Privacybeleid | wefynd

1. Introduction and scope

This privacy policy ("Privacy Policy") governs the processing of your personal data in connection with your use of our platform ‘We Fynd’ available on https://www.wefynd.com (the "Platform"). The Platform provides services to bring students in contact with companies that match their interests, culture and educational background. A more detailed description of our services you can find on our website and in your agreement with We Fynd.

We consider the protection of your privacy extremely important and wish to inform you, as a user of our Platform (in particular (i) students, candidates or jobseekers (“Students”) and (ii) users of companies (“Company Users”) about how, why and on which ground(s) we process your personal data in order to enable you to maintain control over your data as well as about with whom we share your data. We try to inform you in a transparent way.

Your personal data and your privacy will be protected by We Fynd in accordance with Belgian and European data protection laws, including the EU General Data Protection Regulation 2016/679 (“GDPR”) as well as any applicable national implementing and supplementing laws.

Please read this Privacy Policy carefully. It describes not only your rights and provides the required information on the data processing, but also the way in which you can exercise these rights.

Please note that this Privacy Policy does not cover any policies or terms of third parties.

2. Who is responsible for processing your data and how to reach We Fynd?

We Fynd BV, a company incorporated under Belgian law, with registered office at Kipdorp 49, 2000 Antwerp, Belgium, and with company number 0654.979.335 ("We Fynd", "we", "us") is responsible for the lawful processing of Your personal data

We Fynd acts as data controller in the context of this processing. This means that we determine the purposes and means of the data processing, individually or jointly with our customers (companies).

For the processing of personal data of users on the Platform, as described in detail below under section 3, the company (our customer) and We Fynd act as joint controllers. In the agreements with the companies we included the necessary arrangements within the meaning of Article 26 GDPR in order to comply with GDPR.

Please note that in case you apply via the Platform for a specific vacancy of a company using the Platform, the latter will provide you the necessary information on their processing activities in their privacy policy for which We Fynd is not responsible. From the moment that your personal data is processed by the customer / company outside of the Platform, the latter’s privacy policy will apply and will be made available to you.

If you have any questions regarding our data processing activities, you can reach us by e-mail at privacy@wefynd.com.

3. What personal data do we process and for what purposes?

We Fynd processes the following personal data of users for the following purposes:

(i) Students:

Processing purposes	Type of personal data	Legal basis
Communication, questions, contact (including calls, chatbot, online or other meetings, emails, contact form via our website) or other communication in order to provide you with information about our Platform and services or for preparation of a license agreement	First name, last name Address E-mail address Telephone number Content of your question / request (if any)	Our legitimate (commercial) interests, which outweigh your (privacy) rights as you can reasonably expect such processing, or the preparation of the (license or user) agreement with you.
Platform services – execution of the (license) agreement with you, including onboarding, registration, your use of the Platform, user management, providing the platform services and platform operations and related services of We Fynd.	Identification data: first name, last name, email address, address, telephone number Login data (login ID, user ID), passwords, Apple ID, Facebook ID or Google ID, profile data Data on your educational background, curriculum and work preferences: preferences regarding internships, jobs, teleworking, job applications, availabilities, types, degrees and other information on your education, language skills, digital skills, preferences of field / industries, certificates Personality characteristics: competences and weaknesses Electronic identification data in the context of your use of the Platform such as your device data, browser, operating system, IP addresses, cookies or similar technologies, log file data, pages or functionalities used, statistics etc.	Necessary for the performance of the (license or user) agreement with you.
To optimize the Platform and our services	Aggregated data (data that cannot identify you or be linked to you, such as statistical data), pseudonymized or anonymized data, rather than personal data. Electronic data such as cookies or similar technologies that are used to collect data. More information about the use of cookies can be found in our cookie policy.	Our legitimate (commercial) interests which outweigh your (privacy) rights as you can reasonably except such processing when using our Platform.
Direct marketing (commercial and advertising purposes), including our newsletter	Name Email address	Legitimate (commercial) interests. (If you are not a user of the Platform: informed consent via subscription.)
Prevention of fraud or other illegal or unlawful use of the Platform (e.g. to block or deny access to the Platform or take other measures if you violate the agreement(s), terms of use, policies or applicable law)	Identification data	Legitimate purposes.
Other legitimate purposes such as to facilitate our operations and services, generate aggregated statistics, perform analyses, apply our policies and procedures, defend against claims or demands, protect our users and customers and their rights etc.
Compliance with applicable laws or lawful requests or order by supervisory authorities, courts or government agencies	(Depending on which data is requested.)	Legal obligation or our legitimate interests.

