1. Introduction
EFFORTEL TECHNOLOGIES S.A. with registered office at 1170 Brussels, Chaussée de la Hulpe 177/11, Belgium, and registered in the Belgian Company Register under company number BE 0883.209.249 (hereunder « Effortel »), is a Mobile Virtual Network Enabler (MVNE). It provides infrastructure and services to Mobile Virtual Network Operators (MVNOs) across Europe, the Middle East and Africa, to offer mobile communication services to end user customers. Effortel runs a centralized, cloud-based, real-time intelligent network system.
Effortel attaches great importance to the secure, transparent and confidential collection and processing of your personal data. With this privacy policy, Effortel would like to inform you about the collection and processing of your personal data.
We ask you to read this data protection notice carefully, as it contains important information about how and why Effortel processes the personal data you provide us through browsing this website, applying for a position at Effortel, or contacting us.
By providing your personal data, you explicitly declare that you have read this privacy policy and agree to its contents.
2. Who is the data controller?
Effortel is responsible for the processing of your personal data. This means that Effortel shall determine the purpose of and means by which your personal data is processed.
In the collection and processing of your personal data, Effortel complies with the General Data Protection Regulation (GDPR) from its entry into force on 25 May 2018.
You can contact Effortel’s privacy department at this address:
1170 Brussels, Chaussée de la Hulpe 177/11, Belgium
dpo@effortel.com
3. What data is collected and how?
Effortel may collect and process personal data in the context of the processing activities listed hereunder. The processing of personal data does not include profiling and you will not be subject to automated decision-making.
a. Data you personally provide us with when applying for a position
To apply for a position at Effortel through our website’s portal, you are required to fill in a contact form in which you submit certain personal data, such as: your name, e-mail address, and telephone number. You also have the option to upload your CV containing other personal data, such as: your educational and professional history, your current job situation, your qualifications, your gender, your postal address, in some cases your age, and any other data you deem relevant.
Throughout the recruitment process, other additional data may be processed by Effortel. In any event, your explicit and specific consent will be asked prior to the processing of sensitive data, such as: religious or cultural background, political convictions, criminal or health data.
b. Data collected from a user of our website upon your referral to a position
Effortel’s website also offers a portal for referring a friend for a position. In such a case, your referee is required to fill in a contact form in which they submit some of your personal data, such as: your name, e-mail address, and telephone number. Your referee also has the option to upload your CV containing other personal data, such as: your educational and professional history, your current job situation, your qualifications, your gender, your postal address, in some cases your age, and any other data you deem relevant and included in your CV.
By ticking the box “I HEREBY CONFIRM THAT I HAVE RECEIVED THE AUTHORISATION TO FORWARD THE ABOVEMENTIONED INFORMATION FROM THE REFERRAL”, your referee confirms that they have collected your consent to the processing of your data by us.
Throughout the recruitment process, other additional data may be processed by Effortel. In any event, your explicit and specific consent will be asked prior to the processing of sensitive data, such as: religious or cultural background, political convictions, criminal or health data.
c. Data collected upon contacting us
We will collect personal data should you contact us through the contact form on our website, by e-mail or telephone. Such data includes: the so-called IMEI number of the calling and called participant's mobile terminal (i.e. identification number of the end user's mobile device), or the date on and exact time at which the call begins or ends, the location of the call.
d. Data collected based on your use of our website
We also collect data on how you use our services (including usage and traffic data), as well as data relating to the devices used to access our services (e.g. type, brand, model, and operating system of your device).
In addition, we use cookies and similar technologies on our website to improve the user experience, among other things. More details about this can be found in the Cookie Policy.
4. For what purposes will this data be used?
a. Processing of job applications
The data provided through job applications on the online portal hosted on our website will be processed solely for the purpose of evaluating and managing job applications, including assessing qualifications, contacting applicants, and conducting interviews as part of the recruitment process.
Effortel bases this processing on your consent (art. 6(1)(a) GDPR), both when the data is provided by you or your referee.
b. Assistance and addressing of inquiries
Data obtained through contact requests and inquiries submitted via the contact form on our website will be processed for the purpose of responding to and addressing the inquiries or requests you submitted.
This processing is based on your consent (art. 6(1)(a) GDPR) to be contacted for your inquiry to be addressed by Effortel.
When you contact us and provide data from your device, including location data, such information will be processed for the purpose of facilitating communication, providing assistance, and delivering relevant services based on your location, where applicable.
The basis of the processing is our legitimate interest (art. 6(1)(f) GDPR) to control the quality of the service.
c. Improvement of the website’s user experience
Data related to the usage of our website, including traffic data and other browsing activities, will be processed for the purpose of analyzing and improving the functionality, performance, and user experience of the website.
The basis of the processing is our legitimate interest (art. 6(1)(f) GDPR) to control and improve the quality of Effortel’s service.
d. Compliance with legal and regulatory requirements
Based on its legitimate interest (art. 6(1)(f) GDPR) and for compliance with legal obligations (art. 6(1)(c) GDPR), Effortel may also use your data to prevent, detect and investigate illegal or suspected illegal activities, such as fraud (e.g., via a method of payment), as well as to enforce our general terms and conditions.
