Bluecrux (hereinafter ‘we’, ‘us’ and ‘our’) understands the importance of the privacy of its customers and users of its website visitors and the protection of their personal data. This policy sets out how we handle and process your personal data.
Scope
Bluecrux International BV, with its registered office at Korte Keppestraat 9 box 21, 9320 Erembodegem, CBE (Crossroads Bank for Enterprises) number 0728.841.469 manages this website. We act as the data controller when we process our customers’, website users’ and job applicants’ personal data.
We believe it is important to create and maintain an environment where our customers and website users can be confident that their data will not be misused. We comply with the regulations applicable to data protection such as the Regulation (EU) 2016/679 (also referred to as the General Data Protection Regulation, hereinafter “GDPR”) and the Belgian Data Protection Act. The aforementioned regulations concern the protection of personal data and provide you with rights over the said personal data. Where we use AI-supported tools in our recruitment process, we also take Regulation (EU) 2024/1689 (the “Artificial Intelligence Act” or “AI Act”) into account.
The objective of this policy is to indicate what personal data we collect, how we use your data after you have visited our website and to assure you that we process your data appropriately.
This privacy policy and the terms and conditions of use apply when you visit our website. The application of terms and conditions other than those set out herein is explicitly prohibited unless we have provided express permission in writing in advance. In the latter case, this policy applies alongside the specific agreement. The use of this website, the platform and the content contained therein is only permitted subject to compliance with the full text of this policy.
What type of personal data do we collect?
It is not necessary to provide personal data to use most of our website.
We collect and process the following categories of personal data for the purposes stated below:
First name
Last name
Email
telephone number
Company;
Job title;
Additional or optional data are provided by filling out forms on our website or when we contact you (by telephone, email or at trade fairs or events).
We also collect and process data obtained via our website or the devices you use. The collected data may be:
Login details (username and password) for the section of the website reserved for customers;
Location data (collected via social media or the IP address of your device)
Data collected using cookies, web beacons or from the internet. These data are automatically collected and can be related to the website you visited before you navigated to our website or the website you navigated to after visiting our website. We may also collect data on the website pages you have visited, your IP address, the type of browser you use, the access time and your operating system. Read our cookie policy to find out more on how we use cookies.
Data we obtain from other websites, for example if you ask us to link to your Facebook account
Where you apply for a position with us, or where we contact you as a potential candidate, we also collect and process recruitment-related personal data, such as your CV or résumé, education and employment history, qualifications and skills, references, and any other information you choose to share with us during the application process. Where you take part in an interview with us that is recorded with your consent, we also process the audio and video recording of that interview and the written transcript generated from it. How we use this data — including the recording and transcription of interviews and our use of AI-supported screening tools — is described in the section “Recruitment, interview recordings and use of AI-supported tools” below.
We may also collect data from the public domain to check data previously collected or to manage or broaden our activities.
3. We may also collect data from the public domain to check data previously collected or to manage or broaden our activities.
We collect the aforementioned data to create a profile in order to understand your needs and to provide better service, and for the following specific purposes:
Purpose
Personal Data
Legal basis
Data retention period
Direct marketing (customers)
Name and contact details (email)
Legitimate interest
One year after the termination of the commercial relationship
Direct marketing (prospect)
Name and contact details (company, position, email)
Consent
Until contact no longer wants to consent
Customer management
Name and contact details (company, position, email, telephone number)
Required for the execution of the agreement
Legitimate interest
Ten years after the termination of the commercial relationship
Recruitment
Identification and contact data, professional data, interview recordings and interview transcripts (only where you consent to the recording of your interview)
Application file: Legitimate interest (valid for 1 year) or consent if stored longer (valid for 3 years). Consent can be given verbally or via an opt-in. Renewal of consent will be asked via e-mail (including an easy option to have your data deleted) and will be automatically given in case we don’t receive a response. Interview recording and transcription: consent, requested by the recruiter before the recording starts. You may decline or withdraw your consent at any time without any consequences for your application.
Application file (including interview transcripts): One year or three years if consent is given . Interview recordings: up to 60 days (plus up to 93 days in back-ups), after which they are permanently deleted.
4. How will your data be used and shared?
Based on our legitimate interest, we may share your personal data with third parties that assist us with our products and services. Some examples of third-party activities include the hosting of web servers, data analysis, marketing support providers, customer service, our applicant tracking system provider and our collaboration and video-conferencing platform provider (Microsoft, for the recording and transcription of interviews). These companies have access to your personal data but only when this is required to perform their activities. They are not permitted to use your data for any other purposes.
Your personal data will not be sold or leased to third parties.
We may publish your personal data to enforce our policy, to comply with our legal obligations or in the interest of safety, in the public interest or for the purposes of legal enforcement in any country where we have entities or subsidiaries. We may follow up a request from a law enforcement agency, regulatory authority or government agency. We may also publish data for the purposes of current or scheduled court cases or to protect our property, safety, people or other rights and interests.
