1. About this privacy statement
1.3 Irrespective of any branding used on the websites, EPSN is the primary controller of your personal information provided to EPSN or collected for any service.
2. Collection of information
2.1 EPSN collects information about you in three ways: directly from your input, through the service’s technologies, and from third party sources.
2.2 The types of personal information that EPSN collects directly from you depends on how you interact with EPSN and the service and includes:
- Contact details, such as your name, email address, social media handle, postal address and phone number;
- Account login credentials, such as usernames and passwords, password hints and similar security information;
- Other account registration and profile information, such as educational and professional background and photo;
- Payment information, such as a bank account number;
- Comments, feedback and other information you provide to us, including search query data and questions or information you send to customer support; and/or
- Interests and communication preferences, including preferred language.
2.3 All data requested by EPSN under paragraph 2.2 is mandatory and failure to provide this data may make it impossible for EPSN to provide its services. In cases where EPSN specifically states that some data is not mandatory, you are free not to communicate this data without any consequences on the availability of functioning of the service.
2.4 A digital service may automatically collects information about how you and your device interact with the service, including:
- Computer, device and connection information, such as IP address, browser type and version, operating system and other software installed on your device, mobile platform and unique device identifier and other technical identifiers, error reports and performance data;
- Usage data, such as the features you used, the settings you selected, URL click stream data, including date and time stamp, and referring and exit pages, and pages you visited or searched for on the service; and/or
2.5 EPSN also may obtain personal information about you from their group companies and from other third parties, including:
- Social networks when you grant permission to access your data on one or more networks;
- EPSN’s service providers that helps them determine a location based on your IP address in order to customize any service to your location;
- Partners with which EPSN cooperates to offer their services;
- Publicly-available sources and data suppliers from which EPSN obtains data to validate or supplement the information they hold; and/or
- Google Analytics, Google+ like button and social widgets and Facebook like button and social widgets.
3. Processing of information
3.1 Depending on how you interact with EPSN and any service and your preferences, EPSN uses your personal information to:
- Provide, activate and manage your access to and use of any service;
- Process and fulfil a service, request, order, download, subscription or other transaction (including to process payments);
- Search for vacancies, trainings, courses, activities and/or seminars that matches your needs, interest and/or profile;
- Provide technical, product and other support and to help keep the service working, safe and secure;
- Enhance and improve services and to develop new services and benefits;
- Offer you customized content and other personalization to make the service more relevant to your interests and geography;
- Respond to your requests, inquiries, comments and concerns;
- Notify you about changes, updates or other announcements related to
- Deliver targeted advertisements, promotional messages, notices and other information related to your interests and EPSN’s events and services;
- Invite you to participate in user testing and surveys as well as competitions and promotions;
- Identify usage trends and develop data analysis, including for purposes of research, audit, reporting and other business operations, including determining the effectiveness of EPSN’s promotional campaigns and evaluating its business performance, or in other ways pursuant to a customer agreement; and/or
- Comply with its legal obligations, resolve disputes, and enforce its agreements.
4. Sharing of information
4.1 Depending on the service provided, EPSN shares information with:
- Affiliates, trading names and divisions within the EPSN group of companies worldwide, customer service and other shared services functions; and/or
4.2 EPSN shares your personal information with their group companies and with other third parties, including entities for which they are acting as an (recruitment) agent or entities which are used by EPSN for the performance of the service. EPSN will only do this for the performance of the service. This may include sending these parties your personal information if they wish to send you information about their products, vacancies and services or have an open vacancy that may be of interest to you, as determined by your profile.
4.3 A digital service may let you post and share personal information, comments, materials and other content. Any such contributions that you disclose publicly may be collected and used by others, may be indexable by search engines, and might not be able to be removed. Please be careful when disclosing personal information in these public areas.
