Privacy Policy

Date of publication : 25/04/2022

1. About us

We are ClubTrust. Our address is 12 rue du Château d’eau, L-3364 Leudelange (Luxembourg).
 
You can contact us by post at the above address or by email at privacy@clubtrust.io.
 
We created this policy to outline our collection, use, and sharing of data you provide to us when you access or use our website and/or our mobile services (collectively, the “Site”).
 
Please note that we reserve the right to review and update this policy from time to time. Accordingly, each time you access or use the Site, you should check for the last version of this policy.
 
Our policy is an integral part of our Terms of Service. By visiting this Site, you agree to the use of your personal data as described in our policy.

2. What data we collect about you ?

When you register as a talent

When you register as a talent on the Site, you may be asked to provide your personal data, which may include one or more of the following:
● First and last name
● E-mail address
● Phone number
● Profile picture
● Job occupation and title
● Job description, including areas of expertise and sectors of activities 
● Location
● Professional objectives and ambitions
● Your availability
● Employement history
● Educational history
● Personnal documents and data: assessments, credentials, portfolios, certificates, diplomas, references, skills, languages, IDs, salary slip, package data, etc.
● Personality test
● Extra-professional interests
 
Providing your personal data will always be voluntary. You are under no obligation to provide your data although you understand that your refusal to do so may prevent you from using certain of the Site’s features and services.
 
Your information is stored on our website and on our cloud server, both of which are based within the European Union. We keep your information as long as you do not delete your profile.

When you register as a company

When you register as a company on the Site, you may be asked to provide your company’s data, which may include one or more of the following:
● Company name
● Your name
● Your function
● Your professional e-mail
● Your professional phone number
● Other company data : address, website, sector of activity, type of company and size, description, languages spoken, main figures, awards, pictures and videos, social medias, advantages, events, etc.
 
Providing your company’s data will always be voluntary. You are under no obligation to provide such data although you understand that your refusal to do so may prevent you from using certain of the Site’s features and services.
 
Your information is stored on our website and on our cloud server, both of which are based within the European Union. We keep your information as long as you do not delete your profile.

When you contact us

When you contact us, we may ask you for your name, email address and phone number.
 
We use this information to respond to your query, including providing you with any requested information about our products and services.

When you access and use our Site

When you access and use our Site, we may automatically collect and retain certain types of data, including your computer or device’s internet protocol (IP) address, browser type and version, time zone setting, and operating system and platform.
 
We also use cookies on our Sites ; for more information on how we use cookies, please see the section 3 below. 

When you give a recommendation to a talent

When you give a recommendation to a talent, you may be asked to provide your personal data which may include : 
● Your name
● Your function
● Your company name
● Your e-mail
● The nature of the relationhsip you hold with the talent 
 
Providing your data will always be voluntary. You are under no obligation to provide such data although you understand that your refusal to do so may prevent you from using certain of the Site’s features and services.
 
Your information is stored on our website and on our cloud server, both of which are based within the European Union. We keep your information as long as you do not request us to delete your personal information.

3. Why we use cookies and other tracking technologies ?

We use cookies to allow the website to function, to collect useful information about visitors and to help making your user experience better.
 
To manage the cookies that are placed on your computer, you may configure your internet browser to refuse, accept, or delete cookies from our Site at any time.
 
We may also use service providers, such as Google Analytics, that may use cookies or other technologies to collect data about your online activities across this and other sites over time for non-advertising purposes such as those described above. Refer to the following link to learn more about how Google Analytics collects and processes data http://www.google.com/intl/en/policies/privacy/partners/.

4. How we use your data ?

General Uses

We use the data we collect to manage, analyze and improve our Site as well as our products and services.

When you register as a talent 

We may use this data to authorize and administer your access to the Site, verify your identity, authenticate your visits, and provide our products and services to you. We may also use your data to improve and personalize your experience with us.

When you register as a talent, as part of a qualification process 

The qualification process designates all the actions making it possible to specify the profile of an application, from the creation of a profile on our Site to the sending of the qualification file to the recruiting company.

