Privacy Policy

Effective February 1st, 2020

Our Privacy Policy has been updated.

Definitions

The definitions set out in the Terms of Use (ToU) which are available here apply throughout this Privacy Policy, except where this PP expressly states the contrary or where the contrary clearly appears from the context.

Scope of this Privacy Policy (“PP”)

This PP together with UGO’s Cookies Policy (which can be accessed here) applies to the Services provided to Users through the Platform as defined below.

Questions?

For questions about this Privacy Policy or about related cookies or personal data privacy questions please contact : privacy@ugonetworking.com [or write to the UGO Privacy Officer at Avenue Jef Lambeaux / Jef Lambeauxlaan 3, in 3090 Overijse, (Belgium)]

Definitions

  • “Ambassador” means any User having linked his user account to a Client account and using the Services for its own account in particular for proposing job opportunities from this Client to its network ;
  • “Client” means any professional or business that has subscribed to the Premium Services according our Terms of Use to enable specific features for other Users to use the Services as Recruiters or Ambassadors by linking their accounts ;
  • “Candidate” means any User using the Services for networking or job search or any individual being invited to use the Services, and that has not linked his personal account to a Client account and who has not subscribed to the Premium Services ;
  • “Platform” means the websites “ugonetworking.com”, “ugonetworking.be”, any UGO-branded web and mobiles apps and all other UGO-related sites or apps ;
  • “Premium Services” means the part of the Services reserved for Recruiters and Ambassadors of a Client having purchased a paid subscription according our Terms of Purchase ;
  • “Recruiter” means any User having linked his user account to a Client account and using the Services on behalf and with the authorization of such Client to optimize the recruitment services of this latter ;
  • “Services” means all services provided by UGO to You through the use of the Platform ;
  • “Terms of Use” means the terms of use of UGO (accessible here), including present PP and the cookie Policy (accessible here) and terms of purchase as well as any other document mentioned therein, which are an integral part of it ;
  • “UGO” (or “Us”, “We”, “Our”) means SAJECO SPRL having its headquarters located at 3090 Overijse (Belgium), Avenue Jef Lambeaux/Jef Lambeauxlaan n°3, registered at the Belgian company database under the number 0841.675.730 ;
  • “User” (or “You”, “Your”) or “Member” means any individual or legal entity using the Services ;

 

Your Privacy Matters

UGO is a social job referral platform that is designed to help people and companies connect with each other for their mutual benefits. UGO is a hiring web application combined with a social networking platform. It is designed to help companies increase their employee referrals by making it easy and engaging for employees to refer fitting talents in their social and professional networks, and it is designed to help candidates find their ideal jobs.

Central to this mission is our commitment to be transparent about the data we collect about You, how it is used and with whom it is shared.

This Privacy Policy applies when You use our Services (as described above). We offer our Users choices about the data we collect, use and share as described in this Privacy Policy.

 

  1. Data Controller

UGO will be the controller of Your personal data when it is provided to, or collected for or in connection with, our Services.

 

  1. Personal data

“Personal data” means any data about You from which You can be identified such as Your name, address, telephone number, email address, financial details or other data which You may disclose to us via the Platform at any time.

 

  1. When do We collect Your data?

We collect the data which You submit to us when signing up for services provided on the Platform. We also collect certain personal information automatically when You enter and use the Platform. If You do not agree with this PP and in particular with our explanation of How We use Your data (below) please exit the Platform and do not submit any personal data.

 

  1. Privacy protection for children

You must be at least 16 years old to register and submit personal information on this Platform. If You are under 16 years of age You cannot register to use this Platform and a parent or guardian may not assist You to register nor register in Your name. If we learn that a user is under the age of 16, We will take appropriate steps to remove his or her information from our database.

 

  1. Data We Collect

 

  • Data You Provide To Us

 

    • Registration

You provide data to create an account with us.

To create an account You need to provide data including Your name, email address, and a password. If You register for a Premium Service, You will need to provide payment (e.g., credit card) and billing information.

