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This Policy is drawn up by S.P.R.L. PaHRtners, having its registered office at Rue du Warchais, 34, 6210 Les Bons Villers – e-mail: info@pahrtners.be registered with the Cross-Roads Bank of Enterprises under number: BE 0544455654 (hereinafter referred to as "PaHRtners" or "we"). This Policy applies to the website www.pahrtners.be (hereinafter referred to as the "website") and describes the methods we use to collect, process and store your personal data.

We consider the protection of personal data (hereinafter referred to as the data) and respect for the privacy of all persons who come into contact with us to be very important. We want to be fully transparent, in accordance with national and international regulations on the subject, in particular Regulation (EU) 2016/679 of the European Parliament and of 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 (hereinafter referred to as the "General Data Protection Regulation" or "GDPR").

This policy may be modified at any time to comply with any changes in regulations, case law or technology. We invite you to consult it regularly.

You may submit your comments reagarding any of the practices described below by contacting us at the addresses mentioned in the "Contact Us" section of this Policy.

1. Who is this Policy intended for?

This Policy is intended for natural persons whose data are processed by us, including those browsing our website. By way of example, this concerns natural persons who:

  • Browse our website;
  • Work for one of our principals or (potential) clients or use one or more of our services;
  • Are the point of contact with one of our suppliers or potential suppliers;
  • Are external consultants or contact persons at one of the external consulting companies with whom we work or plan to work;
  • Are contact persons for any undertaking (company, public authorities, professional federation of employers or workers, school, university, partner, etc.) with whom we have maintained or maintain or wish to maintain a form of co-operation and whose personal data we process.
  • Who apply as candidates when they register on our website, when they apply for a vacancy, when they communicate and when they share their applications spontaneously and voluntarily;
  • Who, in general, voluntarily provide us with their personal data that will be included in a file.

We inform you that your data will be used in accordance with this Policy.

2. How do we collect your data?

We collect your data through different channels:

  • At your initiative by any clear affirmative action, any manifestation of will that is free, specific, informed and unambiguous, including e-mail, text messages, verbally over the telephone, in our agency, during a visit to your company, during an event, a training course by handing over your business card or in any other way.
  • When your company or organisation identifies you as the contact person for our co-operation with your company.
  • If you are the appropriate contact person so that we can initiate a contact as part of the services we provide.
  • When your data is publicly disclosed or if you yourself have made it publicly accessible on public/social media, especially through professional media (such as LinkedIn)
  • With the contact person you provide us with in order to confirm or provide an external opinion on your profile.

In the context of the use of our site, we collect your personal data in the following ways (non-exhaustive list):

  • When you browse our website, via one or more cookies. When you browse our site, our computer systems may collect passive data such as your IP (Internet Protocol) address or browser type. We also use cookies to collect information about the date and time of your visit or the pages of the site you visited;
  • When you contact us via the form(s) available on the website.

3. What data is collected?

We process your personal data that are strictly necessary for the proper performance of the services we offer or to meet our legal obligations.

The following data that may be collected and processed: 

  • Identification data: surname, first name, home address, e-mail address, telephone number, gender, date and place of birth, marital status, nationality, photograph, occupation.
  • Data relating to your academic and professional background: diplomas, degrees, honours and results obtained, Board of Assessors’ opinions, data relating to dissertations and end-of-studies reports.
  • The results of the evaluations we conduct for our clients.

When you visit our site, we may also collect the following information, among others:

  • Your IP address, browser and referring URL to the message that is automatically detected when sending our forms; your information, if you have voluntarily provided it to us via our forms; information about the pages you have visited on our website. (see Cookies Policy)

4. For what purposes is the data processed?

Depending on the purpose for which you contact us, we will process your personal data for one of the following purposes:

  1. The performance of HR services, our services or the promotion of our service offers;
  2. To initiate or maintain a business relationship, a contract with you, your company or your organisation and enable it to be carried out;
  3. The presentation and development of partnerships;
  4. To select and recruit, with a view to negotiating a permanent or temporary position, including proactively submitting CVs and descriptions of suitable candidate profiles and organising possible interviews;
  5. To enter into and terminate an employment contract and, if necessary, manage salaries and/or subsidies related to this position;
  6. To provide you with interesting information and legal news;
  7. To perform tests as part of your placement;
  8. To support your in-house career;
  9. To manage public relations, commercial promotions, in particular through a technical-commercial screening;
  10. To ensure the follow-up of our invoices and payments;
  11. To provide you with information about our services and other activities and to better match them to your needs and wishes or those of your company or organisation, by monitoring the quality of our services;
  12. To ensure operational security, and in particular to check your identity and activities in our systems in order to prevent any misuse of the information contained in our databases;
  13. To handle complaints and ensure that disputes are resolved.

