Privacy Policy

Introduction

We are GloPros B.V. (GloPros). GloPros matches Clients with talented Professionals and facilitates hiring and deployment processes through its Platform.

The Platform is available through our Website: www.glopros.com. The use of the Platform and our Website are collectively: our Services.

Privacy notice

This is our Privacy Notice. In this document we explain what kind of Personal Data we collect via our Services. We also explain what role we have in the processing of Personal Data, how long we retain them and what rights you have as a data subject.

Personal Data and Controller

We process Personal Data. Personal Data means all information by which a person can be directly or indirectly identified. Under the General Data Protection Regulation (GDPR) we are the so-called Controller of your Personal Data. If you have questions about the processing of your Personal Data, you can always contact us through the contact details listed at the bottom of this Privacy Notice.

What Personal Data do we collect as Controller?

As the Controller, we may process your Personal Data in different contexts. We may process your Personal Data if you use our Services as a Professional. We may also process your Personal Data if you use our Services as a representative of a Client. In this case, we only process Personal Data if the information is referenced to you as an individual or a one-person business. Finally, we may process your Personal Data as a User of any of our Services (such as our Platform, Website, or our social media pages).

Professionals' related data

If you are a Professional, we usually process the following Personal Data of you:

Personal Data we process:

• account information (email address and password); and
• personalia, such as: first- and last name, phone number, address, date of birth, gender (optional), occupation category, geolocation at the time of log-in, profile picture, nationality, company information (if applicable, and only personal data if referenced to an individual or one-person entity)

The purpose of using your personal data

We use this information to:

• register your account;
• allow you to use our Services (such as: creating your personal profile, providing you with a personal dashboard, uploading content on the Platform and chatting with Clients);
• communicate with you, e.g. to assess if you are a proper match for GloPros or one of our Clients; and
• provide personalia details to our Client when there is a match.

The legal basis of why we process your personal data

We may process these Personal Data in order to perform our contract (i.e. provide our Services) with you.

We may also process these Personal Data because we have a legitimate interest:

• to contact you about a possible collaboration with GloPros or one of our Clients; and
• in providing our Clients with sufficient information about you for the proper execution of the work.

Recruitment & selection data

If you are a Professional, we usually process the following recruitment and selection data of you:

Personal Data we process:

• content and date of phone, email, and correspondence with you; and
• notes of expert meetings with you.

The purpose of using your personal data

We use this information to:

• include in our recruitment and selection file; and
• assess whether you are proper match for one of our Clients;
• To train our AI models;

The legal basis of why we process your personal data

We may process these Personal Data in order to perform our contract (i.e. provide our Services) with you

Information from public sources

If you are a Professional, we usually process the following public resource data of you:

Personal Data we process:

information in public profiles, such as LinkedIn and other social networks (where applicable).

The purpose of using your personal data is to

assess whether you are proper match for one of our Clients.

The legal basis of why we process your personal data

We may process these Personal Data because we have a legitimate interest to assess if you are a proper match for one of our Clients.

Please note: we will only process Personal Data that is relevant for your or our Client’s requests, and you get the opportunity to react to our findings.

Professionals' content data

If you are a professional and you have uploaded content on the Platform, we usually process the following data of you:

Personal Data we process:

• information uploaded in your personal dashboard, such as: identification documents (including your national identification number if you make use of our Services as an employee) insurance documentation, and working permits;
• professional information e.g. your resume, which includes: your professional experience, skills, portfolio, assignment preferences, certifications (optional), languages (optional) and content made available via integration of your social media accounts (optional);
• Recommendations of previous clients;
• chat information between you and the Client (user ID, content of the messages, date and time of these chats).
• Whether you have signed up for our partner program, which includes your contract with us.

The purpose of using your personal data is to:

• verify your identity;
• include in your personal dashboard;
• pseudonomyse to make available on the Platform (only in relation to professional information, unless you agree to join our partner program);
• Summarise your professional information utilising AI for publication;
• make available on the Platform to Clients with whom you have a match;
• assess whether you are proper match for one of our Clients;
• flag, report and prevent misuse, fraud and threats regarding to our Services; and
• generate your average response time to messages and show these statistics on the Platform.

Please note: if you upload information that can be directly or indirectly traced back to you (such as specific work history or details in comments), this information may reveal your identity and your online profile may no longer be anonymous. Please keep this in mind when uploading information on the Platform. See further details about our pseudonymisation procedures below.

The legal basis of why we process your personal data

We may process these Personal Data in order to perform our contract (i.e. provide our Services) with you.

We may also process these Personal Data because we have a legitmitate interest:

• to ensure a secure use of our Services; and
• to support you in making your profile relevant to Clients, and providing our Clients with sufficient information about you for the proper execution of the work.

We will only process special categories of Personal Data (such as disabilities or health insurance data), if we have your explicit consent.

