This Privacy Policy will come into effect on October 18th 2023

This Privacy Policy applies to all Personal Data of Users and visitors of our Website(s) (hereinafter: “Visitors”) collected through our Website(s) and Services (Users and Visitors are together referred to as “you”, “your”). This Privacy Policy provides information about, inter alia, the type of Personal Data we process, for what purpose we process these data and on what legal ground the processing is based. We therefore advise you to carefully read this Privacy Policy before using our Website(s) and/or Services.

Terms starting with a capital that are not defined in this Privacy Policy, are already defined in the ToS (Blended Capital’s terms of service) and also apply to this Privacy Policy.

1. Who is Blended Capital?

Blended Capital B.V. is a Dutch limited liability company that engages in commercial activities in the field of recruitment by providing access to a Platform on which Services are offered with the purpose of bringing Talents that seek jobs and Recruiting Organizations that have job vacancies together. Since Blended Capital B.V. determines the purpose and means of the processing of Personal Data, we qualify as a controller under the General Data Protection Regulation (hereinafter: “GDPR”).

Blended Capital B.V.
KvK number (number of the Dutch chamber of commerce): 89408152
Stationsplein 45 3013 AK
Rotterdam, The Netherlands
info@blendedcapital.nl

2. Contact

If you contact us by sending an email to info@blendedcapital.nl, we store your contact details and the content of your email(s) which may include Personal Data such as your name and telephone number. We process this Personal Data i) to reply to your requests, questions or complaints (also see paragraph 13) and ii) to send you information regarding the Website(s) and Services.

We have a legitimate interest, as defined in article 6.1 (f) GDPR, to process Personal Data for this purpose, because it enables us to offer you an efficient customer service and to keep you informed regarding our Website(s)and Services. Relevant in this regard is the fact that processing Personal Data for the above-mentioned purposes is primarily for your benefit and has little to no impact on your privacy.

3. Evaluation

We continuously evaluate the Website(s)and Services. Based on these evaluations we can changes the Website(s)and Services to keep them working properly, offer you the best user experience and to ensure your Personal Data remain safe. To create these evaluations, we process Personal Data. The evaluations that are the result if this processing no longer contain Personal Data and are therefore anonymous. These anonymous data no longer qualify as personal data as meant under article 4(1) GDPR.

Although all Personal Data we process under the Privacy Policy can be used for evaluation purposes, we mostly use automatically generated data. Automatically generated data is Personal Data relating to your use of the Website(s)and Services and includes but is not limited to your IP-address, the type of browser and the computer system you use as well as the pages you visit on the Website(s) and which features of the Services you use.

We also use your email address, name, gender and information regarding your use of the of Website(s) and Services to evaluate customer satisfaction (for instance by sending you customer satisfaction surveys).

The evaluations described above enable us to improve, expand and/or amend the Website(s) and/or Services if necessary, to maintain the high quality of the Services we provide, and to make sure the Website(s)and Services remain as user friendly as possible. It also allows us to keep our security up-to-date and your Personal Data safe.

We have a legitimate interest to process your Personal Data for the purposes described in this paragraph because it enables us to tailor the Website(s) and Services to your liking, optimize your user experience and ensure that appropriate security measures are implemented. Relevant in this regard is the fact that processing Personal Data for the above-mentioned purposes is primarily for your benefit and has little to no impact on your privacy.

4. Services provided to Talents

This paragraph 4 only applies to you if you’re a Talent.

You can create an Account by following the steps on the Website(s). As part of these steps you are requested to provide the following Personal Data: your full name, email address, telephone number (optional), country of origin, level of education (HBO or WO), how you found Blended Capital (flyer, social media, Google, or through a friend/association).

After creating your Account, you can log in on the Platform to complete your User Profile. In addition to the Personal Data already provided, you must also upload: a profile picture, a personal description, additional educational information, the language(s) you speak, your earliest availability date, weekly availability (full-time, part-time, other), work experience, desired job positions and resume.

Once you complete your User Profile and the Personal Data it contains, it will become visible on the Platform for Recruiting Organizations, except for your last name, email address, telephone number, country of origin and your answer to the question how you found Blended Capital.

As part of the Services, you may receive messages from Recruiting Organizations. We also send you emails on a regular basis containing a summary of i) all messages you received and sent and ii) relevant job postings. These emails may also contain information on our Services. Finally, we may send your User Profile to a Recruiting Organization if we think you and the Recruiting Organization may be a match.

