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Privacy Policy
1. General - scope

LAUNCH respects and protects your privacy.

This privacy policy aims to transparently inform you about all the precautions taken by LAUNCH.CAREER BV, with its registered office in Antwerp at Vloeyenbergdreef 7, 2970 Schilde, registered in the CBE with company number BE 0752.653.682, when processing personal data that you entrust to us or that are collected when you use our digital platform (website and apps).

LAUNCH's privacy policy aims to comply with the European General Data Protection Regulation 2016/679 of April 27th 2016 and the corresponding Belgian law of July 30th 2018 regarding the protection of natural persons with respect to the processing of personal data, as well as with all other relevant legislation.
You can therefore visit and use the digital environment of LAUNCH without privacy concerns. To fully comprehend our privacy policy, you should read and understand it together with our terms of use.

This policy is dedicated to LAUNCH's mission, i.e. to introduce students and young
graduates to the business world and the labor market for free, quickly and efficiently and conversely, to allow companies to find and recruit suitable talents easily and cost-effectively. Through their profile, students and young graduates are directly provided with suitable internship and job opportunities, while companies distribute their company information and vacancies digitally, immediately to the right target group.

Using the platform and services offered by LAUNCH means that you thereby accept our privacy policy. When creating an account, you will explicitly confirm this acceptance (including our terms of use).

1. LAUNCH can develop and/or complete this policy at any time, e.g. as a result of changes to services or legislation.

This will of course be done by posting these changes on the LAUNCH platform, stating the date of the latest version.
So make sure to read this policy carefully and remember that with every (renewed) use of the platform, you acknowledge that you have read, understood and approved this (possibly renewed) policy. If you do not agree with the (amended) privacy policy of LAUNCH, you should not create an account or close your existing account and no longer use the services of LAUNCH.

2. Note about underage persons.

If you are under 18 years old, you are not permitted to use our platform and we ask you not to share your personal data with us.

3. What does “processing of personal data" mean.

Processing of personal data means any processing of data that can identify you as a natural person. Regarding a legal person, it concerns the personal data of the natural person acting on behalf of the legal person (e.g. an individual recruiter for the company). Processing is a very broad concept and includes among others collecting, recording, organizing, storing, updating, changing, requesting, consulting, using, distributing, making available, bringing together, combining, deleting or ultimately destroying the personal data.

4 Basis for processing personal data.

LAUNCH respects the policy of minimum data processing of the GDPR when operating its platform and providing its services, and your personal data will only be collected when there is sufficient legal ground. LAUNCH ensures that the personal data it processes are adequate, relevant and necessary for its intended and legitimate purpose.

4.1 Consent.

LAUNCH collects your personal data if you give your consent in whole or in part. This consent may be given explicitly, but may also be implied from your behavior or actions on the platform, e.g. by filling in forms or clicking buttons. With this action you agree that LAUNCH uses the provided data to ensure that our services function properly.

4.2 Necessity.

Furthermore, LAUNCH processes personal data because it is necessary in the framework of another legal ground:
- for the proper execution of the use of LAUNCH and the general terms and conditions that apply;
- to comply with an obligation that LAUNCH must fulfil, e.g. regarding administrative or tax legislation or as part of legal proceedings;
- for the realisation of a legitimate interest of LAUNCH, whereby always a thorough balance will be sought between your own interests and those of LAUNCH.

5. What personal data are processed by LAUNCH?

5.1 Information provided by the user .

By using LAUNCH, visitors, members or recruiters / companies can provide personal data and LAUNCH can collect/process this information. You can provide this information when registering or logging on, when you fill in a form, perform a search query, update or add information or respond to surveys and other LAUNCH functionalities.

This may include:
- account information: when registering / logging on, certain information is entered, such as name, place of residence, email address, job title (recruiter)... .;
- profile information such as your education, skills, interests, work experience and profile picture... .;
- preferences regarding your study and career development, including internships, jobs and employers;
- contact information: if you provide LAUNCH with information about your contacts, LAUNCH can use these contacts as part of its services and marketing activities.

