Privacyverklaring

Flexxy B.V.

Last updated: 14/03/26

Flexxy B.V. (“Flexxy”, “we”, “us”, “our”) respects the privacy of candidates, clients, website visitors and other business contacts. This Privacy Policy explains how we collect, use, store, share and otherwise process personal data in connection with our recruitment and talent advisory services and in connection with the use of our website.

We process personal data in accordance with the General Data Protection Regulation (“GDPR”) and other applicable data protection laws.

1. Who we are

Flexxy B.V. is a recruitment and talent advisory agency.

Controller
Flexxy B.V.
Haarlem, The Netherlands
Website: https://www.flexxy.nl
Email: info@flexxy.nl

Flexxy acts as the data controller in relation to the personal data described in this Privacy Policy.

2. Who this Privacy Policy applies to

This Privacy Policy applies to:

• candidates and prospective candidates;

• clients and client contacts;

• suppliers and other business contacts;

• visitors to our website.

Because the way we process personal data differs depending on the relationship we have with you, some sections of this Privacy Policy are particularly relevant to candidates.

3. What personal data we may collect

Depending on the circumstances, we may collect and process the following categories of personal data.

Candidates and prospective candidates

We may process:

• name, email address, telephone number and other contact details;

• CV, resume, employment history, education, qualifications and skills;

• professional profile information, including information made available on professional networking platforms;

• salary expectations, availability, location preferences and other recruitment-related preferences;

• interview notes, assessments and correspondence;

• references, where relevant and lawful;

• other information you choose to share with us in connection with recruitment opportunities.

Clients and client contacts

We may process:

• name, business contact details and job title;

• company details;

• information relating to assignments, vacancies and recruitment needs;

• correspondence and communications.

Website visitors

We may process:

• IP address;

• browser, device and usage information;

• cookie-related data;

• information submitted through website forms.

4. How we obtain personal data

We may obtain personal data:

• directly from you;

• through applications submitted via our website, email or other channels;

• through professional networking platforms such as LinkedIn;

• through job boards, CV databases and referrals;

• through clients, business contacts, events or other professional interactions.

Where we obtain personal data from sources other than directly from you, we do so only insofar as such data is relevant to our recruitment or business activities and subject to applicable law.

5. Purposes of processing

We may process personal data for the following purposes:

• to identify, assess and approach potential candidates;

• to manage recruitment and selection processes;

• to match candidates with current or future opportunities;

• to present candidates to clients and prospective clients in the context of recruitment services;

• to communicate with candidates, clients and other contacts;

• to maintain and develop our candidate network and talent pool;

• to deliver recruitment and talent advisory services;

• to manage our business operations, website and systems;

• to comply with legal, regulatory, tax and administrative obligations;

• to establish, exercise or defend legal claims.

6. Legal bases for processing

We process personal data on one or more of the following legal bases, depending on the circumstances.

Legitimate interests

We may process personal data where necessary for our legitimate interests, including:

• operating a recruitment and talent advisory business;

• identifying and contacting professionals regarding relevant career opportunities;

• maintaining and managing candidate and client relationships;

• maintaining a candidate network relevant to our business activities;

• managing and improving our services, systems and website;

• protecting our legal position and business interests.

Where we rely on legitimate interests, we consider and balance our interests against your rights and freedoms.

Consent

We may rely on consent where appropriate, including for certain cookies and, where we choose to do so, for retaining candidate information for future opportunities beyond an active recruitment process.

Where consent is used as the legal basis, it may be withdrawn at any time.

Performance of a contract or steps prior to entering into a contract

We may process personal data where necessary to take steps at your request prior to entering into a contract or where processing is necessary for the performance of a contract with you or with our client.

Legal obligation

We may process personal data where necessary to comply with a legal obligation.

7. Candidate-specific processing

Applications for a specific role

If you apply for a specific vacancy, we process your personal data in order to assess your suitability, communicate with you, manage the recruitment process and, where relevant, present your profile in the context of that opportunity.