The overview below describes the purposes for processing the Personal Data collected in accordance with this paragraph as well as the legal ground on which this processing is based.

i)        Purpose: Creating an Account

Type of data: Full name & email address

Legal ground: Necessary for the performance of the Agreement

Explanation: Creating and maintaining an Account is necessary to identify you and grant you access to the Platform to use the Services

ii)       Purpose: Contact Type of data

Type of data: Telephone number

Legal ground: Legitimate interest

Explanation: Providing your telephone number is optional. If you decide to provide your telephone number, we have a legitimate interest to use the telephone number to contact you in relation to (the operation and/or provision of) our Services. Especially since our right to use your telephone number for this purpose can be revoked at any time in the Account.

iii)     Purpose: Contacting you

Type of data: Email address (gender, name)

Legal ground: Necessary for the performance of the Agreement/ legitimate interest

Explanation: In the process of creating an Account you receive emails regarding the verification and activation of your Account. In the process of creating your User Profile you receive emails regarding the validation of your User Profile. Using your email address to send aforementioned emails, is necessary for the performance of our Agreement with you.

Your email address is also used to contact you regarding subjects that directly relate to or have a direct impact on your access to the Platform and/or use of the Services, e.g. emails regarding a breach of the ToS or any other emails concerning the ToS, emails on Service availability, maintenance and downtime, emails on data breaches, important patches and/or updates, and any other emails concerning the integrity and safety of the Services. We have a legitimate interest to process your email address for the purpose described above because it enables us to keep you informed of important and urgent issues, to enable you to take appropriate measures to protect your Personal Data and to protect our rights and interests.

Your email address can furthermore be used for marketing purposes e.g. by sending newsletters¹ containing the latest news and most recent developments regarding the Website(s) and Services and/or by sending emails containing interesting offers. We may make the emails slightly more personal by addressing you by your name and gender (e.g. Dear mrs. [name] or dear mr. [name]).

We have a legitimate interest to process these Personal Data for marketing purposes, because we must stay in touch with you, our customers, to maintain / strengthen our client relationship. Furthermore, it is reasonable to assume that you, since you already use the Services, are also interested to learn about the latest developments in relation thereto. We also need email marketing to become more visible, attract more customers and grow. This makes us less vulnerable and leads to even safer and more constant provision of Services. It also allows us to expand our Services and create new features tailored to your likings/needs. Our email marketing is therefore, at least for a considerable part, also for your benefit. Finally, we act in accordance with the legislation that allows us to send marketing emails.

iv)      Purpose: evaluation or marketing

Type of data: information on how you found Blended Capital

Legal ground: legitimate interest

Explanation: it is important to know how you found us. For instance, if we discover that only a few customers found us via our expensive online advertisement campaign, we can change this campaign as well as our marketing strategy. For these evaluations no Personal Data is needed. For Evaluation purposes see paragraph 3.

The information on how you found us, is also used for marketing purposes. The information is only linked to your name and email address and is only used for very basic and limited marketing purposes. For example, to determine the best way to approach you with offers relating to our Services. We emphasize that these data will not be combined with other Personal Data, other than the data stated above, and are therefore explicitly not used to create a “profile” of you as meant under the GDPR.

We have a legitimate interest in using the information in the way described above because approaching you in a way you prefer ensures a better customer relationship between us and may lead to more business. In this regard it is also relevant that the processing only pertains to one type of non-sensitive data which are only used for limited and non-invasive marketing purposes.

Finally, if you found us through a friend, you are offered the possibility to thank this friend by email and to bring Blended Capital to his/her attention again (‘tell-a-friend’). To facilitate you in sending this email, we process certain Personal Data of you and your friend. We have a legitimate interest to process this Personal Data to offer this feature, since it allows us to contact potential customers that at some point already were interested in Blended Capital. Relevant in this case is that we act in accordance with the regulation allowing the use of tell-a-friend features like the one we offer, which e.g. means that we do not store any Personal Data of your friend.

v)       Purpose: User Profile creation and validation

Type of data: weekly availability and level of education & profile picture, a personal description, additional educational information, language(s) spoken, earliest availability date, work experience, desired job positions, resume.

Legal ground: necessary to perform our Agreement with you.

