INTRODUCTION AND SCOPE
- Other relations of Sqales;
- And visitors to the website of https://www.sqales.com/ or any domain name associated with it.
It is important to us that your personal data is handled with all due care. We comply with all statutory rules, including the General Data Protection Regulation (GDPR), and exercise due care to secure your personal data adequately.
Table of Contents
- The personal data pertaining to you, which we can process
- Why do we process your personal data?
- Grounds on which we process personal data
- Sharing personal data with third parties
- Sharing personal data outside the European Economic Area
- Your rights
- Minors on Sqales’s website
- Cookies and similar applications
- Contact details/questions/complaints
- Retention periods
- Amendments and applicable law
Data subject: A person whose personal data is processed.
Third parties: Natural or legal persons who are not data subjects or part of Sqales, such as natural or legal persons with which Sqales shares personal data pursuant to a contract. These third parties might be processors or co-controllers.
Personal data: All data related to an identified or identifiable person.
Processing: Everything that can be done with personal data, such as collection, recording, storage, alteration, retrieval, use, dissemination, and destruction.
The personal data pertaining to you, which we can process
Below, we explain which of your personal data Sqales can process.
Data you have provided yourself, such as:
- Your contact details (name, address, city/town of residence, email address, telephone number, and function title);
- Your gender and date of birth;
- Data collected from you in a telephone conversation;
- Data collected from an email from you;
- Payment details;
- Data from your CV or about your employment history.
Data we have received via our websites, newsletters, and emails:
- Information about the device you used to visit our website;
- Your surfing behavior on the website, such as:
- Which data/which of our web pages you viewed;
- How you navigate the website;
- Whether you open a newsletter or email and which parts of it you click on;
- The dates and times of your visit to the website;
- The operating system you are using;
- Your browser type and IP address;
- The internet address of the website to which the link is made;
- The geolocation;
- The data you downloaded from the website.
Data we have received from other sources, such as:
- Public sources available and made public by you, such as on social media and business websites;
- The Trade Register of the Chamber of Commerce and the Land Registry.
Why do we process your personal data?
We use your personal data for the following purposes:
- To verify your identity;
- To improve our services (and the safety of those services), including by conducting checks;
- To inform you about news and developments at Sqales and Sqales’s products and services;
- To enable us to evaluate, study, and develop our services;
- To contact you for newsletters if you have signed up for them;
- For internal quality purposes;
- To manage, secure, adjust, and improve our websites;
- For marketing/commercial purposes;
- For recruitment and selection;
- To comply with a statutory obligation imposed on Sqales;
- To be able to contact you and respond to any questions you have submitted;
- To deal with your requests for information and to settle complaints;
- To prevent theft, misuse, vandalism, or other criminal conduct;
- To enable us to conduct satisfaction surveys.
Grounds on which we process personal data
To use personal data, we must have grounds based on the GDPR.
We use the following grounds:
- You have given Sqales your explicit consent;
- The use is necessary for performing or entering a contract with you;
- The use is needed to comply with a statutory obligation;
- In emergencies: the use is required to protect your vital interests or those of another person;
- We have a legitimate interest in the use unless this interest is outweighed by your or a third party’s interest in privacy.
Sqales can invoke the following legitimate interests:
- The protection of your safety;
- The protection of the safety of our clients and/or others and the security of our buildings and property;
- Quality and training;
- The advancement of IT management and the improvement of security;
- The analysis and improvement of the services and content of our websites;
- The supply, improvement, adjustment, support, research, and analysis of our services;
- The advancement of the quality and security of our services;
- Communication with you and other contacts of Sqales;
- The prevention and combating of fraud and unauthorized use.
- The prevention and combating of violations against our general terms and conditions, policy rules, or other harmful or illegal activities.
Sharing personal data with third parties
Sqales may engage contractors from the following categories:
- Organizations Sqales provides sales outsourcing for;
- IT management;
- Website management;
- Website hosting.
Sqales remains responsible for the processing of your personal data. Sqales enters contracts with third parties to ensure your personal data is properly secured.
Sqales may, as the result of a merger, acquisition, or sale of all or part of its organization, share your personal data with a third party, such as a potential buyer or seller. Naturally, we will inform you of this via email and/or a visible notification on our website, and we will notify you of your rights in such a situation.
Sharing personal data outside the European Economic Area
It may sometimes be necessary to transfer your personal data to third parties established outside the European Economic Area (EEA). In accordance with the GDPR, Sqales will only transfer your personal data to countries outside the EEA if:
- The European Commission has decided that the third country offers an adequate level of protection; or
- Appropriate safeguards are offered, you have enforceable rights, and you have effective legal remedies; or
- The transfer is necessary for the performance of your contract with Sqales; or
- You have expressly consented to the transfer after being informed of the risks that such transfer entails; or
- The transfer is necessary for important reasons of public interest; or
- The transfer is occasional and required by the compelling interests of Sqales, and we implemented appropriate safeguards and have informed the Dutch Data Protection Authority of these.
