1. Version

This policy was last updated on 04-07-2023

2. Short Description - Highlights

Summ.link BV is committed to maximizing the protection of your personal data in compliance with the General Data Protection Regulation (GDPR). We strictly process your data for the intended use and adhere to applicable privacy regulations. You have the right to opt-out of non-essential messages and exercise your data rights by contacting us. For essential communication and legally required purposes, opting out may not be possible. Contact us at support@summ.link or through our website for any inquiries.

3. Company Identification & Contact

3.1. HQ

Summ.link
Nederkouter 26
B-9000 Gent
Belgium.
Company registration number: BTW BE 0651.734.783

3.2. General contact

Email: support@summ.link
Website: https://summ.link/

4. Services

We offer the following services that require the processing of personal data:

• Professional Services: People Analytics and Data Science/Engineering roles
• Products: Centr.jobs and Un.whyre

5. Website

For information about our website and its data processing practices, please refer to our Cookie Policy available on our website.

6. Company Internal Operations

If you have any questions as a current or former employee, please contact us at people@summ.link.

7. Data Collection - Website Visitors

We collect the following data from website visitors:

• Behavior: Information on how you use our website, emails, app, products, and platform transactions.
• Data from Other Sources: Data obtained from other sources while using our website.
• IP Address and Location: Your IP address and location when using our app or website.

8. Data Collection - Candidates

If you apply for a job, we collect the following data:

• Curriculum Vitae
• First name
• Last name
• Contact details such as email and phone number

9. Data Collection - Prospects

If you are a prospect, we collect the following data:

• Contact data
• Correspondence with us

10. Data Usage

10.1. To Allow You to Use Our Services

Summ.link services are, amongst others:

• Hiring employees
• Hiring freelancers
• Applicant tracking
• Monthly payments / Payroll

If you use our services, we process the following personal data based on the specific service:

1. First name, Last Name, Personal post address, Personal contact details, CV info, Children + details, Gender, Preferred language, DOB, Criminal weaver, Civil status, Emergency contact details, References, ID documents, Visa / work permit (if applicable), Drivers license.
2. First name, Last Name, Personal post address, Personal contact details, CV info, Gender, Preferred language, DOB, Criminal weaver, Emergency contact details, References, ID documents, Visa / work permit (if applicable), Drivers license.
3. First name, Last Name, Personal post address, Personal contact details, CV info, Gender, Preferred language, DOB, References.
4. First name, Last Name, Personal post address, Personal contact details, Children, Gender, DOB, Civil status, References, Comp&Ben, Bank details.

10.2. To Communicate With You

We may communicate with you via email, WhatsApp, social media, telephone, SMS, messenger, and internal collaboration tools to address your inquiries. We may also provide targeted information on services and products based on legitimate interest or your explicit request. You can opt-out of receiving such communications.

11. Website - Tooling

We use your data on the website to improve and personalize your browsing experience. We utilize the following tools on our website:

• Google Analytics: We use Google Analytics to collect information about your interactions with our website, such as the pages you visit, the time spent on each page, and the referring website. This helps us analyze website traffic and improve our website's functionality and user experience. Google Analytics may collect and process your IP address and other browsing data. Please refer to Google's Privacy Policy for more information on how Google Analytics handles your data.
• Google Tag Manager (GTM): We utilize Google Tag Manager to manage and deploy tags on our website. These tags are used to track user interactions, website analytics, and marketing campaigns. GTM does not collect personally identifiable information (PII) and operates in accordance with Google's Privacy Policy.
• Microsoft Clarity: We employ Microsoft Clarity to gain insights into user behavior and improve website performance. Microsoft Clarity may record and analyze actions and interactions on our website, including mouse movements, clicks, scrolling, and non-personally identifiable information. Refer to Microsoft's Privacy Policy for further details on how Microsoft Clarity handles your data.

