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Protecting your privacy is of great importance to us. We created this Privacy Statement to
demonstrate our commitment to your right to data protection, privacy and to outline how
your Personal Data is processed.
1. Controller of your Personal Data
1.1. Personal Data
Personal Data is any information which is related to an identified or identifiable natural
person. This includes but is not limited to names, email addresses, phone numbers, job
functions and employer details/institutional affiliations, gender and nationality, dietary,
medical requirements or recruitment Information.
1.2. Controller
The Controller of Personal Data, alone or when joined with others, determines the
purposes of any Personal Data and the means of processing it. VONQ B.V. (hereinafter:
“VONQ”, “we”, “us”, “our”) is the operator of this website and applications (hereinafter:
“Online Service”) and the Controller in the meaning of the General Data Protection
Regulation (hereinafter: “GDPR”) for the processing activities described in this Privacy
Statement.
During our business relationship with you, VONQ may share contact information with
affiliated VONQ companies. These affiliated companies and VONQ are jointly responsible
for the protection of your Personal Data (article 26 GDPR). To establish a central point of
contact in the context of this joint controllership, VONQ entered into an agreement with
these affiliated companies granting you the right to centrally exercise your rights as a
data subject under section 6 of this Privacy Statement.
To exercise your rights, you may reach out to our Data Protection Team
via [email protected]. Please consult section 6 to learn more about your rights.
2. Processing of Personal Data when using VONQs Online Services
2.1. Categories of Personal Data
When using our website or applications (hereinafter: “Online Services”), we process
information that you have voluntarily provided about yourself or that was generated by
us by the use of our Online Services; it comprises the following categories of Personal
Data:
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● Contact information, such as first and last name, company, e-mail address, address,
or phone number.
● Other types of Personal Data provided as part of a support issue or the sign-up to any
other type of call-to-action forms and
● Information on your interaction with the Online Service, including your IP address,
browser type and version, operating system, referrer, hostname of the accessing
device; timestamp of the request, the amount of data sent of each request.
2.2. Purpose of processing
Your Personal Data is being processed for the following purposes:
● Providing the Online Services to you;
● Analysing the effectiveness of the Online Services;
● Improvement and further development, securing, updating, and troubleshooting of
the Online Services;
● Verification of your identity and responding to requests;
● Billing the use of the Online Services;
● Providing offers and order processing;
● Contacting you with information about our products and services, providing further
marketing information or, as outlined in section 4, in the context of customer
satisfaction surveys; and
● Prevention of illicit activities, fraud, attacks towards our infrastructure and IT systems,
enforcing our Online Service’s terms and to preserve legal claims.
2.3. Online Services provided by your organization
VONQs Online Services may be provided to you by another company as part of an
employment, contract, or similar relationship, for example by our enterprise customers.
In this case, if our Online Services are provided by another company, there is a data
processing agreement defining the relationship between VONQ and your company.
According to this agreement, your company is the controller of your Personal Data.
Please refer to your company regarding the processing of your Personal Data.
2.4. Cookies
Interacting with our Online Services should be as convenient as possible for you. To
enable this we may use cookies and similar technologies. Cookies are small files
temporarily stored on the hard disk of your device by your browser. Such a file often
includes a unique identifier, i.e. a randomly generated number. While some cookies
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expire at the end of your session; others may remain on your device for a longer period
of time. If cookies are stored automatically, without your consent, these cookies are
technically necessary to provide our Online Services. Other cookies (or similar
technologies) will only be applied based on your prior consent.
2.5. External Links
This Privacy Statement only applies to Online Services that link to this Privacy Statement.
It does not apply to third-party websites or if VONQ only processes information as a
processor on behalf of a controller.
VONQ’s websites contain links or references to other third-party websites we do not
control and to which our Privacy Statement does not apply. We are not responsible for
the content of third-party websites nor their privacy practices.
3. Processing of Personal Data in the context of your business relationship with VONQ
3.1. Categories of Personal Data
In a business relationship with us, VONQ may process the following categories of
Personal Data of employees, contact persons and vicarious agents at (prospective)
customers, suppliers or vendors (hereinafter: “Customers”):
● Contact information, such as first and last name, name of the company you work for,
your job title, the country you or your job are in, your email address and your phone
number;
● Project related information in, but not limited to, Recruitment Marketing Campaigns,
necessarily processed in a project or contractual relationship with us or voluntarily
provided by the Customer, such as Personal Data relating to orders, payments,
requests, issues, and project specification, planning and development;
● Payment information, such as data necessary for processing payments, fraud
prevention and, if mandatory by law, Customer compliance evaluations.
