PRIVACY POLICY
APPLICABLE TO THE SWOP WEB PORTAL AND THE SWOP APPLICATION
This privacy & cookie policy (hereinafter: the Privacy Policy) sets out the data processing activities carried out in connection with the SWOP Web Portal and the SWOP Application by:
The above listed entities (each individually a Group Company) are all part of the House of HR group, a leading European HR services group specialized in engineering & consulting and specialized talent solutions (which includes various companies active in personnel placement and human resources) (the House of HR Group). All companies within the House of HR Group are located within the European Economic Area.
More information with respect to the House of HR Group and its member companies can be found on https://www.houseofhr.com/companies or can be requested by e-mail to info@houseofhr.com.
1 – General
This Privacy Policy describes how your personal data is processed when using the SWOP Web Portal and the SWOP Application (see also the ‘Terms and Conditions applicable to the SWOP Web Portal and the SWOP Application’) and the applications offered on it, being ‘MyTests’ , ‘MyCV’ and ‘MyProfile’.
The processing takes place under the joint responsibility of the Group Companies as joint controllers in accordance with article 26 of the Regulation of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (GDPR). This means that the Group Companies jointly determine the purpose of and the means for processing your personal data. For this purpose, the Group Companies have entered into an agreement on joint controllership, which defines the specific duties, rights and responsibilities of each Group Company in respect of the joint data processing.
If you wish to know more about the individual processing activities of each Group Company, we invite you to consult their respective privacy statements at:
The Group Companies are jointly responsible for compliance with applicable data protection legislation. The Group Companies aim to comply with the GDPR, with ‘the Law of 30 July 2018 concerning the protection of natural persons with regard to the processing of personal data, for the transposing, supplementing and implementing of the European Regulation 2016/679 of 27 April 2016 concerning the protection of personal data’, as well as with ‘the direct marketing provisions from Book XII of the Code of Economic Right concerning the ‘right of the electronic economy’ (to the extent applicable)’.
This Privacy Policy further sets forth your rights in relation to your personal data, which you may assert towards any Group Company. Notwithstanding the foregoing, the Group Companies have designated Accent Group NV to act as your main point of contact, also for exercising your rights in relation to your personal data (for more information on exercising your rights, see article 7).
This Privacy Policy is addressed to the following data subjects: interested parties, website visitors, clients and their employees, suppliers and their employees, companies and their employees and applicants.
2 – Date of last revision
Date of last revision: 15 June 2023.
This Privacy Policy can regularly be revised or updated. To keep you informed of the latest change to our Privacy Policy, we will update the review date each time it is changed. The amended Privacy Policy will take effect on the date of the last revision. Revisions and updates will be released on the Website. We recommend you to consult it on a regular basis. Revisions are always published on the Web Portal/App.
3 – Personal data you provide to us
– Electronic identification data:
Such as for example: IP address;
– Via Cookies: see article 10.3 and 10.4;
You are not obliged to provide your personal data with us, but you understand that the provision of certain services becomes impossible if you refuse to provide the information that is indicated as mandatory.
Do not forget to inform us about a change to your personal data if this information is relevant to us. You can report this change via the contact details mentioned in clause 14.
4 – Personal data that we collect indirectly
We sometimes processes public data, e.g. data that is subject to a publication obligation, such as the publication of your appointment as director of a company, or data that you have made public yourself, such as information on your website or on your LinkedIn page, or data that are well known in your area or have appeared in the press. We also collect information from other public sources (e.g. candidate databases, social media, …).
5 – Purposes of the processing
5.1. General Purposes:
We will only use the collected personal data for the following purposes:
Our legal ground is contractual relationship, except when we use your personal data for statistical purposes or to improve our services. In the latter two cases, our legal ground is legitimate interest (the freedom to undertake).
The legal ground is contractual relationship, Except where we use your personal data to comply with legal obligations, in which case the legal ground is legal obligation.
The legal ground is contractual relationship, Except where we use your personal data to comply with legal obligations, in which case the legal ground is legal obligation.
