Déclaration de confidentialité

Our mission:

To clearXperts, your privacy is very important. You have the right to know which personal data we process and how we do it. In this declaration of privacy, we explain exactly how we work.

With this declaration of privacy, clearXperts plc adheres to the European Regulation 2016/679 of April 27th 2016 on the protection of natural persons with regard to the processing of personal data.

This declaration of privacy answers the following questions:

  1. Who is responsible for the processing of your personal data?

This declaration of privacy regulates the processing of your personal data by the body responsible for processing them: clearXperts plc, registered office on 77c Boomsesteenweg, 2630 Aartselaar, Belgium, registered with the Crossroads Databank of Enterprises under number BE 0837.567.383 and all bodies connected with it, being clearXperts Finance plc, clearXperts HR Ltd., clearXperts Sales & Marketing Ltd. (henceforth ‘clearXperts plc’).

For any questions concerning this declaration of privacy, please contact us at [email protected].

  1. What do a number of important notions in this declaration mean?
  • Personal data: this is all information that is directly (name, address, customer number, email, date of birth, etc…) or indirectly (IP address, car number plate, etc…) linked to a person.
  • Processing personal data: this is the processing operation, or a number of processing operations, concerning the personal data, or a number of personal data, either or not performed by automated procedures, such as collecting, recording, classifying, structuring, saving, updating or changing, requesting, consulting, using, forwarding, dispersing, or making available in any other way, aligning or combining, blocking, erasing or destroying of data;
  • Responsible body for processing: clearXperts plc
  • Cookies: see our cookie policy below
  • Data infringement: an infringement of data protection that, accidently or illegally, leads to the destruction, loss, modification or unlawful supply of, or unlawful access to, forwarded, recorded or otherwise processed personal data.
  • Processor: a partner who processes personal data on behalf of clearXperts plc.
  • Processing agreement: a specific agreement between the processor and clearexperts plc, in which clearXperts plc decides and limits which data can be processed for what purposes.
  1. What personal data of yours do we collect, and when?
  • 3.1 Personal data you provide

3.1.1 When you visit our website

  • IP address
  • Via cookies (see below)
  • Profile name, password, email address, log in data (and photo, where applicable) upon registration on our database

3.1.2 When you register for our newsletter

  • Email address

3.1.3 As an employee of clearXperts plc

  • Name, surname, address, email address, phone number, emergency number
  • Photos, video material of job application
  • CV, letters of application, notes taken during a job interview
  • History of education and employment
  • Assessment forms and results of tests/assessments
  • Payroll information such as national insurance number, date and place of birth, address, seniority, marital status, family composition, bank account number
  • Pay slips, holiday entitlement

3.1.4 As a candidate and/or interim manager

  • Name, surname, address, email address, phone number, emergency number
  • Photos, video material of job application
  • CV, letters of application, notes taken during a job interview
  • History of education and employment
  • Assessment forms and results of tests/assessments
  • Payroll information such as national insurance number, date and place of birth, address, seniority, marital status, family composition, bank account number
  • Pay slips, holiday entitlement

3.1.5 As an employer, client or business associate

  • Name, surname, email address, phone number and bank account number
  • Personal data we collect indirectly
  • 3.2.1 Public data of the employer, client or other business associate

clearXperts plc sometimes processes public data, for instance data subject to a disclosure requirement such as the publication of your appointment as director of a company, or data you yourself have made public, such as information on your website, or data that have been published in the press.

  1. What exactly do we do with these personal data? What is the purpose of processing them?

4.1 General purposes

clearXperts plc will use your personal data for the following purposes only:

  • IP address: (see point 3.1.1) for the management and improvement of the website, and for the inclusion of personal data in anonymous statistics where the identity of specific persons or companies cannot be detected, with as legal ground the legitimate concern of clearXperts plc to constantly improve its website and services.
  • Profile name, password, email address, log in data (and photo if applicable)upon registration on the website: (see point 3.1.1) to facilitate the management of your account on our website, in order to allow us to provide the information or services you want, or to fulfil legal requirements. Our legal ground is the carrying out of an agreement requested by you, and, if so indicated by you, the sending of direct marketing, with as legal ground your explicit prior permission.
  • Email address (on subscription to the newsletter): (see point 3.1.2) for the purpose of sending you direct marketing (automatic email messages or other electronic messages), newsletters, employment information or information about planned activities (lectures, seminars, work lunches, inspirational sessions) with as legal ground your explicit prior permission.
    • Name, surname, address, email address, phone number, pay roll information including national insurance number, address, seniority, marital status, bank account number, family composition, date of birth, pay slips, holiday entitlement, CV, letters of application, notes taken during a job interview, history of education and employment, assessment forms and results of tests/assessments (see points 3.1.3 and 3.1.4) in order to provide the service you requested and to comply with the legal regulations, with as legal ground the carrying out of an agreement.
  • Photos and video material: (see points 3.1.3 and 3.1.4) to be used for our internal communication with as legal ground your explicit prior permission.
  • Name, surname, email address, phone number, bank account number: (see point 3.1.5) in order to provide the service you requested and to comply with legal regulations, with as legal ground the carrying out of an agreement requested by you and, if indicated by you, sending you direct marketing, with as legal ground your explicit prior permission.