4.4 EPSN also discloses your personal information if they have a good faith belief that such disclosure is necessary to:
- meet any applicable law, regulation, legal process or other legal obligation;
- detect, investigate and help prevent security, fraud or technical issues; and
- protect the rights, property or safety of EPSN, its users, employees and others;
4.5 EPSN could disclose your personal information as part of a corporate transaction, such as a transfer of assets to or an acquisition by or merger with another company.
5 Communications Preferences
5.1 You can customize and manage your communications preferences and other settings when you register with a service, by updating your account features and preferences, by using the “opt-out”, unsubscribe mechanism, or other means provided within the communications that you receive. You can also alter the details EPSN holds by emailing to EPSN. We reserve the right to notify you of changes or updates to the service whenever necessary.
6 Accessing and updating information
6.1 The service may allow registered users to directly access and review their account information and make corrections or updates upon login at any time. Keeping such information up to date is solely the responsibility of the user. Registered users may also close their account directly through the service or by contacting the customer support.
7 Data Retention
7.1 EPSN retains your personal information for as long as necessary to provide the service you have requested, and for other essential purposes such as complying with our legal obligations, maintaining business and financial records, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing its agreements.
8 Children’s Privacy
8.1 We do not knowingly collect information from children under the age of 13 or target the service to children under 13.
9 Data Security
9.1 EPSN uses a variety of administrative, physical and technical security measures to help safeguard your personal information.
10 Locations of Processing
10.1 Your personal information may be stored and processed in your region or another country where EPSN group companies and our service providers maintain servers and facilities, including the Netherlands, Belgium, England, Germany, Portugal, Hungary, Spain, Romania, Bulgaria, Poland, Croatia, Greece and Cyprus.
10.2 EPSN takes steps, including through its contracts, to ensure that the information continues to be protected wherever it is located in a manner consistent with the standards of protection required under applicable law.
10.3 Where personal information is transferred from the European Economic Area (“EEA”) or Switzerland to a country that has not received an adequacy decision by the European Commission, EPSN relies on appropriate safeguards, such as the European Commission-approved Standard Contractual Clauses and the EU-U.S. Privacy Shield Frameworks, to transfer the data.
11 Grounds for Processing
11.1 When EPSN collects from you any personal information within the scope of European data protection laws, EPSN does so:
a. with your consent;
b. where necessary to perform a contract with you or at your request prior to entering into a contract;
c. where necessary for our compliance with a legal obligation;
d. where necessary for the performance of a task carried out in the public interest; and/or
e. as necessary to fulfill EPSN’s legitimate interests as described in paragraph 11.2, except where their interests are overridden by your privacy rights. Where EPSN relies on your consent to process personal information, you have the right to withdraw your consent at any time, and where EPSN relies on legitimate interests, you have the right to
11.2 EPSN’s legitimate interests are: to deliver its services to its customers; to detect or prevent fraud; to protect the security of its systems, customers and users; to further develop their services; to conduct direct marketing; to operate its business (by processing payments, perform sales and customer relations management, other relation management, as well as incidental processing in our back office for these purposes); to enable our customers to comply with legal obligations; to provide customer service or support; or fulfil other legitimate interests as described above.
12 Your rights
12.1 You have the right to request free of charge:
- access to and correction or deletion of your personal information;
- that EPSN ceases or limits their processing of your personal information;
- a copy of your personal information, and
- to object at any time to processing of personal information concerning you for direct marketing.
- to revoke at any time a giving consent for the processing of your personal data and that EPSN ceases their processing of your personal information for which the consent was giving. If you would like to exercise any of these rights, please contact EPSN at the address set out below. EPSN will respond to your request consistent with applicable laws. To protect your privacy and security, we may require you to verify your identity.
14 Contact us
Data Protection Officer
EPSN Workforce Europa B.V.
5612 AA Eindhoven
15.1 EPSN hopes that they can resolve any query or concern you raise about its use of your information but you may also lodge a complaint with the data protection authority in the applicable jurisdiction.
Last updated: 28 May 2018