(ii) Company Users or customers (b2b)

Processing purposes	Type of personal data	Legal basis
Communication, questions, contact (including calls, chatbot, online or other meetings, emails, contact form via our website) or other communication in order to provide you with information about our Platform and services or for preparation of a license agreement	First name, last name Address E-mail address Telephone number Function/title within the company Content of your question / request (if any).	Our legitimate (commercial) interests, which outweigh your (privacy) rights as you can reasonably expect such processing, or the preparation of the (license or user) agreement with you.
Platform services – execution of the (license) agreement with you, including onboarding, registration, your use of the Platform, user management, providing the platform services and platform operations and related services of We Fynd.	Identification data: first name, last name, email address, address, telephone number, function/title within the company Information on the company Login data (login ID, user ID), passwords, Apple ID, Facebook ID or Google ID, profile data Electronic identification data in the context of your use of the Platform such as your device data, browser, operating system, IP addresses, cookies or similar technologies, log file data, pages or functionalities used, statistics etc.	Necessary for the performance of the (license or user) agreement with you or our legitimate (commercial) interests as you can reasonably expect such processing in the context of your use of the Platform.
Administration, invoicing	Name of the company Registered office Addresses Company registration number VAT number Payment / financial data: bank account, prices, fees, invoices, other payment details. Any other information you share with us in relation to complaints, data subject requests, inspections, investigations, lawsuits or other legal information or company information.	Necessary for the performance of the agreement with you, our legitimate interests (as you can reasonably expect such processing) and legal obligations (regarding accounting, invoicing).
To optimize the Platform and our services	Aggregated data (data that cannot identify you or be linked to you, such as statistical data), pseudonymized or anonymized data, rather than personal data. Electronic data such as cookies or similar technologies that are used to collect data. More information about the use of cookies can be found in our cookie policy:	Our legitimate (commercial) interests which outweigh your (privacy) rights as you can reasonably except such processing when using our Platform.
Direct marketing (commercial and advertising purposes), including our newsletter	Name Email address	Legitimate (commercial) interests. (If you are not a user of the Platform: informed consent.)
Prevention of fraud or other illegal or unlawful use of the Platform (e.g. to block or deny access to the Platform or take other measures if you violate the agreement(s), terms of use, policies or applicable law)	Identification data	Legitimate interests.
Other legitimate purposes such as to facilitate our operations and services, generate aggregated statistics, perform analyses, apply our policies and procedures, defend against claims or demands, protect our users and customers and their rights etc.	(Depending on the data processing.)	Legitimate interests.
Compliance with applicable laws or lawful requests or order by supervisory authorities, courts or government agencies	(Depending on which data is requested or legally required.)	Legal obligation or our legitimate interests.

We Fynd may process your personal data only if it relies on an appropriate legal basis as indicated above for each processing activity. We briefly explain the applicable legal grounds below:

Performance of a contract: the processing of personal data is necessary for the performance of the contract agreed upon between the relevant parties (e.g. your license / user agreement with We Fynd).
Legitimate interests: This legal basis applies whenever, given the nature of the personal data, We Fynd considers that the processing will not adversely affect your fundamental rights and/or freedoms (as you can reasonably expect such processing). You can always object to processing based on this legal ground by contacting us at privacy@wefynd.com.
Legal obligation: the processing of personal data is necessary for compliance with a legal obligation to which we are subject, or to cooperate with any ongoing judicial investigation, court order or lawsuit.

