In the event you register for our newsletter, your e-mail address will be used in order to send you our newsletters, which may include invites to events, seminars, etc. organized by us.
  • We process your personal data for the purpose of supporting the website and enhancing your user experience, which includes ensuring the security, availability, performance, capacity and health of the website.

We process your personal data to enforce or exercise any rights that are available to us based on the applicable law, such as use for the establishment, exercise or defense of legal claims.

We may also use your personal data to fulfil our obligations as set out by the applicable law.

The following categories of personal data can be distinguished:

  • Contact data: in the event you make use of the contact form, you will be asked to provide the following information: name, address, e-mail address, phone number, and any personal data that you choose to put in the designated blank field (please do not provide us with any sensitive information, such as health information, information pertaining to criminal convictions, or credit card/account numbers). This is information that is provided directly by you.
  • Newsletter: If you register for our newsletter, you will be asked to provide your e-mail address. This is information provided directly by you
  • Usage data: We collect personal data regarding your activities on our website: IP address, device ID and type, referral source, language settings, browser type, operating system, geographical location, length of visit, page views, or information about the timing, frequency and pattern of your service use. This information may be aggregated and used to help us provide more useful information regarding the use of our website. In the event the usage data is completely anonymized (and can therefore not be traced back to you as an individual), this will not be considered personal data for the purpose of this Privacy Policy. This is personal data that is automatically collected through your use of the website.
  • Transaction data: We collect personal data relating to transactions that you make through the website, including your “contact data”, payment information and the goods and/or services purchased. This is personal data provided directly by you.
  • Name category: We collect personal data related to your job application: your name, phone number and email address. This is personal data provided directly by you or collected via the contact forms.
  • 6 months after the termination of your search for a job with us.

The legal basis for the processing of your personal data is your application on the jobs listed on our website.

In the event the legal basis for the processing of your personal data is consent, you will, at all times, have the right to withdraw your consent. This will, however, not affect the lawfulness of any processing done prior to the withdrawal of consent.

In the event the legal basis for processing is our legitimate interests the public interest, you will have the right to object to such processing, as set out in article 4.12 of this Privacy Policy.

Your personal data will solely be used for the purposes as set out in this article.

Retention of your data and deletion

Your personal information will not be kept for longer than is necessary for a specific purpose. However, considering it is not possible for us to specify a period in advance, the period of retention will be determined as follows:

In the event you withdraw your consent or you object to our use of your personal data, and such objection is successful, we will remove your personal data from our databases. Please note that we will retain the personal data necessary to ensure your preferences are respected in the future.

The foregoing will, however, not prevent us from retaining any personal data if this is necessary to comply with our legal obligations, in order to file a legal claim or defend ourselves against a legal claim, or for evidential purposes.

Your rights

This article lists your principal rights under data protection law. We have tried to summarize them for you in a clear and legible way.

To exercise any of your rights, please send us a written request in accordance with article 1 of this Privacy Policy. We will respond to your request without undue delay, but in any event within one month of the receipt of the request. In the event of an extension of the term to respond or in the event we do not take action on your request, we will notify you.

The right to access

You have the right to confirmation as to whether or not we process your personal data and, in the event we do so, you have the right to access such personal data, together with certain additional information that you also find listed in this Privacy Policy.

You have the right to receive from us a copy of your personal data we have in our possession, provided that this does not adversely affect the rights and freedoms of others. The first copy will be provided free of charge, but we reserve the right to charge a reasonable fee if you request further copies.

The right to rectification

If the personal data we hold about you is inaccurate or incomplete, you have the right to have this information rectified or, taking into account the purposes of the processing, completed.

The right to erasure (right to be forgotten)

In some circumstances, you have the right to the erasure of your personal data without undue delay. Those circumstances include:

  • The personal data are no longer needed in relation to the purposes for which they were collected or otherwise processed;
  • You withdraw your consent, and no other lawful ground exists;
  • The processing is for direct marketing purposes;
  • The personal data have been unlawfully processed; or,
  • Erasure is necessary for compliance with EU law or Belgian law.

There are certain exclusions to the right to erasure. Those exclusions include where processing is necessary,

  • for exercising the right of freedom of expression and information;
  • for compliance with a legal obligation; or,
  • for the establishment, exercise or defense of legal claims.

The right to restrict processing;

You have the right to restrict the processing of your personal data (meaning that the personal data may only be stored by us and may only be used for limited purposes), if:

  • You contest the accuracy of the personal data (and only for as long as it takes to verify that accuracy);
  • The processing is unlawful and you request restriction (as opposed to exercising the right to erasure);
  • We no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; or,
  • You have objected to processing, pending the verification of that objection.

In addition to our right to store your personal data, we may still otherwise process it but only:

  • with your consent;
  • for the establishment, exercise or defense of legal claims;
  • for the protection of the rights of another natural or legal person; or,
  • for reasons of important public interest.

We will inform you before we lift the restriction of processing.

The right to data portability

To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

You also have the right to have your personal data transferred directly to another company, if this is technically possible, and/or to store your personal data for further personal use on a private device.

The right to object to processing

You have the right to object to the processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for:

  • The performance of a task carried out in the public interest or in the exercise of any official authority vested in us;
  • The purposes of the legitimate interests pursued by us or by a third party.

