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Privacy Notice for Recruitment

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 IT B.V and Flexxy Sustainable B.V.

We use Loxo, an online application provided by Loxo Holdings, LLC, to assist with Our
recruitment process. We use Loxo to process personal information as a data processor on Our
behalf. Loxo is only entitled to process your personal data in accordance with Our instructions.

When 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.

When 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
● 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
Loxo 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, Github and other public social media profiles.


Loxo’s technology allows Us to search various databases – some publicly available and others
not, which may include your personal data (including 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
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.


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 Loxo and its processors and data providers)
and Partners (such as the job sites through which you may have applied) improve
their services.


Automated decision making/profiling
We may use Loxo’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 provider Loxo, who is
using it only in accordance with Our instructions and as otherwise required by law.
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


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

Where We store your personal data
The data that We collect from you and process using Loxo may be transferred to, and stored at,
a destination inside the European Economic Area ("EEA"). By submitting your personal data,
you agree to this transfer, storing or processing.

In particular, your data may be accessible to i) Loxo’s staff in the USA or ii) may be stored by
Loxo’s hosting service provider on servers in the USA. The USA does not have the same data
protection laws as the United Kingdom and EEA. A Data Processor Agreement has been signed
between Loxo’s Software Limited and its overseas group companies, and between
Loxo’sSoftware 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 organization (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 6 months.

Your personal information will be deleted on one of the following occurrences:
● Deletion of your personal information by you (or by another person engaged by the
Customer); or
● Receipt of a written request by you (or another person engaged by the Customer) to


Your Rights
Under the General Data Protection Regulation 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


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
● Let Us know the information to which your request relates


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.


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


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:
● 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

Autoriteit Persoonsgegevens
Postbus 93374
(+31) (0)70 888 85 00

How do I contact 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


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