This data will only be used for the purpose of managing your requests on the basis of our pre-contractual obligations, your consent or our legitimate interest.

We will not use your data for any other purpose without prior notice and, if necessary, without your consent.

5. What is the legal basis for our processing activities?

Depending on the purpose of our processing activities and the persons whose data we collect, we process personal data on the basis of:

  1. Our contractual and pre-contractual obligations, when we negotiate or enter into a contract with you or your company, we need a certain amount of personal data in order to be able to make a suitable offer, draft the contracts and then fulfil our obligations. Otherwise, it will not be possible for us to start or to provide our services. Then, as part of the joint processing of candidates' and our clients’ data, we may also jointly process certain personal data on this basis, such as evaluations of candidates' profiles.
  2. Express written or unwritten consent: when performing our services for the recruitment and/or selection of employees, we communicate the contact details of the selected candidates to the companies or organisations that use our services. This requires your consent. This consent is express consent, even if it is not given in writing, it is not tacitly given and is based either on our consent form or on you spontaneously providing your data.
  3. Our legitimate interests or those of a third party: if necessary, we use your data to meet our legitimate interests or those of third parties. This may occur, for example, when we offer and promote any services and/or information notices that correspond to what you can reasonably expect from us in the context of our existing or potential future relationship. This may also relate to access controls or internal checks and audits performed to ensure the security and continuity of our systems and businesses. These legitimate interests also exists when we need to store your data in order to initiate, exercise or support any legal action.
  4. Our legal obligations: as part of our activities, the law requires us to collect certain personal data (tax data, etc.).

6. Whom do we share your data with?

The data listed above are accessible to members of our services, to the extent that they are strictly necessary for carrying out their mandate. All staff members are also bound by confidentiality.

We may only transmit some of your personal data if doing so is necessary to fulfil the purposes and in accordance with the legal bases listed above. This way, your data may be shared:

  1. When carrying out a contract for the recruitment and/or selection of applicants, candidates, in particular in the context of appointments for application interviews, or agreements relating to the commencement and performance of their duties.
  2. With our subcontractors, in particular with regard to the provision of services or the performance of duties and mandates (e.g. IT service providers, cloud service providers, access security, accounting departments, etc.). To ensure the security of your data, we select vendors who guarantee a sufficient level of security and enter into agreements that ensure a high level of confidentiality, as a minimum. The list of subcontractors to whom your data are communicated, their fields of activity, the purpose and, if applicable, the country in which the data are stored are available from our "Privacy" department: {mail}
  3. With Federgon (professional federation of HR service providers) (or its audit or research office), in particular for scientific studies, satisfaction surveys and for statistical purposes.
  4. To all other third parties to whom we are required to disclose them by law, pursuant to a court decision or judgment, such as official authorities, in the context of inspections and investigations (NSSO, tax authorities) or accreditation bodies.
  5. Or in good faith by considering that such action is required to comply with any applicable law or regulation or to protect and defend our rights or those of a third party (such as our customers, site users, other candidates).

Your personal data will not be sold, rented or made available to third parties for commercial purposes, except with your prior consent.

7. Subject to what conditions do we allow the transfer of your data outside the European Union?

We sometimes transfer your data outside the European Union, where we will take the necessary contractual and technical protection measures to ensure that all your personal data are adequately protected against loss or unlawful use.

Transfers of data to a country outside of the EU will only be allowed in the following cases:

  1. The European Commission has issued a decision confirming an adequate level of protection equivalent to that provided by European legislation.
  2. The transfer is covered by an appropriate measure granting a level of protection equivalent to that provided for by European legislation, such as the Commission's Standard Clauses or your written or unwritten consent.
  3. The transfer is necessary for performing a contract between you and our customer as joint data controller or for the implementation of pre-contractual measures taken at your request.
  4. The transfer is necessary to enter into or perform a contract entered into in your interest between us and our customers.

8. How long do we retain your data?

We retain your personal data only for as long as is strictly necessary to fulfil our legal or contractual obligations, in the context of processing your case file. We therefore retain the general data included on your CV for a period of 2 years, in our legitimate interests.

