Privacy Policy

Last updated:

October 1st 2026

Table of contents

Welcome to the Wiggli 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.

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

Your privacy rights are important to us. When you use the Wiggli Platform, our aim is to give you control over your privacy rights and to allow you to update or amend your information at any time, as further described in this policy and through use of our Platform and Services.

1. Our Platform and our Services

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) an artificial intelligence tool which enables our recruiter Clients to search a large database of professional profiles, to obtain verified contact details and other professional information sourced from third-party data providers, to run automated Client outreach, candidate outreach, and to match, score, rank and shortlist candidates, in order to assist recruiters in their sourcing and pre-selection process (Wiggli Intelligence);

(ii) an innovative web-based online marketplace for contractor intermediation and introductory services (Marketplace); and

(iii) a total talent recruiting and management suite composed of a state of the art cloud-based: ATS, CRM and Back-office related services and cloud-based products including Employer Branding and Candidate Pools (Talent Acquisition Suite).

We provide the Wiggli Platform and Services to recruiters, organisations, entities and other business users (“Clients”). This privacy policy sets out our role in relation to any processing of personal data carried out through the Platform, as well as the rights of any data subjects whose personal data is processed.

If you are a candidate, this privacy policy does not apply to you: to find out how your personal data is processed and about your rights, please see our separate candidate privacy policy at https://www.wigglers.io/en/privacy-policy.

For more information about Wiggli, what we do and the services we offer, please visit our homepage: https://www.wiggli.io

2. Our role

As part of our Services, we process personal data and are regulated under the General Data Protection Regulation (EU) 2016/679 (GDPR). Depending on the situation, we may act as a data controller or as a data processor acting on your behalf. This section explains when each role applies.

We act as a data controller - meaning we determine the purposes and means of the processing - and in these cases this privacy policy applies. This includes, for example:

  1. when we create, administer and secure your account and provide, maintain and improve the Platform and our Services;
  2. when we build and maintain our own database and datasets that support the Platform and our Services;
  3. when a Client or another user engages with the Marketplace directly through the Wiggli Platform; or
  4. when we process personal data for our own administrative, analytical, marketing or security-related purposes.

We act as a data processor - meaning we process personal data only on your documented instructions and on your behalf, in order to provide our Services to you - and in these cases your own privacy policy governs that processing, which individuals should consult. This includes situations where:

  1. you use our Talent Acquisition Suite to manage your recruitment processes, such as tracking applicants, reviewing candidate information or managing interview workflows; or
  2. you receive a candidate introduction from an agency via the Marketplace, where we act only as the secure channel through which the information is shared; or
  3. you use our sourcing and enrichment tools as part of Wiggli Intelligence, reveal verified contact details or obtain other professional information from third-party data providers, or run candidate outreach, where we process that personal data on your instructions and act as the technical conduit between you and those third-party data providers.

In these situations, you remain responsible for your own compliance with the GDPR, including establishing a lawful basis for the processing and providing affected individuals with the transparency information they are entitled to (for example, at the point you first contact a candidate).

3. The scope of this privacy policy – the Wiggli Platform

This privacy policy applies when you use our website and the Wiggli Platform, and explains how we handle personal data in the circumstances where Wiggli acts as a data controller (see ‘Our role’ above).

Throughout the Wiggli Platform, we may link to other websites owned and operated by third parties, who may collect and process your data and gather information about you under their own separate privacy policies. Please consult those policies as appropriate.

Some of our Platform’s AI features also rely on third-party AI providers, currently including OpenAI, Anthropic and Google Gemini; this list may evolve as we update or expand our AI capabilities. These providers may process your prompts and inputs to generate the outputs you request, and may gather information about you, under their own separate terms and privacy policies. Please consult those terms and policies as appropriate.

4. Our collection and use of your personal information

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 process personal information about our professional users, for example when you access our website, create a Wiggli account, contact us, send us feedback, or use our Services or the Wiggli Platform.

We obtain personal information from the following sources:

(i) directly from you, for example when you create an account, complete your profile, contact us or otherwise use our Services via the Wiggli Platform; 

(ii) indirectly, for example through your browsing activity on the Wiggli Platform (see ‘Cookies’ below); and

(iii) from third-party data providers and publicly available sources, where we obtain business contact details for our marketing and outreach. These providers act as independent controllers and are responsible for their own collection of the data .

