Privacy Policy

Introduction

Collaboration Betters The World is a global technological group working with its clients to create positive business outcomes by using information technologies combined with our experts and clients’ fields of expertise. Our core value is “Collaboration betters the world”, which means individual interactions and exchange of knowledge are the epicentre of new innovations. Collaboration Betters the World and its affiliates (hereinafter referred as “Collaboration Betters The World ecosystem”), are aware that such interactions require advanced cautions regarding the processing of Personal Data. 

In this regard, Collaboration Betters The World ecosystem is deeply committed in the continuous improvement of its internal procedures to comply with the data privacy laws to ensure the protection of Personal Data and the respect of Data subjects rights.

The present privacy policy underlines the processing of Personal Data done at Collaboration Betters The World ecosystem and the rights of individuals regarding such processing of their Personal Data.

What is a Personal Data and why is it important ?

A Personal Data is an information relating directly or indirectly to an individual, whether he/she is an employee, a candidate or another person who has a relative connection to services provided by CBTW. The formal definition of a Personal Data can be found in the definition section below. A Personal Data is important because it gives information to about person’s life to private or public entities.  Being able to know and control which Personal Data are processed by these entities is an essential aspect of a person’s autonomy. This privacy policy, and any other document provided CBTW that completes it, aims at providing adequate information about the processing of Personal Data by Collaboration Betters The World ecosystem.

What role has Collaboration Betters The World ecosystem in the processing of Personal Data under this privacy policy ?

Collaboration Better The World ecosystem is composed of several legal entities located in various countries across the global. Each legal entity part of Collaboration Better The World ecosystem can, for the conduct of its activities, decides to collect or use specific Personal Data. Such power of decision gives the qualification of “Data controller” as defined in the definition section below. 

What do I find in this privacy policy?

This privacy policy exposes all the information, required under the Applicable Data Privacy laws (as defined below in the section “Definition”), regarding our activities which involve Personal Data that are collected and/or used by Collaboration Betters The World ecosystem as a Data controller.

The provisions of this privacy policy explain our internal processes to comply with the applicable Data privacy law when Collaboration Betters The World ecosystem process Personal Data under the legal qualification of Data controller. Such provisions can be completed by additional information that are present in the privacy notice located on document (form, questionnaire, survey, agreement, websites) which describes the specific purpose(s) for a Personal Data processing activity.

How do I know this privacy policy is up to date?

The provisions of this privacy policy are up to date and applicable to the future processing of Personal Data from the moment of their publication. Please note that this privacy policy may be modified at any time.

Definitions

This section describes the key words mentioned in the following provisions :

• Affiliate : means any corporation which, directly or indirectly, controls or is controlled by or is under common control with CBTW (defined in section 1 below). The terms “control” means direct or indirect ownership of or other beneficial interest in fifty percent (50%) or more of the voting stock, other vesting interest, or income of a corporation or other business entity.
• Applicable Data Privacy laws : means all privacy and data protection laws and regulations applicable to CBTW or its Affiliates, as the case may be.
• Data Controller : means CBTW (defined in section 1 below) and all its Affiliates, acting as Data controllers either independently or jointly depending on the specific Personal Data processing.
• Personal Data : means any information relating directly or indirectly to a natural person which can be identified (hereinafter referred to “Data subject”).
• Processing : means any operation, electronic or manual, or set of operations performed on a Personal Data. This includes, without limitation, access, collection, recording, storage, disclosure or deletion. 
• Privacy Policy : means all the provisions of this page.
• we/our : CBTW (defined in section 1 below) and/or its Affiliates.
• you/your : means the user of this website or the Data subject to which originates the Personal Data.

Please note that all of these terms can be used in the Privacy Policy their singular and plural form.

1. Legal information regarding CBTW and its Affiliates

1.1 Collaboration Betters The World is a group specialized in IT consulting activities, It is composed of several brands operating collectively in different legal entities of the Collaboration Betters The World ecosystem. The legal entity in charge of the coordination of the data privacy compliance is Collaboration Betters The World S.A (hereinafter referred to “CBTW”) registered under the company number 0895.492.518 at the Belgian trade registry office “Banque-Carrefour des Entreprises”. Its contact information are :

• Headquarters address : Chaussee de Charleroi 112, 1060 Saint-Gilles, Belgium
• Data Protection Officer : Cedric Neef de Sainval
• Email address : privacypolicy@cbtw.tech

1.2 Each Affiliate of CBTW is solely responsible for the determination of the purposes and means regarding the processing of Personal Data by its brands operating under its supervision.

