Effective May 25, 2018
If you have any questions or concerns about our use of your Personal Information, then please contact firstname.lastname@example.org.
1. The Basics
A. About Us
HoiTalent is the largest job portal for international talents in the Netherlands (the "Services") operated by HoiTek Ventures B.V., a company headquartered in Amsterdam in the Netherlands ("we," "us," "our," and "HoiTalent").
We provide free job and event information, professional career coaching, and useful advice and tips. From 2016, we are also expanding our service to UK, Germany and Belgium. We also provide other related services, such as career coaching and talent searching services.
B. Key Terms
"Member" means any person or entity that is registered with us to use the Services.
"Personal Information" means any information that identifies or can be used to identify a Member, a Contact, or a Visitor, directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information.
2. Privacy for Members
This section applies to the Personal Information we collect and process from a Member or potential Member through our Services. In this section, "you" and "your" refer to Members and potential Members.
A. Information We Collect
The Personal Information that we may collect broadly falls into the following categories:
(i) Information you provide to us: In the course of engaging with our Services, you may provide Personal Information about you. Personal Information is often, but not exclusively, provided to us when you sign up for and use the Services, consult with our consulting team and send us an email.
(iii) Information we collect from other sources: From time to time, we may obtain information about you from third-party sources, such as public databases, social media platforms, and third-party data providers. We take steps to ensure that such third parties are legally or contractually permitted to disclose such information to us.
B. Use of Personal Information
We may use the Personal Information we collect through the Services or other sources for a range of reasons, including:
- To bill and collect money owed to us by you.
- To send you system alert messages.
- To communicate with you about your account and provide customer support.
- To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
- To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
- To prosecute and defend a court, arbitration, or similar legal proceeding.
- To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- To provide, support and improve the Services. For example, this may include sharing your information with third parties in order to provide and support our Services or to make certain features of the Services available to you.
- To provide suggestions to you.
- For our data analytics projects. Our data analytics projects use data from HoiTalent accounts, including Personal Information of Contacts, to provide and improve the Services. We use information like your sending habits and your Contacts’ details and purchase history, so we can make more informed predictions, decisions, and products for our Members. If you or your Contact prefers not to share this data, you can alter the security settings on your account to opt out of data analytics projects, or your Contact can opt out of data analytics projects at any time by emailing us at email@example.com.
- Other purposes. To carry out other legitimate business purposes, as well as other lawful purposes about which we will notify you.
C. Cookies and Tracking Technologies
We and our partners may use various technologies to collect and store information when you use our Services, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. For example, we use web beacons in the emails we send on your behalf. These web beacons track certain behavior such as whether the email sent through the Services was delivered and opened and whether links within the email were clicked. They also allow us to collect information such as the recipient’s IP address, browser, email client type and other similar details. We use this information to measure the performance of your email campaigns, and to provide analytics information and enhance the effectiveness of our Services. Reports are also available to us when we send email to you, so we may collect and review that information.
D. Other Data Protection Rights
You have the following data protection rights:
- To access, correct, update or request deletion of Personal Information. HoiTalent takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete and up to date. As a Member, you can manage your individual account and profile settings within the dashboard provided through the HoiTalent platform, or you may contact us directly by emailing us at firstname.lastname@example.org.
- In addition, individuals who are residents of the EEA can object to processing of their Personal Information, ask to restrict processing of their Personal Information or request portability of their Personal Information. You can exercise these rights by contacting us.
- Similarly, if Personal Information is collected or processed on the basis of consent, the data subject can withdraw their consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent. \\
- The right to complain to a data protection authority about the collection and use of Personal Information. For more information, please contact your local data protection authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection law. We may ask you to verify your identity in order to help us respond efficiently to your request. If we receive a request from one of your Contacts, we will either direct the Contact to reach out to you, or, if appropriate, we may respond directly to their request.
3. General Information
A. How We Share Information
(i) Our service providers: Sometimes, we share your information with our third-party service providers, who help us provide and support our Services and other business-related functions.
(ii) Advertising partners: We may partner with third-party advertising networks and exchanges to display advertising on our Websites or to manage and serve our advertising on other sites and may share Personal Information with them for this purpose.
(iii) Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.
(iv) A potential buyer (and its agents and advisors) in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition.
(v) Any other person with your consent.
B. Legal Basis for Processing Personal Information (EEA Persons Only)
If you are from the European Economic Area, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.
However, we will normally collect and use Personal Information from you where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms. Typically, our legitimate interests include improving, maintaining, providing, and enhancing our technology, products, and services; ensuring the security of the Services and our Websites; and for our marketing activities.
If you are a Member, we may need the Personal Information to perform a contract with you. In some limited cases, we may also have a legal obligation to collect Personal Information from you.
If we ask you to provide Personal Information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not, as well as of the possible consequences if you do not provide your Personal Information.
Where required by law, we will collect Personal Information only where we have your consent to do so.
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us email@example.com.
C. Your Choices and Opt-Outs
Members who have opted in to our marketing emails can opt out of receiving marketing emails from us at any time by clicking the "unsubscribe" link at the bottom of our marketing messages.
Also, all opt-out requests can be made by emailing us using the contact details firstname.lastname@example.org. Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management, and Members cannot opt out of these messages unless you cancel your HoiTalent account.
D. Our Security
We take appropriate and reasonable technical and organizational measures to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. If you have any questions about the security of your Personal Information, you may contact us at email@example.com.
HoiTalent accounts require a username and password to log in. Members must keep their username and password secure, and never disclose it to a third party. Because the information in a Member’s HoiTalent account is so sensitive, account passwords are hashed, which means we cannot see a Member’s password. We cannot resend forgotten passwords either. We will only provide Members with instructions on how to reset them.
E. Retention of Data
We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we'll refer to these criteria in order to determine retention period:
- Whether we have a legal or contractual need to retain the data.
- Whether the data is necessary to provide our Services.
- Whether our Members have the ability to access and delete the data within their HoiTalent accounts.
- Whether our Members would reasonably expect that we would retain the data until they remove it or until their HoiTalent accounts are closed or terminated.
When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
F. Changes to this Policy
G. Questions & Concerns
If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, you can contact us by filling the contact form or by postal mail or email at
HoiTek Ventures B.V.
Karspeldreef 14, 1101 CK Amsterdam, the Netherlands