5.2 Information that is automatically processed

When you use the platform or services provided by LAUNCH as a visitor, member or recruiter/company, LAUNCH automatically collects information, including:
-usage information: information about your interactions with LAUNCH, such as the pages or content you view, your language preference, your search queries for events, internships or jobs, and other actions you take, such as clicking links from third-party applications;
- log data and device information: IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data and the pages you viewed or interacted with before or after using LAUNCH;
- location data: information about your location as determined by data such as your IP address.
- cookies: LAUNCH may use cookies and other similar technologies, such as web beacons, pixels and mobile IDs. Only essential cookies are activated without your explicit consent. These are cookies where the usage is based on LAUNCH's legitimate interest, i.e. for essential functions (logging on, saving consent or refusing of other cookies...) or for anonymous statistics. Other categories of cookies or similar technologies always require your explicit consent.

5.3 Information Obtained From Other Sources.

LAUNCH may obtain information including personal data from third parties and sources, such as from partners and advertisers. The latter are themselves responsible for having a legal ground for the processing and transferring of personal data and for compliance with 3 privacy regulations. If LAUNCH links this data to self-collected/processed data, this combined information will be treated in accordance with the present privacy policy.

5.4 Information that LAUNCH does not process.

As the law stipulates, LAUNCH does not process any sensitive information, such as data about your ethnic origin, political opinions, sexual preferences and health.

6. How LAUNCH processes personal data.

LAUNCH processes the information it collects, including your personal data, of course to organize its platform and its services as efficiently as possible as part of its mission. LAUNCH ensures that the personal data it processes are adequate, relevant and necessary for the intended purpose.

This means among others that LAUNCH processes the information :

6.1 For optimal functioning and improving of the platform.

The collected personal data and other information is processed:
- to allow you to efficiently access and use all platform's features, e.g. when choosing preferences and receiving suitable offers regarding events, internships and job offers;
- to enable communication between members and recruiters /companies based on the mission of LAUNCH;
- to protect, personalise and optimise the individual use of the LAUNCH platform based on your profile information, preferences, search history and actions;
- to effectively expand the LAUNCH membership and the file of recruiters/companies if you provide us information from contacts.

6.2 To perform analyses and to search for matches.

The collected personal data and other information is processed:
- for analyzes of among others user navigation, to measure, evaluate and optimise the operation of the LAUNCH platform;
- for analysis to find relevant matches between members and recruiters/companies based on profile information, preferences, search history, actions etc.
- to prepare information reports and statistics for recruiters/companies;
- for studies, e.g. analysis of social, economic and/or labor market trends, based on
LAUNCH's mission; data reported externally are anonymised and cannot therefore be traced back to a specific individual.

6.3 To provide customer service.

The personal data and other information collected is processed:
- to help visitors, members and recruiters/companies make the best use of LAUNCH and to solve possible problems;
- to send messages such as account and security notifications, service or support messages, updates and reminders, where you can set communication preferences without possibility to opt out of certain service messages such as security notices and legal notices.

7. With whom does LAUNCH share the processed data.

7.1 Members and recruiters/companies.

To fulfil the mission of LAUNCH, information, including processed personal data, is
exchanged between members on the one hand and recruiters / companies on the other hand. The data is used e.g. for analysis based on profile information, preferences, search history, actions etc., to realize matches between members and recruiters/companies. The exchange of data will partially depend on how complete youe profile information is and your specific use of LAUNCH (e.g. activating offers such as events, internships or jobs).

7.2 Necessity.

LAUNCH may disclose / share your information, including personal data, to comply with another legal basis:
- for the proper execution of the use of LAUNCH and the general terms and conditions that apply, e.g. to protect against fraudulent or unlawful use;
- for compliance with an obligation which LAUNCH must fulfil, e.g. regarding administrative or tax legislation;
- as part of legal proceedings, e.g. to help fulfil a liability claim, to protect property or other legal rights of LAUNCH, to enforce our contracts or to protect the rights, property or safety of others, or by order of a judicial authority;
- to realise a legitimate interest of LAUNCH, whereby a thorough balance will be sought between your own interests and those of LAUNCH.

7.3 Anonymized information.

LAUNCH may share aggregated information, i.e. information of users that is combined or analysed so that it no longer identifies or refers to an individual user, with third parties. This is also applicable for other anonymised information, e.g. for regulatory compliance, market analysis, demographic profiling, marketing and other business purposes, such as creating information reports and statistics for recruiters/companies.

