Privacy Policy

May 2024

Flexxy B.V, Flexxy IT B.V and Flexxy Sustainable B.V. (“We”, “Us”) are committed to
protecting and respecting your privacy. This Privacy Notice (together with any other documents
referred to herein) sets out the basis on which the personal data collected from you, or that you
provide to Us, will be processed by Us in connection with Our recruitment processes. Please
read the following carefully to understand Our views and practices regarding your personal data
and how We will treat it.

For the purpose of the General Data Protection Regulation (“GDPR”) the Data Controller is
Flexxy B.V., Flexxy IT B.V and Flexxy Sustainable B.V.

We use Workable, an online application provided by Workable Software Limited, to assist with our recruitment process. We use Workable to process personal information as a data processor on our behalf. Workable is only entitled to process your personal data in accordance with our instructions.

Where you apply for a job opening posted by Us, these Privacy Notice provisions will apply to our processing of your personal information in addition to our other Privacy Notice which has been provided to you separately or is available on our Website.

Where you apply for a job opening via the application function on a job site or similar online service provider (“Partner”), you should note that the relevant Partner may retain your personal data and may also collect data from Us in respect of the progress of your application. Any use by the Partner of your data will be in accordance with the Partner’s Privacy Notice.

Your Personal Information

Personal data is any information relating to an identified or identifiable natural person. A person
is identifiable, if the person can be identified, directly or indirectly, in particular by reference to an
identification number, an email address, a photograph, a phone number or a mailing address.

Who is responsible for processing your data?

Flexxy B.V, Flexxy IT B.V and Flexxy Sustainable B.V. is responsible for processing your data.
The Dutch DPA is the lead authority for all personal data processing implemented by Flexxy.

What kind of personal data does Flexxy collect?

We collect and process the following categories of data:

Candidates’ data
● Information that you provide when you apply for a role. This includes information
provided through an online job site, via email, in person at interviews and/or by any other
method.
● Personal Information: last name, first name, date of birth, phone number, email
address, profile picture, location.
● Data related to working life: current position, employer, degrees, diplomas, training,
professional experience, skills, curriculum vitae, sector of activities.
● Additional Information: LinkedIn Id, LinkedIn profile content
● Connection data: statistical data on browsing, referring URL (address of the website
visited before accessing our website), cookies.
● Data relating to your use of our services: content uploaded on our platform, history of
your communications and messages, access status (content transmitted, not found,
etc.), comments, notices, notes, requests.
● If you contact Us, we may keep a record of that correspondence.
● A record of your progress through any hiring process that We may conduct.

Clients’ data
● Personal Information: last name, first name, date of birth, gender, phone number, email
address, profile picture, location
● General Information about the company: sector of activity, number of employees,
legal structure, company logo, profiles sought, company needs
● Financial Information: billing information, accounting contact, bank details
● Connection data: statistical data on browsing, referring URL (address of the website
visited before accessing our website), cookies.

Data relating to your use of our services

Content uploaded on our platform, history of your communications and messages,
access status (content transmitted, not found, etc.), comments, notices, notes, requests.

Information We collect from other sources

Workable provides Us with the facility to link the data you provide to Us, with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles.

Workable’s technology allows Us to search various databases – some publicly available and others not, which may include your personal data (include your CV or Resumé), to find possible candidates to fill our job openings. Where We find you in this way we will obtain your personal data from these sources.

We may receive your personal data from a third party who recommends you as a candidate for a specific job opening or for our business more generally.

Uses made of your information

Lawful basis for processing

We rely on legitimate interest as the lawful basis on which We collect and use your personal data. Our legitimate interests are the recruitment of staff for our business and clients.

Purposes of processing

We use information held about you in the following ways:

To consider your application in respect of a role for which you have applied.
To consider your application in respect of other roles.
To communicate with you in respect of the recruitment process.
To enhance any information that we receive from you with information obtained from third party data providers.
To find appropriate candidates to fill our job openings.
To help our service providers (such as Workable and its processors and data providers) and Partners (such as the job sites through which you may have applied) improve and develop their services (including the use of aggregate data).

Automated decision making/profiling

We may use Workable’s technology to select appropriate candidates for Us to consider based on criteria expressly identified by us, or typical in relation to the role for which you have applied. The process of finding suitable candidates is automatic, however, any decision as to who We will engage to fill the job opening will be made by our staff.

Disclosure of your information

As set out above, we pass your information to our third party service providers, including Workable, who use it only in accordance with our instructions and as otherwise required by law.

Where you have applied for a job opening through the Indeed Apply functionality, We will disclose to Indeed certain personal data that We hold, including but not limited to a unique identifier used by Indeed to identify you, and information about your progress through our hiring process for the applicable job opening, as well as tangible, intangible, visual, electronic, present, or future information that we hold about you, such as your name, contact details and other information involving analysis of data relating to you as an applicant for employment (collectively “Disposition Data”). Indeed’s Privacy Notice in respect of Indeed’s use of the Disposition Data is available on Indeed’s website.