5. The personal information we process

The personal information we process depends on the activities carried out through the Wiggli Platform. This information relates to you as a professional user, such as a recruiter or other Client.

This information may therefore include:

  1. name, address and contact details (including professional and/or personal email address and landline or mobile telephone number);
  2. professional or job title;
  3. details of any feedback you give us by phone, email, post or via social media;
  4. information about the Services we provide to you;
  5. your account details, such as username and login details; and
  6. company incorporation information (which may contain personal data).

We may use this personal information to:

  1. create and manage your account;
  2. verify your identity;
  3. provide our Services to you;
  4. customise the Wiggli Platform and its content to your preferences;
  5. notify you of any changes to the Wiggli Platform or our Services that may affect you;
  6. conduct direct marketing, where you have given us your consent to do so; and
  7. 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.

6. Sensitive Personal Data

We do not intentionally 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). Our Platform is not designed to capture such data, and Clients are contractually prohibited from submitting it through the Platform. Where we do process such data (for example where you provide it to us directly), we will only do so with your explicit consent, which you may withdraw at any time by contacting us; withdrawing your consent will not affect the lawfulness of any processing carried out beforehand.

7. Our legal basis for processing your personal information

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

The legal bases we may rely on include:

  1. Performance of a contract: where the processing is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into a contract (e.g. to manage your account, respond to requests, or provide Services).
  2. Consent: where you have given clear and unambiguous consent to process your personal data for specific purposes (e.g. receiving marketing emails).
  3. Legitimate interests: where the processing is necessary for our legitimate interests or those of a third party, provided those interests are not overridden by your rights and interests (e.g. to improve the Wiggli Platform, protect security, or conduct analytics).
  4. Compliance with a legal obligation: where we are required to process your personal data by law (e.g. to comply with tax or employment laws).

We will only use your personal information where we are satisfied that we have a lawful basis to do so. You can contact us if you would like more information on the specific legal ground we rely on for a particular processing activity.

8. 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:

What we use your personal information for Our reasons
To provide our Services and administer them to you For the performance of our contract with you or to take steps at your request before entering into a contract and in our mutual legitimate interests
To prevent and detect fraud against you or Wiggli or our Clients For our legitimate interests or those of a third party, i.e., to minimise fraud that could be damaging for us and for you and our Clients
Conducting checks to identify our users and verify their identity To comply with our legal and regulatory obligations and to comply with our Client requirements (pursuant to the subscription contract we have with them)
Ensuring business policies are adhered to, e.g. policies covering security and internet use and IT For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you and our Clients
Operational reasons, such as improving efficiency, training and quality control For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you, and where the Services attract a fee or require a subscription, at the best price
Ensuring the confidentiality of commercially sensitive information For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information
Statistical analysis to help us manage our business, e.g. in relation to our user base, Services or other efficiency measures For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price, where our Services attract a fee or require a subscription

9. Who we share your personal information with

We share personal data only where necessary for the purposes described in this policy. Depending on the circumstances, we may share personal data with the following categories of recipient:

  1. our service providers and sub-processors who help us provide, operate and secure the Platform and our Services (such as hosting, database and infrastructure providers), under appropriate contractual and data protection terms;
  2. Wiggli’s associated companies, where you have consented to receive information from them about their services;
  3. our professional advisers; and
  4. public authorities, regulators or law enforcement, where we are required to do so by law.

We may also share personal data where you have agreed to this, or where we are otherwise permitted to do so under applicable data protection law.

A current list of the sub-processors we engage to help support the Wiggli Platform and our Services is available in our Sub-processors page. These are the partners who support Wiggli’s own processing activities as a data controller. Where Wiggli acts as a data processor on behalf of a Client, the sub-processors engaged in connection with that processing are set out in the relevant data processing agreement between Wiggli and the Client, which falls outside the scope of this policy.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.

Aside from the scenarios described above, we will not share your personal information with any other third party without your consent. We only allow our service providers to handle your personal information where we are satisfied they take appropriate measures to protect it, and we impose contractual obligations requiring them to use it only to provide services to us and to you.

