Privacy Policy

  1. General

    This is the privacy statement (“Privacy Policy“) of nonzerosum BV with registered office at Guldensporenpark 120, 9820 Merelbeke, VAT BE 0688.999.314 (hereinafter “nonzerosum“).

    This Privacy Policy explains how nonzerosum collects, stores, uses and shares personal data, being any information relating to an identified or identifiable individual (”Personal Data”) when using the website www.nonzerosum.be (the ”Website”) and in the framework of our services (collectively, the ”Services”). It therefore applies regardless of our relationship (visitors to the Website, (potential) candidate, (potential) interim expert, (potential) freelancer, client, supplier, etc.) and regardless of how we received your Personal Data.

    Please read this Privacy Policy carefully as it contains your rights and obligations to nonzerosum, including how you can exercise control over your Personal Data.

    This Privacy Policy may be revised periodically. The most recent version is available on our Website.

    The controller of your Personal Data is nonzerosum. The collection and processing of Personal Data is subject to strict conditions. Nonzerosum acts in accordance with:

    1. the European Regulation 2016/679 of 27 April 2016 on the protection of Personal Data;
    2. the Law of 30 July 2018 on the protection of natural persons with regard to the processing of personal data.
  2. Collected Personal Data

    From whom? What Personal Data?
    Visitors to the Website By visiting our Website, we may collect data related to your use of the Website, such as usage, activity logs and click-throughs.

    This data is automatically collected using cookies. More information about cookies and the specific cookies we use on the Website can be found in our Cookie Policy.

    Candidate employees at nonzerosum By submitting an application for an internal position at nonzerosum, we may collect the following information:

    • identification and contact information, such as name, address, telephone number, e-mail address
    • personal characteristics, such as date and place of birth, gender, nationality and language skills
    • photo
    • information about education and work experience
    • current salary and salary expectations
    • CV, cover letter and notes taken during interviews
    • other relevant information that you yourself additionally provide
    Candidates If you are a candidate, this means that we have already had contact with you and received information from you. We will therefore collect your data if you register as a candidate through the Website, by responding to vacancies, by an intake interview and/or by sharing your data with us after you were approached by us as a potential candidate. In doing so, we may collect the following information:

    • identification and contact details, such as name, address, telephone number, e-mail address
    • personal characteristics, such as date and place of birth, gender, nationality and language skills
    • photo
    • information about education and work experience
    • current salary and salary expectations
    • CV, cover letter and notes taken during interviews
    • other relevant information that you yourself additionally provide
    Interim experts and freelancers By working with us as an interim expert or freelancer and/or sharing your information with us for the purpose of working with us as an interim expert or freelancer, we may collect the following information:

    • identification and contact information, such as name, address, telephone number, e-mail address
    • personal characteristics, such as date and place of birth, gender, nationality and language skills
    • photo
    • information about education and work experience
    • current salary, salary expectations and/or fees
    • billing information, such as VAT number and account number
    • content of communications with us and clients
    • timesheets
    • CV, cover letter and notes taken during interviews
    • other relevant information that you yourself additionally provide
    Potential candidates, potential interim experts and potential freelancers When we are looking for potential candidates, potential interim experts and potential freelancers, we rely on the information we find online. Therefore, by using online sources and platforms such as LinkedIn and Indeed, we may receive your data indirectly. This only concerns information that you yourself have made available online and may include the following data:

    • name, e-mail address, telephone number
    • data relating to your education, such as diplomas
    • data about your professional experience, such as employer, current position, previous position and other experience
    (Potential) clients and suppliers By (potentially) working with us as a customer or supplier, we may collect the following information:

    • identification and contact information, such as name, address, telephone number, email address and website
    • Billing information, such as VAT number and account number
    • general information about the company in the context of assignments
    • content of communications

    We may process public data related to your company or organization, such as:

    • Data subject to mandatory publication
    • Directors of your company
    • Information on your website or social media
    References or contact persons It may happen that you were specified by a candidate, interim expert or freelancer as a reference or contact. In that case, we process data such as:

    • identification and contact details, such as name, telephone number, e-mail address
    • function
    People who contact us When you contact us through the contact form on the Website, through another means of communication, or in person, we collect the information you provide to us, such as:

    • identification and contact information, such as name, phone number, email address
    • content of the communication
    Individuals who subscribe to newsletters and/or other email communications By signing up on the Website to receive newsletters and/or other email communications such as white papers, we collect only your email address.

     

  3. Purposes of processing and legal basis

    Nonzerosum collects and processes your Personal Data primarily to provide its services in an optimal manner.

