Last updated and effective as of 25th May 2018.
For Skeeled the protection of your privacy is a primary concern.
Based on Skeeled’s existing contractual relations with the Recruiter, Skeeled is required to process
Data on behalf of the Recruiter depending on the Recruiter’s choices (in particular which information
collected and which questions shall be asked).
Not withstanding their respective obligations under applicable data protection legislation, the
Skeeled agreed that Skeeled may provide you with information on the processing of your Personal Data
the Skeeled Services and comply, if applicable, with your requests to exercise your data subject rights.
Personal Data by Skeeled on behalf of the Recruiter in relation to the provision Skeeled
3. Definitions & interpretation
- a reference to a document is a reference to that document as modified or replaced from time to
- a reference to a person shall include any natural person, company, corporation or any other
- words importing the singular shall be treated as importing the plural and vice-versa;
convenience and in no way defines or explains any section or provision hereof.
4. Controller & Processor
Skeeled processes your Personal Data exclusively for the Recruiter as set forth by the contractual
concluded between Skeeled and the Recruiter.
As a consequence, the Recruiter – acting in its capacity as controller – determines the
the means of the processing of your Personal Data. Skeeled – acting in its
capacity as processor (unless expressly stipulated otherwise) – processes your Personal Data only
behalf of the Recruiter.
5. Data protection
Skeeled has designated a data protection officer with a view to inform and advise Skeeled on how to
your privacy and who can be contacted as follows:
Phone: 00352 20 40 46 65
6. Categories of Personal Data collected and processed
6.1. Categories of Personal Data collected directly from you
For any access or use of the Skeeled Services, Skeeled collects from you on behalf of the Recruiter,
others, the following categories of Personal Data:
- your contact information, such as name, home address, email address, telephone and/or mobile
- identity verification information;
- information on your educational background (e.g. academic titles, diplomas, schools and
attended, skills and merits related) and professional records(e.g. professional experience,
previous job contracts, previous position titles, practice areas, assessments established by
- information on your skills which may be relevant for the Recruiter (e.g. possession of a valid
license or extra skills whose value and usefulness should be emphasised during the recruitment
as your linguistic competences, whether oral or written);
- information on your personal situation (e.g. information on gender, date of birth, nationality,
address, civil status, parenthood, profile pictures);
- other information required by the Client to be submitted by you during the personality test
process such as information contained in your answers to questions chosen by the Recruiter;
- information contained in your self-recorded videos (sound and images);
- browser and device information (e.g. device type, operating system name and version, Internet
- connection (including location) information, such as IP addresses (a number that is assigned to
that you use to access the Internet): Skeeled automatically logs IP addresses in its server log
whenever you access or use Skeeled, along with the time of your visit and the page(s) that you
- information about how you use the Skeeled Services (e.g. date and time your device connects with
servers, what information and files you have uploaded, saved, accessed, rectified, or otherwise
the features you use, your search queries and the amount of data you submit);
- personal messages and comments you submit on a voluntary basis (e.g. reviews on the application
or provided by you when raising questions or introducing complaints;
In addition to the foregoing, you may also be required to provide additional Personal Data when you,
others, require support, send us information for troubleshooting or other analysis, participate in a
other promotional activities, or solicit any other communication from the Skeeled or the
Please also note that Skeeled may in the course of the processing of your Personal Data on behalf of the
Recruiter also be obliged to collect and process additional Personal Data relating to you.
6.2. Categories of Personal Data collected from other sources
In addition to the Personal Data Skeeled collects on behalf of the Recruiter directly from you, the
Skeeled on behalf of the Recruiter may also collect Personal Data relating to you from other
The Categories of Personal Data not directly collected from you may at least include the categories of
Data which may be collected directly from you.
The Categories of Personal Data not directly collected from you stem from the following sources:
- publicly available sources, such as LinkedIn or other sources from the Internet;
- public databases;
- joint marketing partners;
- social media platforms;
- conference hosts;
- social media platforms;
- event companies and other third parties
Cookies are small text files that are placed on your computer by websites that you visit. They are
in order to make websites work, or work more efficiently, as well as to provide information to the
owners of the
Cookies are typically stored on your computer's hard drive. Information collected from cookies is used
Skeeled on behalf of the Recruiter to analyse trends, to administer the Skeeled Services and to evaluate
effectiveness. With this knowledge, Skeeled can provide you with a more personalised experience when
Skeeled Services and Skeeled can improve the quality of such experience by recognising and delivering
the most desired features and information and by resolving access difficulties. Skeeled may on behalf of
emails to help us confirm your receipt of, and response to, its emails.
