Privacy Statement Recruitment Process
About Us
D2X Group N.V. (“D2X”, “we”, “us”) is an investment firm authorised to operate a Multilateral Trading Facility (“MTF”), as defined by Article 4(1)(22) of MiFID II. D2X has its registered office at Ijsbaanpad 2, 1076CV, Amsterdam, the Netherlands.
1. Objective of the Privacy Statement
This recruitment privacy statement (the “Privacy Statement”) describes how D2X collects, controls, processes and transfers personal data about you and your rights regarding your personal data during the course of the recruitment process. The purpose of the Privacy Statement is to make applicants aware of how and why their personal data will be used and how long it will be retained. D2X retains the right to amend this Privacy Statement from time to time. D2X processes your personal data in accordance with the applicable EU data protection rules. In case of a conflict between this Privacy Statement and applicable law, the latter governs the recruitment process.
2. Personal Data D2X Collects
For the purposes of the recruitment process, D2X may request the following personal data:
2.1 During the application process, we may request the following personal data:
a) personal details (such as full name, educational and professional background);
b) contact information (such as email address, phone number);
c) if applicable, information regarding visa status;
d) other information relevant to the recruitment process.
2.2 If you are selected for the position and accept the letter of offer, D2X may additionally request the following personal data:
a) identification details (such as passport or identification card, photo ID, national identification number and social security number);
b) proof of address (such as citizen service number (BSN), utilities bill on your name) and, if applicable, residency permit;
c) certificate of good conduct (VOG);
d) other proof and/or information relevant to the applicants' educational and professional background.
2.3 D2X does not request special categories of personal data
D2X does not request special categories of personal data (such as racial or ethnic origin, political opinions, religious or gender identity).
2.4 D2X may only collect special categories of personal data if candidates:
a) have explicitly consented to, indicating also the specific purpose for the collection and processing of it;
b) the processing is required by applicable law, or;
c) the processing is otherwise permitted under applicable law.
These special categories of personal data may include data about a person's criminal behaviour, or unlawful or objectionable conduct connected with a ban imposed with regard to such conduct. They may also include the personal phone number for the purposes of the recruitment process or for purposes related to the recruitment process or to fulfil the responsibilities of the role associated with the vacancy.
2.5 No automated decision-making
D2X does not use automated decision-making for recruiting or evaluating suitable candidates, including profiling.
3. How Does D2X Collect Personal Data
D2X collects personal data that is directly provided by the candidates in their curriculum vitae and Cover Letter or obtained from other third-party sources. D2X may use personal data collected from third party sources, such as:
a) regulatory authorities that contain personal data of candidates;
b) public sources such as newspapers and the internet; and
c) data files from other parties that have collected personal data on candidates, such as Trade Registers, referrals and businesses who contact D2X regarding our business activities who may provide us with information that relates to you.
4. How Does D2X Process Personal Data
4.1 The processing of personal data by D2X is being conducted for legitimate business and contractual interests, legal and regulatory purposes. D2X processes personal data in order to assess the skills, qualifications and suitability of candidates for the role they have applied to or any other role D2X may consider them for.
4.2 As part of processing your personal data, D2X may keep records to fulfil the purpose of the recruitment process and/or to comply with various legal and regulatory requirements.
4.3 D2X may use your personal data in order to:
a) assess your suitability for a position;
b) protect D2X's interests in relation to property, performance of duties and compliance with rules by employees and enforcement of D2X's legal rights;
c) conduct statistical research and improve our recruitment process (upon pseudonymisation for this purpose).
5. Data Security
5.1 D2X is committed to protecting candidates' personal data. D2X takes all appropriate measures to ensure that the personal data is not accidentally lost, used or accessed in an unauthorized way, altered or disclosed, including but not limited to restricting access to candidates' personal data.
5.2 Candidates' personal data will be stored in databases used by the recruitment and human resources department of D2X for the purposes mentioned above. D2X may also hire third party processors in order to process your personal data.
5.3 Access to candidates' personal data is strictly controlled through an extensive security system in our network. Access to our database is limited to explicit human resources professionals, managers/heads, certain persons from the legal and/or compliance department(s) and will only be shared with other personnel or agents on a “need to know basis” for the purposes as set out above.
6. Data Sharing
6.1 Candidates who submit their personal data to D2X acknowledge that their data might be shared with certain third parties in the course of legitimate business activities of D2X or to comply with our legal and contractual obligations.
6.2 D2X asks all third parties to treat the personal data they receive in accordance with this policy and with the applicable laws and regulations.
7. Data Retention
7.1 D2X will retain candidates' personal data for as long as necessary to achieve the purposes specified above, and in any case at least as long as required under applicable law.
7.2 If you are not hired, D2X will retain your personal data for a maximum of one (1) year after the end of the recruitment process for a potential match with future positions as allowed under the applicable laws. You may request your data to be deleted at any time.
8. Candidates Rights
8.1 Candidates who submit their personal data to D2X have the right to:
a) request access, view and receive a copy of their personal data.
b) request correction of inaccurate personal data.
c) object to the processing of their personal data;
d) request transfer of their personal data to another party;
e) request the erasure of their personal data;
f) withdraw consent that was previously provided.
8.2 Candidates who wish to exercise any of their rights under 8.1 or have any questions regarding this Privacy Policy and its contents, must contact the Data Protection Officer at dpo@d2x.com. The DPO will respond to any request submitted as soon as reasonably possible.
8.3 D2X will inform you at the latest within one (1) month about the receipt of your request and the steps taken to satisfy that.
9. Consequences of Refusal to Submit Data
9.1 Subject to Article 9.2 below, you are not required by law to provide all information requested by us but an application for a position may be excluded from the assessment if not all requested information is provided.
9.2 Candidates who fail to or refuse to provide the requested personal data to D2X, pursuant to a statutory or contractual obligation, or that may be necessary for the execution of a contract, will result in disqualification from the recruitment process, refusal from us to enter into a contract with you, or if a contract has already been entered into -- may have consequences for the contract between the candidate and D2X.