PLANEPAL PRIVACY POLICY

Version 1.1 - Last update: 28 June 2023

1. GENERAL INFORMATION

In this section, we provide you with general information about us, Planepal, and this Privacy Policy.

1.1 About the Privacy Policy
This Planepal privacy policy (the “Privacy Policy”) governs the processing of personal data collected from individual users (“you” and “your”) through the platform www.Planepal.com, the related domain names (e.g., www.Planepal.eu, www.plane-pal.com software applications, and services (collectively, “Planepal”). The Privacy Policy does not cover any third-party websites, applications or software that integrate with Planepal or any other third-party products and services.

1.2 Data controller
Planepal is owned and operated by The Hunting Division nv having a registered place of business at Heirbaan 80, 8570 Anzegem, Belgium, and the company number BE 0471.865.277 (“we,” “us,” and “our”).

1.3 Minors
Planepal is not intended for use by persons under the age of 18. We do not knowingly collect personal data belonging to persons younger than 18. If you become aware that such a person has provided us with his or her personal data and you are a parent or a legal guardian of that person, please contact us immediately and we will remove the child’s personal data from our systems.

1.4 Term and termination
This Privacy Policy enters into force on the effective date indicated at the top of the Privacy Policy and remains valid until terminated or updated by us.

1.5 Amendments
This Privacy Policy can be changed from time to time to address the changes in our business practices, the functionalities of Planepal, laws, regulations, and industry standards. The amended version of the Privacy Policy will be posted on this page and, if we have your email address, we will send you a notice about all the changes implemented by us. We encourage you to review our Privacy Policy to stay informed. For significant material changes in the Privacy Policy or, where required by the applicable law, we may seek your consent.

2. WHAT DATA DOES PLANEPAL COLLECT?

In this section, we explain in detail what personal data we collect from you, for what purposes we use it, what technical data is collected automatically when you use Planepal, and how we communicate with you.

2.1 Sources of personal data
We obtain your personal data from the following categories of sources:

• Directly from you. For example, if you submit your personal data when you register your user account, conclude a service agreement with us, or contact us;
• Directly or indirectly through your activity on Planepal. When you use Planepal, we automatically collect technical information about your use of Planepal by means of cookies and analytics services; and
• From third parties. We may receive information about you from third parties to whom you have previously provided your personal data, if those third parties have a legal basis for disclosing your personal data to us (for example, for payment processing purposes).

2.2 Collection of personal data

We comply with data minimisation principles. This means that we collect only a minimal amount of personal data that is necessary for your use of Planepal. We use your personal data for limited, specified and legitimate purposes explicitly mentioned in this Privacy Policy. For example, we use it only for the purposes of providing you with access to Planepal, processing your orders, maintaining and improving Planepal, replying to your enquiries, and pursuing our legitimate interests. We do not repurpose your personal data. This means that we do not use it for any purposes that are different from the purposes for which your personal data was provided. Below, you can find an overview of the types of personal data that we collect, the purposes for which we use it, and the legal bases on which we rely when processing it.

Your individual user account
When you register your account as an individual user, we collect your name, email address, bio, birthday, phone number, soft skills, test result, hard skills, languages, means of transport, location, wage scale, availability, status, resumé, education, and a link to your LinkedIn profile. We use the said information to register and maintain your user account, enable you to access and use Planepal, provide you with the requested services (e.g., provide you with job matches), contact you, if necessary, ensure Planepal security, and maintain our business records. The legal bases on which we rely are ‘performing a contract with you’ and ’pursuing our legitimate interests’ (i.e., operate, analyse, grow, protect, and administer Planepal). We will store this data until your user account is deleted unless we are required by law to keep some records longer.

Your company account
When you register your company account, we collect your company name, address, email address, phone number, website URL, contact’s name, number of employees, founding date, revenue, locations, baseline, billing details, and other company details. We use the said information to register and maintain your company account, enable you to access and use Planepal, provide you with the requested services (e.g., connect you with new talents), contact you, if necessary, ensure Planepal security, and maintain our business records. The legal bases on which we rely are ‘performing a contract with you’ and ’pursuing our legitimate interests’ (i.e., operate, analyse, grow, protect, and administer Planepal). We will store this data until your user account is deleted unless we are required by law to keep some records longer.

Enquiries
When you contact us by email or through Planepal, we collect your first name, last name, email address, and any information that you decide to include in your message. If you contact us as a company, we may also collect your company information (e.g., We use such data to respond to your enquiries and provide you with the requested information. The legal bases on which we rely are ‘pursuing our legitimate interests’ (i.e., to grow and promote Planepal) and ‘your consent’ (for optional personal data). We will store this data until you stop communicating with us.

