Privacy policy

We ask that you read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

The present policy is established by Wiggli, a trading name of Hireme SA, situated at 2 Boulevard de la Woluwe, 1150 Brussels, Belgium registered in the Companies Database under the number 0678.483.029 (hereafter called Wiggli).

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The present policy is established by Wiggli, a trading name of Hireme SA, situated at 2 Boulevard de la Woluwe, 1150 Brussels, Belgium registered in the Companies Database under the number 0678.483.029 (hereafter called Wiggli).

This website and our platform (available at: https://www.wiggli.io) is operated by Wiggli, a trading name of Hireme SA, situated at 2 Boulevard de la Woluwe, 1150 Brussels, Belgium registered in the Companies Database under number BE0678.483.029 (“Wiggli”). In this policy, references to “us”, “we”, “ours”, “our” refer to Wiggli.

We have developed an innovative cloud-based software platform and related services known as the Wiggli Platform or the Services. The Wiggli Platform comprises: (i) a total talent recruiting and management suite composed of a state of the art cloud-based: Applicant Tracking System, Vendor Management System and Freelance Management System and related services and cloud-based products including Employer Branding and Candidate Pools (Talent Acquisition Tool); (ii) a web-based job-board portal where registered companies are able to post vacancies and registered users can apply for them (CV Library); and (ii) an innovative web-based online marketplace for contractor intermediation and introductory services (Marketplace). For more information about Wiggli, what we do and the services we offer, please visit our homepage: https://www.wiggli.io

When you use the Wiggli Platform, our aim is to give users full control over their privacy rights and to allow them to update or amend their profile and status at any time, as further described in this policy and through use of our Services.

As part of our Services, we will process personal data. When we do so, we are regulated under the General Data Protection Regulation (EU) 2016/679 (GDPR) which applies across the European Union (including in Belgium). Depending on the Services that we are providing to you, our role under the GDPR will change.

As a candidate or user of our Services, you will be required to create an account with Wiggli. We are generally the data controller of, and are therefore responsible for, all personal information processed via your Wiggli account, save in specific situations which we have set out below.

For example, when our clients use our Talent Acquisition Tool to process your process your personal data (such as your job application with them or your candidate/employee profile), they are acting as the data controller of your personal data and we are acting as a processor. This is because we will only process your personal data in accordance with clients’ instructions (namely in order to provide our clients with the Talent Acquisition Tool). You should therefore check the privacy policy of the company you work for or are applying to, when they use our Talent Acquisition Tool for information on how they process your personal data.

When you use our CV Library, we are acting as data controller of your Wiggli profile and of any information you submit when using our CV Library. However, when you apply for a vacancy that is available via our CV Library, when you click ‘Submit’, the company to which you apply to will then also become data controller of the information submitted to them as part of your application. You should therefore ensure that you check the privacy policy of the company you are applying to see how they commit to handling your personal data.

Finally, when we are providing our Marketplace, we act as data controller of any personal information about our users that they provide via the Wiggli portal in order to benefit from the Marketplace Services. If you are a candidate and you are introduced to a company by an agency via the Marketplace, the company and the agency are data controllers of your personal data, and in that case, we are only acting as a data processor (being the secure channel by which your information is shared). Therefore, you should consult the company you have been introduced to or the agency you are represented by to receive details of their privacy policies, if you have not already done so.

This privacy policy relates to your use of our website and Wiggli Platform (available at: https://www.wiggli.io) when you, have an account with us, and use our Talent Acquisition Tool, the CV Library and the Marketplace – situations when we are acting as data controller.

Throughout the Wiggli Platform, we may link to other websites owned and operated by third parties, and your data may be collected and processed by third parties (such as companies seeking to hire or recruitment agencies). These other third parties and their websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third parties or their websites, please consult their privacy policies as appropriate.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We collect personal information about you when you access our website, create a Wiggli account, contact us, send us feedback, use our Services or the Wiggli Platform, upload material to the Wiggli Platform, and complete surveys on the Wiggli Platform.

We collect this personal information from you either directly, such as when you create an account with us, contact us or use our Services via the Wiggli Platform or indirectly, such as your browsing activity while on the Wiggli Platform (see ‘Cookies’ below), or where we have obtained your details from third parties.

When you use our Services, such as the CV Library, our users have full control over their privacy rights and can update or amend their status as they see fit, and at any time.

Accordingly, you can set your visibility options via your Wiggli account. You can set your status to: active (enabling you to look for jobs and clients are able to search for your profile); passive (enabling you to look for jobs but clients will not be able to find your profile); or anonymous (which is the same setting as “active”, but you will be able to hide your personal information. You are in full control over what information you want to reveal to clients or other users.