Performance information

If you are a professional, we usually process the following performance data of you:

Personal Data we process:

• evaluation interviews and any complaints or warnings as received from our Clients.
• number of completed assignments at Clients;

The purpose of using your personal data

We use this information to:

• formulate points for improvement for you and monitor and analyse your performance;
• assess whether you are a proper match for one of our Clients; and
• include in our recruitment & selection file.

The legal basis of why we process your personal data

We may process these Personal Data because we have a legitimate interest in doing so. It is in our interest as well as yours to evaluate and improve your performances so that we can connect you to our Clients in the best possible way.

Financial information

If you are a professional, we usually process the following finance data of you:

Personal Data we process:

• invoice information (such as: bank account number, IBAN, BIC and VAT number);
• payment history between you and the Client; and
• bank account statement;

The purpose of using your personal data

We use this information to:

• handle the payment of your fees; and
• include in our administration for the benefit of the tax authority.

The legal basis of why we process your personal data

We may process these Personal Data because this is necessary to perform our contract with you. In addition, we are legally obliged to process (some of) these personal data for the benefit of the tax authority.

Client related data

If you are representative of our Client, we usually process the following Personal Data of you:

Client account data

Personal Data we process

• account information (email address, and password);
• personalia, such as: first- and last name, date of birth, gender, profile picture phone number, location, company name, industry, about.

The purpose of using your personal data

We use this information to:

• register your account;
• allow you to use our Services (such as: creating your company profile, providing you with a personal dashboard, uploading content on the Platform and chatting with Professionals);
• communicate with you, e.g. to assess if you and the Client you represent are a proper match for GloPros or one of our Professionals; and
• provide your personalia details to the Professional when there is a match.

The legal basis of why we process your personal data

We may process these Personal Data in order to perform our contract (i.e. provide our Services) with the Client you represent.

We may also process these Personal Data because we have a legitmitate interest:

• to contact you about a possible collaboration with GloPros or one of our Professionals; and
• in providing our Professionals with sufficient information about you for the proper execution of the work.

Recruitment & selection information

Personal Data we process

• content and date of phone, email, and chat correspondence with you; and
• notes of correspondence with you.

The purpose of using your personal data

We use this information to:

• include in our recruitment and selection file; and
• assess whether the Client you represent is a proper match for one of our Professionals.

The legal basis of why we process your personal data

We may process these Personal Data in order to perform our contract (i.e. providing our Services) with the Client you represent.

Information from public sources

Personal Data we process

Information in public profiles, such as LinkedIn and other social networks (where applicable).

The purpose of using your personal data

We use this information to:

• assess whether the Client you represent is a proper match for GloPros; and
• assess whether the Client you represent is a proper match for one of our Professionals.

The legal basis of why we process your personal data

We may process these Personal Data because we have a legitimate interest to assess if you are a proper match for one of our Professionals.

Please note: we will only process Personal Data that is relevant for your or our Professional’s requests, and you get the opportunity to react to our findings.

Content uploaded by clients

Personal Data we process

• company information and work description;
• chat information between you and the Professional (User ID, content of the messages, date and time of these chats).

The purpose of using your personal data

We use this information to:

• include in your personal dashboard;
• provide or make available on the Platform for our Professionals;
• assess if the Client you represent is a proper match for one of our Professionals; and
• flag, report and prevent misuse, fraud and threats regarding to our Services.

The legal basis of why we process your personal data

We may process these Personal Data in order to perform our contract (i.e. providing our Services) with the Client you represent.

We may also process (some of) these Personal Data because we have a legitimate interest:

• to ensure a secure use of our Services; and
• to support you in making your profile relevant to Professionals, and providing our Professionals with sufficient information about you for the proper execution of the work.

Financial information

Personal Data we process

• (Company) name, email address, bank details (account number, IBAN and SWIFT/BIC-code) and VAT number; and
• Payment history between you and the Professional.

The purpose of using your personal data

We use this information to:

• process and administer your payments; and
• include in our administration for the benefit of the tax authority.

The legal basis of why we process your personal data

We may process these Personal Data because this is necessary to perform our contract with the Client you represent.

In addition, we are legally obliged to process (some of) these personal data for the benefit of the tax authority.

Compliance information

Personal Data we process

Full name, home address, bank account number, type of bank account, transaction history, company name, registration number at GloPros, VAT number, account report (credit score, limits, directors/shareholders)

The purpose of using your personal data

We may use this information to:

• To send invoices to you;
• verify your identity; and
• perform a creditworthiness assessment

The legal basis of why we process your personal data

We may process these Personal Data, because it is necessary to perform our contract with the Client you represent.We may also process these Personal Data, because we are legally obliged to verify your identity based on the Dept Rescheduling Natural Persons Act, and to prevent fraud and money laundering based on the Dutch AML legislation. We may also process part of these Personal Data, because we have a legitimate interest to check whether the Client you represent is creditworthy enough to use our Services.