If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

The right to complain to a supervisory authority

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. In Belgium, you can submit a complaint to the Authority for the protection of personal data (Privacy Commission), Drukpersstraat 35, 1000 Brussel (commission@privacycommission.be),https://www.privacycommission.be/nl/contact.

Providing your personal data to others

In order to provide you with our website, we work with service provider to process and store your personal information. We use the following categories of service providers:

The companies you apply for through our website

We may also disclose your personal data in the event such disclosure is required or necessary in order to fulfil a legal obligation. We may also disclose personal data in order to protect your vital interests or the vital interest of another natural person.

As such, we do not disclose your personal data to our social media partners. We do, however, make use of social media plugins to direct you to our social media channels and to allow you to interact with our content. These social media channels are Facebook and LinkedIn. In the event you click such link, such social media service provider may collect personal data about you and may link this information to your existing profile on such social media.

We are not responsible for the use of your personal data by such social media service provider. In such case, the social media service provider will act as controller. For your information only, we have included the relevant links (these may be changed from time to time by the relevant service provider):

international transfers

We will not transfer your personal data outside of the European Economic Area

Cookies

What are cookies?

Cookies are small pieces of data that a website asks your browser to store on your computer, laptop or mobile device when you visit a website or certain pages of that specific website. The cookie allows that website to “remember” your actions or preferences over time and to apply them during subsequent visits, for example your preferred language.

Cookies usually contain the name of the website where the cookie has come from, how long the cookie will remain on your device (its expiry date), and a value which is usually a randomly generated unique number.

A distinction is made between strictly necessary cookies and other cookies.

The strictly necessary cookies are necessary for the proper functioning of the Website, for example for the security of our Website and its accessibility. By virtue of the applicable legislation, we are not required to ask your consent to use such cookies.

A further distinction on the basis of the category can be made according to the specific purpose of the cookie. For each of these categories (unless they are strictly necessary), we will ask your consent.

Cookies can be divided into the following categories:

  • Permanent cookies and session cookies: The task of a permanent cookie is to recognize the web browser with a view to repeat visits to the Website, while the task of a session cookie is to recognize the web browser during the visit to the Website. Permanent cookies will remain stored on your computer or mobile device. Session cookies will be deleted at the end of every session.
  • First party cookies and third party cookies: first party cookies are set by the Website itself. Third party cookies are set by other websites than our Website. This happens when our Website incorporates elements from other websites, such as social media plug-ins or advertisements that are put on our Website.
  • Performance cookies and functional cookies: performance cookies monitor how the visitor uses the Website. This enables the website administrator to adjust and optimize the content and ease of use of the Website (for example: how many people have visited the different pages on the Website and which language is the most popular amongst our visitors). Functional cookies are cookies that remember your preferences when you use the Website, such as your chosen language, and will make the Website more user-friendly and enhancing your user experience.

Cookies will not always contain personal data but may contain information that may lead to your identification, in which case such cookie shall be treated as personal data. To the extent a cookie can be considered as personal data, our Privacy Policy will apply.

Which cookies do we use? [IB1]

Strictly necessary cookies: These are required for the operation of our Website. They include for example cookies that enable you to log in. No consent for these cookies is required.

Name

Category

Content of cookie

Purpose

Retention period

Other cookies: These cookies can be divided into different categories, as mentioned earlier in this Cookie Policy. For these cookies, your consent is required.

Name

Category

Content of cookie

Purpose

Retention period

Cookies used by our partners[IB2]

Our Website makes use of social media plugins. These social media partners use third party cookies. The following social media partners are used: LinkedIn, Facebook. We refer to article 5 of the Privacy Policy for how we use these social media plugins. For your information, we will also provide you the links to the relevant cookie policies:

Managing and blocking cookies

When visiting the Website visitors will be informed (by means of a pop-up) which cookies are being used by us, and we will ask the visitor’s consent for the use of each of the cookies. You can at all times manage or delete cookies using the settings on your internet browser, allowing you to refuse some or all cookies, except for the strictly necessary cookies, since these cookies are essential for the visitor to browse the Website and its features. Turning off cookies will limit the service that we are able to provide and may affect your user-experience. Deleting cookies may result in manually adjusting preferences every time you visit our Website.

For more details about controlling and/or deleting cookies, visit the page corresponding to your browser for more information:

Amendments to the Cookie Policy

We reserve the right to make amendments to this Cookie Policy. The most recent version of the Cookie Policy can be consulted on our Website. or visit, http://aboutcookies.org/how-to-delete-cookies/.

Amendments to the privacy policy

From time to time, we have the right to modify this Privacy Policy. You will always be able to consult the most recent version of the Privacy Policy on the website

[IB1]To be completed. This is different for every website. In the event only strictly necessary cookies are being used, the other table can be deleted. In that case, no consent will be required from the visitors of your website. In the event you also have to complete the “other cookies” table, you have to provide a pop-up on your website so that every visitor can provide its “active consent” for each category of cookie that is being used.

In the event Google Analytics is used, this is to be incorporated in the table under ‘Other cookies’.

[IB2]These are third party cookies and can be added under ‘other cookies’. Make sure the relevant links to the third parties are also incorporated in the cookie policy.

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