2. CBTW’s commitments regarding the protection of Personal Data

2.1 Given the importance of protecting Personal Data, CBTW and its Affiliates is committed to adhere to Applicable Data Privacy laws and take all reasonable measures to ensure that Personal Data provided to us will remain properly handled, confidential where appropriate and safely protected.

2.2 This Privacy Policy published on our website explains the Processing your Personal Data when you use our services (clients), visit our website (prospects, candidates or simple visitor), use our mobile application or interact with us (candidates, clients, prospects, employees). This Privacy Policy also instructs you how to exercise your rights relating to your Personal Data.

2.3 More specifically, CBTW and its Affiliates undertake to respect the following principles:

• your Personal Data are processed lawfully, fairly, and transparently;
• your Personal Data are collected for specific, explicit and legitimate purposes;
• your Personal Data are stored in an appropriate and relevant manner and are limited to what is necessary for the purposes for which they are processed;
• your Personal Data are accurate and kept up to date
• your Personal Data are kept in a form which permits identify you only to the extent such identification is necessary under the relevant purpose and only as long as such purpose exists.
• to implement appropriate technical and organizational measures to ensure appropriate security of your Personal Data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage. Such measures are described in section 10 of this Privacy Policy.

2.4 If you have any questions regarding this Privacy Policy, please contact privacypolicy@cbtw.tech.

3 Types of Personal Data CBTW and its Affiliates may be processing

3.1 For the conduct of our business activities, we are processing Personal Data. Your Personal Data might be part of our Processing. We collect Personal Data directly from you, for instance when you subscribe to one of our events or newsletters, and indirectly by using external providers which collect for us your Personal Data.  This includes, but is not limited to:

• Identification data: such as your first name, last name, personal and/or professional email address(es);
• Business contact information: such as your phone number and country of residence;
• Professional profile: such as your education, expertise, interests, skills, current and previous work experience information;
• User information: such as your connection information (Internet Protocol address), interaction and user information (email receipt confirmation ; device ID).

3.2 To collect these types of Personal Data, we may rely on third-party tools such as cookies. For more information about the cookies used on our websites, please refer to the specific “Cookies policy” available on such websites.

4 Purposes for which your Personal Data is processed by CBTW and its Affiliates

The purposes for which CBTW and its Affiliates processes your Personal information are, unless specified otherwise in the privacy notice applicable to the processing, the following:

4.1 To perform our contractual obligations and enable an appropriate level of service, such as without limitation obligations in our clients’ agreements and employees agreements;

4.2 To create and improve our products, services and processes, such as without being limited client satisfaction surveys and employees wellness questionaires;

4.3 To communicate with you; such as prospection calls and reply to questions submitted by you;

4.4 For direct marketing purposes, such as without limitation sending you newsletters and contents to provide you information regarding a specific technology topic in which you may have an interest;

4.5 For organizing corporate activities and events, such as without limitations, webinars, clients meetings, job fairs, corporate and social responsibility challenges;

4.6 For recruitment purposes, such as without limitation, contacting and conducting interviews with potential candidates or freelancers;

4.7 To provide you access to CBTW materials, including without being limited to access to CBTW and its Affiliates’ websites, downloading CBTW documents regarding a specific topic;

4.8 For complying with local and international regulations;

4.9 For security purposes, such as without being limited to the use of firewalls, the analysis of IP addresses and the use intrusion detection systems;

4.10 For statistics purposes, such as without being limited to ratings of participation to a webinar, types of replies obtained to a survey.

4.11 To handle complaints and disputes, such as without being limited to filing legal claims and defend our legal rights.

5 Existence of automated decision-making

For the following processing, CBTW and its Affiliates use automatic measures to process and select your personal data which results in an automated decision-making:

• iCIMS (application tracking system): When submitting your application on CBTW iCIMS website, depending on your answers to mandatory questions, your application will be processed through an automated decision-making algorithm. This is the case regarding the possession of a valid work-permit when it is required for the job position considered. In such case, your answer “No” will result in an automatic rejection for this job position.