    More specifically, we use your Personal Data only for the following purposes:

    1. General purposes

      From whom? For what purpose? What legal basis?
      Visitors to the Website We process data from visitors to the Website for:

      • maintaining and improving the security of the Website
      • creating statistics to improve our Services.
      These processing operations are based on your consent to the use of cookies and on our legitimate interest in the use of essential cookies.
      Candidate employees at nonzerosum We process data of candidate employees at nonzerosum in order to:

      • assess the applicant’s suitability as part of a selection process
      • answer the applicant’s questions and communicate with the applicant
      • develop and improve our recruitment process
      These processing operations are based on the need to take measures for the conclusion of the (employment) contract at the applicant’s request and/or on our legitimate interest to make optimal decisions regarding recruitment before we make an offer.
      Candidats Candidate data is processed in order to:

      • assess the suitability of the candidate as part of a selection procedure
      • assist in finding a suitable position
      • answer the candidate’s questions and communicate with the candidate
      • introduce the candidate to potential employers following his or her consent
      • contacting the candidate about open positions which we think may be of interest
      • manage our database
      • develop and improve our services
      Depending on the circumstances, these processing operations are based on the need to take action at the candidate’s request to conclude an (employment) contract with our client, our legitimate interest in helping the candidate develop his or her career and/or the candidate’s consent to share data with our client(s).
      Interim experts and freelancers Data of interim experts and freelancers are processed for:

      • the conclusion and execution of the agreement entered into with the interim expert or freelancer
      • Assessing the suitability of the interim expert or freelancer for an assignment.
      • Assisting in finding a suitable assignment
      • Answering the questions of the interim expert or freelancer and communicating with the interim expert or freelancer
      • Introducing the interim expert or freelancer to clients
      • Contacting the interim expert or freelancer about new assignments we think might be of interest
      • Manage our database
      • Develop and improve our services
      • Follow-up on the assignments of the interim expert or freelancer
      Depending on the circumstances, these processing operations are based on the need to take measures, at the request of the interim expert or freelancer, to conclude a contract, the performance of the contract and/or our legitimate interest in helping the interim expert or freelancer develop his or her career.
      Potential candidates and freelancers If we have collected data from a potential candidate, interim expert or freelancer indirectly – for example via LinkedIn – we will only use it to contact the potential candidate, interim expert or freelancer in case we have a suitable position or opportunity.

      In this way, we can determine whether the potential candidate, interim expert or freelancer is interested in our services.

      If there is interest – for example by scheduling an interview or providing additional information – there is a candidate, interim expert or freelancer and Personal Data will be processed as described above.

      This processing is based on our legitimate interest in helping the potential candidate, potential interim expert or potential freelancer develop his or her career.
      (Potential) clients and suppliers Data of (potential) clients and suppliers are processed:

      • for the establishment and implementation of the agreement
      • to help our clients find a suitable candidate or freelancer
      • to answer questions and communicate with the (potential) client or supplier
      • to inform the (potential) client or supplier about our services
      These processing operations are based on the performance of the contract between the customer or supplier and nonzerosum or our legitimate interest.
      References or contact persons Data of references or contacts are processed only to contact this person to confirm the reference or information. This processing is based on our legitimate interest.
      People who contact us Data of persons who contact us are processed in order to:

      • respond to inquiries and requests
      • follow up on communication
      • inform the person concerned about our services
      These processing operations are based on the execution of a contract, and on the consent of the data subject if he or she wishes to be kept informed about our services.
      Individuals who subscribe to newsletters and/or other email communications Data from individuals who subscribe to newsletters or other email communications will be used only for the purpose of sending those communications. The processing is based on the consent of the person who subscribes to the newsletter and/or other email communications.

       

    2. Direct marketing

      To the extent provided in this Privacy Policy, your Personal Data may be used for direct marketing purposes based on our legitimate interests to ensure the proper operation and growth of our business. These legitimate interests must not outweigh your privacy interests. In this way, nonzerosum may use your Personal Data to send you marketing materials as well as other materials related to nonzerosum, its affiliates and its Services.

      You have the opportunity at any time, free of charge and without motivation, to opt out of receiving such emails by clicking on the cancellation button at the end of each promotional email.

    3. Access to your Personal Data by clients

      Personal data of candidates, interim experts and freelancers will only be shared with clients, if you give us permission to do so. Without this consent, we will not share data with our clients. We also share only the most necessary Personal Data. Generally, this is your contact information, a written proposal/description and your resume.

    4. Transfer to other parties

      Nonzerosum will rely on third parties to perform and enable our Services. Examples of these vendors and service providers include freelancers, interim attorneys, and entities that provide analytics and web hosting services.

      Nonzerosum will not sell, rent, distribute or otherwise make your Personal Data commercially available to third parties, except as provided in this Privacy Policy.

      Nonzerosum has taken all legal and technical precautions to prevent unauthorized access and use.

      Nonzerosum guarantees a similar level of protection by providing contractual obligations to these appointees, which are similar to this Privacy Policy.

      Nonzerosum may also make your Personal Data available to companies affiliated and associated with nonzerosum or companies with whom nonzerosum forms a consortium. This only in the context of cooperation and/or for the performance of the Services of nonzerosum.

      In the event of a total or partial reorganization or transfer of nonzerosum’s business in which nonzerosum reorganizes, transfers, assigns its business or in the event nonzerosum were to be declared in bankruptcy, your Personal Data may be transferred to new entities or third parties. Nonzerosum will notify you in advance if nonzerosum transfers your Personal Data to a third party, unless it is a transfer to a company affiliated or associated with nonzerosum, or a company with whom nonzerosum forms a consortium.