Explanation: the aforementioned Personal Data are requested because they align with the information Recruiting Organizations find essential to assess User Profiles. Processing these Personal Data is therefore necessary to perform our Agreement with you.

vi)      Purpose: Matchmaking

Type of data: contacting information, messages, the User Profile data & email address

Legal ground: necessary to perform our Agreement with you.

Explanation: the main purpose of the Services is to match you with Recruiting Organizations. Our Services enable Recruiting Organizations and Talents to contact each other, send each other messages and start 1-on-1 chats. To facilitate this we must process certain Personal Data such as the time, date and content of messages you received and sent as well as your User Profile. Without processing these Personal Data we cannot offer you (all of) our Services.

Processing these Personal Data is therefore necessary for the performance of our Agreement with you.

vii)    Purpose: protecting our rights and interests

Type of data: Personal Data exchanged during the 1-on-1 chat feature that is part of the Services;

Legal ground: legitimate interest

Explanation: under the Agreement Recruiting Organizations are obligated to notify us when a Talent fills a job vacancy of the Recruiting Organization. This notification obligation also applies to the Talent. This notification is very important to us because without it we won’t receive payment for (a part of) our Services. To make it possible for us to, to a limited extent, check compliance with the Agreement we use software. This software monitors the correspondence between a Recruiting Organization and Talent during their use of the 1-on-1 chat feature. This is an automated process without human intervention. Only in the event that the software notifies us of a possible breach of the Agreement will one of our employees actually look at the aforementioned correspondence. We have a legitimate interest to process your Personal Data in this manner because this enables us to protect our contractual right of payment. The impact on your privacy is limited since we will only look at the correspondence after the software alerts us to a possible breach of the agreement.

5. Services provided to Recruiting Organizations

This paragraph 5 only applies to you if you are a Recruiting Organization.

As a Recruiting Organization you work for and/or represent a company. Most information provided by you under our Agreement is therefore information about that company. This information does not qualify as Personal Data. The only Personal Data we process about you are your full name as well as your company email address and/or telephone number. Although not all company email addresses and/or telephone numbers necessarily qualify as Personal Data, for the purpose of this Privacy Policy we assume that they do.

We need to identify you to verify your claim that you are entitled to represent the company and that you have the right to enter into agreements on its behalf. Processing your name for this purpose is therefore necessary to determine if we can enter into a legally binding agreement.

Finally, your name as well as your email address and telephone number (if provided) are also used to communicate with you. We have a legitimate interest to contact you personally not only because this is customary and expected of us but also because not doing so may be detrimental to our professional relationship with you.

6. Retention of Personal Data

We do not retain Personal Data longer than necessary for the realization of the purposes for which the Personal Data are collected.

If you are a User, we will delete or anonymize Personal Data 1,5 years after you delete your Account or stop using the Services. We will delete or anonymize Personal Data of Visitors ultimately one (1) year after the date of collection.

Deviations from the above-mentioned retention periods are possible if applicable legislation requires us to retain (parts of the) Personal Data longer and/or (parts of) the Personal Data remain necessary for evaluation purposes and/or (parts of) the Personal Data are necessary to protect our rights and interests and/or (parts of) the Personal Data are necessary for litigation purposes.

7. Transfer to third parties

We will not sell your Personal Data to third parties for direct marketing purposes without your prior consent.

However, in other circumstances we may need to transfer (as meant in article 46 GDPR) (parts of) your Personal Data to third parties, inter alia for the purpose of hosting, performing external audits, obtaining external (legal) advice and/or in the event of a merger or acquisition.

We use third parties for hosting purposes, for instance to host the Websites(s) and the Platform. These third parties qualify as “processors” as defined in article 4 (8) GDPR. We have entered into processors’ agreements with these third parties which, inter alia, describe the technical and organizational measures implemented by these third parties to protect Personal Data.

As a principal, we store all Personal Data within the European Economic Area (“EEA”). However, it is possible that parts of the Personal Data are stored on servers outside the EEA. In that case we will make sure to comply with the applicable legislation and regulations.

We have a legitimate interest to engage third party processors to provide essential services. Without these processors we would not be able to provide you our Services. Relevant in this matter is also that the GDPR explicitly allows the use of processors and the transfer of Personal Data outside the EEA provided the applicable conditions are met.

Furthermore, we are entitled to transfer Personal Data to third parties if we are required to do so by law and/or in the case of obtaining external audits, obtaining external (legal) advice, litigation and/or to otherwise protect our rights and interests.

Processing Personal Data because of a legal obligation is based on article 6.1(c) GDPR.

