Legal information and Candidates privacy information statement

Legal information:
Registered place of business : 29 Boulevard Grande-Duchesse Charlotte, 1331 Luxembourg
Activity: Counselling and professional training
Launch of the activity: June 2016
Founder : Stéphane Brun
TVA number : LU29562657
Luxembourgish ministerial authorisation number: 10081163

Candidates privacy information statement
We look forward to working with you to help you to further develop your career. As you’d expect, to properly perform our services, we collect and use information about you.
Gamechanger is committed to protecting and respecting your privacy. This Candidate Privacy Information Statement ‘this Statement’ describes your privacy rights in relation to the information about you that we process, as well as the steps we take to protect your privacy. We know it’s long, but please read this Statement carefully.

How do we handle changes to this Statement?
Firstly, we need to be clear about how we use some words in this statement.
It may seem obvious, but in this Statement you will be referred to as ‘the Candidate’ or ‘You’.
When we talk about ‘us’ or the ‘Company’ we mean Gamechanger Luxembourg having its registered office at 29 Boulevard Grande-Duchesse Charlotte, 1331 Luxembourg. Through its various activities and business lines Gamechanger provides several HR (Human Resources) activities like staffing, recruitment & selection, career transition, talent development, training & education and outplacement (‘our Activities’).
To carry out our Activities the Company uses several IT systems. Finally, this is a statement about information about people. This type of information is sometimes called ‘Personal information’, ‘Personally Identifiable Information’ or ‘PII’. We use the term ‘Personal Information’ in this Statement.

What personal information does the company collect and use?
Personal information that the company usually collects includes, but is not limited to:
• Your name, date and place of birth, e-mail address, contact details and qualifications (education, training courses and internships), documents evidencing your identity and right to work and any other information you listed on your resume or CV;
• Your LinkedIn profile data or any other social media account;
• If you contact us, in some cases we will keep a record of that correspondence;
• We may also collect information on your visits to our website including (but not limited to) your IP address, browser, timestamp, location, country traffic data, location data, weblogs and other communication data and the resources that you access. This information will make your visit to our website easier in the future.
• We may also collect information for marketing purposes and analysis, including information on how your respond to email, sms, phone and other marketing campaigns
• Photos and videos of your attendance at training or similar sessions (you will be given a chance at the session to ask not to be videoed or photographed);

Why do we use personal information about you?
The company collects and processes personal information:
1. To provide you with the services you expect us to, like finding you suitable jobs to apply for, helping you with training, or facilitating the process of applying for jobs. This includes sending your CV to prospective employers for their consideration and keeping you informed of future work opportunities by email, telephone, mail and/or other communication methods;
2. With your consent we may also use your contact data for direct marketing for example via e-mail, messaging or telephone;
3. To further develop, test and improve our website, or other existing or new systems/processes to better serve you; this mainly takes place in the context of new IT systems and processes, so that information about you may be used in the testing of those new IT systems and processes where dummy data cannot fully replicate the operation of that new IT system;
4. To perform studies and statistical and analytical research, for example to compare the effectiveness of our placement of candidates between different business sectors and geographies and seek to identify factors that might influence any differences we identify;
5. Where necessary, to comply with any legal obligation;

What does the law say about this?
We are required by law to have a ground set out in the law to process the information we hold about you.
Our processing of personal information for all these purposes is based on processing grounds like the performance of a contract to which the data subject is a party (purposes 1 and 6-7), processing necessary to comply with legal or regulatory obligations (purposes 6-7) and/or processing necessary in the legitimate interests of Gamechanger in exercising its and its staff fundamental rights to run a business in a way which does not unduly affect your interests or fundamental rights and freedoms (purposes 1-5 and 7). When processing is necessary for the legitimate interests of Gamechanger, we ensure that processing is conducted in such a manner that our legitimate interests outweigh any individual’s interest.
We shall only process your personal information other than on these grounds with your consent (a further processing ground).

Do you have to give us the personal information we ask for?
You are not obliged to provide your personal information to us, but it is more or less impossible for us to work with you and provide our services if you do not.

Do we process information about you without any human intervention at all?
The Company may use automated systems/processes (like profiling) to provide you, and our clients, with the services you request from us. Nevertheless, when we use profiling for decision-making, human intervention is always involved.
For example, when our clients are looking for candidates for jobs, we may conduct a search of our lists of candidates using criteria which takes into account your availability, skillset, pay rate and in some circumstances previous feedback we have received from clients to compile a shortlist which ranks which candidates are most likely to fulfil the client’s requirement. This means that sometimes your position in the rank may be higher than others, depending on how these factors match the clients’ needs.

How long do you keep my personal information for?
The Company can keep your personal information for up to 5 years from the date of your last application.

Do we transfer your data to third parties?
Your validation will always be needed before any transfer of data to any third party.
As mentioned above, we usually disclose your data to third parties. This is done to complete the purposes set out above. We do this in the following circumstances:
• To our clients/prospective employers: we will share your data with clients of ours who are offering jobs you may be interested in, or who are interested in your profile. They owe contractual and other confidentiality obligations in relation to your data to us, and to you;
• We will share your data with government, police, regulators or law enforcement agencies if, at our sole discretion, we consider that we are legally obliged or authorised to do so or it would be prudent to do so; and

What are your rights?
• Right to access and obtain a copy of your personal information
You are entitled to request confirmation whether we process any of your personal information. In some cases, you can ask us to provide you with an electronic copy of your information.
• Right to correct your personal information
If you can demonstrate that personal information we hold about you is not correct, you can request that this information is updated or otherwise corrected.
• Right to be forgotten/have data deleted
In certain circumstances, you have the right to request that we restrict the processing of your personal data and/or that your personal data is deleted. You may make such a request at any time and Gamechanger will evaluate if your request should be granted, however this right is subject to any legal rights or obligations we may have to retain data. For situations where in accordance with the law, we determine that your request to have your personal information deleted must be granted, Gamechanger will do so without undue delay. Please bear in mind, once your data is deleted – that the Company might not be of service to you anymore once this data about you has been deleted. If you want to re-register with the company again, you will need to re-enter your data. • Right to object
As far as the company’s processing of your data is based on the company’s legitimate interest (and no other processing ground) or relates to direct marketing, you are entitled to object to the Company processing your data by reference to your particular situation. If you want to exercise any of your rights, please email us at stephane.brun@gamechanger.lu.
When you email us to exercise your rights, the Company may ask you to identify yourself before actioning your request.
Finally, you have the right to lodge a complaint with the data protection authority in the place where you live or work, or in the place where you think an issue in relation to your data has arisen.
• Right to object
As far as the company’s processing of your data is based on the company’s legitimate interest (and no other processing ground) or relates to direct marketing, you are entitled to object to the Company processing your data by reference to your particular situation. If you want to exercise any of your rights, please email us at stephane.brun@gamechanger.lu.
When you email us to exercise your rights, the Company may ask you to identify yourself before actioning your request.
• Finally, you have the right to lodge a complaint with the data protection authority in the place where you live or work, or in the place where you think an issue in relation to your data has arisen.

How could you contact us?
If you have any questions or concerns regarding our Statement, would like further information about how we protect your information (for example when we transfer it outside Europe), please email us at stephane.brun@gamechanger.lu.

How do we handle changes to this Statement?
The terms of this Statement may change from time to time. We shall publish any material changes to this Statement through appropriate notices either on this website or contacting you using other communication channels.


Only the French version of the Candidate Privacy information statement shall have the force of law.