3.2. Purpose of processing
● Administrating and developing business relationships with Customers, including the
exchange of information about Online Services, Recruitment Marketing Campaigns
and projects in general by, for example, inquiries or requests or providing you with
information about services purchased;
● Planning, performing and managing business relationships with Customers by
performing orders and transactions, maintaining an up-to-date job board portfolio,
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processing payments, accounting, auditing, billing and providing support in the
aforementioned areas;
● Market evaluation and analysis, organizing events and other Customer focused
activities;
● Ensuring the confidentiality, integrity, availability and resilience of our Online Services,
as well as the detection and prevention of security threats, fraud or other illicit or
malicious activities;
● Compliance with legal frameworks, best business practices and internal policies.
● Dispute resolution, enforcement of contractual agreements and any actions related
to legal claims.
● Contacting you to exchange further information and offers regarding our Online
Services, providing further marketing material and conducting customer satisfaction
surveys as outlined in the following section 5.
4. Processing of Personal Data in the context of VONQ KoPilot
4.1. Categories of Personal Data
In the context of KoPilot, VONQ may process the following categories of Personal Data of
potential candidates (hereinafter: “Candidate”):
● Contact information such as salutation, name, email address, and phone number.
● Professional information such as resume/CV content, including education,
experience, skills, and certifications. AI chat and interview information such as
answers to AI bot questions and interview transcript.
● Match Score Data: compatibility score generated through automated analysis
comparing your profile with the job description.
VONQ collects the above mentioned categories of personal data directly from you as a
candidate on our proprietary KoPilot Candidate journey platform when you submit your
resume/CV, when you chat with our AI agent and when you engage in conversation with
our AI agent in the initial interview.
4.2. Purpose of Processing
VONQ collects this Personal Data for the purpose of facilitating recruitment activities for
our clients.
5. Processing of Personal Data in the context of direct marketing and surveys
We may process your contact information for direct marketing purposes (e.g. product
updates, newsletters, invitations or similar) and for customer satisfaction surveys, You may,
of course, opt-out of the processing of your contact data for these purposes at any time by
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contacting our Data Protection Team via [email protected] or by using the opt-out mechanism
provided in the respective communication.
6. Transfer of Personal Data
Your Personal Data may be transferred to:
● third-party IT service providers, such as hosting providers, cloud software providers or,
but not limited to, text processors;
● third-party compliance providers, such as suppliers helping us with tax or legal
obligations, financial compliance, also regulatory bodies, law enforcement, government
authorities, or attorneys and consultants and;
● third-party suppliers and sales partners.
Those third-party recipients of your Personal Data may be located outside of your country of
residence.
7. Your Rights
You may be entitled to specific rights pertaining your Personal Data, depending on the data
protection laws in the jurisdiction in which you reside. In particular, illustrated using the
example of the GDPR, you may be entitled to:
● Withdraw consent at any time with effect for the future (article 7 subs. 3 GDPR);
● Obtain information on the purposes of the processing, the categories of personal data
concerned, the recipients of the data and the envisaged storage period (article 15 GDPR);
● Request that incorrect or incomplete Personal Data be rectified or supplemented (article
16 GDPR);
● Request the erasure of data – especially if the data is no longer necessary in relation to
the purposes for which it was collected or is unlawfully processed, or you withdrew your
consent according to the above (article 17 GDPR);
● Demand, under certain circumstances, the restriction of processing Personal Data (article
18 GDPR);
● The right to data portability, receiving your Personal Data in a commonly used, open and
machine-readable format (article 20 GDPR);
● Object to the processing of data on the grounds of legitimate interests, for reasons
relating to your particular situation (article 21 sec. 1 GDPR).
8. Security
VONQ implemented appropriate technical and organizational measures to protect your
Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or
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destruction and to ensure the confidentiality, integrity, availability and resilience of our
systems.
9. Retention Period
VONQ will only retain your Personal Data for as long as it is required, unless indicated
otherwise at the time of the collection of your Personal Data. If required by mandatory law
(commercial or tax law) VONQ will erase your Personal Data once the retention of that
Personal Data is no longer necessary for the purposes for which it was collected.
10. Contact
In case of comments, concerns or questions regarding your Personal Data or your wish to
exercise your rights, please contact our Data Protection Team via: [email protected].