Consent: the processing of personal data is based on the freely given, specific, informed and unambiguous consent to the processing (e.g. your consent to our customer for storing / retaining data for the purposes of maintaining a recruitment reserve).

4. With whom do we share your personal data?

Your personal data can be processed by our partners, service providers or suppliers in connection with the use of the Platform or our services (e.g. hosting provider, IT partner, web administrator, partner for communication services or media services).

We Fynd verifies with its processors that they take the necessary appropriate (security) measures in accordance with GDPR or other applicable data protection legislation to protect your data and concludes the necessary data processing agreement with such processors.

Your personal data may be shared by We Fynd with the following third parties / processors:

Third Party	Processing activities	Categories of personal data	Location
CompanyMatch	Mapping of the company culture. Both the students and the company fill in an assessment with 26 questions in order to match both students and companies.	Name, family name, e-mail address, behavioral and personal data about students.	EEA
Mollie	Processing of payment data.	Name, family name, e-mail address, payment card details (card number)	EEA
Campaign Monitor	Sending of e-mails to users (students and companies)	Name, family name, e-mail address, IP address	EEA
Yuki	Accountancy	Name, family name, job title, professional e-mail address, professional phone number, professional address, financial and details of the company and company number	EEA
HubSpot	CRM platform, services	Name, family name, e-mail address, telephone number, CV related data, communication content	EEA

We Fynd will only share personal data that is relevant and necessary in the context of your use of the Platform and our activities. We always ensure that appropriate safeguards and security measures are taken when we transfer your personal data to those third parties / processors.

In addition, we may disclose your personal data if this is required by law, or if we determine in good faith that such disclosure is required in order:

a) to comply with any request of a supervisory authority, pending judicial inquiry, judicial order or litigation pertaining to the Platform;

b) to respond to claims against We Fynd regarding personal data that violate any rights of third parties;

c) to safeguard the rights, property and safety of We Fynd, its employees, contractors, users, and the general public.

If you would be redirected to another website via the Platform, other terms and conditions, privacy and cookie policies may apply. We therefore recommend that you read these additional terms and conditions carefully.

Your personal data and your profile will not be lent or sold to third parties without your prior express consent. Your personal data will only be viewed and made available to processors, employees or contractors of We Fynd and other third parties on a “need-to-know” basis, limited to the extent necessary to perform their services.

5. Will your personal data be transferred to countries outside the EEA?

Your data will not be transferred outside the European Economic Area (EEA). If We Fynd would so, we shall ensure that (additional) measures are taken in accordance with the applicable data protection legislation (e.g. the implementation of standard contractual clauses or other measures / appropriate safeguards).

6. How do we protect your personal data?

We Fynd takes appropriate technical and organizational security measures to ensure a level of security appropriate to the specific risks we have identified in the context of the data processing activities related to the Platform, including, but not limited to, technical controls and measures, encryption, restore and appropriate backup process in case of incidents, regular testing etc.

More information about our security measures is available upon request made to privacy@wefynd.com.

Despite these measures taken by We Fynd, you should be aware that there are always risks involved in transmitting personal data over the Internet. The security and protection of your personal data can never be fully guaranteed.

7. Data retention

We will only process, store or retain your personal data for as long as necessary to fulfil the purposes described in section 3 of this Privacy Policy, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

We may retain your personal data for a longer period in case of a legal obligation or in the event of a complaint or if we reasonably believe there is a dispute or possible litigation in respect to our relationship with you or the company or organization you work for. Afterwards it is still possible that they can be found in our back-ups or archives, but they will no longer be actively processed.

The retention periods may vary depending on the purposes on the processing and our legal obligations.

We Fynd applies the following retention periods:

For students: two (2) years after termination of your (user) agreement or after your last use of the Platform.