The service providers of Skeeled may also place cookies on the hard drive of your device with a view
to receive information that will educate Skeeled and the Skeeled service providers on different aspects,
how you navigate on the Skeeled Services. Skeeled’s service providers may analyse this data with a view
us to better understand your interests in the Skeeled Services and to better serve those
other data, including Personal Data, relating to you that Skeeled processes on behalf the Recruiter.
You can choose to deactivate cookies, however in such circumstances you will not be able to use parts of
Skeeled Services which require cookies to be active.
6.4. Possible consequences of a refusal to provide Personal Data via
Please note that Skeeled may not be able to provide the Recruiter with all information required by the
during the application process, if you do not provide all Personal Data requested during the application
The refusal to provide the information requested by the Recruiter via Skeeled during the application
process, may thus prevent you from using Skeeled Services and may thus negatively influence the outcome
Application and may even lead to its refusal.
7. The purposes of the processing
Skeeled processes your Personal Data on behalf of the Recruiter for various purposes, namely:
- to complete, fulfil and process your Application, including any subsequent stages of the
- to communicate with you and to provide you with any service related to your Application;
- to fulfil identity verifications;
- to respond to your inquiries and support needs and to fulfil or comply with any other request
- to provide you with the Skeeled Services, including any updates;
- to allow you to manage your Application;
- to send you administrative information, such as information concerning changes to the Policies
other legally binding document governing your use of the Skeeled Services announcements or any
relating to any internship or any job position advertised by the Recruiter or other
the Skeeled Services;
- if necessary or appropriate:
- to meet or comply with any applicable rules, laws, regulations, codes of practice or
by any legal or regulatory bodies which are applicable to the Skeeled Services
(including but not
limited to responding to regulatory complaints, disclosing to regulatory bodies and
checks, due diligence and investigations);
- to respond to requests from public and government authorities, including public and
authorities outside your country of residence;
- to enforce the Policies;
- to protect the Recruiter and Skeeled as well as their operations or those of their
- to protect the rights, privacy, safety and property of the Recruiter and Skeeled as well
service providers, you, or others;
- to allow the Recruiter and Skeeled to pursue available remedies or limit the damages
that the the
Recruiter and Skeeled or its service providers may sustain;
- to test, assess, or otherwise evaluate the effectiveness of the technical and organisational
(e.g. ensuring the security of the processing of your Personal Data) put into place by the
Skeeled or by Skeeled’s processors, or to give effect to such measures;
- to ensure that the Skeeled Services are functioning properly;
- to personalise your experience by presenting content tailored to your interests;
- to allow you to participate in usability studies, surveys and product tests;
- for the Recruiter’s or Skeeled’s business purposes, such as performing data analysis and audits,
or developing new features or services relating to the Skeeled Services;
- to track user movement;
- for statistical or scientific research purposes;
- to develop new features to the Skeeled Services or other products;
- to prevent any unauthorized or fraudulent use of the Skeeled Services;
- to prevent, detect and investigate crime and analyse and manage commercial risks and conducting
investigations relating to disputes, billing or fraud;
- to investigate or report actual or potential violations of the Policies or any other suspected
- to respond to a verified request relating to a criminal investigation (e.g. subpoena, court
substantially similar legal procedure) or alleged illegal activity or any other activity that
may expose the
Recruiter, Skeeled, any of their service providers, or you to any legal proceeding or legal
- to prevent physical harm or financial loss or any other risk for the Recruiter, Skeeled, any of
service providers, you or any other individual intervening in the provision of the Skeeled
- to prevent any data breach or circumvention of the security measures or to mitigate their
- for troubleshooting purposes;
- in connection with any claims, actions or proceedings (including but not limited to drafting and
documents, transaction documentation, obtaining legal advice, and facilitating dispute
protecting and enforcing contractual and legal rights and obligations of the Recruiter or
- to conduct any other activities that are required to provide the Skeeled Services or other
offered by the Recruiter or Skeeled;
8. Legal bases allowing for the processing of your Personal Data
8.1. The collection and processing of your Personal Data in relation to Skeeled Services is lawful as
prior to any collection or any processing of your Personal Data, given your explicit consent to the
8.2. The collection and processing of your Personal Data in relation to Skeeled Services is also lawful
as it is
necessary in order to take steps, at your request, prior to entering into a contract with the Recruiter.
8.3. The processing of your Personal Data in relation to Skeeled Services is also lawful as it is
the purposes of the legitimate interests pursued by the Recruiter and by Skeeled.
Skeeled’s commercial activity consists in providing its clients (i.e. the Recruiter) by means of a
the possibility to determine which candidates are suited for a job or traineeship position. The
your Personal Data constitutes thus a necessary ancillary to Skeeled’s activities allowing Skeeled to
commercialise its product and services.
The legitimate interest of the Recruiter consists in making to make a well-informed decision on which
hire for a certain traineeship or job position.