We may also use your personal data to satisfy legislative and regulatory requirements that Effortel must comply with and to have audits and controls performed. Effortel may be required by law to disclose personal information in the context of a dispute or litigation, or should this be required by certain government agencies (e.g., police, courts, emergency services). For the purpose of complying with these legislative and regulatory requirements, we may disclose this information without your knowledge, consent or even without notification thereof.
e. Marketing
Upon contacting us through the contact form on our website, we may ask you to consent to the processing of your personal data to send you commercial and promotional communications.
Your data will be used to inform you on news, future actions/promotions which we think might be interesting for your business, or to offer you new products and services of Effortel.
Effortel bases this processing on your consent (art. 6(1)(a) GDPR).
5. For how long are the data kept?
Personal data is stored and processed for a period of time necessary depending on the purposes of the processing and the relationship (contractual or not) with you.
a. Job applications data
Effortel will retain the personal data provided by applicants during the recruitment process for a period of one year from the date of submission of the application. This retention period allows us to assess candidates' qualifications for current and future job opportunities within the organization.
If explicit consent is given for the processing of sensitive data, such as religious or health information, this data will be retained only for the duration of the recruitment process and will be deleted once the process is completed.
b. Assistance and addressing of inquiries
Personal data collected when contacting us, including IMEI numbers, call timestamps, and location data, will be retained for a period of two months from the date of contact. This retention period enables us to respond to inquiries, address concerns, and provide follow-up assistance as needed. After the two-month period, this data will be deleted unless there are legal or regulatory requirements necessitating longer retention periods.
c. Improvement of the website’s user experience
We will retain data collected based on the usage of our website, for a period of four months from collection. This retention period allows us to analyze website performance, improve user experience, and ensure the security of our systems.
Data collected through cookies and similar technologies will be retained in accordance with our Cookie Policy, which you can refer to for specific details on retention periods for such data.
d. Compliance with legal and regulatory requirements
Personal data collected for compliance with legal and regulatory requirements will be retained for ten years after the time of collecting or after the end of the contractual relationship with you, if any.
e. Marketing
Your contact data will be stored and processed for this purpose for three years after you have given your consent.
A proof of your consent will be stored for the duration of the consent (three years) + five years.
6. To which third parties might this data be transmitted?
- To affiliates of Effortel: other companies of the Effortel Group can have access to your data.
- To suppliers, subcontractors, and other service providers: including, for the job application portal, SAGE S.A., with registered office at Spaces – Brussels, Tour & Taxis – Gare Maritime, Rue Picard 7, Boîte 100 –1000 Brussels, Belgium, with company number BE 419.618.535 and telephone number +32 (0)2 620 08 38.
- To government offices: Effortel reserves the right to share or transmit personal data, under the following circumstances: (i) to comply with applicable laws or legal processes; (ii) to detect, prevent, or address fraud and technical security issues; or (iii) to safeguard Effortel's rights and property, including the enforcement of our general terms and conditions of use.
- Business transfers: your personal data may be passed on to other third parties in the event of a partial or complete reorganization of Effortel, if its activities are transferred or in the event of a declaration of bankruptcy.
It is possible that one or more of the third parties may be located outside the European Economic Area. However, personal data will only be passed on to third countries with an adequate level of protection.
Under no circumstances will Effortel sell your personal data or make it available to direct marketing bureaus or similar service providers, unless you have given your prior consent.
7. What rights do you have?
In accordance with the GDPR, you have the following rights:
- Right of access: You have the right to inspect and, as far as is reasonable, to inspect the personal data that Effortel processes about you and to verify for what purposes it is used.
- Right to rectification: You have the right to obtain rectification (correction) of incorrect personal data concerning you as well as the right to complete incomplete personal data concerning you.
- Right to object: you have the right to object to the processing of personal data concerning you for serious and legitimate reasons. However, you may not object to the processing of data that is necessary for the fulfilment of a legal obligation, the fulfilment of a contract or its legitimate interest, insofar as this data is necessary for the purposes for which it was collected.
- Right to be forgotten or to erasure of data: You have the right to request that Effortel erase your personal data. Effortel may refuse the deletion or restriction of data that is necessary for the processing of wages, the fulfilment of a legal obligation, the fulfilment of an employment contract or in its legitimate interest insofar as such data is necessary for the purposes for which it was collected.
- Right to withdraw your consent: in the case of processing of personal data based on your consent, this consent may be withdrawn.
- Right to data portability: You have the right to receive the personal data concerning you that you have provided to Effortel, in a structured, commonly used and machine-readable format. You have the right to transmit this data to another controller.
You may exercise the aforementioned rights free of charge, unless your request should be manifestly unfounded or excessive due to its vexatious nature, by contacting: dpo@effortel.com
8. Security measures
Effortel takes technical and organisational measures to process the data at a sufficient level of security and to protect your personal data against destruction, loss, falsification, unauthorised access to or notification to third parties in error as well as unauthorised processing of such data.
Under no circumstances can Effortel be held liable for any direct or indirect damage caused by the incorrect or unlawful use of personal data by a third party, except processors.
9. Amendments to this privacy policy
From time to time, this privacy statement shall be amended, for example in the context of changes to our services. At such time that the amendments to the privacy statement are published, the date of the ‘last update’ shall be modified at the bottom of the document and you shall be notified thereof in advance (e.g., notification by e-mail).
10. Miscellaneous
This privacy statement is governed by Belgian law. All disputes relating to this privacy statement fall under the exclusive jurisdiction of the courts of Brussels, Belgium.