The personal information we collect about you depends on the particular activities carried out through the Wiggli Platform, and whether you are a website visitor, a registered user, or a candidate, or a client.

This information may therefore include:

• your name, address and contact details
• your professional title / job title
• assignment or job details for ongoing applications or projects
• your CV (including work history, education, skills, hobbies, languages, salary information, availability and any other professional information)
• geographical location and / or geographical availabilities and mobility data
• date of birth
• details of any feedback you give us by phone, email, post or via social media
• information about the services we provide to you
• your account details, such as username, login details
• company incorporation information (which may contain personal data)
• details about your nationality for right to work and visa purposes

We use this personal information to:

• create and manage your account with us
• verify your identity
• provide our services to you
• customize the Wiggli Platform and its content to your particular preferences
• notify you of any changes to the Wiggli Platform or to our services that may affect you
• conduct direct marketing, where you have provided us with your consent to do so, and
• improve our services.

The Wiggli Platform is not intended for use by children and we do not knowingly collect or use personal information relating to children.

We do not collect any Sensitive Personal Data (also known as Special Categories of Personal Data) about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) unless we have obtained your express consent to do so, and you provide this information to us directly. You are also able to withdraw your consent to our processing your sensitive personal data at any time by contacting us. You are also able to remove sensitive personal data from your profile at any time via your personal space in the Wiggli Platform. You have full control over the information you share in your Wiggli account, your settings, status and who can see your profile.

When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases on which we may rely, depending on what personal information we process and why.

The legal bases we may rely on include:

• with your and our service providers located outside the EEA.
• if you are based outside the EEA.
• where there is an international dimension to the services we are providing to you.

These transfers are subject to special rules under European and Belgian data protection law.

Some countries outside of the EEA do not have the same data protection laws as Belgium and other countries in the EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission (the Standard Contractual Clauses). For clarification, since the United Kingdom has now left the European Union, we currently conduct EU-UK data transfers in reliance on the grace period which has been accorded between the two territories, until such time as the UK Adequacy Decision is granted by the European Commission. If the grace period ends prior to a UK Adequacy Decision being granted or if this decision is not granted, then we will ensure that EU-UK transfers of personal data are protected by entering into the Standard Contractual Clauses for these transfers.

We will not otherwise transfer your personal data outside of the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries. If you would like further information, please contact us (see ‘How to contact us’ below).

How and why we use your personal information The table below explains what we use (process) your personal information for and our reasons for doing so:

The above table does not apply to special category personal information, which we will only process with your explicit consent.

We do not share your personal data with any third parties unless you expressly agree that we may do so.

For example, if you are a candidate using the CV Library, we will share your personal data with companies you apply to, or who reach out to you, if you give your consent to do so by clicking on the relevant button within the Wiggli Platform. Likewise, if you are a client or other third party using our Marketplace, we will share your personal data between the relevant stakeholders when you have mutually agreed to take a proposal forwards. All of this takes place within the Wiggli Platform, and the information shared is the data that you input to create your profile. You can modify your profile at any time within your private space on the Wiggli Platform. As part of this, you can change your status on your profile to active, passive, or anonymous, for greater control over the visibility of your personal data, as set out above.

We also share your personal data with our external suppliers and service providers to ensure the proper administration of our Services. For example, we may also share your data with third party service providers providing us with IT, development, cloud hosting and storage, marketing and customer engagement providers, legal, financial and tax services. This data sharing enables the relevant third parties to carry out their tasks and also enable us to properly perform our agreement with you, and/or provide you with our Services.

Some of those third-party recipients may be based outside the European Economic Area — for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the EEA’ below. We will only share personal information with law enforcement or other authorities if required by applicable law.

Aside from the scenarios referred to above, we will not share your personal information with any other third party without your consent. Furthermore, we only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers and all third parties to ensure they can only use your personal information to provide services to us and to you.

To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

• With your and our service providers located outside the EEA.
• if you are based outside the EEA.
• where there is an international dimension to the services we are providing to you.

These transfers are subject to special rules under European and Belgian data protection law.

Some countries outside of the EEA do not have the same data protection laws as Belgium and other countries in the EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission (the Standard Contractual Clauses). For clarification, since the United Kingdom has now left the European Union, we currently conduct EU-UK data transfers in reliance on the grace period which has been accorded between the two territories, until such time as the UK Adequacy Decision is granted by the European Commission. If the grace period ends prior to a UK Adequacy Decision being granted or if this decision is not granted, then we will ensure that EU-UK transfers of personal data are protected by entering into the Standard Contractual Clauses for these transfers.

We will not otherwise transfer your personal data outside of the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries. If you would like further information, please contact us (see ‘How to contact us’ below).