Personal Data of all users

Statistical information

Personal Data we process

• The resume of Professionals, with age and gender removed.
• Analytical data about your use of the Platform;

The purpose of using your personal data

We use this information to:

• rank your profile in search results for our Users;
• generate personal recommendations for our Users; and
• analyse to monitor and predict workforce trends, career development and potential matches.

The compilation of these profiles is always subject to human review.

The legal basis of why we process your personal data

We may process these Personal Data because we have [a legitimate interest to provide you with relevant information and recommendations tailored to your needs, and to support you in making your profile relevant on the Platform

Personal Data we process a user contacts us:

your name, email address and/or telephone number (depending on how you contact us), and the content of the correspondence between you and us.

The purpose of using your personal data

We use this information to:

• answer your questions and/or handle any complaints;
• support you in using our Services;
• improve our Services as a result of requests and feedback from you; and
• flag, report and prevent misuse, fraud and threats regarding to our Services.

The legal basis of why we process your personal data

We use this information to:

• answer your questions and/or handle any complaints;
• support you in using our Services;
• improve our Services as a result of requests and feedback from you; and
• flag, report and prevent misuse, fraud and threats regarding to our Services.

Personal Data we process in user surveys

: your name, email address, and the (chat) conversation, in case you participate in a survey.

The purpose of using your personal data

We use this information to:

• approach you to ask if you want to participate in our survey program;
• conduct the survey; and
• improve our Services.

The legal basis of why we process your personal data

We may process these Personal Data to assess whether you qualify to participate in our survey program, because we have a legitimate interest in selecting a group of Users eligible for our survey program.

In case you participate in our survey program, we process your Personal Data if we have your consent.

Personal Data we process when a user subscribes to our newsletter

first- and last name and email address.

The purpose of using your personal data

send you our newsletter and keep you informed on all our (future) Services.

The legal basis of why we process your personal data

We may process these Personal Data, if you gave us your consent to do so (by subscribing via our Website). We may send our Users who paid for our Services newsletters, because we have a legitimate interest to do so. In every newsletter there is a link via which you can unsubscribe.

Personal Data we process when we collect technical data of a user

: user ID, IP address, which pages/features you visit/use, on which links you click and other technical information (e.g. type of browser and operating system)].

We collect these Personal Data using cookies and similar techniques. Please see our Cookie Statement [include link] for which cookies and/or similar techniques we use.

The purpose of using your personal data

We use this information to:

• analyse your use of our Services in order to improve our Services; and
• flag, report and prevent misuse, fraud and threats of/regarding to our Services.

The legal basis of why we process your personal data

We may process these Personal Data because we have a legitimate interest to gain insight in the use of our Services in order to provide, improve and secure our Services, or because we have obtained your consent.

Personal Data we process via our social media pages

information of visitors who leave a comment or otherwise post something on our social media pages, including the Personal Data within these comments and/or posts.

The purpose of using your personal data

We use this information to:

• contact the visitors in reply of their post and/or comment via our social media pages; and
• process the feedback left on our social media pages.

The legal basis of why we process your personal data

We may process these Personal Data, because we have a legitimate interest to process these data and because the visitors voluntarily made public such information.

Our social media pages are also controlled by the social medium itself. Please check their own privacy notices, to see how each social medium handles Personal Data:

LinkedIn: Privacy Policy

Please note: all Personal Data processed by our Clients and the Professionals in the context of the performance of the work, will be directly exchanged between the Professional and the Client. This Personal Data will be processed in accordance with the privacy notice of the Client.

Pseudonymization of your resume as a Professional

Privacy and confidentiality are an important part of our Platform. If you use our Platform as a professional, we will take the following measure to make the possibility of identifying you as low as possible:

• We will not publish your full resume publicly - your public profile will not contain any information that can directly be linked to you.
• Other information on your resume, such as your work experience, will be summarized utilizing Artificial Intelligence.
• If a Client has been verified by us and has logged in to our platform, more information on your professional capacities is shown;
• If a Client has shown interest in you and you have accepted their request, your full profile is shown.

Note that the previous does not exclude the possibility that based on the information that is publicly available, people are able to infer or make an educated guess that a profile belongs to you. For example, if you are the only person to have a certain combination of degrees or if you have advertised on social media (such as LinkedIn) that you are using our Platform. Note that if you have joined our partner program, your profile will be publicly visible.

Mandatory information

When you engage our Services, it may be (e.g. legally or contractually) required that you provide us with certain Personal Data. For example, information regarding your identity. Where you do not provide us with such information, this will usually imply that we will not be able to provide our Payment Services or perform part of our agreement.