Our legal ground is contractual relationship, except when we use your personal data to improve our services. In the latter two cases, our legal ground is legitimate interest (the freedom to undertake).
Our legal ground is contractual relationship.
5.2. Direct Marketing:
The personal data can also be used for direct marketing (including promotions and marketing campaigns in the context of the service). Direct marketing related to our services may be sent to existing customers of the Group Companies and their affiliates, based on our legitimate interests to ensure the smooth operation and growth of our business (freedom to undertake and direct marketing).
5.3 Transfer to third parties:
5.3.1
The personal data processed pursuant to this Privacy Policy is shared amongst the Group Companies and can also be shared with other member companies of the House of HR Group, which may vary from time to time. All member companies of the House of HR Group are located within the European Economic Area. More information with respect to the House of HR Group and its member companies can be found on https://www.houseofhr.com/companies, or can be requested by e-mail to info@houseofhr.com.
If we share personal data with the other member companies within the House of HR Group, it will be in the framework of intra-group collaboration and/or intra-group services in order to improve, facilitate and simplify the activities and services of SWOP and the respective member company (for instance ICT-services, accounting, analytics and statistics, debtor management, (possible) direct marketing, etc.).
5.3.2
We can also share your personal data to third party service providers who handle technical and operational support and to third party service providers (such as, but not limited to, lawyers, auditors, etc.) in general in so far as this is necessary for the professional services and/or contributes to the corporate governance structure and/or if they are obliged to do so based on a statutory provision or a judicial ruling.
We can also provide personal data to a third party employer whose Vacancy is offered through the App, it being understood that the User must first have applied for such Vacancy of the third party employer.
5.4 Transfer to third countries:
We may transfer your personal data outside the European Economic Area in order to process the data in accordance with this Privacy Policy. In case data is transferred outside the European Economic Area, to a country not providing an adequate level of protection, we warrant to undertake all measures to protect your personal data including implementing contractual clauses that offer sufficient safeguards on data protection for the data to be transferred internationally. In practice, this will generally be achieved through standard contractual clauses with the recipient. More information on standard contractual clauses can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_nl.
6 – Duration of processing
The personal data is stored and processed by us as follows:
If the period required to achieve the purposes referred to in Article 5 of this Privacy Policy is about to expire, we can always ask you for permission to keep the data longer.
7 – Your rights
You have rights concerning your personal data. Some of these rights have a specific scope, specific conditions or exceptions.
7.1. Right of access:
You have the right – at any time, free of charge – to take cognizance of the personal data that we are processing of you, as well as the right of asking information about the way of processing. You are also entitled to a copy of the data being processed.
7.2. Right to rectify, complete and restrict:
You always have the right to ask us to rectify, complete or delete all/part of your personal data if that data is incorrect.
You may also ask to restrict the processing of your personal data under specific circumstances.
7.3. Right to erasure (‘Right to be forgotten’)
This right allows you to have your personal data processed by us permanently deleted. This right may only be exercised under specific conditions.
7.4 Right to object:
You also have a right to object against the processing of your personal data on grounds relating to your particular situation.
In addition, you always have the right to oppose the use of personal data for purposes of direct marketing. In such a case, you do not have to give any reasons.
7.5. Right to data portability:
You have the right to obtain your personal data that are processed by us in a structured, commonly used and machine-readable form and/or to transfer them to other controllers.
7.6. Right to withdraw consent:
In so far as the processing is based on your consent, you have the right to withdraw this consent.
7.7. Exercising your rights:
You may exercise your rights towards each Group Company participating to the joint controlling. However, in order to facilitate the exercise of your rights, the Group Companies have designated Accent Group NV as joint controller representative to manage and coordinate any requests in respect thereto. You can exercise your rights by contacting the data protection officer of Accent Group NV on the following e-mail address: joke.vancoppernolle@accentjobs.be. The Accent Group NV DPO is the lead DPO for this joint processing activity and will liaise, where necessary, with the DPO’s of the other Group Companies.