9. What are cookies and what are they used for?

  1. What is a cookie?
    A cookie is the equivalent of a small text file automatically placed on the user's terminal (computer hard drive, tablet, smartphone, or any other similar device) through their browser.
  2. What cookies do we use?
    Cookies have different functions and they collect and retain different types of information, such as visitors' language preferences and statistics about visitors to a website, or they ensure that the website functions properly. Some of these cookies are therefore necessary to enable you to access our site in the best possible way. They are automatically installed on your computer, without us being able to ask you for permission. Other cookies are only stored when you give your consent.

    We may use different types of cookies.
    1. Cookies necessary for browsing, called "functional" cookies
      For these cookies, your consent is not required.
      These are the following cookies:
      1. authentication cookies
      2. security cookies.
    2. "Third-party" cookies
      These cookies require your consent. We will not place any cookies without your consent. However, third parties may place cookies on your device when you browse our site, if you provide your consent.
      These third-party cookies are the following:
      1. Cookies to measure traffic patterns;
      2. Advertising cookies;
      3. Social network sharing cookies.

        These third-party cookies are placed via our site by third parties. The list of third parties is available on the following link: {PDF- cookie list}
        When you visit our website, socio-demographic and profile data are collected and stored anonymously in a commercial cookie.
  3. Why do we use these cookies and what happens if you refuse them?
    The purposes and consequences of refusing cookies vary according to the type of cookies in question.
    1. Functional cookies
      These cookies are required to enable you to visit our website and facilitate the use of certain parts of the website.
      They enable you to:
      1. Navigate between the different sections of the website and help you to return to the previous pages;
      2. Fill in forms;
      3. Customise services by recording your preferences (language, currency, location, browsing data, etc.);
      4. Avoid having to repeat your choices each time you visit the site;
      5. Collect the information provided in the online forms;
      6. Generate statistics (e.g. number of unique visitors);
      7. Analyse the use of the site and the popularity of our pages.
        Your browser settings allow you to manage these cookies, but if you refuse these cookies, some parts of our website will not work as intended, or not at all. We do not accept any liability in this respect.
    2. Types of third-party cookies
      These cookies require your prior consent.
      Advertising cookies enable:
      1. you to avoid having to watch the same advertisements repeatedly
      2. us to measure the effectiveness of our various marketing and advertising actions
      3. us to personalise the advertising on our website.
        If you refuse these cookies, advertisements will still be shown, but they will no longer be personalised. This simply means that the services displayed on our site will not be based on your supposed interests. You can also still receive behavioural ads from other companies, if you have not refused their cookies.
    3. Traffic pattern measurement cookies help to improve the content and functioning of the website through the use of Google Analytics.
    4. Social network sharing cookies enable you to share our content with your network and friends and track your browsing on other sites and profile your interests.
      If you do not accept social cookies, you may not be able to use, or even view, the sharing tools.
  4. How do you give or withdraw your consent?
    Placing a cookie on your device is essentially subject to your prior and explicit consent. A cookie management banner on the home page enables you to express your consent to our cookies.
    You may express and modify your consent at any time and free of charge in various ways:
    1. By modifying your browser settings.
      You have the option of configuring your browser to prevent cookies from being stored on your computer or to delete cookies already stored.
      This setting may change your internet browsing experience and your conditions of access to certain services requiring the use of cookies.
      This configuration is specific to each browser. It is described in the help menu of your browser, which will explain how to change your cookie preferences.
      For Internet Explorer : http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies
      For Safari : http://help.apple.com/safari/mac/9.0/#/sfri11471
      For Chrome : http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647
      For Firefox : http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies
      For Edge : https://privacy.microsoft.com/fr-fr/windows-10-microsoft-edge-and-privacy
      For other browsers: please refer to the help section of your browser or go to the website of its publisher.
    2. You can also set your browser to send a code to tell websites that you do not want to be tracked, using the “Do Not Track" option:
      For Internet Explorer : http://windows.microsoft.com/fr-fr/internet-explorer/use-tracking-protection#ie=ie-11
      For Safari : http://support.apple.com/kb/PH11952
      For Chrome : https://support.google.com/chrome/answer/114836?
      For Firefox : https://support.mozilla.org/fr/kb/comment-activer-option-ne-pas-pister
  5. What is the cookie management policy of "third-party cookie" operators?
    1. With regard to Google Analytics,, our website uses the services of Google Analytics, a web analytics service provided by Google Inc. Google Analytics uses cookies which enable the analysis of your use of the website. This information is generally transmitted to a Google server in the USA and stored there.
      If you decide to make the IP address anonymous on this website, it will first be truncated within the Countries or States that have signed the Agreement on the European Economic Area. The complete IP address will only be transmitted in exceptional cases to a Google server in the United States where it will be abridged. Google will use the information collected to analyse how users use the website, to compile reports on website activity and to provide the operator with other services related to website use and internet browsing in general. The IP address provided by your browser as part of Google Analytics will not be linked to any other data held by Google. You can block the storage of cookies by configuring your browser accordingly.
      However, we draw your attention to the fact that disabling this feature may prevent you from using certain features of the website. You can prevent the collection of data generated by the cookie and related to your usage of the website (including your IP address) by Google, as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=fr.
      Google's privacy policy is available at http://www.google.com/intl/fr/policies/privacy/
      Google Analytics: https://tools.google.com/dlpage/gaoptout
    2. With regard to other third-party cookies:
      Our site includes links to other sites. The content of this Privacy Policy only applies to our own website. It is your responsibility to review the privacy policy of the sites to which these links refer.
      Facebook: https://www.facebook.com/help/cookies
      LinkedIn: https://www.facebook.com/cookies
  6. How long are cookies stored on your device?
    Most cookies only work for the duration of a single session or visit. Persistent cookies are stored until your consent expires, unless you decide to delete them earlier. Session cookies expire at the end of the session, as soon as you close your browser window.
  7. How long do we retain your consent for the use of cookies?
    We retain your consent for the use of cookies for a maximum period of 13 months.