4.2 Direct marketing

Your personal data will also be used for direct marketing, on condition that you have given your additional explicit permission.

If you are already on our mailing list for receiving marketing material electronically, clearXperts plc can use your data for sending marketing material concerning the services of clearXperts plc.

Additionally, clearXperts plc can pass on your data to partners with a view to direct marketing.  This permission can be retracted at any time, without motivation or expenses, by contacting us via email on [email protected].

  • 4.3 Transferring data to a third party

ClearXperts plc shall never pass on your personal data to a third party, with the exception of the other bodies clearXperts Finance plc, clearXperts HR Ltd. and clearXperts Sales & Marketing plc, or one of its clients with a view to employment, or to technical service providers who assure technical support if necessary for technical services and/or if they are obliged to do so on the basis of a statutory provision or a judicial verdict.

Within reason, ClearXperts plc shall try to notify you in advance of the fact that your data have been passed on to the aforementioned third party, but you will acknowledge that this is not technically or commercially feasible in all circumstances.

ClearXperts plc shall not sell, rent out or distribute your data or transfer them in any other commercial way to a third party, except as described or unless you have given prior permission.

  • 4.4 Legal requirements

In rare cases, it can happen that clearXperts plc is obliged to divulge your personal data as a consequence of a court order or in order to comply with mandatory rules or regulations. Within reason, ClearXperts plc will try to notify you in advance about this matter, unless the matter is subject to legal limitations.

  1. Duration of processing

The personal data are kept by us and processed for the period necessary for the purpose of processing, as described in article 4 and subject to the contractual relationship between clearXperts plc and yourself:

  • IP address: (see point 3.1.1) for the duration of your visit to the website.
  • Profile name, password, email address, log in data (and photo if applicable): (see point 3.1.1) for the duration of the provision of the requested services.
  • Email address (on subscription to the newsletter): (see point 3.1.2) for the duration of the provision of the requested services.
    • Name, surname, address, email address, phone number, payroll information such as national insurance number, address, seniority, marital status, bank account number, family composition, date of birth, pay slips, holiday entitlement, CV, letters of application, notes taken during a job interview, history of education and employment, assessment forms and results of tests/assessment: (see points 3.1.3 and 3.1.4) for the duration of the provision of services requested, for employment and in compliance with the relevant legal rules.
  • Name, email address, phone number and bank account number: (see point 3.1.5) for the duration of the provision of services requested.

The aforementioned personal data will be retained in compliance with the specific legal requirements and the limitation period that oblige us to retain your personal data for a longer time, for instance in order to defend ourselves against a claim in the courts.

  1. How do we protect your legal data?

Since clearXperts plc values your privacy, we do our utmost to fully protect your personal data. We have taken all the necessary technical and organisational steps to protect your data against possible data breach.

  1. With whom do we work together?

For certain processing operations we have entered into a processing agreement with other parties.  ClearXperts plc recommends you check the declaration of privacy of these partners.

  • SD WORX for the payroll of our employees
  • Carerix for monitoring our applicants for vacancies.
  1. What are your rights?

When you share data with clearXperts plc, you as the person involved have a number of rights concerning your personal data. These are described below.

  • The right to information: this right is described in our declaration of privacy.
  • The right to access and perusal: you can always request to peruse all data stored by clearXperts plc free of charge, or obtain a print in legible format. When you request this information, clearXperts plc will provide all the necessary information such as the processing, the retention period, the legal ground for processing and the recipients.

This information will be sent to you within a month.

  • The right to amendment: you have the right to request that all your personal data processed by us be rectified if you know or suspect that they are not correct. clearXperts plc will amend them within a reasonable time.
  • The right to object: you also have the right to object to the processing of your personal data for grave or legitimate reasons.  Moreover, you retain the right to object to the use of your personal data for the purpose of direct marketing. In that case, you do not need to supply a reason.
  • The right to removal: if you no longer wish clearXperts plc to process your personal data, you can request to have these data removed from the files/databases of clearXperts plc.