Sourced candidates

If we identify you via a professional network, job board, referral or another professional source, we may process limited professional information to assess whether our services or a vacancy may be relevant to you.

Future opportunities and candidate network

Recruitment services are not always limited to a single application or vacancy. As part of our legitimate interests in operating a recruitment business, we may retain and use candidate information to consider whether a candidate may be relevant for future roles, projects or client needs, provided that such retention remains proportionate, relevant and lawful.

Where we determine that consent is appropriate or required for retention beyond an active recruitment process, we may request such consent separately.

Sharing candidates with clients

We may share candidate information with clients or prospective clients where this is relevant to our recruitment services and where there is a valid legal basis for doing so. We aim to do so only in a controlled recruitment context and with appropriate transparency.

8. Recipients of personal data

We may share personal data with:

• clients and prospective clients in the context of recruitment services;

• recruitment software providers, CRM providers, hosting providers, email providers, cloud providers and other IT service providers;

• professional advisers, including legal, tax, compliance and accounting advisers;

• courts, regulators, public authorities and law enforcement bodies where required by law or where necessary to establish, exercise or defend legal claims;

• other service providers supporting our business operations.

We do not sell personal data to third parties.

Where third parties process personal data on our behalf, we require them to process such data under appropriate contractual and security arrangements.

9. Data storage and security

Personal data may be stored and processed in secure digital systems used by Flexxy or by trusted third-party service providers that support our operations.

We implement appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access and other unlawful forms of processing. Such measures may include access controls, authentication measures, system monitoring, secure environments and encryption where appropriate.

10. International transfers

Where personal data is transferred to, stored in, or accessed from outside the European Economic Area, we will ensure that appropriate safeguards are in place in accordance with applicable data protection law, including where relevant the use of adequacy decisions or Standard Contractual Clauses.

11. Retention of personal data

We do not keep personal data longer than necessary for the purposes for which it was collected and processed. Retention periods may vary depending on the nature of the relationship, the purpose of processing, the sensitivity of the data, business necessity, legal requirements and the existence of actual or potential disputes.

Candidates in an active recruitment process

Where a candidate is involved in an active recruitment process, we retain personal data for the duration of that process and for a limited period thereafter as reasonably necessary for recruitment administration, evaluation, follow-up, handling candidate queries, internal recordkeeping and the establishment, exercise or defence of legal claims.

Unsuccessful applicants

Where a recruitment process has concluded and no further lawful basis applies, we may delete candidate data in accordance with applicable law and regulatory guidance. In the Netherlands, the Dutch Data Protection Authority states that it is customary to delete the personal data of unsuccessful applicants no later than 4 weeks after the end of the application procedure, unless there is a lawful basis to retain the data for longer, such as consent.

Candidate network and future opportunities

As a recruitment agency, we may retain candidate information for future recruitment opportunities where this remains relevant, proportionate and compatible with the original recruitment-related purpose or otherwise supported by a valid legal basis. We may periodically review whether continued retention remains appropriate. Where consent is used as the legal basis for such retention, candidates may withdraw that consent at any time.

Clients, suppliers and business contacts

We retain personal data for as long as necessary to manage the relevant business relationship and thereafter for as long as necessary to comply with legal, tax, accounting, regulatory and evidential requirements.

12. Your rights

Subject to applicable law, you may have the right to:

• request access to your personal data;

• request rectification of inaccurate or incomplete personal data;

• request erasure of your personal data;

• request restriction of processing;

• object to processing carried out on the basis of legitimate interests;

• request portability of your personal data where applicable;

• withdraw consent at any time where consent is the legal basis.

You also have the right to lodge a complaint with the competent supervisory authority. In the Netherlands, this is the Autoriteit Persoonsgegevens.

To exercise your rights, please contact us at:
info@flexxy.nl

13. Cookies

Our website may use cookies and similar technologies. More information is available in our Cookie Policy.

14. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The most current version will always be available on our website.

15. Contact

If you have any questions about this Privacy Policy or about how we process personal data, please contact:

Flexxy B.V.
Haarlem, The Netherlands
info@flexxy.nl