Cookies

We may use functional, tracking and/or analytical cookies on our Website. A cookie is a simple small text file that can be stored in your device when visiting the Website. This text file identifies your browser and/or device. When visiting our Website again, the cookie ensures that your browser/device is recognized.

For more information on our use of cookies, please refer to our cookie statement.

How long do we keep the Personal Data?

We will not process or store any Personal Data that we do not need. We store Personal Data for as long as we need it for the above purposes, unless we are legally obliged to retain the Personal Data for a longer period. In this respect, we apply the following retention periods:

• Contact details | Your contact details will be retained as long as we have a contract with you and for a maximum period of 5 years thereafter.
• Account data | Your account data will be retained as long as your account is activated and will be deleted 6 months after deactivating of your account.
• Recruitment & selection files | Your recruitment and selection file will be retained as long as your account is activated and will be deleted 6 months after the deactivating of your account.
• HR Analytics data | Personal Data contained in our statistical data for HR Analytics will be retained as long as you have an Account with us.
• Compliance information | These Personal Data will be retained as long as we have an account and for a maximum period of 5 years thereafter.
• Finance information | These Personal Data will be retained as long as we have an account and for a maximum period of 7 years thereafter.
• Newsletters | We retain the Personal Data used for sending newsletters until you unsubscribe from our newsletter.
• Personal Data in our correspondence | These Personal Data will be retained as long as necessary to handle your message/question/complaint, and as long as your account is active.
• Other information | We store other Personal Data only for as long as it is necessary for the purposes. These Personal Data are deleted as soon as it is no longer necessary for the purposes for which we processed it.

Accounts that have shown no activity for [twelve months] will be deactivated by us. You will be notified of this deactivation.

After expiry of the retention period, we may process and retain certain Personal Data to comply with legal retention obligations and/or for fraud/misuse investigations or to substantiate a (legal) claim. In such events, we will retain the Personal Data separately and only use such Personal Data for the aforementioned purposes.

Do we share your Personal Data with others?

Processors

We use third parties (Processors) who support us in providing our Services. Within this context these Processors receive Personal Data from us which they process on our behalf. For instance, we use Processors for our CRM system, building and maintaining our Website and Platform, sending marketing emails, hosting and structuring our data, and managing our invoicing process.

These Processors may only use or disclose the data collected and processed by us within the scope of our instructions to them and under no circumstances for other purposes. We enter into a data processing agreement with all of our Processors.

External Controllers

In addition, some of the Personal Data may be processed by other controllers (External Controllers):

• Payments on the Platform will be processed by our third-party payment providers Stripe and Exact).
• We share (parts of) our financial administration with the national tax authority, if we are legally obliged to do so.
• We share some of your Personal Data with the Client or the Professional, if this is needed to provide our Services (i.e. facilitate the match between the Professional and Client and the subsequent HR process).

Any Personal Data provided to these External Controllers will be processed in accordance with their own privacy notices.

Apart from the above, we will not share your Personal Data with third parties, unless we are legally obliged to do so.

Export of Personal Data outside the European Union

We may transmit Personal Data to parties outside the European Union, if one of our Processors or Controllers is established outside the European Union. The Personal Data will only be transferred to countries and/or parties that provide an adequate level of protection in accordance with the European standards. Please contact us if you wish to receive more information or a copy of the safeguards we take in this scope where necessary.

Third party websites

You may find advertising or other (hyper)links on our Website that link to the websites, products and services of partners, suppliers, advertisers, sponsors, licensors or other third parties. We do not control the content or the links that appear on these websites and we are not responsible for the practices employed by websites linked to or from our Website. In addition, these websites, products and services, including their content and links, may be constantly changing. These websites, products and services may have their own privacy notices, user terms and customer service policies. Browsing and interaction on any other website, including websites that are linked to or from our Website, are subject to the terms and policies of that website.

Changes of the Privacy Notice

The Privacy Notice may be changed from time to time. Please check our Privacy Notice frequently. The new Privacy Notice will be effective immediately upon posting on our Website. If we change our Privacy Notice significantly, then we will state so on our Website together with the revised Privacy Notice.

You have the right to:

Access

Obtain confirmation as to whether or not your personal data are being processed by us, and, if that is the case, access to the (categories of) personal data and information about our processing activities and a copy of your personal data.

Rectification

Obtain rectification of any inaccurate personal data concerning you. You also have right to have incomplete data concerning you completed.

Erasure

Obtain the erasure of your personal data under certain circumstances, for example if the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.

Restriction of processing

Obtain restriction of processing of your personal data under certain circumstances. In such case, we may still store your personal data, but our use of your personal data for certain purposes will be restricted.

Data portability

Receive the personal data you have provided to us in a structure, commonly used and machine-readable format and to transmit those data to another controller or have us do that for you under certain circumstances.


Object

Object to our processing of your personal data based on (among others) legitimate interest under certain circumstances. You may always object to the processing of your personal data for direct marketing purposes.