10. How do we protect your privacy?

We take appropriate technical and organisational measures (encryption technology and security measures to protect and avoid the loss, misuse or alteration of information collected on the websites) to ensure that the data collected on the website is as secure as possible. We take into account the state of knowledge, the costs of implementation and the nature, scope, context and purposes of the processing and the risks to your rights and freedoms.

11. How can you exercise your rights?

We consider the rights you have as a data subject to be very important. To this end, we invite you to contact our Privacy Officer at the following e-mail address: {mail} or by sending a message to our contact address (see above)

If your data are processed on the basis of our legitimate interests or your consent, you have the right to withdraw your consent to processing at any time. However, it may not be possible to remove all information, in particular for contractual or legal reasons. Nevertheless, you have the right to be informed about the purposes for which your data will be processed and the persons who will have access to your data and/or will be involved in the processing of your data.

Upon simple written request, which you can send by e-mail or by post, you have the right:

  • to access and consult your personal data;
  • to request corrections, if certain information is not correct;
  • to the erasure of your data;
  • to the restriction of their processing;
  • to receive all information about you that is recorded in a portable and readable format, and to obtain the transfer of your data to another service provider whose identity you specify (right of portability);
  • to object to processing on the basis of a legitimate interest, to processing for direct marketing and profiling purposes and to processing for the purposes of scientific or historical research or statistics which are not in the public interest;
  • not to be the subject of individual automated decision-making.

In principle, you can exercise your rights free of charge.

Within one month of receiving your request, we will inform you in writing of the action taken following your request. Depending on the complexity of your request or the number of requests we receive from other people, this period may be extended by two months. In such case, we will notify you of this extension within one month of your request. In some cases (e. g. legal obligations, rights of other persons, limitations, etc.), you may not be able to exercise your rights, in whole or in part. You will then be informed of this and of the reasons for which we cannot fully comply with your request.

12. How to file a complaint or contact us

If you wish to respond to any of the practices described in this Policy or wish to inform us of a leak you are aware of, you can contact us at the following address:

ADRESSE : Rue du Warchais, 34 à 6210 Les Bons Villers
TEL 0032-473.640.320
MAIL info@pahrtners.be

You can file a complaint with the Belgian Data Protection Authority at the following address:

Data Protection Authority
Rue de la Presse, 35 – 1000 Bruxelles
Tel : +32 (0) 2 274 48 00 – Fax : +32 (0)2 274 48 35
Email : contact@apd-gba.be

You can also file a complaint with the Court of First Instance of your place of residence.

For further information on complaints and possible remedies, you are invited to consult the following address of the Data Protection Authority: https://www.autoriteprotectiondonnees.be/introduire-une-requ%C3%AAteune-plainte

13. Applicable law and jurisdiction

La présente Politique est régie par le droit belge. Tout litige relatif à l’interprétation ou l’exécution de la présente Politique sera soumis au droit belge et relèvera de la compétence exclusive des tribunaux de l’arrondissement judiciaire du Brabant Wallon.

14. Updating this Policy

This Policy may be updated at any time and without prior notice. We invite you to consult it regularly.