1. Introduction

• With this privacy notice, we wish to inform you on how and why we Process your Personal Data and which rights you have under the European General Data Protection Regulation (« GDPR ») and other local laws on Privacy and the Processing of Personal Data (« Applicable Laws »).
• You will see defined terms in this privacy notice. If not defined within this privacy notice, these terms have the meaning provided for in the Applicable Laws.

2. Processing of Personal Data

• Phoenix Biosciences process personal data  about you, as candidate employee, candidate consultant or candidate intern (« Data Subject(s) » or « you ») in the manner described below.
• We are committed to protecting your privacy and your Personal Data and to respecting your rights. This notice explains how we Process your Data, in the context of your application and our internal human resources recruitment processes, in accordance with the Applicable Laws.

3. Phoenix Biosciences SA as Data Controller

• Where Phoenix Biosciences SA is the recruiting entity and for its respective contacts with you in this respect, Phoenix Biosciences SA (as further identified below) will qualify as the sole Data Controller for its Processing of your Personal Data, which means it solely determines why and how your Data is Processed. Phoenix Biosciences SA will make sure your Data is Processed in a lawful, transparent, and secure manner.

4. How and why we Process your Personal Data 

• We may Process your Personal Data for various purposes. Below, we describe for each purpose, the type of activities we perform, the categories of Data Subjects to whom such Processing relates to, the categories of Personal Data we Process, as well as the applicable legal basis and retention period.  
  • Recruitment and administration of (candidate) personnel

• In addition to the Data categories listed above, we may use other types of Data relating to you that you may have voluntarily provided to us, that were provided to us in the context of our business relations or that we have deducted or generated from Data that were already in our possession.

5. We collect your Data in different ways

• We may collect Data that you have voluntarily provided to us when you apply for a position within Phoenix Biosciences SA, by letter or email.
• It may also be possible that we receive or indirectly collect Data about you, for example, from our human resources recruitment partners or from public sources such as social networks, public websites or on the basis of a recommendation/reference.

6. Sharing your Personal Data with others

• Within Phoenix Biosciences SA, we restrict access to your data to employees and any person acting under our authority on a need-to-know basis, who respect our confidentiality rules and comply with our instructions. 
• Any person having access to your Personal Data (e.g. our HR team) and acting under our authority Processes your Data in respect of the instructions that we have given them and has committed him or herself to respect our confidentiality rules.
• Phoenix Biosciences SA may call on intragroup or external Processors for the Processing of your Personal Data (e.g. intragroup service providers, payroll agencies). In this case, we only call on Processors providing sufficient guarantees on the lawfulness, transparency and the security of the Processing of your Data.
• We may also need to transfer your Data to other Recipients (both intragroup and external) if we believe in good faith that this is necessary, at all times taking into account our obligations under the Applicable Laws. We could transfer your Data, if and in so far as necessary, to for example:
  • Attorneys or courts to safeguard the rights and interests of our organization, our people, our customers and partners or the public in general;
  • Public or enforcement authorities to comply with a legal obligation or procedure;
  • External or internal service providers;
  • Our (statutory) auditors to perform an audit.
• We are an international organisation, operating globally and may therefore transfer your Personal Data outside the European Economic Area (EEA). Transfers from our entities in the European Economic Area to entities outside the EEA are covered by intercompany data transfer agreements in line with Applicable Laws. When your personal data is shared by us with or transferred by or to a third party outside the EEA, when required, we will enter into the appropriate data transfer agreements or otherwise make sure appropriate safeguards are in place.

7. Minimizing and securing your Personal data – Data retention & deletion

• At all times we aim to minimize the Personal Data we process, to make sure we only use your Data when and in so far, we need it. Where possible we also pseudonymise or key-code your Data so that you cannot be directly identified.
• We only keep your data where and in so far as we need it, in line with the mandatory retention terms and the provisions of our Data Retention Policy.
• For recruited candidates, we keep your Personal Data until the decision on the application, following which the data will be processed and kept in line with our HR Privacy Notice which will be communicated to the recruited candidates.
• For candidates which are not selected for a position, we keep your Personal Data until 1 year following our decision on the application unless we have obtained your consent to keep it for a longer period of time.

8. We respect your rights

• We have implemented reasonable, risk-based technical and organisational measures to ensure that your Data is protected from loss or disclosure, unauthorised use, modification or destruction.
• Under the Applicable laws You have certain rights in relation to the Personal Data we hold about you, including:
  • the right of information about and access to your Personal Data;
  • the right to rectify or erase certain Personal Data;
  • the right to restrict or to object to certain processing;
  • the right to data portability;
  • the right to withdraw your consent, where the processing is based on consent.
• You can request the exercise of your rights by contacting us using the contact details below.
• In order to guarantee the security of your Data and to avoid any misuse, before responding to your request, we will ask you to provide us with an acceptable proof of your identity and will verify the legitimacy of your request and whether all the conditions have been satisfied.

9. Contact us

• If you have any questions or concerns about the way we collect, store and use your Data, do not hesitate to direct them to our centralised privacy point of contact:
  • By email: info@quantoom.com
  • By mail: Phoenix Biosciences SA, Rue de la Maîtrise, 1400 Nivelles, Belgium
• We will deploy our best efforts to find a quick and fair solution to any concern that you may submit to us.
• In addition, if you have reasons to believe that the Processing of your Personal Data by Phoenix Biosciences SA infringes the Applicable Laws, you have the right, at all times, to lodge a complaint with a supervisory authority. You can reach the Belgian Data Protection Authority through: www.dataprotectionauthority.be