Welcome to the HReset’s privacy policy.
HReset respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Purpose of this privacy policy
This privacy policy aims to give you information on how HReset collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or purchase a service or apply for the position.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy notices. This privacy policy supplements other notices and is not intended to override them.
Controller
HReset is the controller and responsible for your personal data (collectively referred to as HReset, “we”, “us” or “our” in this privacy policy).
HReset Group helps end-clients worldwide from large multinationals and consulting firms, to government and SME’s safely address those new business needs that are mission-critical in areas of Talent Acquisition, Professional Employer Organization (PEO) or Employer of Record (EoR) solutions and Global Mobility.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, please contact the DPO using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:
Full name of legal entity: Nova Status B.V. / HReset
Email address: privacy@hreset.nl
Postal address: Barbara Strozzilaan 201, 1083 HN Amsterdam, The Netherlands
You have the right to make a complaint at any time, you can in the first instance complain to the relevant national regulator. We would, however, appreciate the chance to deal with your concerns before you approach the national regulator, so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We review our privacy policy on regular basis. We reserve the right to modify this policy relating to the website or services at any time, effective upon posting of an updated version of this policy on the website. You can find the date of our last update at the top of the document.
HReset encourages you to periodically review this policy to be informed of how HReset is protecting your information.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
1. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Special Categories of personal data includes sensitive data;
biometric data in the form of face photo or scan for our identity verification and health data – e.g. disability, sickness absence, pregnancy confirmation, information about criminal convictions and offences etc.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
2. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a survey; or give us feedback or contact us;
- discuss employment relationship.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Perform the contract we are about to enter into or have entered into with you. This means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Legitimate interests of HReset (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Comply with a legal obligation. This means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
- Consent. When we rely on this basis we only process Personal Data about you for the specific purposes you expressly authorise. You can withdraw your consent whenever you wish.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
To register you as a new customer | (a) Identity (b) Contact | Performance of a contract with you |
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us | (a) Identity (b) Contact (c) Financial (d) Transaction (e)Marketing & Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile (d)Marketing & Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
To enable you to complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e)Marketing & Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e)Marketing & Communications (f) Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing & Communications | Necessary for our legitimate interests (to develop our products/services and grow our business) |
To verify identity of employee candidate; to administer, perform and terminate the employment agreement | (a) Identity (b) Contact (c) Financial (d) Technical (e) Profile (f)Special Categories | Performance of a contract (Art. 6(1)(b), (c) and Art. 9(2)(g) of GDPR). |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.
Cookies
HReset website uses cookies to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you.
One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you personalize HReset pages or register with HReset website or services, a cookie helps HReset to recall your specific information on subsequent visits. This simplifies the process of recording your personal information such as billing addresses, shipping addresses, and so on. When you return to the same HReset website the information you previously provided can be retrieved so you can easily use the HReset features that you customized.
You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies you may not be able to fully experience the interactive features of the HReset services or websites you visit.
4. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
Internal Third Parties
- Other companies in the HReset Group acting as joint controllers or processors and provide IT and system administration services.
External Third Parties
- Service providers acting as processors who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, notaries, bankers, auditors and insurers based, HR and payroll providers, immigration partners and identity verification service providers and others who provide services needed for the performance of our contracts or are required for purposes of our legitimate interests.
- Local labour and tax authorities, regulators and other authorities or agencies or courts of law acting as processors or controllers who require reporting of processing activities in certain circumstances.
- Clients acting as joint controllers whom personnel files, such as employment and contractor agreements and payslips may be disclosed upon request. Our contracts with clients require them comply with applicable data protection law when processing any personal data they receive from us. Such disclosure is required for the purposes of our client’s legitimate interests (that are connected with contractual obligations of our clients to have copies of personnel files.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
5. International transfers
We make use of services offered by providers that may be located in “third countries”, countries that do not have a level of data protection comparable to that in the European Union. Where this is the case and where the European Commission has not adopted an adequacy decision (Article 45 of the GDPR), we have taken precautions to ensure an adequate level of data protection for any transfers of data. These include the European Union’s standard contractual clauses. For transfers out of other jurisdictions operating transfer restriction regimes, we take additional steps to ensure compliance with local law.
6. Data security
We are compliant with the EU’s General Data Protection Regulation. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period. The relevant retention periods depend on the national legislation of the country you are based in.
If the personal data is no longer required for the performance or enforcement of contractual or legal obligations, we will delete it regularly, unless its further temporary storage is still necessary to fulfil our obligations pursuant to the contract; fulfil our obligations pursuant to the employment agreement; or establish, exercise, and defend a legal claim; or fulfil statutory obligations to which HReset is subject, such as continued storage pursuant to accounting legislation.
8. Your legal rights
In order to assert your rights described here, you may contact us at any times using the contact details given above.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We aim to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.