11. Legal basis of processing
In case your Personal Data is processed by one of our companies located in the European
Economic Area (hereinafter: “EEA”) the following applies:
11.1. Legal basis of processing
The legal basis for processing your Personal Data is that such processing is necessary
for:
● the performance of the contract with you or in order to take steps at your request
prior to entering into a contract (article 6 sec. 1 lit b GDPR);
● compliance with a legal obligation to which we are subject to (article 6 sec. 1 lit. c
GDPR); and/or
● the purposes of legitimate interest pursued by us (article 6 sec. 1 lit. f GDPR).
● In other cases, you have given your consent to the processing of your Personal Data
(article 6 sec. 1 lit. a GDPR).
11.2. Purpose and legal basis of processing Personal Data when using VONQs Online
Services
Providing the Online Services to you; analysing their effectiveness, improvement and
further development, securing, updating and troubleshooting of the Online Services:
● Performance of the contract, article 6 sec. 1 lit. b GDPR,
● Legitimate interest, article 6 sec. 1 lit. f GDPR.
Identity verification
● Performance of the contract, article 6 sec. 1 lit. b GDPR,
● Legitimate interest, article 6 sec. 1 lit. f GDPR.
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Billing your use of the Online Services;
● Performance of the contract, article 6 sec. 1 lit. b GDPR,
● Legitimate interest, article 6 sec. 1 lit. f GDPR.
Providing offers and processing your order;
● Performance of the contract, article 6 sec. 1 lit. b GDPR,
● Legitimate interest, article 6 sec. 1 lit. f GDPR.
Contacting you product information and services, providing further marketing
information or, as outlined in section 4, in the context of customer satisfaction surveys;
● Consent, article 6 sec. 1 lit. a GDPR,
● Legitimate interest, article 6 sec. 1 lit. f GDPR.
Prevention of illicit activities, fraud, attacks towards our infrastructure and IT systems,
enforcing our Online Service’s terms and to preserve legal claims.
● Legal obligation, article 6 sec. 1 lit. a GDPR,
● Legitimate interest, article 6 sec. 1 lit. f GDPR.
11.3. Purpose and legal basis of processing Personal Data in the context of your business
relationship with VONQ
Administrating and developing business relationships with Customers, including the
exchange of information about Online Services, Recruitment Marketing Campaigns and
projects in general by, for example, inquiries or requests or providing you with
information about services purchased;
● Performance of the contract, article 6 sec. 1 lit. b GDPR,
● Legitimate interest, article 6 sec. 1 lit. f GDPR.
Planning, performing and managing business relationships with Customers by
performing orders and transactions, maintaining an up-to-date job board portfolio,
processing payments, accounting, auditing, billing and providing support in the
aforementioned areas;
● Performance of the contract, article 6 sec. 1 lit. b GDPR,
● Legal obligation, article 6 sec. 1 lit. a GDPR.
Market evaluation and market analysis, organizing events and other Customer focused
activities;
● Consent, article 6 sec. 1 lit. a GDPR,
● Legitimate interest, article 6 sec. 1 lit. f GDPR.
Ensuring the confidentiality, integrity, availability and resilience of our Online Services, as
well as the detection and prevention of security threats, fraud or other illicit or malicious
activities;
● Legitimate interest, article 6 sec. 1 lit. f GDPR.
Compliance with legal frameworks, best business practices and internal policies.
Dispute resolution, enforcement of contractual agreements and any actions related to
legal claims.
● Legal obligation, article 6 sec. 1 lit. a GDPR,
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● Legitimate interest, article 6 sec. 1 lit. f GDPR.
Information exchange and offers concerning our Online Services, providing further
marketing material and conducting customer satisfaction surveys, as outlined in section
5;
● Consent, article 6 sec. 1 lit. a GDPR,
● Legitimate interest, article 6 sec. 1 lit. f GDPR.
11.4. Purpose and legal basis of processing Personal Data in the context of VONQ KoPilot,
as outlined in section 4:
● Consent, article 6 sec. 1 lit. a GDPR.
12. International Data Transfers
If we transfer your Personal Data to third countries outside the EEA, we ensure that your
data is safeguarded by appropriate data protection controls, for example by so-called
Standard Contractual Clauses (hereinafter: “SCCs”). Pre-approved by the European
Commission, SCCs are consistent with the GDPR.
13. Region Specific Provisions
13.1. Do Not Track
The “Do Not Track” browser feature is currently not honored by our Online Services.
13.2. Usage by Children
VONQ’s website and Online Services are not directed to minors, we do not knowingly
process Personal Data of children under the age of 13. If you, as parent or legal guardian,
believe that VONQ processed your child’s Personal Data, please contact our Data
Protection Team via [email protected]. We will initiate the appropriate steps to remove the
information as soon as possible.
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