Please note that we are not always obliged to deal with your request to exercise your rights – your rights only apply in the cases and to the extent provided for by law.
If we have reasonable doubts about your identity, we may ask you to provide additional evidence.
7.8. Right to file a complaint:
You have the right to file a complaint with the supervisory authority:
Prior to filing a complaint, we invite you to contact us in order to find a speedy solution for your issue by sending an e-mail to joke.vancoppernolle@accentjobs.be.
8 – Security and confidentiality
We have developed security measures that are appropriate on the technical and organizational levels to prevent the destruction, loss, falsification, modification, unauthorized access or accidental disclosure to third parties of collected personal data as well as any other unauthorized processing of these data.
You must always observe the security rules, including by preventing any unauthorized access to your login and code. You are thus solely responsible for the use that is made as of the Website from your computer, IP address and from your identification data, as well as for the confidentiality thereof.
In order to be able to process your personal data, we grant access to your personal data to our employees and agents. We guarantee an identical level of protection by making contractual obligations that are opposable to these employees and agents. This means that our employees and agents are bound by confidentiality and that only those for whom it is necessary for the performance of their duties have access to your personal data.
9 – Link to other website and/or social media
The Web Portal/App may contain references to other websites and applications. We are not responsible for the processing of personal data through these other channels.
We can only advise you to check the Privacy Policy and the conditions of these websites and applications.
10 – Cookies
10.1 What are cookies?
A “cookie” is a small file send by Accent’s server and placed on the hard drive of your computer/smartphone. The information stored on these cookies can only be read by us and only for the duration of the visit to the App.
10.2 Why do we use cookies?
Our App uses cookies and similar technologies to distinguish your usage preferences from those of other app Users, which helps us to provide you with a better user experience when you use the App and also allows us to optimise our App.
As a result of recent legislative changes, all apps targeting certain parts of the European Union are required to ask for your permission to use or store cookies and similar technologies on your computers or mobile devices. This Cookie Policy gives you clear and complete information about the cookies we use and their purpose.
10.3 The Webportal only uses the following cookies:
Cookies | Specifications | |
Functional cookies | These cookies help make a website usable by enabling basic functions such as page navigation and access to secure areas of the website. Without these cookies, the website will not function properly. | |
1. | Name | OptanonConsent |
Function | auth0.com/docs – Set by OneTrust’s cookie consent solution. The cookies are used to store the information about the user’s consent on the basis of which the cookies will be set on the browser. | |
Type | Sessie | |
Retention period | 24 hours | |
10.4 Google Analytics
Google Analytics is a web analytics service provided by Google that tracks and reports website traffic. Google uses the collected data to track and monitor the use of our services. This data is shared with other Google services. Google may use the information collected to contextualise and personalise the advertisements of its own advertising network.
You may choose not to make your activity on the service available to Google Analytics by installing the ‘Google Analytics opt-out browser add-on’. The add-on prevents Google Analytics from sharing JavaScript (ga.js, analytics.js and dc.js) information with Google Analytics about visiting activity.
For more information about Google’s privacy policy, please visit Google’s Privacy and Terms and Conditions webpage: https://policies.google.com/privacy?hl=nl.
10.6 Your consent:
You can refuse or block cookies by changing the configuration parameters of your navigation system. Switching off cookies can mean that you can no longer make use of certain functionalities of the Website.
Should you have further questions or comments with regard to the processing of your personal data, don´t hesitate to contact us by post.
You can also find more information about cookies at: http://www.allaboutcookies.org/. You can find more information about online behavioral advertising and online privacy here: http://www.youronlinechoices.eu/
11 – Applicable law and competent court
This Privacy & Cookie Policy is controlled, explained and implemented in accordance with Belgian law that applies exclusively.
