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.
This Privacy Policy aims to provide clear and transparent information, in accordance with Regulation (EU) 2016/679 (the “GDPR”), on how and why Effortel processes personal data and on the rights of data subjects.
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
Effortel acts as data controller within the meaning of Article 4(7) GDPR.
3. What data is collected and how?
Effortel processes only personal data that is adequate, relevant and limited to what is necessary in relation to the purposes described below.
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, Effortel may exceptionally process personal data falling under special categories within the meaning of Article 9 GDPR, only where strictly necessary to comply with legal obligations or where the candidate has given their consent.
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.
The person making the referral declares that they have informed the data subject about the referral and the processing of their data by Effortel. Where your personal data has been provided to Effortel by a third party (your referee), Effortel will inform you directly of the processing of your personal data in accordance with Article 14 GDPR. Such information will be provided at the latest within one month of receiving your data, or at the time of the first communication with you, whichever is earlier. The information provided will include, at a minimum, the content set out in this Privacy Policy, including the purposes and legal bases of the processing, the categories of data processed, the retention periods applicable, and your rights as a data subject.
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 may include identification and contact data as well as limited technical communication metadata (such as date and time of the communication), processed strictly in accordance with applicable electronic communications and ePrivacy legislation.
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.
The processing is based on:
- - Article 6(1)(b) GDPR (processing necessary for taking steps prior to entering into an employment contract), and
- Where applicants consent to the retention of their application data for future job opportunities, such processing is based on Article 6(1)(a) GDPR. Applicants may withdraw their consent at any time.
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 Article 6(1)(f) GDPR, namely Effortel’s legitimate interest in ensuring the continuity, quality and security of its communications with existing and prospective clients and partners, and in maintaining an effective channel for addressing inquiries.
You have the right to object to this processing at any time on grounds relating to your particular situation.
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.
This processing covers two distinct categories, each with its own legal basis:
(i) Technical website data collected without cookies (e.g., server logs, basic traffic data): The basis of this processing is our legitimate interest (Art. 6(1)(f) GDPR) in detecting technical issues, optimizing the performance and security of our website, and enhancing the overall user experience of our digital services, which interest is not overridden by the rights and freedoms of website visitors given the limited intrusiveness of such processing and their reasonable expectation that basic technical data is processed when browsing a corporate website.
(ii) Data collected via analytics and marketing cookies (e.g., Google Analytics, HubSpot):
This processing is based on your consent (Art. 6(1)(a) GDPR). These cookies will only be placed and read if you have given your prior consent via our cookie consent banner. You may withdraw your consent at any time, without affecting the lawfulness of processing prior to withdrawal, by updating your cookie preferences via the cookie settings available on our website.
For more details on the cookies used and their purposes, please refer to our Cookie Policy.
d. Compliance with legal and regulatory requirements
Effortel may use your personal data to prevent, detect and investigate illegal or suspected illegal activities, such as fraud, as well as to enforce our general terms and conditions. This processing is based on Effortel's legitimate interest (art. 6(1)(f) GDPR) in protecting its financial and operational integrity against fraudulent conduct and ensuring compliance with its contractual rights. For compliance with its legal obligations (art. 6(1)(c) GDPR), Effortel may also use your data to satisfy legislative and regulatory requirements 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 or consent 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).
You may withdraw your consent at any time, without affecting the lawfulness of processing prior to withdrawal.
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.
Personal data is retained only for as long as necessary for the purposes for which it is processed, unless a longer retention period is required by law.
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.
Where personal data is transferred outside the European Economic Area, such transfers are carried out subject to appropriate safeguards in accordance with Articles 44–49 GDPR, including adequacy decisions or Standard Contractual Clauses approved by the European Commission.
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 at any time to the processing of your personal data based on Effortel’s legitimate interests. Where data is processed for direct marketing purposes, you have an unconditional right to object.
- 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.
- Right to restriction of processing: You have the right to request that Effortel restricts the processing of your personal data in certain circumstances, including where you contest the accuracy of the data, where the processing is unlawful, or where you have objected to the processing.
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.