INBETWEEN SA acting as a data controller or data processor, (altogether “INBETWEEN SA”, “we”, “us”, or “our”) collect data to operate effectively and provide you (any data subject in relation with INBETWEEN SA) with the best services. This is why, at INBETWEEN SA we are highly committed to safeguarding your privacy. We have developed a Privacy Notice that covers how we may collect, use, share, protect and keep information about you as well as the rights to which you are entitled in this respect.
To provide its services, INBETWEEN SA needs to collect and process certain information about you. The data we collect depends on the context of your interactions with INBETWEEN SA, the choices you make including the services which are provided to you.
It is to be noted that you have choices about the data we collect. When you are asked to provide personal data, you may decline. If you choose not to provide data that is necessary to provide the service, we may not be able to deliver the service.
The data we collect and process can include the following, but is not limited to:
Further to the categories of data mentioned above, INBETWEEN SA guarantees that, except to the limited extent that may be necessary in the context of employment and in the context of performing a contract with a client, we neither request not collect special categories of data (i.e., personal information specifying criminal offences/convictions, medical or health conditions, biometric or genetic data, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual).
Please also refer to the HR section.
This Privacy Notice applies to personal data, which is information that INBETWEEN SA collects from you and other third parties that specifically identifies you as an individual. INBETWEEN SA may collect your personal data in various manners.
Information that we automatically collect when you use our Website: when you use our Website, we automatically collect, through Cookies, the following information:
Personal data that we collect when you do business with INBETWEEN SA: we may collect and process your data when you conduct business with us. "Personal data" means information relating to an identified or identifiable natural person that INBETWEEN SA receives on behalf of the client himself/herself/itself. Examples of categories of such personal data can be found in the previous section.
Personal data we obtain from other sources: we also may periodically obtain both personal and non-personal information about you from INBETWEEN SA’s subsidiaries, affiliates, business partners or other third-party sources where they are legally permitted to share such information with us, and add it to the information we already hold about you, such as, but not limited to:
Personal data that we collect when you apply online for employment: please refer to the HR section.
For processing to be lawful under the General Data Protection Regulation (the “GDPR”), a lawful basis needs to be identified before processing personal data.
We use or may use your personal data for the following purposes (or as otherwise described at the point of collection) in line with the lawful basis under the GDPR:
We may contact you by mail, telephone, fax, video conference, email or other electronic messaging service to notify you about special events, new features or other information that may be of interest to you in accordance with your interaction with INBETWEEN SA. Where required by applicable law, your prior consent will be obtained before sending you direct marketing and you may object or opt out of receiving marketing messages from INBETWEEN SA.
INBETWEEN SA does not in any way sell, lease or rent your information to third parties.
INBETWEEN SA shares your personal data as necessary to render any service you have requested or authorised.
INBETWEEN SA may also share your personal data with your consent namely for the following purposes:
Service providers: we may disclose/transfer your data with third parties that we refer as service providers solely to the extent necessary to enable such service providers to provide services to INBETWEEN SA and to assist us in providing services to you. INBETWEEN SA’s policy is to maintain contracts with all third parties with whom we disclose/transfer personal information that restrict their access, use and disclosure of personal data. Service providers must, in fact, abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose.
Third parties: we may disclose/transfer your data with third parties such as administration and public authorities, banking institutions, notaries, domiciliation agents and to professional advisors and auditors of INBETWEEN SA.
Safety, security and compliance with law: we will access, transfer, disclose and preserve personal data to comply with applicable law or respond to subpoenas, court orders or other valid legal process, for reasons relating to national security, to defend against legal claims, to protect the rights and safety of INBETWEEN SA, INBETWEEN SA’s clients, employees or others. This may involve the sharing of your data with law enforcement, government agencies, courts and other organisations.
Consent: we may share your data in other ways and for new purposes if you have asked us to do so and have consented to such sharing.
Those recipients may be located in and outside the European Union. Your personal data will not be transferred to any country outside the European Union which does not ensure an adequate level of protection unless you gave us prior authorization to do so or specific measures (such as adequate contractual arrangements) have been taken by us in order to ensure that the requirements of the applicable data protection law have been fulfilled.
Where personal data is transferred/disclosed to INBETWEEN SA’s affiliates/branches/subsidiaries, such transfer is based on specific measures, specifically the model clauses issued by the European Commission with regards to transfer of personal data outside the European Union. Should you wish to consult the latter, please let us know by contacting us to the contact information provided in the section “HOW TO CONTACT US” of this policy.
INBETWEEN SA seeks to ensure that you are able to exercise your rights at any time. INBETWEEN SA will address any request within the limits of its technical and organizational means.
Please be aware that these rights are not always absolute and there may be some situations in which, technically or legally, INBETWEEN SA may not be able to comply with your request.
INBETWEEN SA acknowledges your trust and is committed to protecting the data you provide to us. We maintain appropriate organisational, physical and technical security measures (including with respect to personnel, facilities, hardware and software, storage and networks, access controls, monitoring and logging, vulnerability and breach detection, incident response, encryption of personal data) to protect against unauthorised or accidental access, loss, alteration, disclosure or destruction of personal data.
INBETWEEN SA will notify its client of any personal data breach by INBETWEEN SA, its processors, or any other third-parties acting on INBETWEEN SA’s behalf without undue delay, only where the personal data breach is likely to result in a high risk to the rights and freedoms of the client.
INBETWEEN SA will only retain your personal data:
We expect you to inform us in writing and without undue delay of changes in the information you provided to us or others about you, so that we can keep it up-to-date.
*Last update on 20/02/2020
Personal data that we collect when you apply online for employment: you may submit personal data through the use of our website to be considered for employment at INBETWEEN SA. Such information includes, amongst others, your name, your address, your phone number, your email address, experience, education, job skills and other information contained on your curriculum vitae (CV) and/or your cover letter. INBETWEEN SA uses such data solely for consideration of your candidacy for employment, to communicate with you and to generate related correspondence, including offer letters and employment agreements. Such data may also be used, subject to applicable local laws, to conduct necessary background checks for compliance and other employment related purposes (including the assessment of your profile in view of the conclusion of a potential employment contract, to the extent permitted by applicable laws and regulations). Finally, INBETWEEN SA only retains such data for as long as is necessary to address your employment application and any questions that may arise regarding your application’s processing.
Attention : Serge Moucheron INBETWEEN SA, Data Protection Officer Avenue de la porte neuve 12 L-2227 Luxembourg GRAND DUCHE DE Luxembourg