 

    • Profile

You create Your UGO profile (a complete profile helps You get the most from our Services).

You have choices about the information You share on Your profile, such as Your education, work experience, skills, photo, city or area and endorsements. You do not have to provide additional information on Your profile; however, profile information helps You to get more from our Services, including helping other Users to find You.

 

    • Posting and Uploading

The information that You post will help You to engage with Your network over our Services. You may give other data to us, such as by syncing Your address book or calendar.

We collect personal data from You when You provide, post or upload it to our Services, such as when You post content (e.g., a job description) or submit a resume on our Services.

 

    • Social Networks

Our Platform includes Social Media Features, such as Widgets, such as the Share this button or interactive mini-programs that run on our Platform. These Features may collect Your IP address, which page You are visiting on our Platform, and may set a cookie to enable the Feature to function properly. Your interactions with these Features are governed by the privacy policy of the company providing it.

 

    • “Send to network” messages.

The Platform may allow You to send information on the Platform via email, social network, or other messaging system to recipients who You feel may be interested in receiving such information. To use this feature You provide us with certain information about the receiving party and by doing so You warrant that You have their consent to do so.

Any personal information You provide in connection with sending such other party the message, such as Your name and Your email address will, of course, be disclosed to such other party. While, due to technical restrictions, the recipient’s information may be retained in our systems as required for delivery and logging, we do not share it with third parties and we do not use this personal information for any purpose except to send this one-time message (unless the recipient has already consented to such use of his/her personal information). Recipients of these messages will not be opted-in to any future communications from the Platform unless they have previously given their consent and then in accordance with their privacy choices.

 

  • Data From Others

 

    • Contact Information

Others may sync their contacts with our Services.

We receive personal data (possibly including contact information) about You when others import or sync their contacts to our Services, or send messages using our Services (including invites or connection requests). If You or others opt-in to sync email accounts with our Services, we will also collect email information when available that we can associate with Member profiles.

 

    • Clients

Clients may provide data to us.

We may receive personal data (e.g., Your job title and work email address) about You when You use our Services, such as employers and applicant tracking systems providing us job application data.

 

  • Service Use

We log Your visits and use of our Services.

We log usage data when You visit or otherwise use our Services, including our sites, app and platform technology. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify You and log Your use.

 

  • Cookies and Similar Technologies

We collect data through cookies and similar technologies.

As further described in our Cookies Policy, we use cookies and similar technologies to collect data (e.g., device IDs) to recognize You and Your device(s) on, off and across different services and devices where You have engaged with our Services. You can opt out from our use of data from cookies and similar technologies that track Your behavior. UGO’s Cookies Policy can be accessed here.

 

  • Messages

If You communicate through our Services, we learn about that.

We collect information about You when You send, receive, or engage with messages in connection with our Services. For example, if You get a UGO connection request, we track whether You have acted on it and will send You reminders.

 

  • Workplace and Student Information

When Your organization (e.g., employer) buys a Premium Service for You to use, they might give us data about You.

Others buying our Services for Your use, such as Your employer, can provide us with personal data about You and Your eligibility to use the Services that they purchase for use by their workers or alumni. For example, we will get contact information for “Company Page” administrators and for authorizing users of our premium Services, such as our recruiting products.

 

  • Other

Our Services are dynamic, and we’d like to introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we collect, use or share Your data, we will notify You, request Your consent if the purpose(s) or use(s) of Your personal data change, and we may also modify this Privacy .

 

  1. How We Use Your Data

We use Your data to authorize access to our Services and to honour Your settings. We use Your data to provide, support, personalize and develop our Services.

How we use Your personal data will depend on which Services You use (please refer to our Terms of Use for more information), how You use those Services and the choices You make in Your settings. We use the data that we have about You to provide and personalize our Services, including with the help of automated systems and inferences we make, so that our Services can be more relevant and useful to You and others.