Payments
When you make a payment on Planepal, we collect your personal data, such as your company details, full name, billing details, billing address, payment details (e.g., credit card number, CVV code, expiration month and year). Your payment data is used to process payments and maintain our accounting records. The legal bases on which we rely are ‘performing our contractual obligations’ and ‘pursuing our legitimate interests’ (i.e., to administer and protect our business). We store such data for the period prescribed by law (in Belgium, we need to keep accounting records for 7 years).

2.3 Cookies and other tracking technologies
When you browse Planepal, we collect your cookie-related data and use other tracking technologies (e.g., Meta Pixel). We use such information to analyse the technical aspects of your use of Planepal, conduct our marketing campaigns, prevent fraud and abuse, and ensure the security of Planepal. For more information on our use of cookies and other tracking technologies, please refer to our Cookie Policy. The legal bases on which we rely are ‘pursuing our legitimate interests’ (i.e., analyse our content and protect Planepal) and ‘your consent’. We will store this data as long as analytics records are necessary for our activities, or you withdraw your consent.

2.4 Sensitive data
We do not collect or have access to any special categories of personal data (“sensitive data”) from you, unless you decide, at your own discretion, to provide such data to us. Sensitive data refers to your health, religious and political beliefs, racial origins, membership of a professional or trade association, or sexual orientation.

2.5 Refusal to provide personal data
If you refuse to provide us with your personal data when we ask for it, we may not be able to perform the requested operation and you may not be able to use the full functionality of Planepal, receive the requested information, or get our response. Please contact us immediately if you think that any personal data that we collect is excessive or not necessary for the intended purpose.

2.6 Collection of analytics data
When you browse Planepal, we collect certain technical analytics data collected from you. Such data may include but are not limited to the following information:

• Number of users and sessions;
• Average session duration;
• Average pages per session;
• Ratio of new to returning visitors;
• Bounce Rate;
• Information about organic vs. paid sessions;
• Google Ads;
• Search Console – Queries;
• Average time on page;
• Etc

2.7 Purposes of analytics data.
We use your analytics data to analyse what kind of users access and use Planepal, measure your engagement with Planepal, see which parts of Planepal are interesting to you, improve our content, develop new products and services, and investigate and prevent security issues and abuse. In most cases, such analytics data is non-personal and it does not allow us to identify you as a natural person. However, if some of such data may be deemed personal data, we will make sure that we have the necessary legal basis for processing such data. When we process your analytics data that is personal data, we rely on the ‘legitimate interest’ (i.e., to analyse, improve, and protect Planepal) and ‘your consent’ bases.

2.8 Your feedback
If you contact us, we may keep records of any questions, complaints, recommendations, or compliments made by you and the response. Where possible, we will de-identify your personal data (i.e., we will remove all personal data that is not necessary for keeping such records).

2.9 Aggregate and de-identified data
In case your non-personal data is combined with certain elements of your personal data in a way that allows us to identify you, we will handle such aggregate data as personal data. If your personal data is aggregated or de-identified in a way that it can no longer be associated with an identified or identifiable natural person, it will not be considered personal data and we may use it for any legitimate purpose.

2.10 Newsletters
If you opt-in for our newsletter, subscribe to our newsletter, or conclude a service contract with us, we will inform you about our new services, features of Planepal, and special offers. The legal bases on which we rely is ‘your consent’ (if you opt-in) and ‘pursuing our legitimate business interests’ (i.e., promote Planepal). You can opt-out from receiving our commercial communication at any time free of charge by clicking on the “unsubscribe” link included in our newsletters or by contacting us directly.

2.11 Transactional notices
If we have your email address and it is necessary to do so, we may send you important informational messages, such as order confirmations, payment receipts, invoices, and other technical or administrative emails. Please note that such messages are sent on an “if-needed” basis and they do not fall within the scope of commercial communication that may require your prior consent. You cannot opt-out from service-related notices.

3. HOW LONG DOES PLANEPAL STORE MY DATA?

In this section, we explain for how long we keep your data in our systems and how we delete it.

3.1 Storage of personal data
We and our data processors store your personal data only for as long as such personal data is required for the purposes described in this Privacy Policy or until you request us to update or delete your personal data, whichever comes first. For more details about the period for which each type of personal data is stored, please refer to section 2.2. After your personal data is no longer necessary for its purposes and there is no other legal basis for storing it, we will immediately securely delete your personal data from our systems. We do not store any personal data longer than strictly necessary.

3.2 Storage of non-personal data
We retain non-personal data pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include storing non-personal data for the period of time needed for us to examine our activities, fulfil our contractual obligations, pursue our legitimate interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

3.3 Storage as required by law
When we are obliged by law to store your personal data for a certain period of time (e.g., for keeping accounting records), we will store your personal data for the time period stipulated by the applicable law and delete the personal data as soon as the required retention period expires.

4. HOW DOES PLANEPAL DISCLOSES MY DATA?

In this section, you can find information about third parties that may have access to your personal data.