The processing of Personal Data for the other purposes mentioned above is based on our legitimate interest as meant in article 6.1(f) GDPR. We have a legitimate interest to engage third parties to perform audits, obtain (legal) advice, litigate, and otherwise protect our interest and rights, because it enables us to keep the Websites(s)and Services safe, offer them in compliance with applicable laws and regulations and to protect us against any person or company that infringes on our rights and/or interests.

We may also transfer Personal Data to third parties in case of a merger and/or acquisition. This means that in the event we are acquired by another company or in the event we acquire another company, that other company (and its advisors) will get access to the Personal Data, if necessary.

We have a legitimate interest to allow these third parties access to your Personal Data in case of a merger or acquisition since it would otherwise be impossible to acquire another company or be acquired by another company.

Finally, we can transfer Personal Data to third parties if you have consented to this. The processing of Personal Data is in that case based on consent (article 6.1(a) GDPR).

8. Security

Keeping Personal Data and our Website(s)and Services safe is important to us. We have therefore taken appropriate technical and organizational measures to protect your Personal Data from loss or any other form of unlawful processing. These measures inter alia include: measures to keep our software up-to-date by installing updates, upgrades and patches, hosting our central database which contains most Personal Data separately from other databases, limiting access to Personal Data by only allowing such access on a need-to-know basis, using strong passwords that are regularly changed, performing stress- and penetration tests on a regular basis.

We have implemented these, and other, measures in various policies that are we review regularly to ensure our measures remain state of the art.

9. Your rights

Under the GDPR, you have several rights when it comes to the processing of your Personal Data. This paragraph 9 describes the process we have implemented in this regard.

Process

If you wish to exercise any of the rights you may have with regard to the processing of your Personal Data, please send a substantiated request by email to: info@blendedcapital.nl.

We try to respond to requests within a reasonable period of time, and normally within one (1) month. However, it is possible that we need additional time. If that is the case, we will inform you thereof before the end of the aforementioned one (1) month period. The additional time will not exceed two (2) months.

We can only comply with a request if we are sure that the Personal Data to which your request pertains are really about you. If we have doubts regarding your identity we are legally obligated to verify it. In that case we will request you to send us information enabling us to identify you (if you send us a copy of your passport or identification card, please make the BSN number shown on your ID illegible).

Below you will find a list of rights you have under the GDPR with regard to the processing of your Personal Data. Please be advised that we can only comply with a request to exercise these rights if all applicable conditions as stipulated in the GDPR are met. If, in our opinion, the applicable conditions are not met, we will reject your request and inform you of this decision in accordance with the aforementioned timelines. If you disagree with our rejection, you can file a complaint with the Dutch Data Protection Authority (Dutch: “Autoriteit Persoonsgegevens”).

i)  Right of access

Means your right to receive from us and made available to you, a copy of the Personal Data we process about you.

ii) Right to rectification

iii) Right to be forgotten (right to erasure)

Means your right to require us to permanently delete or anonymize (certain) Personal Data about you.

iv) Right to restriction of processing

v) Right to data portability

vi) Right to object

10. Newsletters

We will use your email address to send you newsletters you subscribed to. We can use your name and/or gender in the newsletters to address you correctly and make the newsletter slightly more personal. Every newsletter offers the opportunity to unsubscribe.

We have a legitimate interest to use your email address to send you the newsletter you subscribed to, because it enables us to stay in touch with you and to keep you informed of all news regarding our Website(s) and/or the Services. In making the newsletter a bit more personal by including your name and/or gender we try to give you a better customer experience.

11. Cookies

Our Website(s) use cookies. Blended Capital’s Cookie Policy applies to all cookies we use and describes the type of cookies and their purposes. If cookies collect Personal Data, this Privacy Policy applies to the processing of the Personal Data in addition to Cookie Policy.

12. Changes to this Privacy Policy

We have the right to change this Privacy Policy at any time. Changes will be announced on the Website(s) and/or on the Platform. The latest version of the Privacy Policy is dated September 19th, 2023.

13. Complaints

If you contact us with a complaint regarding the processing of your Personal Data and we are unable to resolve this complaint together, you can submit your complaint to the Dutch Data Protection Authority (Dutch: “Autoriteit Persoonsgegevens”).

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¹The term “newsletters” used here, refers to emails send to you on our initiative and therefore do not include newsletters to which you have actively subscribed. (For these newsletters see paragraph 10).