6 Legal basis of the processing of your Personal Data

6.1 CBTW and its Affiliates process your Personal Data (i) on the basis of your explicit consent, (ii) to perform the contract or in order to take steps at the request of the Data subject prior to entering into a contract, (iii) to comply with legal obligations CBTW or its Affiliate is subject to or (iv) to perform CBTW or its Affiliate’s legitimate interests.

6.2 Your consent may always be withdrawn at any time in accordance with Article 10.2. In such case, be aware that the withdrawal of consent shall not affect the lawfulness of processing based on your consent before the withdrawal.

6.3 Furthermore, if you refuse to provide CBTW with some Personal Data or if you provide CBTW with incomplete or inaccurate information required for the performance of the contract or for compliance with a legal obligation, be aware that we may not be able to provide or deliver your all or parts of the services, which you may have requested from us in full quality.

6.4 When we process your Personal Data for our legitimate interests or the interests of a third party, CBTW ensures that a balance of these interests against your legitimate interests has been done. When necessary we have taken appropriate measures to limit implications and prevent unwarranted harm to you.

7 Period for Personal Data retention

CBTW and its Affiliates will retain your Personal Data for the period necessary to fulfill the purposes outlined above, unless a shorter or longer retention period is required or permitted by Applicable Data Privacy law or until you exercise your right to be forgotten or right to withdraw your consent, as outlined in section 10.2 of this Privacy Policy.

8 Entities processing your Personal Data

8.1 Being part of a group of several legal entities located worldwide, CBTW may receive Personal Data that you provided to an Affiliate. In such case, CBTW and its Affiliates act either as independent Data controllers or as joint controllers. For more information regarding such processing of Personal Data by CBTW from its Affiliates, please send a request at privacypolicy@cbtw.tech.

8.2  Except if stipulated otherwise, your Personal Data will be processed by CBTW and all its Affiliates as they share common IT tools (software, databases, processes). CBTW and its Affiliates may delegate some of its IT Processing to external suppliers and other third parties. You may contact us at the address mentioned in section 11 of this Privacy Policy to get additional information about the third parties involved in a specific Processing of your Personal Data. You may contact us at the same address to know the source of our Processing of your Personal Data in case we collected them from a third-party.

8.3 CBTW may be required by law, legal process, litigation and/or requests from public and governmental authorities within or outside your country of residence to disclose your Personal information.

8.4 Additionally, in the event of a reorganization, merger, or sale of one or more Affiliates, we may transfer any and all Personal Data we have collected to the relevant third party. CBTW will use its best endeavors to ensure that all its employees and third parties who are involved in the collection, processing and disclosure of Personal Data will observe and adhere to the provisions this Privacy Policy including the technical measures described in section 10.

9 Transfers of Personal Data outside you country of residence

9.1 You are informed that CBTW and its Affiliates may transfer your Personal Data to third parties located outside your country of residence in order to be processed and stored.

9.2 In such case and if applicable, CBTW undertakes to guarantee the processing of your Personal Data in accordance with the provisions of the Applicable Data Protection Laws, such as article 46 of GDPR.

10 Technical measures for protecting Personal Data

To secure the safety of Personal Data, CBTW and Affiliates have implemented or are implementing the following technical, managerial and physical devises:

• ISO 27001 “Information Security Management” best practices; 
• appropriate technical and organizational measures, such as pseudonymization, depending on the types of Personal Data to ensure an appropriate level of security;
• confidentiality, integrity, availability and resilience of IT systems;
• restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident;
• ensure a process for regular testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing;
• minimize the number of employees for managing Personal Data.

11 Your rights in the Processing of your Personal Data

11.1 Based on the Applicable Data Protection laws, you may have the following rights which can be exercised at the following email address: privacypolicy@cbtw.tech.

Please note that if you choose to request information from CBTW or its Affiliate you may need to communicate Personal Data of a general nature to us, such as identification information. In addition to, if you choose to correspond further with us through email, we may retain the content of your email messages together with your email address and our responses as proof of completing or rejecting your request. We provide the same protection for these electronic communications that we employ in the maintenance of information received by mail or telephone.