12 – Contact us
You can also reach us at any time:
SWOP (House of HR)
Beversesteenweg 576
8800 Roeselare
België
E-mail: hello@swop.com
Tel: 051 46 05 00
TERMS AND CONDITIONS
APPLICABLE TO THE SWOP WEB PORTAL AND THE SWOP APPLICATION
Article 1 – Contact details
House of Invest NV
Beversesteenweg 576
8800 Roeselare
BTW BE0552.778.551
E-mail: hello@swop.com
Tel: 051 46 05 00
Article 2 – Definitions
The terms, hereinafter indicated with a capital letter, have the following meaning in these general terms and conditions:
Article 3 – Applicability
3.1 Applicability Web Portal
The Web Portal facilitates the User’s registration options with the various applications offered by HOI and/or by another entity within the House of HR group. Once a User has created an account on the Web Portal, the User shall be able to log in with the same Registration Data to various other applications offered within the House of HR group.
3.2 Applicability App
Finding a job is child’s play via the App. On the basis of the Profile Data provided by the User himself, suitable Vacancies are offered to the User free of charge.
By swopping to the right, the User can apply for the relevant Vacancy, by swopping to the left he can skip the Vacancy and the next suitable Vacancy is offered.
If the User swipes to the right and applies for a particular Vacancy offered through a Powerhouse, he shall be contacted within 48 hours for an interview by an employee of the House of HR group. By applying for the Vacancy offered through a Powerhouse, the User explicitly agrees that his Profile Data are made available to the relevant Powerhouse through which the Vacancy is offered.
If the User swipes to the right and applies for a particular Vacancy offered through a third-party employer, the third-party employer shall be informed by an employee of the House of HR group of the solicitation by sharing the name, surname, telephone number and email address of the User and the User shall:
The third-party employer who has registered on SWOP Recruiter shall, once the User has applied for the Vacancy offered by such third-party employer, be informed of this solicitation by updating the User’s Profile Data that shall appear on the portal of the third-party employer. This is a free tool offered by HOI to connect the User and the third-party employer as quickly as possible.
Also the third party-employer who has not registered on SWOP Recruiter, but whose Vacancy is made available in the App, shall be informed if a User solicitates for such Vacancy via the contact information of the third party-employer mentioned in such Vacancy. This is a service offered by HOI free of charge in order to connect the User and the third-party employer as quickly as possible. The contact details of the third-party employer mentioned in the Vacancy shall only be used for this purpose.
3.3 Applicability Web Portal and App
By registering as a User on the Web Portal/App, the User explicitly acknowledges having read and accepted these General Terms and Conditions.
These General Terms and Conditions must not contain any deletions and take precedence over all others. They can always be consulted on the Web Portal/App. Any deviation from the General Terms and Conditions must be agreed in writing with HOI.
Article 4 – Object
4.1 Object Web Portal
By registering as a User on the Web Portal, the User shall save a lot of time and effort. Registering once on this Web portal means that the User can log in with the same Registration Data to various applications offered by the House of HR group.
Every User who registers on the Web Portal must provide at least his Registration Data, so that the Web Portal can pursue its objective and this because of the legitimate interest that HOI has in the context of carrying out its activities.
In the event that the User registers with the same Registration Data on another application offered by the House of HR group, these Registration Data shall be automatically recognised, after which the User shall be asked whether his known Profile Data may be shared with the application on which he wishes to register. In addition, the User shall have to agree separately with the general terms and conditions and the privacy policy applicable to the application on which the User wishes to register.
In addition, the Web Portal offers without any obligation a number of ‘own’ applications, in particular MyTests, MyCV and MyProfile. These applications are further explained in the articles below.
In order to use the applications, the User must in any case create an account on the Web Portal.
4.2 Object App
The App developed by HOI makes the search for a suitable job easier.
Every User who wishes to use the App shall be able to provide certain Profile Data when using the App, so that the App can pursue its objective and this because of HOI’s legitimate interest in carrying out its activities.
Article 5 – Intellectual property rights – Right of use
All intellectual property rights belonging to the Web Portal and the App (as well as any adjustments and/or extensions) are and shall remain with HOI. The Web Portal and the App is owned by HOI.