Where you have applied to a job opening through another service provider, we may disclose data similar to the Disposition Data defined above to such service provider. The service provider shall be the data controller of this data and shall therefore be responsible for complying with all applicable law in respect of the use of that data following its transfer by Us.

How We store your personal data

Security

We take appropriate measures to ensure that all personal data is kept secure including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted through any online means, therefore any transmission remains at your own risk.

Where We store your personal data

Where we store your personal data in our own systems, it is stored in EU.

The data that We collect from you and process using Workable’s Services may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the UK or the EEA who work for Us or for one of our suppliers. Such staff maybe engaged in, among other things, the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.

In particular, your data may be accessible to i) Workable’s staff in the USA or ii) may be stored by Workable’s hosting service provider on servers in the USA as well as in the EU. The USA does not have the same data protection laws as the United Kingdom and EEA. A Data Processor Agreement has been signed between Workable Software Limited and its overseas group companies, and between Workable Software Limited and each of its data processors. These data processor agreements are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.

If you would like further information please contact Us (see ‘Contact’ below). We will not otherwise transfer your personal data outside of the United Kingdom or EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

How long We keep your personal data

We will hold all the data for 12 months.

Your rights

Subject to local data protection laws and in particular under the GDPR and the UK GDPR, you have a number of important rights free of charge. In summary, those include rights to:

access to your personal data and to certain other supplementary information that this Privacy Notice is already designed to address
require Us to correct any mistakes in your information which We hold
require the erasure of personal data concerning you in certain situations
receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
object at any time to processing of personal data concerning you for direct marketing
object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
object in certain other situations to our continued processing of your personal data
otherwise restrict our processing of your personal data in certain circumstances
claim compensation for damages caused by our breach of any data protection laws.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the UK GDPR.

If you would like to exercise any of those rights, please:

contact us using our contact details below
let Us have enough information to identify you,
let Us have proof of your identity and address, and
let Us know the information to which your request relates.

How to complain

We hope that We can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation and the UK GDPR also gives you right to lodge a complaint with a supervisory authority, in particular (under the GDPR) in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.

Contact

All questions, comments and requests regarding this Privacy Notice should be addressed to quentine@flexxy.io

Third-Party Websites
Our Service may contain links or references to other websites outside of our control. Please be
aware that this policy does not apply to these websites. We encourage you to read the privacy
statements and terms and conditions of linked or referenced websites you enter. These
third-party websites may send their own cookies and other tracking devices to you, log your IP
address, and otherwise collect data or solicit personal data.

WE DO NOT CONTROL AND ARE NOT RESPONSIBLE FOR WHAT THIRD PARTIES DO IN
CONNECTION WITH THEIR WEBSITES, OR HOW THEY HANDLE YOUR PERSONAL DATA.
PLEASE EXERCISE CAUTION AND CONSULT THE PRIVACY POLICIES POSTED ON EACH
THIRD-PARTY WEBSITE FOR FURTHER INFORMATION.

Children Under the Age of 16
Our Service is not intended for children under 16 years of age, and we do not knowingly collect
or use any personal data from children under the age of 16. No one under the age of 16 may
provide any information to or on the Service. If we learn that we have collected or received
personal data from a child under the age of 16, we will delete that information. If you believe we
might have any information from or about a child under the age of 16, please contact us at
quentine@flexxy.io.

Revisions to Flexxy’s Privacy Policy
● We reserve the right to change this policy at any time. Any changes we make will be
posted on this page: https://www.flexxy.io/privacy-policy.
● If we make material changes to how we treat your personal data, we will notify you.
● Your continued use of our services after such amendments will be deemed your
acknowledgement of these changes to this policy.
● The date this policy was last revised is identified at the top of the page.

How to complain
You also have the right to file a complaint to the competent supervisory authority concerning the
processing of your personal data. For Flexxy, the lead authority for personal data protection is:
The General Data Protection Regulation also gives you the right to lodge a complaint with a
supervisory authority, in particular in the European Union (or European Economic Area) state
where you work, normally live or where any alleged infringement of data protection laws
occurred.

Autoriteit Persoonsgegevens
https://autoriteitpersoonsgegevens.nl/nl
2509 AJ DEN HAAG
Postbus 93374
(+31) (0)70 888 85 00

How do I contact flexxy.io regarding data privacy aspects?
If you have any requests, questions, or suggestions related to data privacy.

Flexxy B.V, Flexxy IT B.V and Flexxy Sustainable B.V.
Delftlaan 327
2024 CJ Haarlem
Netherlands
quentine@flexxy.io