11.2 Your rights are:
The right of information and access:
Any Data subject concerned may request if any of his/her Personal Data  is processed by CBTW and its Affiliates acting as Data Controller, and to request access or  copy of his/her Personal Data currently processed by CBTW or its Affiliates. Please note that for any additional copies or specific requests regarding the format of such Personal Data, we may charge you  our internal administrative costs to complete such request.

The right of rectification:
CBTW and its Affiliates do their best efforts to keep your Personal Data accurate, complete and up to date. You have the right to obtain from CBTW the rectification of inaccurate or incomplete Personal Data concerning you.

The right to be forgotten:
You have the right to obtain the erasure of your Personal Data stored by CBTW and its Affiliates. Please note that this rights is not absolute and may be subject to exception, such as without being limited any legal obligation imposed to CBTW or its Affiliates to keep record of your Personal Data.

The right to restriction of processing:
You have the right to obtain from CBTW or its Affiliates a limitation of the Processing of your Personal Data without deleting the Personal Data concerned. Depending on the Applicable Data Privacy laws, certain exemptions may apply to your exercise of such right.

The right to Data portability:
You have the right to recover some of your Data for your own use or to transmit them to another company. Please note that, depending on the Applicable Data Privacy laws, this right is not absolute and may only apply in specific situations.

The right to object:
You have the right to object at any time to the Processing of your Personal Data by CBTW or its Affiliates. Please note that, depending on the Applicable Data Privacy laws, certain exemptions may apply to your exercise of such right.

The right to withdraw consent:
When the processing of your Personal Data is subject to your prior consent, you have the right to withdraw your consent at any time.

You shall be aware that the withdrawal of consent shall not affect the lawfulness of Processing based on your consent before the withdrawal. In case of withdrawal, it may mean that we will not be able to provide or deliver you all or parts of our services.

The right to lodge a complaint:
If you are a located in the European Union, you have the right to lodge a complaint with the Data Protection Authority (DPA) of your country of residence or the Belgian DPA if you consider that the Processing of your Personal Data constitutes a violation of the GDPR. The contact information of the Belgian supervisory authority is:

Autorite de protection des donnees, Rue de la Presse 35, 1000 Bruxelles, Belgique
contact@apd-gba.be

12 Communication with you and notification to the Data Protection Authority in case of a breach of your Personal Data

12.1 We will communicate without undue delay, when your Personal Data are breached, to you and the Data Protection Authority every time it is required by the Applicable Data Privacy laws. This communication about your Personal Data breach will describe in clear and plain language the nature of the Personal Data breach and contain at least the following information and measures:

• communicate the name and contact details of the Data Protection Officer or other contact point where more information can be obtained;
• describe the likely consequences of such breach;
• describe the measures taken or proposed to be taken by CBTW or its Affiliates to address the Personal Data breach, including, when appropriate, measures to mitigate its possible adverse effects.

12.2 This communication shall not be required if any of the following conditions are met:

• CBTW and its Affiliates has implemented appropriate technical and organizational protection measures, and those measures were applied to the Personal Data affected by the Personal Data breach, in particular those that render the Personal Data unintelligible to any person which is not authorized to access it, such as encryption;
• CBTW and its Affiliates has taken subsequent measures which ensure that the high risk to your rights and freedoms referred to in the first paragraph is no longer likely to materialize;
• It would involve disproportionate effort for CBTW or its Affiliates. In such a case, there shall instead be a public communication or similar measure whereby you are informed in an equally effective manner.

13 The Data Controller and the Data Protection Officer

13.1 The Data Controller is Collaboration Betters The World S.A., with registered offices in Chaussée de Charleroi, 112 in 1060 Brussels and registered under the company number 0895.492.518 (email: privacypolicy@cbtw.tech).

13.2 In order to ensure the security of your Personal information and to protect your rights and freedoms, CBTW has appointed a Data Protection Officer:

Mr. Cédric Neef de Sainval
Address:  Chaussée de Charleroi, 112 in 1060 Brussels, Belgium
Email: privacypolicy@cbtw.tech