Privacy Notice for Applicants

We are committed to the security and confidentiality of your personal data that we collect and use. This privacy policy informs you about the processing of your personal data and was last updated on 17 October 2022.

1. Scope?

1. We process your personal data when you apply in response to one of our vacancies.
2. This privacy notice may be amended as provided in article 8.

2. Who are we?

1. "We" in this privacy notice refers to Be-Mobile NV:
   

   Name:	Be-Mobile NV
   Address:	Kardinaal Mercierlaan 1a, 9090 Melle
   Company number:	0881.959.533
   E-mail:	privacy@be-mobile.com
   Phone:	+32 9 330 51 80

2. We are responsible for collecting and using your personal data in the manner explained in this privacy notice. If you have any questions about this, please contact us by e-mail (privacy@be-mobile.com).
3. In certain circumstances, third parties may (also) be responsible for processing your personal data (e.g. recruitment and selection agency). In that case, we recommend consulting the privacy policies of these third parties.

3. What personal data do we process and why?

1. We process your personal data only for a specific purpose and to the extent permitted by law. We further explain below the cases in which we collect and use your personal data when you apply for a job with us.
   

   What personal data?	Why?	Legal basis?
   Identity and contact details (e.g. name, e-mail address and telephone number), your CV and the information contained therein, your photograph (if required) and your motivation. If we conduct an interview with you or contact your references, we usually keep a record of this as well.	To assess your application and, if necessary, to contact you and/or invite you to job interviews and/or make you an offer.	We rely on the necessity of processing your personal data to reach any agreement with you. If we recruit you, our employee privacy notice will also apply. If we decide not to work with you, we will include your data in our recruitment reserve if you have given your consent. If you have not given your consent, we will delete your data as soon as the application process for the vacancy you applied for has been fully and definitively completed (see article 6.2).
   Identity and contact details (e.g. name, e-mail address and phone number), your CV and the information contained therein, your photo (if required) and your motivation.	To include you in our recruitment reserve and contact you in this context for other or future vacancies that may match your profile.	Your consent. You can withdraw your consent at any time by contacting us.

2. However, for any personal data we collect in the above circumstances, we would like to clarify that we will also process your personal data in the following cases.
   

   What personal data?	Why?	Legal basis?
   Personal data listed above.	To fulfil our legal obligations or comply with any reasonable request from competent police forces, judicial authorities, government agencies or bodies, including competent data protection authorities.	Our legal obligation.
   Personal data listed above.	To prevent, detect and combat fraud or other illegal or unauthorised activities.	Our legal obligation.
   Personal data listed above.	To defend ourselves in legal proceedings.	Our legitimate interest in using your personal data in these procedures.
   Personal data listed above.	To inform a third party in the context of a possible merger with, acquisition of/by or demerger by that third party, even if that third party is located outside the EU.	Our legitimate interest to enter into business transactions.

4. From whom do we receive your personal data?

1. In principle, we receive your personal data from you. However, in certain cases, we may also receive data about you from third parties, as further explained in this article.
2. We may receive personal data from (one of) your previous employer(s):
   1. If you provide us with the contact details of a reference person (e.g. in your CV), we consider this to be an invitation to contact that reference person. We may contact this reference person to collect additional data about you for the above purposes.
   2. If you do not provide us with the contact details of a reference person, but only the company name of (one of) your previous employer(s), we will inform you that we will contact (one of) your previous employer(s) so that you can possibly provide us with the contact details of a reference person. At any time, you can withdraw your application.
3. We may collect personal data from you via the internet or through your social media. In principle, we only consult the information that is publicly available about you on the internet or your social media. However, in certain cases, we may also include such information that is publicly available on the internet in your profile if we believe it is relevant to the job you are applying for. If you do not want us to consult your social media in the context of your application or if you do not want us to include information that is publicly available on the internet in your profile, we recommend that you adjust your social media privacy settings accordingly or contact us.
4. We may receive personal data from you through our recruitment and selection agencies. Some recruitment and selection agencies we work with provide us with your profile without your name and/or contact details, which means we are initially unable to identify or contact you directly. As soon as we are interested in your profile, we will obtain your details in order to contact you. In that case, we will inform you of this privacy notice. In certain cases, recruitment agencies do provide us with your name and/or contact details before we have expressed interest in your profile. In that case, we always ask the recruitment and selection office to request your consent to pass on your personal data to us. To this end, we conclude the necessary agreements with our recruitment and selection agencies.

5. With whom do we share your personal data?

1. In principle, we do not share your personal data with anyone other than the people who work for us, as well as the suppliers who help us process your personal data. Anyone who has access to your personal data will always be bound by strict legal or contractual obligations to keep your personal data secure and confidential. This means that only the following categories of recipients will receive your personal data:
   1. You;
   2. Our employees and suppliers;
   3. Other companies within our group (see clause 5.2); and
   4. Government or judicial authorities to the extent that we are obliged to share your personal data with them (e.g. tax authorities, police or judicial authorities).
2. Your application will be centralised within Be-Mobile which means that your application will be shared with other companies within our group. If you prefer not to do this and wish to apply only for a particular entity, you should expressly oppose the sharing of your application by notifying us in writing.
3. Your personal data will not be transferred by us outside the European Economic Area (EEA) (the European Economic Area consists of the EU, Liechtenstein, Norway and Iceland). Should a transfer take place, we will take sufficient safeguards to protect your personal data upon transfer (e.g. by entering into an agreement based on standard data protection clauses approved by the European Commission).