All data that we obtain about You will be used in accordance with current data protection legislation and this PP. We, or data processors acting on our behalf, will process Your personal data as follows:

 

For Our legitimate interests

For example:

    • To provide You with our Services and to ensure that they are performed in a way which is tailored to Your needs and interests and Your use of our Platform; or
    • To ensure the security of our websites, mobile applications and other technology systems; or
    • To deal with any enquiries made by You including for the following purposes:
      • To process Your registrations;
      • To action Your subscriptions;
      • To process survey information You have submitted.

We may occasionally use Your email address and, in rare situations, postal address or phone number, to contact You regarding administrative matters or notices and to manage and respond to any queries You make or any correspondence that You send to us.

 

To perform a contract with You

Including for example making a payment.

 

To comply with a legal obligation 

Including where You exercise Your rights to make requests under data protection law and to comply with lawful requests from government or law enforcement officials.

 

Based on Your consent

 For the following purposes:

    • To provide You with our Services and to ensure that they are performed in a way which is tailored to Your needs and interests and Your use of our Platform ;
    • To send You marketing communications ;
    • Where You provide special categories of data to us (with sensitive personal data) to provide You with tailored services.

 

We may also use aggregated data for market research and statistical analysis and to analyse the use of Our Services so that We can improve them.

 

  • Communications

We contact You and enable communications between Members.

We may contact You through email, messages to Your UGO inbox, and in other ways through our Services, including text messages and push notifications, such as messages about the availability of our Services, security, or other service-related issues. We may also send messages about how to use our Services. Please be aware that You cannot opt out of receiving service messages from us, including security and legal notices.

We also enable communications between You and others through our Services, including for example invitations and messages between connections.

 

  • Advertising

We don’t advertise on our Services. We cannot offer You choices regarding personalized ads. We do not share Your data with any third-party advertisers or ad networks.

 

  • Marketing

We may promote our Services to You and others both on and off our Services.

We may use Members’ data for invitations and communications promoting membership and network growth, engagement and our Services, such as by recommending opportunities for connections on our Services.

 

  • Developing Services and Research

 

    • Service Development

We develop our Services and conduct research.

We use data, including public feedback, to conduct research and development for our Services in order to provide You and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services, and help connect people to each other and to economic opportunity.

 

    • Other Research

We seek to uncover socioeconomic opportunities for Our Members. We use the personal data available to us to research social, business and other trends.

 

    • Surveys

Polls and surveys may be conducted by us and others through our Services. You are not obligated to respond to polls or surveys, and You have choices about the information You provide.

 

    • Customer Support

We use data to help You and fix problems.

We use data (which can include Your communications) to investigate, respond to and resolve complaints and for Service issues (e.g., bugs).

 

    • Insights That Do Not Identify You

We use Your data to produce and share insights that do not identify You. For example, we may use Your data to generate statistics about our members, their profession or industry.

 

    • Security and Investigations

We use data for security, fraud prevention and investigations.

We use Your data (including Your communications) for security purposes or to prevent or investigate possible fraud or other violations of our User Agreement and/or attempts to harm our Members, Customers or others.

 

  1. How We Share Your Information

 

  • Our Services

 

    • Profile

Some elements of Your profile may be visible to some Members and Premium Service Clients, such as Your name and current title.

 

    • Messages

Our Services allow viewing and sharing information including through posts on other social media (e.g. a Member using our social media features to post a Client vacancy).

When Your profile is linked to a Client (e.g., Your employer), You may be visible to Your network as an employee of that Client.

Your employer can see how You use any Services they have provided for Your work (e.g. as a Recruiter or Ambassador) and related information. We will not show them Your job searches or personal messages.

 

    • Enterprise Accounts

Your employer may offer You access to our Premium Services as a Recruiter or Ambassador. Your employer can review and manage Your use of such Premium Services.

We understand that certain activities such as job hunting and personal messages are sensitive, and so we do not share those with Your employer unless You choose to share it with them through our Services (for example, by applying for a new position internally).

 

  • Service Providers

We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to Your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

 

  • Legal Disclosures

We may need to share Your data when we believe it’s required by law or to help protect the rights and safety of You, us or others. We may pass Your data to the police, regulatory bodies, legal advisers or parties whose request we reasonably consider to be justified in connection with any alleged criminal offence, any suspected breach of the UGO Terms of Use or any other abuse of our Services by You.

