1. Introduction

1.1. This privacy statement (hereinafter the “Statement”) applies to all Personal Data (as defined below) that we process of our agents, customers, prospective customers, partners, suppliers, (website) visitors, job applicants and participants of (online) events.

1.2. We consider it important that your Personal Data is handled with care. This Statement sets out which principles HSO applies to the collection, use, processing, storage, disclosure and transfer of your Personal Data and which rights you have in relation hereto.

2. Purpose, Categories of Personal Data & Legal Basis

2.1. We only process your Personal Data for specified, explicit and legitimate purposes, and, in any event, subject to applicable local laws and regulations and based on one or more of the following legal bases:

• Consent;
• Conclusion or performance of a contract;
• Legal obligation; or
• Legitimate interest.

2.2. Depending on the purpose, we collect and process a variety of Personal Data, which could include your name, postal address, email address, phone number, date of birth, gender, company name, business title, qualifications, experience, information relating to your employment history, skills experience that you provide to us, as well as your video in case you conduct your interview using a video interview feature.

2.3. If you provide us with Personal Data via our website, please also see our Cookie Policy.

2.4. To the extent that the Personal Data is necessary for the conclusion or performance of your contract with us or to comply with our legal obligations, you are obliged to provide the relevant Personal Data. Failure or refusal to provide your Personal Data to us may result in our inability to inform you or manage your (contractual) relationship with us.

3. Sharing Your Personal Data

3.1. We may engage HSO Subsidiaries, third-party service providers or partners for the purposes as described herein.

3.2. We will only share your Personal Data with personnel of HSO Subsidiaries, third-party service providers or partners who (i) are authorized to receive and process your Personal Data, (ii) have a legitimate need to have access to your Personal Data to perform their responsibilities, (iii) have implemented appropriate technical and organizational measures to ensure the security and confidentiality of your Personal Data, (iv) process your Personal Data as instructed by us only as necessary to perform their responsibilities, and (v) more generally, meet all requirements under applicable local laws and regulations.

4. Transfers of EU Personal Data to Third Countries

4.1. In relation to Personal Data of residents of the European Union, such Personal Data may be accessed by HSO Subsidiaries, third-party service providers or partners located outside of the European Economic Area ("EEA") in countries not offering a level of protection of Personal Data equivalent to that offered within the EEA, in which case we will ensure, in addition to the measures described above, that the transfer of your Personal Data will be made pursuant to contractual measures based on the European Commission model clauses (controller to controller or controller to processor) to establish and confirm that they will provide an adequate level of protection of your Personal Data, pursuant to Article 46 of the GDPR.

5. Security

5.1. We’ve implemented appropriate technical and organizational measures to protect your Personal Data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access and against all other forms of unlawful processing. Also, we require our data processors to implement such appropriate technical and organizational measures.

6. Retention Period

6.1. Your Personal Data will be stored no longer than is necessary for the purposes for which the Personal Data is collected, unless otherwise required by law. With respect to your Personal Data gathered by us in relation to a contract between you and us, we will keep your Personal Data at least until termination of the relevant contract.

7. Your Rights

7.1. You may contact us by using the contact details as set out below, if you wish:

• to know whether or not we process your Personal Data;
• to rectify your data;
• to erase your data;
• to restrict your data;
• us to transmit your data to another organization;
• to object us relying on a legitimate interest to process Personal Data; and/or
• to withdraw your consent.

7.2. We will review your request in accordance with applicable laws and regulations.

7.3. We may request provision of additional information necessary to confirm your identity. If required, we will inform you of our follow up actions without undue delay.

7.4. You have the right to lodge a complaint with the supervisory authority if we do not respond in time or for any other reason.

8. Contact Us

8.1. If you have any questions, comments or complaints regarding this Statement or the processing or your Personal Data, please contact us via legal@hso.com.

9. Applicability

9.1. This Statement applies to any and all third parties providing Personal Data to HSO.

9.2. In case of any conflict between this Statement and your contract with us, your contract will take precedence.

10. Miscellaneous

10.1. Changes. We reserve the right to change or cancel any term of this Statement at any time, at our sole discretion. We will ensure that the most recent version of this Statement will remain available to you both upon your request and via our website, HSO.com.

10.2. Severability. If any term or provision of this Statement is held to be invalid or unenforceable, the validity or enforceability of the remainder of this Statement will not be affected and we will strive to provide a provision that will replace the invalid and/or unenforceable provision with a provision that comes as close as possible to our initial intent.

11. Definitions and Interpretation

11.1. “HSO” (also referred to as either “we”, “us” or “our” in this Privacy Statement) means, as the context may require, either one individual HSO Subsidiary or HSO Group B.V., a combination hereof, or all HSO Subsidiaries and HSO Group B.V. collectively.

11.2. “HSO Group B.V.” is a company incorporated under the laws of the Netherlands with its registered seat in Utrecht and maintaining a place of business at Newtonstraat 27, 3902 HP Veenendaal, the Netherlands, which is the ultimate parent company of the HSO group of companies.

11.3. “HSO Subsidiary” means any person, corporation, partnership, joint venture or other form of entity that directly or indirectly, through one or more intermediaries, is controlled by HSO Group B.V.. The term “control” means the possession, directly or indirectly, of the power to direct or cause the direction of the management and policies, whether through the ownership of voting securities, by contract or otherwise.

11.4. “Personal Data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

11.5. “Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

11.6. “You” or “your” refers to any and all third parties providing Personal Data to HSO, including our agents, customers, prospective customers, partners, suppliers, (website) visitors, job applicants and participants of (online) events.

Version History

Current version: 1.0 (23 December 2022)