However, this right is not an absolute right and you need to take into account that another legislation can limit this right. For instance, you cannot request the removal of data if a legal storage time limit has been agreed on and this time limit has not yet been reached. You also cannot request the removal of data for which clearXperts plc has defined a storage time limit if this time limit has not yet been reached.

However, all personal data of yours that we process on a basis of ‘permission’ can be requested by you to be removed if you withdraw your permission. This can be done at your single request via the email address [email protected].

However, in case of disputes such as a court case or a discussion that can have legal consequences, ClearXperts plc has a ‘justified interest’ not to remove any data. As long as these disputes are on-going, we cannot remove data.

  • The right to limitation of processing: if you do not agree with one or several of the processing procedures clearXperts plc applies to your data, you can demand the limitation of these procedures.
  • The right to data transfer: you have the right to obtain the personal data processed by us in a structured, accepted and machine readable form and/or to transfer them to other persons responsible.
  • The right to withdraw permission: where the processing is based on your prior permission you have the right to withdraw that permission.
  • The right to complain to the Belgian Authorities: if you suspect or claim to know that clearXperts plc treats your data without due care or does not respect the rights described above, you can complain to the relevant Belgian Data Protection Authorities at 35 Drukpersstraat, 1000 Brussels, tel. +32 (0)2 274 48 00, email address [email protected].  This leaves a provision for a civil court unaffected. If you suffer damages as a consequence of the processing of your personal data, you can bring action to claim compensation.
  1. Exercising your rights

You can exercise your rights by contacting us on the email address [email protected], enclosing a copy of the front side of your identity card.

  1. Security and confidentiality

We have put technical and organisational security measures in place to prevent the destruction, loss, falsification, unauthorised access or accidental disclosure to a third party of personal data, as well as any other unauthorised processing of these data.

Therefore, under no circumstances can clearXperts plc be held responsible for any direct or indirect damages resulting from the wrongful or improper use of the personal data by a third party. clearXperts plc has made sure that, if it calls on a third party for the processing of personal data, the same rules apply to this third party.

You are obliged to comply with the safety rules at all times. In other words: you are solely responsible for the use made of data from the website of your computer, IP address and your identification data, as well the confidentiality of those data.

  1. Access by a third party

In order to process your personal data, we give our employees access to your data. We guarantee an equal level of protection by making contractual obligations enforceable to our employees and appointees, similar to this declaration of privacy.

  1. Cookies

12.1 What are cookies?

A ‘cookie’ is a small file sent by the server of clearXperts plc and placed on the hard disk of your computer. The information stored on these cookies can only be read by us, and only for the time of your visit to the website.

12.2 Why do we use cookies?

Our website uses cookies and similar technologies in order to distinguish your preferences of use from those of other users of our website. This helps us give you a better user experience when visiting our website, and allows us to optimise our website.

As a consequence of recent changes in the law, all websites directed to certain parts of the European Union are obliged to ask your permission for using or storing cookies and similar technologies on your computer or mobile devices. This cookie policy gives you clear and extensive information about the cookies we use and their purpose.

12.3 The website only uses the following cookies

Functional cookies

Name Function
Advertising cookies To offer targeted advertising via advertising networks
User input cookies ‘lifestyle identifier’ Remembering a website user’s actions
User interface customisation cookies Used to remember the preferences of the user

Non-functional cookies

Name Function
Tracking cookies Used to identify the surfing behaviour of visitors

For cookies placed by third parties (such as Google Analytics) we refer to the statements published by these parties on their respective websites. Please note: we have no influence at all on the content of those statements, nor on the contents of the cookies from these third parties: Google Analytics cookies.

  1. Your permission

You can refuse or block cookies by changing the configuration parameters of your navigation system. Deactivating cookies may mean that you cannot use certain functionalities of the website. If you have further questions or remarks concerning the processing of your personal data, please feel free to contact us by email on [email protected].

  1. Who will contact you if you have questions about the declaration of privacy?

clearXperts plc has trained its internal employees to answer all your questions concerning the declaration of privacy. They address all questions about the processing of your personal data and how to exercise your rights in this respect. You can contact them on the email address [email protected].

  1. Amendment of the declaration of privacy

clearXperts plc retains the right to update this privacy policy. Therefore, it is important that you always consult the most recent version by clicking on the relevant link on the website www.clearxperts.com

  1. Applicable law and competent court

This declaration of privacy is managed, explained and implemented in accordance with the Belgian law that applies exclusively.

The Antwerp courts are exclusively competent to hear any dispute stemming from the interpretation or implementation of this declaration of privacy.