Trademarks, logos, images, photos, animations, videos and text on the Web Portal/App are the intellectual property of HOI and cannot be reproduced, used, published, distributed, sold or displayed without the express, prior written permission of HOI .
User acknowledges this fact.
HOI grants a non-exclusive right to the User to use the Web Portal/App in accordance with the General Terms and Conditions.
For the User, this right of use commences the moment the User registers on the Web Portal/App.
If the User violates these General Terms and Conditions and/or wrongly uses and/or misuses the Web Portal/App, HOI reserves the right to immediately deny the User access and use of the Web Portal/App and/or block him and /or to remove him, without prior notification being necessary.
HOI may, at its own discretion, make changes to the Web Portal/App. HOI shall inform the User in a timely manner about the processing of the updates and/or upgrades insofar as they are important for the use of the Web Portal/App. This is always at the discretion of HOI.
Article 6 – Availability and registration use of the App
HOI may, without prior notice, disable access to or restrict its use to the Web Portal/App to the extent necessary for maintenance or modifications or improvements to be made to the Web Portal/App or for any other reason, without that this entails any right to compensation from the User vis-à-vis HOI.
The User’s behaviour on the App is registered. The purpose of registering the User’s behaviour is to optimise the functionality of the App and to make improvements where necessary.
Article 7 – Liability
HOI only commits itself to an obligation of means and does not guarantee any result with regard to the effective finding of a job by the User.
The information on the Web Portal/App is of a general nature. The information is not adapted to personal or specific circumstances of the User, and can therefore not be regarded as personal, professional or legal advice to the User.
HOI makes every effort to ensure that the information provided is complete, correct, accurate and up-to-date. HOI takes the necessary steps to protect the User’s data, which the User has provided in the Web Portal/App, as well as reasonably as possible against loss, theft and unauthorised access.
Despite these efforts, inaccuracies may occur in the information made available.
If the information provided contains inaccuracies or if certain information on or via the Web Portal/App is unavailable, HOI will make all reasonable efforts to rectify this as soon as possible.
However, HOI cannot be held liable for direct or indirect damage resulting from the use of the information on the Web Portal/App or for direct or indirect damage resulting from inaccuracies in the information made available.
If you should identify inaccuracies and/or unlawful use in the information made available via the Web Portal/App, you can contact the administrator of the Web Portal/App. This can be done via the contact information stated in Article 1 of the General Terms and Conditions.
The content of the Web Portal/App (including any links) may be adapted, modified or supplemented at any time without notice or notification. HOI does not guarantee the proper functioning of the Web Portal/App and cannot be held liable in any way for malfunctioning or temporary (un)availability of the Web Portal/App or for any form of damage, direct or indirect, that would result from accessing or using the Web Portal/App.
HOI cannot under any circumstances be held liable to anyone, directly or indirectly, in a special or other way, for damage attributable to the use of the Web Portal/App, in particular as a result of links or hyperlinks, including without limitation, of all losses, work interruptions, damage to programs or other data on the computer system, of equipment, software or other of the User.
The Web Portal/App may contain hyperlinks to websites or pages of third parties or refer to them indirectly. Placing links to these websites or pages in no way implies an implicit approval of their content. HOI expressly declares that it has no control over the content or other features of these links/websites and can in no way be held liable for their content or features or for any other form of damage resulting from their use.
The User acknowledges and accepts that the Web Portal/App can never be perfect or 100% free of imperfections and that not all imperfections will (can) be repaired, although HOI will make all reasonable efforts to do so.
Article 8 – The Networker
The Networker shares a Vacancy offered through Accent with a Proposed Candidate by means of a link. Using that link, it is possible for a Proposed Candidate to apply for a Vacancy offered through Accent.
