THE PRIVACY STATEMENT OF THALENTO® NV
Thalento® NV is committed to the guarantee of privacy and data protection. By means of this privacy statement (hereinafter referred to as the "Privacy Statement"), Thalento® NV wishes to inform the participant in detail about the processing of his/her personal data and associated rights when using the Thalento® platform. We encourage you to read this privacy statement carefully.
By using the Thalento® platform, Thalento® NV will have access to your personal data, which will be processed with respect for the privacy of the participant and with compliance to the law of 8 December 1992 on the protection of privacy with respect to the processing of personal data, which will be replaced from 25 May 2018 by the (European) General Data Protection Regulation (also known as the GDPR).
If you wish to receive more information concerning privacy and data protection, please visit the website of the Commission for the Protection of Privacy (also referred to as the Privacy Commission).
Whenever we modify this Privacy Statement, you will be informed. If applicable users will be asked to accept the new and therefore most recent version of this Privacy Statement.
This Privacy Statement was last reviewed on 14 May 2018.
TO WHOM DOES THIS PRIVACY STATEMENT APPLY?
This Privacy Statement applies to all of our potential/present/previous participants and users of the Thalento® platform.
CONTACT DETAILS THALENTO® NV
Corda Campus – Corda 6
Kempische steenweg 293/35
3500 Hasselt, België
Company number 0830.586.452
WHAT MEANS …
- Processing of personal data
By 'processing' we mean any operation or set of operations performed on personal data (whether or not by automatic means, such as collection, recording, organisation, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, as well as the blocking, erasure or destruction of personal data).
By 'personal data' we mean all information about an identified or identifiable natural person.
- A processor
A processor is the natural or legal person, de facto association or public administration who processes personal data on behalf of the controller, with the exception of persons who are authorised to process the data under the direct authority of the controller.
- A controller
A controller (person in charge of processing) is any natural or legal person, de facto association or public administration who alone or jointly with others determines the objectives and legal and technical means for the processing of personal data.
- A user
A user is an individual who uses the Thalento® platform to organize an e-assessment.
- A participant
A participant is an individual who uses the Thalento® platform by answering questions.
WHO IS RESPONSIBLE FOR THE PROCESSING?
Thalento® as a processor
Thalento® is considered to be a processor of personal data in so far as it processes personal data on behalf of its customers, in which case these customers act as data controllers.
Thalento® as the data controller
Thalento® is considered controller and responsible for processing when it determines the purpose and means for the processing of personal data.
If you apply to company X and you complete an assessment via company X using the Thalento® platform, company X is responsible for processing, while Thalento® NV is the processor.
If you carry out an assessment directly via Thalento® NV within the Thalento® platform, Thalento® NV is responsible for processing.
The Thalento® platform offers a wide range of possibilities for the customer/participants to process personal data. If the customer copies your personal details from Thalento® on his own initiative and processes them via another medium, the customer will be responsible for processing.
A participant who wishes to exercise his rights as a data subject must always contact the controller.
WHO IS A DATA PROTECTION OFFICER?
Thalento® NV has appointed a Data Protection Officer who is responsible for supervising and monitoring Thalento®'s privacy and data protection policy with respect to the processing of personal data. You can contact the Data Protection Officer on email@example.com for all of your questions concerning privacy and data protection, regarding the processing of your personal data and the exercise of your rights.
WHAT PERSONAL DATA IS PROCESSED BY THALENTO® NV WHEN OFFERING THALENTO® SERVICES?
The personal data processed by Thalento® is the data you provide to us when you use our platform, whether or not at the request of our customer (e.g. by answering questionnaires).
For the Thalento® user
Organising e-assessments in function of the development of professionals.
Thalento® processes the personal and electronic identification data of the Thalento® users in function of the ability to organize e-assessments based on the legitimate interest of Thalento®.
Thalento® processes images and additional personal identification data from the Thalento® user in function of creating a Thalento® account and based on your permission.
Thalento® processes personal identification data of the Thalento® user in the context of the customer relationship in order to keep them informed of other products and services and allows Thalento® users to unsubscribe at any time, based on the legitimate interest of Thalento®.
For the Thalento® participant
Performing e-assessments on personality and motivation, cognitive and skills characteristics, language and technical knowledge.
Thalento® processes personal identification data in order to carry out the above e-assessments and compile the corresponding reports. This is done on the basis of the personal data Thalento® obtains and collects through questionnaires. The processing of personal data is based on legitimate interest in the function of the assessment of the employee's working capacity.
Thalento® uses the results of the many participants to situate an individual participant between other participants, which act as a reference group. In this context, Thalento® anonymises or aggregates the personal data of former participants in order to identify possible reference groups.
Thalento® NV only processes sensitive personal data if the participant has given his explicit consent prior to processing. In order for explicit consent to apply, content must be obtained in a free, specific, informed manner and by an unambiguous active act. If required, Thalento® NV will ask you specifically for the use of this information.