12. Legal Basis for the Processing of Your Data

We process your personal data in strict accordance with the applicable privacy legislation and on the basis of the following legal grounds:

• Performance of the agreement: we need to process some of your data to deliver our services and comply with our obligations. For example, we need your contact details to be able to deliver your parcels, your e-mail address to let you know that your visitor has arrived, the address of your addressee to be able to send a parcel and your invoicing data to be able to invoice you (if you use a paying service).
• Legal obligation: in some cases, we are legally obligated to process certain information about you, for example, when we have to send your invoices.
• Legitimate interest: if you are a customer, user or more generally in an existing trade relationship with us, we will send you information and newsletters about our products and services based on a legitimate interest to do so, unless you have unsubscribed.
• Consent: we may also process your data if we are given express consent, e.g. when you register for a newsletter or for certain (targeted) offers (direct marketing).

13. Data Sharing

We only share your personal data with the following trusted partners:

• Besox: Our payroll provider, to process salary payments and related HR administration.
• Mbrella: A mobility planning service provider, to assist with transportation-related services.
• Officient: An HCM (Human Capital Management) tool, to streamline HR processes and employee management.
• Alan: A healthcare planning service provider, to offer healthcare-related benefits and support.

We have data processing agreements in place with these partners to ensure they handle your data in compliance with applicable data protection laws and regulations. There are companies that could process your data for their own purposes via third-party cookies, for more information see the Summ.link Cookie Policy.

14. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes outlined in this policy or as required by law. The retention period may vary depending on the type of data and the purpose for which it is processed.

15. Security Measures

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures are in line with the recommendations of the General Data Protection Regulation (GDPR) and ISO 27001 standards.

16. Your Rights

You have the following rights regarding your personal data:

• Right to access: You can request access to the personal data we hold about you.
• Right to rectification: You can request the correction or update of your personal data if it is inaccurate or incomplete.
• Right to erasure: You can request the deletion of your personal data under certain circumstances.
• Right to restrict processing: You can request the restriction of processing your personal data under certain circumstances.
• Right to data portability: You can request a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to object: You can object to the processing of your personal data under certain circumstances, such as for direct marketing purposes.
• Right to withdraw consent: If we process your personal data based on your consent, you have the right to withdraw your consent at any time.

To exercise your rights or for any privacy-related inquiries, please contact us at privacy@summ.link.

17. Changes to the Policy

We may update this Data Protection Policy from time to time. The latest version will be published on our website, and any substantial changes will be communicated to you

18. Your Right to Submit a Complaint regarding Data Usage

We value your trust and take your data privacy seriously. If you believe that we have mishandled your data in any way, we encourage you to bring your concerns to our attention. By informing us of your objections, we can thoroughly investigate the matter and take appropriate steps to address and resolve any issues that may arise. In addition to contacting us directly, you also have the right to lodge a complaint with the relevant data protection authorities. The following bodies can receive and assess complaints related to data protection:

• De Gegevensbeschermingsautoriteit (BE)
• De Autoriteit Persoonsgegevens (NL)
• Der Bundesbeauftragte für den Datenschutz (DE)
• CNIL, La Commission Nationale de l'Informatique et des Libertés (FR)
• La Commission nationale pour la protection des données (LU)
• Garante per la Protezione dei Dati Personali (IT)
• The Information Commissioner's Office (UK)

These authorities are responsible for safeguarding data protection rights and ensuring compliance with relevant regulations in their respective jurisdictions. Please note that we strive to address any concerns internally and resolve them to your satisfaction. However, should you choose to escalate the matter to a data protection authority, we respect your right to do so and will cooperate fully during any investigation.

It is important to us that your data is handled in accordance with applicable laws and regulations, and we appreciate your feedback and engagement in helping us maintain a high standard of data protection.

19. Compliance with Data Protection Legislation

Our commitment to protecting your data is in accordance with the relevant "Data Protection Regulations", which encompass international, European (such as GDPR), and national legislation, as well as binding recommendations and regulations issued by privacy authorities. To ensure transparency and alignment with evolving privacy requirements, we reserve the right to update this Data Protection Policy periodically. Any changes will be reflected in a new version posted on our website. We strongly encourage you to regularly review this page to stay informed about any modifications. In the event of significant changes to this policy that may impact your rights or how we handle your data, we will notify you through postings on our website or, where applicable, by directly contacting prospects and customers. Additionally, we maintain an archive of previous policy versions, which you can access by contacting us. By adhering to applicable data protection legislation and keeping you informed of any policy updates, we aim to maintain the highest standards of privacy protection and ensure our practices align with your expectations.