10. Transfer of your information out of the EEA

To deliver our Services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), for example:

  1. with service providers (whether yours or ours) located outside the EEA;
  2. if you are based outside the EEA; or
  3. where there is an international dimension to the Services we provide to you.

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

Whenever we transfer your personal information outside the EEA, we ensure it remains protected to a standard equivalent to that required under European and Belgian data protection law. Our primary basis for doing so is an adequacy decision of the European Commission, which recognises that a particular country, territory or framework ensures an adequate level of protection - for example, for transfers to the United Kingdom, or for transfers to organisations in the United States that are certified under the EU-US Data Privacy Framework. Where no adequacy decision applies, or one ceases to apply, we instead rely on appropriate safeguards, such as the European Commission’s Standard Contractual Clauses (together with the UK Addendum where relevant).

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).

11. How long your personal data will be kept

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:

  1. to respond to any questions, complaints or claims made by you or on your behalf;
  2. to show that we treated you fairly; and
  3. 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, we keep information necessary for tax and accounting purposes for the period required by applicable law. When it is no longer necessary to retain your personal information, we will delete or anonymise it.

12. Cookies and other tracking technologies

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.

13. Marketing and prospecting

We would like to keep you up to date with information about our Services and any news or updates that may be of interest to you. We may do this through marketing (communications to people we already have a relationship with) and through prospecting (outreach to potential business contacts with whom we have no prior relationship, such as cold outreach, or with whom we have only a limited connection, for example through a professional network such as LinkedIn). We may send you these communications by post, email, telephone, text message (SMS) or automated call.

The basis on which we contact you depends on the circumstances and the applicable data protection and e-privacy rules in your country. In most cases we rely on your consent. Where you are a business contact or professional prospect, we may instead rely on our legitimate interests in business-to-business marketing and prospecting. Whichever basis applies, we always comply with the relevant e-privacy requirements, and you can object or unsubscribe at any time, free of charge.

Where we rely on your consent, we will ask whether you would like to receive marketing messages from us, for example when you tick the relevant boxes as you sign up to the Wiggli Platform, contact us, subscribe to our newsletter, activate this option in the notifications tab of your account, or respond to an introductory email we have sent you. Every marketing message we send also includes a link to this privacy policy. However you have been contacted, you can withdraw your consent or object to and unsubscribe from our marketing at any time by:

  1. contacting us;
  2. using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts; or
  3. 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.

14. Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way.

The technical measures we take to protect your data include:

  1. Encryption of data at rest and in transit
  2. Strict role-based access control
  3. Logging of user actions
  4. Automated deletion of unsubscribed data

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.

15. Your rights

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

  1. 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.
  2. The right to request correction of your personal data.
  3. 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.
  4. 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.
  5. The right to request restriction of processing your personal data if you believe the data is incorrect; 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.
  6. 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.
  7. The right to withdraw your consent for your personal data to be processed.
  8. The right to withdraw consent for direct marketing purposes at any time, free of charge.

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

Would you like to exercise any of these rights?

  1. write to us by registered mail at Wiggli SA – Data Protection, 2 Boulevard de la Woluwe, 1150 Brussels, Belgium, or email us at support@wiggli.io with the subject “GDPR Rights – Wiggli”;
  2. provide us with enough information to identify you (for example, your username, registration or account details);
  3. provide us with proof of your identity and address (for example, a copy of your driving licence or passport and a recent utility or credit card bill); and
  4. 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 will respond to your request within one month, although we may extend this by up to two further months for complex or numerous requests, in which case we will let you know.

16. How to complain

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:

  1. Data Protection Authority, Rue de la Presse 35, 1000 Brussels, Belgium;
  2. Telephone. + 32 2 274 48 00; Fax. + 32 2 274 48 35
  3. Email: contact@apd-gba.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.

17. Changes to this privacy policy

This Privacy policy was published on 12th November 2019 and last updated on 1st October 2026. We may change this privacy policy from time to time, and when we do we will inform you via this page.

18. How to contact us

If you have any questions about this privacy policy, or wish to contact us about the information we hold about you, please email us at support@wiggli.io or write to Wiggli SA - Data Protection, 2 Boulevard de la Woluwe, 1150 Brussels, Belgium.