You can further manage and control the retention period by sending us an email to privacy@wefynd.com or choose any of the following options in the profile settings on the Platform:

“Delete user”: your data will immediately be removed and you will no longer be visible to any company you showed interest in or matched with.
“Deactivate user”: your profile will be temporarily be put on hold. Companies will no longer be able to see your profile, but your personal data will remains to be stored in the database of the Platform. If you do not reactivate your account within two (2) years, your personal data and profile will be removed from our database.

Companies: ten (10) years after termination of the (license) agreement or after the last use by a Company User.

Technical or electronic data or information: 12 months after collection.

In any case, the general principle applies that we do not keep your data longer than necessary.

If your personal data are no longer required for the purposes intended, we will, if necessary, delete or otherwise anonymize your personal data in a manner that protects it form unauthorized access or use.

8. What are your rights and how can you exercise them?

Within the limits defined in Articles 15-22 of the GDPR, you have the following legal rights in relation to your personal data processed in the context of the Platform:

Right of access: you have the right to obtain confirmation from us as to whether or not we are processing your personal data, to access that personal data and how and why it is being processed, as well as to receive a copy of that data.
Right to rectification: you have the right to obtain a rectification of your personal data or to request that we complete your personal data when you become aware that we are processing incorrect or incomplete data about you.
Right to erasure ('right to be forgotten'): you have the right to obtain erasure of your personal data in certain specific cases. As a Student exercising your right to erasure, you acknowledge that We Fynd has a legitimate aim to anonymize your personal data and retain data on your education and competences.
Right to restriction: You have the right to have the processing of your personal data restricted in certain specific cases.
Right to portability: You have the right to obtain the personal data you have provided to us in a structured, commonly used and machine-readable form, and to transfer (have transferred) that personal data to another controller.
Right to object: You have the right to object to the processing of your personal data on the basis of our legitimate interest for reasons relating to your specific situation. You can at any time and free of charge, object to the processing of your data for direct marketing purposes.

You can exercise the above rights by sending an e-mail to privacy@wefynd.com

The exercise of these rights is in principle free of charge. Only in the event of unreasonable or repeated requests we may charge a reasonable administrative fee.

We always try to answer your requests or questions as quickly as possible. It is possible that we will first ask you for proof of identity in order to verify your identity. Generally we will request a copy of your identity card in order to verify who is actually making the requests if we have any reason to doubt your identity. Please ensure that any information or data not required for the verification and conformation of your identiy is blacked out or otherwise removed or rendered illegible.

You have the right to lodge a complaint with the competent Data Protection Authority if you believe the processing of your personal data violates the applicable regulations. In Belgium, the competent authority is the Data Protection Authority (www.gegevensbeschermingsautoriteit.be, contact@apd-gba.be, Drukpersstraat 35, 1000 Brussels).

If you believe our business has violated the applicable regulations, we would like to have the opportunity to deal with any issues, so we kindly ask you to contact us first before contacting the Authority.

9. Changes to the Privacy Policy

We Fynd may modify this Privacy Policy at any time. The date of the last amended version is listed at the bottom of the Privacy Policy. Changes will be notified via the Platform and, if necessary, will be submitted for approval.

Amended versions of the Privacy Policy take effect seven (7) days after publication on the Platform and/or any other form of announcement, unless such modifications are necessary to comply with a legal requirement. In the latter case, such changes will take effect immediately.

10. Applicable law and jurisdiction

This Privacy Policy shall be governed, interpreted, and implemented in accordance with Belgian laws.

The Antwerp courts (department Antwerp) are exclusively competent to decide on any dispute that may arise from the interpretation or implementation of this Privacy Policy, without prejudice to the consumer’s right to present a dispute before a competent court on the basis of a mandatory statutory provision.

11. Contact

If you have any questions or concerns regarding this Privacy Policy or the processing of your personal data by us, please do not hesitate to contact us by sending an e-mail to privacy@wefynd.com.

Latest update: 08.06.2023.