The purpose is to make the recruitment process efficient and objective, by means of automation and data parsing, which should make it possible to accelerate the first stages of the processing of applications while highlighting the potential of the most relevant applications.

As a candidate, you are informed that we have been mandated by the recruiting company to proceed with the qualification of your profile as part of your application.

We will make our best efforts to ensure the consistency and accuracy of the information collected during the execution of our mission. You agree to assist us for the purposes of our mission and to communicate to us, if necessary, all additional information and data in relation to the mission entrusted to us.

When you contact us

We may use this data to understand and respond to your request.

When you access and use our Site

We use passively collected data to manage and improve the performance of our Sites and to help to make your user experience better.

Aggregate data

We may aggregate our user’s personal data and passively collected data to create aggregate data which cannot be used to identify you. We may use such aggregate data to measure and quantify the effectiveness of our products and services. We also reserve the right to use and/or transfer Aggregate Data about the Site’s users for any lawful purposes.

5. With whom do we share data ?

Jobs offers – when registered as a talent

Upon your approval, we may share your personal data with a potential employer when our Site determines that you might be a good match for this employer. Your approval is always needed to transfer your personal data to a potential employer.

Jobs offers – when registered as a company

We may share your company data with a potential talent when our Site determines that the talent might be a good match for your company.

Qualification services – as a talent

As part of our Qualification services, we are mandated by the company for which you applied to qualify your profile. Thus, once you have completed your qualification process, we will share your personal data with your future potential employer in order to complete our mandate. 
 
Plus, you authorize us to contact by any means the references you have given.
 

We are not responsible for the information and statements communicated by third parties consulted as part of our mission. We cannot be held responsible for the follow-up given by the employer to your application after submitting your application, and in particular if the employer decides not to retain your file.

 
Providing your data will always be voluntary. You are under no obligation to provide such data although you understand that your refusal to do so may alter your candidature.

External providers

We may hire external providers to perform certain business-related functions. Examples include maintaining databases, data storage, cloud services, and hosting services. These external providers are authorized to use your data only as necessary to provide these services to us.

Legal Requirements

We may disclose personal data if required to do so by law or in the good faith belief that such action is necessary to protect and defend our rights or property; act in urgent circumstances to protect the personal safety of users of the Site or the public; protect against legal liability; or as otherwise required or permitted by law.

Other Third Parties

We may disclose your data to other third parties with your prior express consent.

6. Your rights regarding your data

By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate.
If we have asked for your consent to process your personal data, you may withdraw that consent at any time.
 
You have the right to ask us to stop using your information for a period of time if you believe we are not doing so lawfully.
 

In accordance with EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (RGPD) and the Law of August 1, 2018 on the organization of the National Commission for Data Protection and implementation of the GDPR, you have the right to access, rectify or delete information concerning you, which you can exercise through your account settings or by contacting us at privacy@clubtrust.io.

You can also, for legitimate reasons, oppose the processing of data concerning you. In the context of a qualification process as described in section 4, you understand that we will not be able to carry out the mission entrusted by the employer and verify the data concerning you.

Any complaint should be submitted to the CNPD: https://cnpd.public.lu/

7. Others

Blogs and public features of the Sites

Our Site may contain features, e.g. blogs, community forums, sharing functions, etc., that permit you to post or distribute content and data. Any data that you choose to disclose becomes public data over which we are unable to exercise control. You should exercise caution when deciding to disclose such data, and you agree to assume all responsibility for doing so.
Third-party sign-in
You can create an account using sign-in services such as LinkedIn. This service will authenticate your identity and provide you the option to share certain personal data with us in order to pre-populate your account.
 
You can do a personnality test using the service provided by Assessfirst. This service will ask you to create an account and ask you the option to share your reports with our partner Talantlers S.à.r.l. This will allow us to access your personnality assessment reports and send them to you. You are under no obligation to provide such data although you understand that your refusal to do so may prevent you from using certain of the Site’s features and services.
 
Please note that your relationship with LinkedIn, or any other third-party website such as Assessfirst is governed solely by your agreement with such third-party website.
Minor
Visitors under 18 years of age are not permitted to use and/or submit their personal data at the Site.