The legitimate interests of, both, the Recruiter as well as Skeeled are not overridden by your interests
fundamental rights and freedoms. Rather, the processing of your Personal Data also allows to best serve
interest, namely to present you and your job or traineeship application in the best possible manner to
9. Conditions applying to your consent
Please note that you have at any time the right to withdraw your consent. The withdrawal of your consent
however not affect the lawfulness of processing based on your consent before its withdrawal.
In the event a Recruiter would allow for Applications to be made by persons below the age of 16 years,
processing of your Personal Data will in accordance with applicable data protection legislation only be
on the basis of your consent if and to the extent that such consent to the processing is also given or
authorised by a holder of parental responsibility over you.
If you are younger than 16 years, Skeeled will thus inform the Recruiter of your age in order to allow
verification that a holder of parental responsibility over you is also consenting or giving his or her
10. Your data protection rights
To exercise your data protection rights outlined in this section, you can (i) either contact Skeeled by
an email to firstname.lastname@example.org or (ii) contact the Recruiter directly.
Please make clear in your request what Personal Data you would like to access or would like to rectify,
its processing or erase.
Please be aware that your data protection rights are not absolute and it remains that, in accordance
applicable data protection laws, your rights may be withheld. In such event, you will, however, be
the reasons for not complying with your request.
Your request will be processed as soon as reasonably practicable and will provide you with information
action(s) taken without undue delay and in any event within one month of receipt of the request. This
be extended by two further months where necessary, taking into account the complexity and number of your
request(s). In this event you will be informed of any such extension within one month of the receipt of
request, together with the reasons for the delay.
In the event, it has been decided not to comply with your request or if your request has not been
within the aforesaid timeframe, you can lodge a complaint with the national supervisory authority (see
and you can seek a judicial remedy against such decision.
10.2. Your right to access, rectification, restriction of processing and erasure
your Personal Data & your right to data portability
You have, if applicable and within the limits of applicable data protection laws, the ability to
right to access to your Personal Data processed by Skeeled on behalf of the Recruiter and to seek the
rectification or erasure of your Personal Data or to request the restriction of its processing.
You have, within the limits of applicable data protection laws, the right (i) to receive the Personal
have submitted to Skeeled on behalf of the Recruiter in a structured, commonly used and machine-readable
and (ii) to transmit those Personal Data to another controller. Skeeled will on behalf of the Recruiter,
applicable and technically feasible, transmit your Personal Data directly to another data controller of
10.3. Automated individual decision-making
Please note that the processing of your Personal Data by Skeeled on behalf of the Recruiter implies that
subject to a decision which is based on automated processing of your Personal Data.
The software commercialised by Skeeled and relied upon by the Recruiter allows on the bases of the
established by the Recruiter and by the processing of your Personal Data in particular to establish an
employability profile of you, to allow the Recruiter to better evaluate your Application; and to allow
(on behalf of the Recruiter) to determine which candidates are suited for a job or traineeship position.
These automated decision-making processes include however the risk that your Application is refused
As the Recruiter and Skeeled are aware of those risks for your rights and freedoms, Skeeled ensures on
the Recruiter that suitable measures to safeguard your legitimate interests are put into place. In the
your Application has not been satisfied exclusively due to an automated decision making, you will thus
possibility to express your point of view in a written form by sending an email to
10.4. Your right to object
If applicable in accordance with applicable data protection legislation, you have the right to
grounds relating to your particular situation, at any time to the processing of your Personal Data
on behalf of the Recruiter, unless:
- there exist compelling legitimate grounds for such processing which override your interests,
- the processing is necessary for the establishment, exercise or defence of legal claims.
Notwithstanding the foregoing, please be aware that you have the right to object at any time to
your Personal Data for direct marketing purposes. In this event, you may opt-out of such processing
an email to email@example.com. Where your Personal Data is processed for scientific or
purposes or statistical purposes, you shall on grounds relating to your particular situation have
the right to
object to processing of your Personal Data, unless the processing is necessary for the performance
of a task
carried out for reasons of public interest.
11. International transfers of Personal Data
As a matter of principle, your Personal Data should be stored and processed in the European
This objective to process your Personal Data exclusively in the European Union shall, however, be
prejudice to the Recruiter’s right to transfer your Personal Data via Skeeled to a third country in
with the applicable legislation.
Your Personal Data is processed within the European Union or, subject to the condition that either an
level of protection is ensured or that appropriate safeguards are put into place, in any third country.
shall apply without prejudice to possible derogations that may apply in accordance with applicable data
protection legislation (e.g. when you consent to the transfer of your Personal Data).