The Networker receives a Networker fee for each Proposed Candidate proposed by him and who is employed by or through Accent and this on the cumulative condition that:
The Networker fee is equal to the amount stated in the App for the relevant Vacancy. The Networker fee is only allocated to the Vacancies offered through ACCENT, not to the Vacancies offered through another Powerhouse or through a third-party employer. If several Proposed Candidates are employed by Accent or are recruited by a customer through Accent, the Networker is entitled to a Networker fee for each of these Proposed Candidates.
The Networker is paid based on the data he has provided in the App (see also article 13 of the Privacy Policy). Neither HOI nor Accent can under any circumstances be held liable for possible erroneous pay-outs, if these could be due to incorrect personal data provided by the Networker.
Article 9 – MyTests
In the Web Portal/App, tests are offered to the User. It concerns the ‘Company Culture Test (What do I want)’ and the ‘Personality Test (Who Am I)’. These tests help both the User and the future employer to search and find the right person for the right company. One test examines what the User considers important in the workplace, while the other test tries to determine who the User is as a person. At the end of both tests, the User receives an analysis and description in PDF of what can be derived from his test results.
The User is free to choose whether or not to participate in the tests. The tests are offered via a separate application in the Web Portal/App. By participating in these tests, the User explicitly agrees that his test results can be shared with HOI and other entities within the House of HR group from which he wishes to use a particular application. In addition, a potential employer can consult the User’s MyTests results via SWOP Recruiter, it being understood that the test results are only made available to employers where the User has applied for an open Vacancy. The User has the free choice to share these tests with other third parties.
Article 10 – MyCV
An application is offered on the Web Portal and the App that draws up a Curriculum Vitae (CV) of the User on the basis of the information that the User provides to the application. The information that the User must provide includes his education, his experience, a number of open questions (including the question about his greatest achievement to date, etc). On the basis of this information, MyCV makes a CV available to the User in PDF format. Certain fields must be filled in by the User, others are optional. The mandatory fields must be provided so that MyCV can pursue its objective.
MyCV is offered via a separate application in the Web Portal/App. The use of MyCV in conjunction with MyProfile has a reinforcing effect. By making use of MyCV, the User explicitly agrees that the Profile Data provided in the application MyProfile are used to feed the MyCV application. In addition, the User can also choose to add the ‘Personality Test’ to his CV in the application MyCV.
The User can freely choose whether he wishes to use MyCV. By using MyCV, the User explicitly agrees that his data in MyCV are shared with HOI and other entities within the House of HR group from which he wishes to use a particular application. The User is free to share the CV generated via MyCV with other third parties.
In addition, a potential employer can consult the User’s CV via SWOP Recuiter, it being understood that the CV is only made available to employers where the User has applied for an open Vacancy.
Article 11 – MyProfile
This application is offered on the Web Portal and is also completely non-binding. In addition to the Registration Data that the User must enter to create an account, the User has the option to complete his Profile Data in this application. None of the fields must be obligatory filled in by the User.
In case the User fills in one or more of the optional fields, there will also be a synergy here with the other applications. The use of MyProfile in conjunction with MyCV also has a reinforcing effect here. The data entered in the MyCV application feeds the MyProfile application.
By using this application, the User explicitly agrees that his data are shared with HOI and other entities within the House of HR group from which the User wishes to use a particular application.
Article 12 – Applicable law and competent court
The agreement between the parties is governed, interpreted and executed in accordance with Belgian law which is exclusively applicable.
Article 13 – Privacy Policy
The Privacy Policy is an integral part of these General Terms and Conditions.
By creating an account on the Web Portal and/or registering/using the App/MyTests/MyCV/MyProfile, the User acknowledges having read the Privacy Policy. The Privacy Policy can always be consulted on the Web Portal/App.
Article 14 – Other provisions
The Dutch version of the General Terms and Conditions takes precedence over any translations.
If any provision of the Terms and Conditions is invalid or unenforceable, this shall not affect the enforceability of the remaining provisions. The invalid or unenforceable provision shall be deemed superseded by an alternative valid and enforceable provision that most closely reflects the parties’ original intent, as permitted by applicable law.