6. How long do we process your personal data?

1. Your personal data will only be processed for as long as necessary to fulfil the purposes described above or, where we have asked you for your consent, until you withdraw your consent. In this article, we provide you with the information you need to assess how long we keep your personal data identifiable.
2. We retain all personal data collected from us as part of your application for employment for the duration of the entire application process and until the full and final conclusion of the application process. This usually does not exceed 120 days. After this, we will delete your personal data, unless (1) we choose to recruit you (see article 6.3), (2) the application process has exceptionally not yet ended, or (3) you agree that we may keep your personal data for a longer period as part of our recruitment reserve. You will in most cases automatically receive an e-mail 90 days after your application asking whether we may keep your personal data for longer. If you agree, we will keep your personal data for 650 days longer.
3. If we choose to employ you, your personal data will be kept for the entire duration of your (employment) contract with us and for up to 5 years after the termination of that contract. However, we will inform you separately about the processing of your personal data in the context of your employment.
4. As a general rule, we will de-identify your personal data when it is no longer needed for the purposes described above or when the retention period, as explained in this article, has expired. We will only keep your personal data for longer if necessary in the context of any legal dispute or if we cannot delete your personal data in the event of a legal or regulatory obligation or a court or administrative order preventing us from deleting it.

7. How do we secure your personal data?

The security and confidentiality of the personal data we process is very important to us. We have therefore taken measures to ensure that all personal data processed is kept secure. These measures include technical and organisational measures to secure our infrastructure, systems, applications and processes. We have also taken other measures, such as restricting access to your personal data to those involved in the application process.

8. Your rights in relation to your personal data

1. When we collect and use your personal data, you enjoy a number of rights which you can exercise as described below.
2. You have the right to access your personal data, which means you can ask us to provide you with information about the personal data we hold about you. You can also request a copy of your personal data.
3. You have the right to request that we correct your personal data if you can prove that the personal data we process about you is inaccurate, incomplete or out of date.
4. If we request your consent to collect and use your personal data, you have the right to withdraw this previously given consent.
5. You may ask us to delete your personal data if such personal data is no longer necessary for the purposes for which we collected it, if its collection was unlawful or if you have successfully exercised your right to withdraw your consent or your right to object to the processing of your personal data. If any of these circumstances apply, we will delete your personal data immediately, unless legal obligations or administrative or judicial orders prohibit us from deleting your personal data.
6. You can ask us to restrict the processing of your personal data:
   1. during the time we assess your request for correction of your personal data;
   2. during the time we assess your objection to the processing of your personal data;
   3. where such processing was unlawful, but you prefer restriction to erasure; and
   4. when we no longer need your personal data, but you need it for the establishment, exercise or defence of legal claims.
7. Where we process your personal data based on our own interests, i.e. you have not given us your consent and we do not need them for the performance or execution of a contract or to comply with legal obligations, you have the right to object to our processing of your personal data.
8. Where we have collected your personal data based on your consent or because it was necessary for the performance or performance of a contract with you, you have the right to obtain a copy from us in a structured, commonly used and machine-readable format. However, this right only applies to personal data that you have provided to us.
9. If you wish to exercise any of these rights, please send an e-mail to privacy@be-mobile.com. If you have already applied online for one of our vacancies, you will receive a confirmation e-mail. In this e-mail, you can also click on "request a data correction" or "request to be deleted" to correct or delete your personal data. The above rights may be subject to certain legal conditions. A request must clearly indicate and specify which right you wish to exercise. If we have doubts about your identity, we may ask you to prove your identity, for example by providing a copy of the front of your valid identity card. We will inform you immediately as soon as we receive your request. If the request proves to be justified, we will inform you as soon as possible and no later than 30 days after receiving the request.
10. If you have a complaint about the processing of your personal data by us, you can always contact us at the e-mail address mentioned article 8.9. If you are not satisfied with our response, you may lodge a complaint with the competent data protection authority.

9. Changes to this privacy notice

1. We reserve the right to change this privacy notice at our own initiative and at any time. If material changes to this privacy notice may affect the processing of your personal data, we will communicate these changes to you in a manner in which we normally communicate with you (e.g. via e-mail).
2. We invite you to review the latest version of this privacy notice on our website (www.be-mobile.com). Our privacy notice indicates the date on which our privacy notice was last amended.

10. How can you contact us?

Should you have any further questions regarding the processing of your personal data, please do not hesitate to contact us. You can contact us via e-mail at: privacy@be-mobile.com.