    5. Legal obligations

      In rare cases, we may need to disclose your Personal Data in response to a court order or to comply with other mandatory laws or regulations. We will make reasonable efforts to provide you with advance notice of such circumstances, unless restricted by law.

  4. Duration of processing

    The Personal Data will be retained and processed by us for the period as long as this is essential for the purposes of processing, legal obligations or for providing our Services.

    From whom? Retention period
    Visitors to the Website The retention period of data of visitors to the Website, depends on the cookies used. More information about cookies and the specific cookies we use on the Website can be found in our Cookie Policy.
    Candidate employees at nonzerosum Data of candidate employees at nonzerosum will be kept for 2 years after the end of the selection procedure in a recruitment reserve. If you do not wish this, you may object at any time.
    Candidates Candidate data is kept for 5 years after our last meaningful contact, except in case of an ongoing dispute. You can always request us to delete all or part of your data. Data of candidates who were successfully placed with a client will be kept for 10 years after the termination of the agreement with the client, except in case of dispute.
    Interim experts and freelancers Data of interim experts or freelancers are kept for 5 years after our last meaningful contact or – in case of an agreement – for 10 years after the end of the cooperation, unless in case of dispute.
    Potential candidates, potential interim experts and potential freelancers Data of potential candidates, interim experts and freelancers with whom there has been no personal contact and / or in whom there is no further interest in our services will be kept for 1 month.
    (Potential) clients and suppliers Data of (potential) clients and suppliers are kept for 10 years after the termination of the cooperation or after the last contact, unless in case of dispute.
    References or contact persons Reference or contact information will be retained for the duration of the selection process.
    People who contact us Data of individuals who contact us is kept for 5 years after the last meaningful contact.
    Individuals who subscribe to newsletters and/or other email communications Data of individuals who subscribe to newsletters and/or other email communications will be retained for as long as the mailings are desired or until the email address is no longer active.
  5. Your rights

    1. Right of access and inspection

      You have the right to learn about your Personal Data and the use we make of your Personal Data at any time.

    2. Right of correction, deletion and restriction

      You are free to communicate or not communicate certain Personal Data to us.

      You always have the right to request us to amend your Personal Data.

      You may also request that the processing of your Personal Data be restricted if you believe that your data is inaccurate and you subsequently notify us accordingly.

      Additionally, you have the right to request nonzerosum to delete your data to the extent we are not able to make it anonymous.

      However, if you refuse to provide certain Personal Data, or if you ask us to delete it, we may no longer be able to provide our Services in an optimal manner.

    3. Right of objection

      You also have a right to object to the processing of your Personal Data when you have serious and legitimate reasons to do so.

      You also have the right to object to the use of your Personal Data for direct marketing purposes. In this case, no specific justification will be requested.

    4. Right of free data transfer

      You have the right to obtain your Personal Data processed by us in structured, common and machine-readable form and/or to transfer it to other responsible parties.

    5. Right to withdraw consent

      You have the right to withdraw your prior consent to the processing of your Personal Data.

    6. Automated decisions and profiling

      You have the right to request us not to be the subject of a decision based solely on automated processing, including profiling, that produces legal effects concerning you or significantly affects you.

    7. Exercising your rights

      You can exercise your rights by contacting our DPO,

      via e-mail to dpo@nonzerosum.be

      or by post to

      nonzerosum

      Attn. DPO

      Guldensporenpark 120

      9820 Merelbeke

    8. Right to file a complaint:

      You have the right to file a complaint with the Belgian Data Protection Authority:

      Data Protection Authority

      Drukpersstraat 35, 1000 Brussel,

      Tel +32 (0)2 274 48 00, Fax +32 (0)2 274 48 35,

      Email: contact@apd-gba.be

      This is without prejudice to a remedy before a civil court. If you are from or operating in another EU member state, you may also file a complaint with your local data protection authority.

      If you should suffer damage as a result of the processing of your Personal Data, you may make a claim for compensation.

  6. Security and confidentiality

    We have developed security measures adapted at technical, administrative and organizational level to avoid the destruction, loss, falsification, modification, unauthorized access or accidental communication to third parties of your Personal Data as well as any unauthorized processing of this data.

    However, in the event that this did occur and it affected your Personal Data, nonzerosum will notify you of the breach, including a description of the potential impact and a recommendation to mitigate the potential negative consequences of the breach.

    We store your Personal Data securely on our servers located within the European Economic Area.

    In no case Nonzerosum can be held liable for any direct or indirect damage resulting from a wrongful or unlawful use by a third party of the Personal Data.

  7. Applicable law and competent court

    This Privacy Policy is governed, interpreted and implemented in accordance with Belgian law which is exclusively applicable.

    The courts of Ghent and Brussels have exclusive jurisdiction over any dispute that might arise from the interpretation or implementation of this Privacy Policy.