Last revised on: 24 May 2018

1. GENERAL

Playpass, a limited liability company, with registered office at Lange Gasthuisstraat 29-31, 2000 Antwerp, Belgium and registered with the Crossroads Bank for Enterprises under number 0501.728.738, RLE Antwerp, section Antwerp (“Playpass”, “Employer” or “we”) takes the measures mentioned in this privacy policy (“Privacy Policy”) to protect your privacy. We believe the protection of the privacy of applicants and staff is important. With this Privacy Policy we want to inform you as good as possible about what data we collect, how and why we process your data and how you control it. According to the legal definition, personal data means any information relating to an identified or an identifiable natural person (“Personal Data”).

Playpass will only use your Personal Data for the purposes stated in this Privacy Policy and we will not disclose your Personal Data to any other natural person, legal person, or entity other than ourselves (“Third Party”), except as provided for in Section 4. of this Privacy Policy.

Each processing will therefore always be done in compliance with the applicable privacy legislation, more specifically the EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, together with the codes of practice, codes of conduct, regulatory guidance and standard clauses and other related legislation resulting from such Regulation, as updated from time to time (the “Privacy Legislation”).

This Privacy Policy applies to the relationship between you and Playpass in its capacity as Employer or potential Employer. We assume that you have read this Privacy Policy and to the extent required, that you agree with the collection and processing of your Personal Data by Playpass in accordance with the provisions of this Privacy Policy.

Playpass reserves the right to amend this Privacy Policy at any time, provided it has informed you. 

2. COLLECTION OF PERSONAL DATA

Playpass collects and processes the following Personal Data of applicants:

  • name, first name, marital status, date of birth, nationality and place of birth, passport photo;
  • contact details (e.g. postal address, telephone number and e-mail address);
  • data allowing to assess whether your application is eligible for a specific job (e.g. education and diplomas, language skills, professional experience, job title(s), period, company name, company type, main tasks and responsibilities, references and skills);
  • data collected during the application process; and
  • in case of registration via LinkedIn (or any other social media account): profile details, public details of your contacts and e-mail address.

Playpass collects and processes the following Personal Data of staff:

  • name, first name, marital status, date of birth, nationality and place of birth, passport photo;
  • contact details (e.g. postal address, telephone number and e-mail address);
  • data allowing to assess whether your application is eligible for a specific job (e.g. education and diplomas, language skills, professional experience, job title(s), period, company name, company type, main tasks and responsibilities, references and skills);
  • data collected during employment; and
  • bank account number, national register number.

We will only store you Personal Data on servers located in the European Economic Area.

3. STORAGE AND ACCESS TO PERSONAL DATA

The Personal Data that are thus communicated or collected through applications, through the further course of the application process and during recruitment and employment, are collected and processed in Playpass’ HR database.

Playpass must therefore be considered as the “controller”, as defined in the applicable Privacy Legislation, for the processing of your Personal Data and also controls the processing that other parties perform on its request.

In any event, Playpass will not longer save your Personal Data than contractually and/or legally permitted.

4. PURPOSES OF THE DATA COLLECTION AND PROCESSING

We will collect and process all your Personal Data for the following purposes (the “Purpose”):

1.    In the case of applicants:

  • Assessment of the suitability of the person concerned for a position that is or may be vacant;
  • Internal control and operational safety; and
  • To further develop and improve the website, our services and our systems.

2.    In case of staff:

  • For staff management and payroll administration;
  • For career counselling, career guidance, career coaching or strengthening leadership;
  • For entering into and managing freelancer assignments;
  • For improving your personal development (e.g. following an additional training);
  • For management purposes including management information, providing internal control and operational safety; and
  • To apply for subsidies, exemption from withholding tax and to be able to comply with legislation and regulations, including but not limited to labor law, tax and social security law.

Playpass may rely on Third Parties, active in the field of payroll, HR, tax and social legislation, which take over a part of the aforementioned Purpose.

Furthermore, Playpass has free access to your Personal Data, and may freely save and publish your Personal Data in the following cases:

  • to comply with applicable laws or regulations;
  • if a law enforcement authority or other government agency so requests;
  • for investigating suspicious or fraudulent or illegal activities; and/or
  • to protect security and/or your rights or these of Playpass.

5. SECURITY OF YOUR PERSONAL DATA

Playpass takes the appropriate and necessary organizational and technical security measures to protect your Personal Data and your privacy in order to prevent the loss, the unauthorized use or change of information we receive. In some cases, your Personal Data will be shared with Third Parties, who must also take the necessary and appropriate administrative, technical and organizational measures to protect the Personal Data.

We try to achieve this protection of your privacy by restricting access to your Personal Data to a carefully selected group of staff members. These Playpass staff members will only be granted access to your Personal Data to the extent necessary to perform their duties properly.

6. TRANSFER OF PERSONAL DATA

Unless otherwise stated in this Privacy Policy, we will not sell, transfer or otherwise disclose your Personal Data to Third Parties without your prior explicit consent, unless this is necessary for the Purpose set out in this Privacy Policy, or unless we are required to do so by law.

Such Third Parties will only have access to the Personal Data they need in order to perform their duties, and may not use such data for any other purpose. These Third Parties are also subject to the contractual duty of confidentiality and must provide the necessary guarantees that appropriate organizational and technical security measures are taken to protect your Personal Data and privacy.

7. WHAT ARE MY RIGHTS AS DATASUBJECT?

We want to guarantee a safe and lawful processing of Personal Data, and we assure you that your Personal Data will be processed in a straightforward and lawful way. This implies that the Personal Data will only be processed for the aforementioned, explicitly stated and legal Purpose. Playpass also ensures that the Personal Data will always be processed in an adequate, relevant and non-excessive manner.

My right of access and inspection

If you have questions or suggestions regarding the processing of your Personal Data, then you have the right to request information about this processing. We will then give you access to the Personal Data that we process about you and the source of these Personal Data.

In order to exercise your right of access and to prevent any unauthorized disclosure of your Personal Data, you must provide us with a proof of your identity. We therefore ask you to add a copy of the front of your identity card to your written request by e-mail or by mail when exercising your right of access.

My right of rectification or erasure

You have the right to have your Personal Data rectified, erased or amended, free of charge, to correct inaccuracies, in the event these Personal Data is incomplete or incorrect, or is being processed in an unlawful manner.

In the event of a request for erasure, you must be aware that we must retain certain Personal Data in order to comply with our legal obligations.

In the event of any questions regarding this Privacy Policy, or if you wish to exercise the above rights, this will be possible via a signed, written request addressed to Playpass by mail to Playpass NV, Lange Gasthuisstraat 29-31, 2000 Antwerp, Belgium or via e-mail to administration [at] playpass.be. Playpass undertakes to answer any request to exercise the aforementioned rights within thirty (30) calendar days.

Responsible for processing:

Playpass NV
Lange Gasthuisstraat 29-31
2000 Antwerp
Belgium
Ron Schuermans
CFO