12. Disclosure of Personal Data
The Recruiter as well as Skeeled (on behalf of the Recruiter) may disclose your Personal Data to others
accordance with applicable laws and regulations, in particular with a view to accomplish the purposes
12.1. General principles of disclosure
As a matter of principle, the Recruiter as well as Skeeled (on behalf of the Recruiter) do not sell,
exchange, share or otherwise disclose (hereinafter “share”
) your Personal
third parties for their marketing purposes. This shall, however, not prejudice the Recruiter’s as well
Skeeled’s (on behalf of the Recruiter) right to disclose your Personal Data to others (including public
authorities, law enforcement agencies, data protection authorities or regulatory agencies, government
- it is necessary for the conclusion or the performance of a contract or for the provision of the
- it is required by law or by virtue of public interest;
- it is required by virtue of your vital interest;
- it is necessary to pursue the the Recruiter and Skeeled’s legitimate purposes;
- you have given your consent (e.g. when exercising your right to data portability);
- so allowed to by another legal bases.
12.2. Recourse to service providers
Recruiter as well as Skeeled (on behalf of the Recruiter) may disclose your Personal Data to its service
providers (including namely processors), in particular to fulfil the purposes set forth in the present
Recruiter’s as well as Skeeled’s (on behalf of the Recruiter) service providers, which are contractually
to the Recruiter and Skeeled, shall be allowed to process your Personal Data on the Recruiter and
12.3 Categories of recipients of your Personal Data
Your Personal Data are currently disclosed to the following categories of recipients:
- Recruiters and Recruiters’ processors;
- Law enforcement agencies, regulatory agencies and data protection authorities;
- Skeeled’s sub-processors (i.e. service provider to which Skeeled Services);
13. Security of Personal Data
Please be aware that today no processing, transmission or storage of data, including Personal Data –
high security environments and notwithstanding any appropriate security measure – ensures an absolute
and can for example be subject to hacks and/or attacks.
If you have reason to believe that your Personal Data is no longer secure, you shall immediately notify
risk by contacting firstname.lastname@example.org.
14. External Websites
Occasionally, the Skeeled Services may provide references or links to, or facilitate access to other
online services (hereinafter "External Websites").
Skeeled does not control these External Websites or any of their content. Skeeled shall in no way be
or liable for External Websites to which Skeeled makes reference or provides a link thereto, whether
indirectly. Skeeled shall in particular be in no way responsible or liable for External Websites'
information displayed thereon, policies, privacy standards, promotions, products, any practice, services
actions and/or any damage, loss, failure or problem caused by, related to, or arising from those
Please be aware that the inclusion of a link or any other reference within the Skeeled Services does not
endorsement of an External Website by Skeeled and it remains that such External Websites have separate
independent privacy policies. Skeeled consequently encourages you to review the policies, rules, terms,
practices and regulations of each site that you visit.
15. Storage of your Personal Data
Without prejudice to the right to further process your Personal Data for purposes that are not
the initial purpose, and subject to incumbent legal and regulatory obligations on the Recruiter and
Recruiter and Skeeled shall store your Personal Data in a form which permits identification for no
is necessary for the purposes described in the Policies.
Skeeled – acting in its capacity as processor – has been instructed by the Recruiter to store your
for the time periods listed below:
- in the event that you notified Skeeled the intention to terminate the use of the Skeeled
At latest one (1) month after you have notified your intention to no longer use the Skeeled
- in the event your Application has been accepted by the Recruiter: Your Personal Data are
for the performance of the employment or internship contract to which you and the Recruiter are
well as to take the relevant steps allowing you and the Recruiter to enter into such contract.
event, your Personal Data will need to be stored by the Recruiter (and if so decided by such
by Skeeled) in accordance with applicable legislation and in particular in accordance with
- unless points (a) or (b) apply: Unless expressly otherwise consented by you, Skeeled
provide the Recruiter with access, in whatsoever manner, to the Personal Data submitted by you
twelve months after its collection and Skeeled shall erase or anonymise such Personal Data in a
Unless you have exercised your right to object, Skeeled (on behalf of the Recruiter) will
you prior to the expiration of each twelve-month period in order to give you the possibility to
the processing for an additional twelvemonth period.
The Recruiter (and thus Skeeled) reserves the right to revise, change, modify, update, supplement, add
Your continued use of Skeeled subsequent to the notification of such changes, or the absence of any
17. Merger/Corporate Acquisition
If the Recruiter or Skeeled merge with another company or entity, of whatsoever form, or are partially
entirely acquired by such company or entity, the acquiring company or entity shall be entitled to
process all of
your Personal Data in the Recruiter or in Skeeled’s possession.
18. Questions or complaints
processing activities carried out by the Skeeled on behalf of the Recruiter in relation to the Skeeled
you can contact Skeeled’s data protection officer or write directly to Skeeled.
If you do not feel satisfied with our response, you can always contact the Commission Nationale pour la
des Données (the data protection authority in Luxembourg) having its seat at 1, avenue du Rock’n’Roll,