 

  • Change in Control or Sale

We may share Your data when our business is sold to others, but it must continue to be used in accordance with this Privacy Policy.

We can also share Your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys UGO or part of our business will have the right to continue to use Your data, but only in the manner set out in this Privacy Policy unless You agree otherwise.

 

  1. Your Choices & Obligations

 

  • Data Retention

We keep most of Your personal data for as long as Your account is open.

We generally retain Your personal data as long as You keep Your account open or as needed to provide You Services (e.g., we keep a history of the referrals or applications that Our Users made on UGO). This includes data You or others provided to us and data generated or inferred from Your use of our Services (e.g., we keep User CVs available for them to use when applying for a position through Our Services). Even if You only use our Services when looking for an opportunity every few years, we will retain Your information and keep Your profile open (e.g., this is required to be able to receive career opportunities for other Users), unless You close Your account. In some cases we choose to retain certain information (e.g., insights about Services use) in a depersonalized or aggregated form.

 

  • Your rights in relation to Your personal information

You have the right:

    • to access Your personal data and to be informed about its use
    • to correct Your personal data
    • to have Your personal data deleted
    • to restrict the use of Your personal data
    • to object to the use of Your personal data
    • to complain to a supervisory authority
    • to withdraw Your consent to the use of Your personal data
    • to ask for the portability of the personal data You shared with Us

You have the right to access the information that we keep about You. Furthermore, You may ask us to make any necessary changes to ensure it is accurate and up-to-date. You can also request deletion, or a limitation of the treatment, of Your data. You also have the right to object to any processing.

 

  • Changes to this PP and Your right to withdraw Your consent

UGO (“we” or “us”) can modify this Privacy Policy in our absolute discretion.

If we make minor or technical changes You acknowledge that Your continued use of our Services after we publish or send a notice about the changes to this Privacy Policy means that the collection, use and sharing of Your personal data remains subject to the updated Privacy Policy, as of its effective date.

If we make material changes to this Privacy Policy, we will provide You with advance notice through our Services or by other means, so that You can review and accept the changes before they become effective.

You are at liberty to withdraw Your consent to our use of Your personal information at any time. If You object to any changes, You may close Your account by writing to privacy@ugonetworking.com [or write to the UGO Privacy Officer at Avenue Jef Lambeaux / Jef Lambeauxlaan 3, in 3090 Overijse, (Belgium)].

 

  • Account Closure

We may keep some of Your data (e.g., depersonalized usage trends, invoices) even after You close Your account.

If You choose to close Your UGO account, Your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.

We may retain Your personal data even after You have closed Your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse.

 

  1. Other Important Information

 

  • Security – how do we protect Your data?

We use industry standard efforts to safeguard the confidentiality of Your data. All the data collected by us is stored on a secure server. However, please keep in mind that the internet and the World Wide Web are not secure mediums.

We will retain Your information for as long as Your account is active, as needed to provide You Services and will use Your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

  • Contact Information

You can contact us or use other options to resolve any complaints.

  • For questions about this Privacy Policy or about related cookies or personal data privacy questions please contact : privacy@ugonetworking.com [or write to the UGO Privacy Officer at Avenue Jef Lambeaux / Jef Lambeauxlaan 3, in 3090 Overijse, (Belgium)]
  • In case of infringement of Your personal data protection rights You may lodge a complaint with the Belgian Data Protection Authority, Rue de la Presse 35 / Drukpersstraat 35, 1000 Brussels, T +32 (0)2 274 48 00, F +32 (0)2 274 48 35, contact@apd-gba.be.
  • The relevant complaints form is available from the APD/GBA website:

in French at https://autoriteprotectiondonnees.be/citoyen/agir/introduire-une-plainte;

and in Dutch at https://www.gegevensbeschermingsautoriteit.be/burger/acties/informatie-aanvragen.