7.4 Business transfers.

In the event of a merger, acquisition, sale, bankruptcy or insolvency of LAUNCH, it is possible that its assets including personal data are to be transferred, either in whole or in part. Should this occur, LAUNCH will of course notify you before your personal information is transferred and subject to a different privacy policy.

8. How your data is protected.

Launch.career BV follows generally accepted company standards to secure the personal data provided to LAUNCH, both during transfer and upon receipt.
LAUNCH takes appropriate organizational and technical measures / safeguards to protect personal data against accidental or unlawful destruction, accidental loss, unauthorised edits, unauthorised disclosure or access, misuse and against any other unlawful form of processing of personal data. LAUNCH employees are trained to handle confidential data appropriately.

Technical security may include firewalls, anti-virus software, intrusion and anomaly detection, password protection, access and authentication controls, as well as SSL technology to encrypt data while it is being transmitted over the public internet, and security features of application layers to further anonymize personal data.
However, no method of transmission over the Internet or means of electronic storage and processing is completely secure. LAUNCH cannot completely guarantee the security of any information you transmit to us or store on the platform. You do this at your own risk, without possibility of LAUNCH being held liable for any damages incurred. Nor can LAUNCH fully guarantee that such information will not be used, disclosed, altered or destroyed when our
organisational or technical security measures are violated, without LAUNCH being liable for any damages.

If you believe your personal information has been compromised, please contact LAUNCH immediately. For its part, LAUNCH will notify you and the appropriate authorities as soon as possible if a breach of the security system is detected; in compliance with the applicable law.

Certain operations of processing personal data collected on the LAUNCH platform fall under the responsibility of other companies. This happens as part of legal obligations or because the processing of personal data requires the expertise of other companies. LAUNCH carefully selects these processors and concludes the necessary agreements to maximally guarantee confidentiality and security of your personal data, in accordance with the European regulations.

Insofar as personal data are processed outside the European Union, LAUNCH uses
contractual or other measures to ensure that these data receive a similar protection status.

9. Your choices and rights regarding the processing of personal data.

9.1 Self-management of personal data.

You can manage your personal information yourself by opening your account and by updating or deleting your personal data, or changing the permitted use of it via the “My Profile" and/or “Personal Settings" section on the LAUNCH platform.
If you have chosen to link your LAUNCH account to a third party application such as
Facebook or Google, you can change your settings and remove permission through the settings for “social login integration" in your “personal settings" of the LAUNCH platform. You are of course solely responsible for keeping your personal information up-to-date. You have always the right to ask LAUNCH to remove or correct inaccurate or incomplete personal information that you cannot update in your LAUNCH account. You can always request access or even request a copy of your personal information that is stored by LAUNCH, in which case LAUNCH will respond to your request as soon as possible.

9.2 Withdrawal and restriction of processing.

If you have expressly or implicitly given your consent in whole or in part to the processing of your personal data by LAUNCH, you can withdraw this consent in whole or in part at any time by changing your account settings or by requesting LAUNCH to do this for you. This withdrawal or limitation of consent does not affect the legality of processing activities based on a (broader) consent before you withdrew or limited it.

9.3 Data retention and deletion.

LAUNCH usually stores your personal data for as long as necessary to achieve the purpose for which the information is collected. The retention period can therefore differ per purpose and can sometimes be very short. The period may be longer, e.g. because LAUNCH must comply with relevant legal obligations, e.g. with regard to administrative or tax legislation. Upon expiry of the applicable retention periods, personal data will be deleted or anonymised. If you no longer want LAUNCH to use your personal data to provide its platform and services, you can delete your account or request LAUNCH to delete and close your account. LAUNCH will then delete or anonymise all your data, in compliance with the legal regulations. Information you have shared with others (such as job applications and messages) may still be visible to other users.

As part of the LAUNCH platform's protection measures against accidental and unlawful loss and destruction, or to help fulfil legal obligations, personal data may sometimes continue to be stored on backup systems for a limited period.

10. Exercising your rights, questions, complaints and feedback.

LAUNCH takes your privacy and your rights very seriously and we thank you for reading this privacy policy carefully.

To exercise your rights, ask questions, file complaints or provide feedback, you can always contact the person responsible for data protection at LAUNCH by:
- sending an email to legal@launch.career;
- posting a signed letter to Launch.career BV, privacy department, Vloeyenbergdreef 7 in 2970 Schilde.


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