In situations where Sqales transfers your personal data outside the EEA, we ensure that your personal data remains adequately protected.
At Sqales, we take your privacy seriously and the security of your personal data. Strict safety measures are crucial, especially within the recruitment industry. We make it extra hard for malicious people to access our systems.
We have taken the following measures, among other things:
- Access to personal data is restricted to authorized people, whereby this number is kept as low as possible;
- All employees of Sqales have signed a confidentiality agreement whereby they undertake to observe complete confidentiality regarding all information (including personal data);
- The electronic transmission of personal data always takes place via a secure connection;
- The website is secured via HTTPS;
- We ensure that your personal data is only shared with third parties if we have agreed on appropriate security measures with these third parties.
If your personal data is processed, you have several rights. These are set out below. You can exercise these rights by submitting your request in writing to Sqales or by emailing firstname.lastname@example.org. Sqales will verify your identity before your submission can be fulfilled.
Sqales will respond to your request as soon as possible, in one month at the latest. Sqales will only charge you for processing your aforementioned requests if your requests are excessive.
- Access to personal data
You can ask us any time to indicate which (categories of) your personal data Sqales processes, for which purposes, from which source the data comes, and which retention periods are applied.
- Changing personal data
In addition, you can contact us at any time to complete or correct your personal data. In the unlikely event that Sqales has processed and/or provided incorrect personal data about you, Sqales will rectify this immediately. If Sqales has changed your personal data, Sqales will notify you accordingly.
- Minimizing the processing of your personal data
If you disagree with the content of the personal data about you stored by Sqales, you can submit a request to minimize the processing of your personal data temporarily.
- Withdrawing consent
You can also withdraw the consent you have given for the processing of your personal data. Upon receipt of your letter or email, Sqales will immediately cease processing your personal data for which you have given your consent. However, withdrawing your consent will not affect the processing operations that have already taken place.
- Right to transfer personal data (right to data portability)
You can retrieve the personal data about you stored by Sqales in a structured, commonly used, and machine-readable format. After receiving your personal data, you are free to transfer this information.
- Right to be forgotten
If you no longer wish to make use of Sqales’ services, you may submit a request for the deletion of all your personal data.
- Right to object
You have the right to object to processing your personal data, which Sqales bases on the grounds of a legitimate interest of Sqales or a third party or ‘performance of a task carried out in the public interest.’ If Sqales bases itself on these grounds, Sqales will weigh its interests against your privacy. The right to object entitles you to require Sqales to repeat this weighing of interests.
- Right to lodge a complaint/pursue a judicial remedy
We make efforts to join you in working to find a fair solution if you have a complaint or problem relating to our use of your personal data. However, suppose your position is that we cannot assist you with your complaint or concern. In that case, you can also lodge a complaint with the Dutch Data Protection Authority or institute judicial proceedings. You will find the contact details of the Dutch Data Protection Authority (Nederlandse Autoriteit Persoonsgegevens) by clicking here.
Minors on Sqales’ website
Although visitors of all ages might visit our website, we do not collect personal data from children under 16 years of age without the consent of their parents/guardians. This means that if you are 16 years old or younger, you may only use our website under the supervision of your parent/guardian.
Cookies and similar applications
Our contact details are:
+31 (0) 20 76 57 560
Sqales only retains personal data for as long as is necessary for the processing. Sqales maintains your personal data as long we consider this essential to provide you with services, enable you to use our website, comply with applicable laws, resolve disputes with parties, and for other purposes that allow us to conduct our commercial activities. Sqales, in any case, retains your personal data during the period in which you are party to a contract with Sqales. If you are a client of Sqales, we will keep the company details and contact details stored on our systems.
After ending the client agreement, we might keep these details in our systems, for example, when a contact is linked to an agreement, invoice, or any other official document. We store data on (potential) candidates for three years. After this period, we will ask the (potential) candidate for permission to keep their personal data for another three years. Potential candidates can access their personal data that is stored in our systems. If a potential candidate no longer wishes to be approached by Sqales, they can file a request for the deletion of their personal data.
If you have applied for any of our internal vacancies at Sqales but are not invited for a job interview, or when we unexpectedly cannot agree on your contract, we will keep your personal data stored for four weeks. After this period, we will ask you for permission to store the personal data for three years. We do this to approach you again in the future, for example, when a new vacancy comes up that matches your profile.
Amendments and applicable law