As a participant, you have the right to withdraw your consent at any time. See What are my rights and how can I exercise them?
Google Analytics is a web analytics service provided by Google Inc. ("Google"). Thalento® NV uses Google Analytics within the Website. Thalento® NV does not transfer any personal data to Google. By analysing this information, based on legitimate interest, Thalento® NV learns how the website is used and Thalento® NV can improve it.
WHO RECEIVES MY PERSONAL DATA?
When a participant uses the Thalento® platform, Thalento® NV collects personal data. Only if this processing is carried out on behalf of a customer (as controller) will this customer also receive the personal data of the participant.
Your personal data will not be passed on to other external parties without prior consent, unless Thalento® NV is obliged to do so on the basis of a statutory provision or a court order. Your personal data will not be passed on to the partners of Thalento® NV.
IS ANONYMOUS DATA USED FOR REPORTING PURPOSES?
We may use anonymous data for commercial purposes or for external reporting. Anonymous data are personal data that are rendered anonymous to such an extent that they no longer relate to an identified or identifiable person, or the data is displayedanonymously so that the individual is not, or is no longer, recognisable.
HOW LONG WILL MY DATA BE STORED?
Thalento® NV will only retain your personal information for the minimum period necessary to fulfill the purposes set out in this Privacy Statement, except in the case of dispute resolution or if a longer retention period is required by law. Non-personal information may be retained without restriction for statistical purposes.
DATA SECURITY AND RETENTION
Thalento® NV acknowledges that the security of personal data is part of data protection. Thalento® NV therefore takes appropriate technical and organisational measures to protect your personal data against unauthorised processing or unauthorised access in order to prevent misuse.
When transferring personal data to a processor outside the EEA, Thalento® NV always does so in accordance with the terms of this Privacy Statement and Thalento® NV follows the applicable data protection laws and regulations to ensure adequate safeguards.
Cookies are text files that can be placed on your computer in order to collect standard internet logging information and behavioural information. This information is used to track the visitor behaviour of the Thalento® Platform and to compile statistical reports on the Thalento®platform.
WHAT ARE MY RIGHTS AND HOW CAN I EXERCISE THEM?
A participant who wishes to exercise his rights as a data subject must always contact the controller. See: who is responsible for processing: who is responsible for the processing?
How can I exercise my rights as a data controller at Thalento® NV ?
You can exercise your rights by sending an e-mail to firstname.lastname@example.org.
In order to prevent any unauthorised disclosure of your personal data, it is mandatory to send the request stating the e-mail address linked to your Thalento® account. In addition, we ask you to state when you last participated in an assessment within the Thalento® platform, as well as for which client.
Thalento® NV has one month to reply to your request. This period starts when Thalento® NV has received your application and has all the information required to satisfy it.
Thalento® NV will provide the requested information free of charge. Where requests are unfounded or excessive, in particular because of their repetitive nature, Thalento® NV may charge a reasonable fee or Thalento® NV may refuse the request.
If for any reason you believe that Thalento® NV has not dealt with your application correctly, you can contact the data protection officer of Thalento® NV at email@example.com who will work with you to resolve any issues.
For the sake of completeness, we inform you that if Thalento® NV does not respond to your request, if it refuses or if the response does not meet your expectations, you are entitled to lodge a complaint with the Commission for the Protection of Privacy (Privacy Committee), Drukpressstraat 35 in 1000 Brussels or firstname.lastname@example.org.
What rights can I exercise?
- Right of access: You can ask us which personal data we process from you, what we process it for, which categories of personal data we process, with which categories of third parties we share your personal data, what the origin of the data processed is.
- Right of rectification: It is currently possible for each participant to improve their account details whenever an assessment is started via the Thalento® platform. In order to keep your data up to date, please make any changes yourself or contact us.
- Right to erase data: You can ask us to erase your account. As a result, it is no longer possible to use the Thalento® platform. After the request, Thalento® NV will suspend your account for 30 days in order to give you the necessary reflection period. After that, the account will be anonymised. See also: Is anonymous data used for reporting purposes?
- Right to limitation of processing: in the cases defined in Belgian and European privacy legislation. Where processing within the Thalento®platform is restricted, your personal data (except for storage) will only be processed with your consent or for the creation, exercise or defence of any legal claim or for the protection of the rights of any other natural or legal person or for reasons of public interest. After obtaining this processing restriction, you will always be notified by Thalento® NV before the processing restriction is lifted.
- Right to withdraw consent: If the processing of personal data is based on basic consent, you as a participant have the right to withdraw this consent at any time.
- Right of objection: You have the right to object to the processing of your personal data only if the processing is based on a general interest or a legitimate interest.
IS MY DATA USED FOR AUTOMATIC DECISION MAKING?
There is no automatic decision-making, including profiling, within the Thalento® platform.