We will keep your personal information while you have an active account with us or while we are providing Services to you or for as long as you remain a user of the Wiggli Platform. Thereafter, we will keep your personal information for as long as is necessary:

• To respond to any questions, complaints or claims made by you or on your behalf.
• to show that we treated you fairly.
• & To keep records required by law and tax requirements or in defence or pursuit of a legal claim.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. For example, the personal data of a candidate is retained for 3 years following our last meaningful contact with you and/or from when your profile was last updated (whichever is later). Personal data collected by cookies is generally kept up to a maximum of 12 months following the date on which you consented to such cookies (unless you withdraw your consent beforehand). For more information, please visit our Cookie Policy. We may have to keep your personal data for a longer period of time, in order to comply with a legal obligation or to establish, exercise or defend legal claims. However, when it is no longer necessary to retain your personal information, we will delete or anonymise it.

We may have to keep your personal data for a longer period of time, in order to comply with a legal obligation or to establish, exercise or defend legal claims. However, when it is no longer necessary to retain your personal information, we will delete or anonymise it.

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies on our website and the Wiggli Platform. For further information on cookies, please see our Cookie Policy.

We would like to send you information about our Services and any latest news or updates which may be of interest to you. Where we have your consent, we may do this by post, email, telephone, text message (SMS) or automated call.

We may obtain your personal information from third party companies, such as suppliers, job boards and social media. We may also share your personal data with Wiggli’s associated companies, so that they may send you information about their services. When we do either of these things, we always ensure that we respect relevant requirements under e-privacy law. Accordingly, we will only ask whether you would like us to send you marketing messages when you tick the relevant boxes when you sign up to the Wiggli Platform, contact us, sign up to our newsletter or activate this option in your notifications tab within your account or respond to an introductory email we have sent you. If you have previously agreed to being contacted in this way, you can unsubscribe at any time by:

• Contacting us
• Using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts\
• Updating your marketing preferences in the notifications tab of the Wiggli Platform.

It may take up to 30 days for this to take place. For more information on your rights in relation to marketing, see ‘Your rights’ below.

Under the General Data Protection Regulation (GDPR), you have a number of important rights. An overview of these rights is set out below:

• The right to request access to your personal data, subject to certain exceptions. At our discretion we may require you to prove your identity before providing this information and if you require multiple copies we may charge a reasonable admin fee.
• The right to request correction of your personal data.
• The right to request erasure of your personal data, known as the right to be forgotten, unless we are required to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
• The right to object to processing of your personal data where the legal justification for our processing of your personal data is in our legitimate interest. We will abide by your request unless there are legitimate grounds which override your interests or rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.
• The right to request restriction of processing your personal data if you believe that the data is incorrect, or; if our processing is unlawful, or; if we no longer need to process your data for a particular purpose but cannot delete it due to a legal obligation or because you do not want us to delete it.
• The right to request the transfer of your personal data (portability), if you have provided personal information to us and we are processing data on the basis of your consent or in order to perform our obligations under a contract to you.
• The right to withdraw your consent for your personal data to be processed.
• The right to withdraw consent for direct marketing purposes at any time, free of charge.

For further information on each of those rights, including the circumstances in which they apply, please visit the website for the European Data Protection Supervisor, here.

• Write to us by registered mail at Hireme SA – Data Protection, 2 Boulevard de la Woluwe, 1150 Brussels, Belgium.
• Let us have enough information to identify you (e.g. username, registration or account details)
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill).
• & let us know the information to which your request relates including any relevant dates, categories of information, individuals involved in the processing and any reference numbers, if you have them.

All requests will be managed in accordance with the GDPR and our internal Data Subject Request Handling Policy.

We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit their website.

We hope that we can resolve any query or concern you raise about our use of your information.

The GDPR also gives you the right to lodge a complaint with a supervisory authority or national court in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. Our appointed Lead Supervisory Authority is the Belgian Data Protection Authority and they can be contacted via the following details:

• Data Protection Authority, Rue de la Presse, 35 1000 Brussels, Belgium,
• Telephone. + 32 2 274 48 00; Fax. + 32 2 274 48 35
  Email: commission@privacycommission.be.

If you are usually resident outside of Belgium, you can identify and contact your local supervisory authority by consulting the European Data Protection Board’s list here.

This Privacy policy was published on 12th November 2019 and last updated on 1 March 2021. We may change this privacy policy from time to time, and when we do we will inform you via this page.

Please contact us if you have any questions about this privacy policy by sending an email to support@Wiggli.io.

If you wish to contact us generally or otherwise write to us about the information we hold about you, please write to Wiggli, a trading name of Hireme SA – Data Protection, 2 Boulevard de la Woluwe, 1150 Brussels, Belgium