4.1 Disclosure to data processors
We keep your personal data in strict confidentiality. However, if necessary for the intended purpose of your personal data, we will disclose your personal data to entities that provide services on our behalf (our data processors). Your personal data may be shared with entities that provide technical support services to us, such as hosting, payment processing, and email distribution services. We do not sell your personal data to third parties and do not intend to do so in the future. The disclosure of your personal data is limited to the situations when it is required for the following purposes:

• Ensuring the proper operation of Planepal;
• Delivering you the requested services;
• Processing your payments;
• Responding to your enquiries;
• Pursuing our legitimate interests;
• Enforcing our rights, preventing fraud, and security purposes;
• Carrying out our contractual obligations;
• Law enforcement purposes; or
• If you provide your prior consent to such a disclosure.

4.2 List of data processors
We choose our data processors carefully and make sure that they ensure an adequate level of protection of personal data that is consistent with this Privacy Policy and the applicable data protection laws. The data processors that will have access to your personal data are:

• Our web hosting service Combell located in Belgium States;
• Our newsletter service provider MailChimp located in the United States;
• Our analytics service providers Google Analytics and Meta Pixel located in the United States, and Hotjar located in Malta; and
• Our independent contractors and consultants.

4.3 Disclosure to other users of Planepal
If you use Planepal as an individual user and you agree to share your personal data with companies that use Planepal to search for new talent, we will share your personal data with those companies. Such sharing is necessary to match you with the right companies. If you do not provide your consent, we will not share your personal data with those companies. However, please note that, in such a case, you may not be matched with the right company or recruited.

4.4 International transfers
Some of our data processors may be based outside the country where you reside. For example, if you reside in the UK or a country belonging to the European Economic Area (EEA), we may need to transfer your personal data outside the UK or the EEA. In case it is necessary to make such a transfer, we will make sure that the country in which our data processor is located guarantees an adequate level of protection for your personal data or we conclude an agreement with it that ensures such protection (e.g., a data processing agreement based pre-approved Standard Contractual Clauses).

4.5 Disclosure of non-personal data
Your non-personal data may be disclosed to third parties for any purpose as it does not identify you as a natural person. For example, we may share it with prospects or partners for business or research purposes, for improving Planepal, responding to lawful requests from public authorities or developing new products and services.

4.6 Legal requests
If requested by a public authority, we will disclose information about the users of Planepal to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.

5. HOW DOES PLANEPAL PROTECT MY DATA?

5.1 Security measures
We implement technical and organisational information security measures that protect your personal data from loss, misuse, unauthorised access and disclosure. The security measures taken by us include encryption (AES-256-CBC and SSL), XSS validation, proper authentication, secured networks, strong passwords, limited access to your personal data by our staff, anonymisation of personal data (when possible), and carefully selected data processors.

5.2 Security breaches
Although we put our best efforts to protect your personal data, given the nature of communication and information processing technology and the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data caused by circumstances that are beyond our reasonable control. In case a serious breach occurs, we will take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breach will be limited to the highest extent permitted by the applicable law.

6. HOW CAN I MANAGE MY PERSONAL DATA?

Here you can find detailed information about the rights that you have with regard to your personal data and how to exercise those rights.

6.1 The list of your rights
You have the right to control how we process your personal data. Subject to any exemptions provided by law, you have the following rights:

• Right of access: you can get a copy of your personal data that we store in our systems and a list of purposes for which your personal data is processed;
• Right to rectification: you can rectify inaccurate personal data that we hold about you;
• Right to erasure (‘right to be forgotten’): you can ask us to erase your personal data from our systems;
• Right to restriction: you can ask us to restrict the processing of your personal data;
• Right to data portability: you can ask us to provide you with a copy of your personal data in a structured, commonly used and machine-readable format and move that personal data to another processor;
• Right to object: you can ask us to stop processing your personal data;
• Right to withdraw consent: you have the right to withdraw your consent, if you have provided one; or
• Right to complaint: you can submit your complaint regarding our processing of your personal data.

6.2 How to exercise your rights?
If you would like to exercise any of your legitimate rights, please contact us by using our contact details available at the end of the Privacy Policy and explain in detail your request. In order to verify the legitimacy of your request, we may ask you to provide us with an identifying piece of information, so that we can identify you in our system. We will answer your request within a reasonable time frame but no later than 30 days.

6.3 Complaints
If you would like to launch a complaint about the way in which we handle your personal data, we kindly ask you to contact us first and express your concerns. After you contact us, we will investigate your complaint and provide you with our response as soon as possible (no later than 30 days). If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.

7. CONTACT

If you have any questions about this Privacy Policy, your rights, or our data protection practices, please contact us by using the following contact details:
Email: admin@planepal.com
Postal address: Planepal, Heirbaan 80, 8570 Anzegem, Belgium