Should Bluecrux International bv be sold or merges with another company, your data will be accessible to the advisor of the potential buyer and transferred to the new company owners. In that case, we will take the appropriate measures to guarantee the integrity and confidentiality of your personal data. The use of your personal data will always be subject to this policy.
5. Recruitment, interview recordings and use of AI-supported tools
This section applies where you apply for a position with Bluecrux, are contacted by us as a potential candidate, or otherwise take part in a recruitment process with us. For candidate personal data, Bluecrux acts as data controller. We process this data through our applicant tracking system and, where relevant, through selected service providers acting as our processors under a data processing agreement.
As part of our recruitment process, we may use AI-supported tools within our applicant tracking system and collaboration platforms to assist our recruiters during the initial review of applications. These tools can help assess how well a candidate’s profile aligns with predefined, role-related criteria by providing a non-binding, indicative score. The use of such tools is strictly supportive. All applications are reviewed by a human recruiter, and no decision producing legal effects or similarly significant effects for a candidate is taken on the basis of automated processing alone. Candidates are not automatically shortlisted or rejected on the basis of AI-generated outputs. AI-supported screening is used solely to improve the efficiency and consistency of our recruitment process, and our recruiters remain fully responsible for all hiring decisions. Where interview transcripts are generated via our collaboration platforms (Microsoft Teams), they are used solely to summarise and document information explicitly provided by the candidate during the interview. We do not use interview recordings or transcripts to analyse candidate behaviour, personality, emotions, engagement, or other inferred characteristics. We do not request AI-generated recommendations, assessments, rankings, or advice regarding hiring decisions or next steps. All hiring decisions remain the responsibility of our recruiters and hiring managers.
Interview recording and transcription. With your consent, we may record interviews held via Microsoft Teams. The recruiter will ask for your consent before recording starts; you may decline or withdraw it at any time without any consequences for your application, in which case we take notes manually. The recording is used solely to generate a transcript, from which our recruiters document the objective, factual information you provided. The transcript is added to your candidate record and kept no longer than your application file; the recording itself is not kept in your record and is deleted within the retention period below. Microsoft acts as our processor for this functionality. The indicative score is only one of several elements a recruiter may consider and is never determinative. We do not use these tools to infer special categories of personal data (such as data revealing health, racial or ethnic origin, political opinions, religion or trade-union membership). You are entitled to obtain human intervention on our part, to express your point of view, to contest any assessment, and to object to processing based on our legitimate interest.
Interview recordings are retained for up to 60 days. Following deletion, recordings may remain recoverable through system backup or recovery processes for a further period of up to 93 days, after which they are permanently deleted. Only the interview transcript, and not the recording itself, may be retained as part of the candidate's recruitment record in accordance with our retention policies.
AI-generated scores are retained together with, and for no longer than, your application file.
The AI-supported tools and collaboration platforms we use operate under human oversight and are used in accordance with applicable data-protection and AI legislation, including the GDPR and Regulation (EU) 2024/1689 (the AI Act). Meaningful information about the logic involved, and the significance and the envisaged consequences of this processing, is available on request via privacy@bluecrux.com.
6. Transfer of your personal data outside the European Economic Area
We may transfer your personal data to third parties in third countries (outside the European Economic Area (EEA)) or other Bluecrux affiliates in third countries (i.e. United States). The said transfer of data outside the EEA is legal if the recipient of the data resides in a country with a level of protection deemed adequate by the European Commission. Some of these countries may not have enacted equivalent data protection legislation to protect the use of your personal data. Where a country does not benefit from an adequacy decision, we ensure that appropriate safeguards are in place before any transfer, in particular the European Commission’s standard contractual clauses, supplemented where necessary by additional measures following a transfer impact assessment. Transfers to the United States take place to recipients certified under the EU–U.S. Data Privacy Framework or, failing that, on the basis of standard contractual clauses. You may obtain a copy of the relevant safeguards by contacting privacy@bluecrux.com.
7. Rights of the data subject
You are entitled to inspect the data we hold on you and to request and receive a copy of the personal data on our records. You are entitled to request that we amend, add to or delete any outdated, incorrect or incomplete personal data relating to you when your personal details change. You are also entitled to limit the processing of your personal data and to object thereto. You are also entitled to receive the personal data you have provided to the data controller in a structured, commonly used, machine-readable format, and to transmit it to another data controller.
Right of access/inspection You are entitled to receive confirmation from us of whether your personal data is processed by us. If we do process your personal data, you are entitled to request to view your personal data.
Should it not be included in this policy, we will provide you with information on:
the purposes of the processing;
the categories of personal data concerned;
the recipients or categories of recipient to whom the personal data have been or will be disclosed; the transfer thereof to recipients in third countries or international organisations;
where possible, the intended period for which the personal data will be retained, or if this is not possible, the criteria used to determine that period;
your entitlement with regard to your personal data as listed in this section;
where the personal data are not collected from you, all the information available regarding the source of the data;
the existence of automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and the intended consequences of the said processing for the data subject.
We will produce a copy of the personal data relating to you in our records upon request. Should you make repeated and disproportionate requests for copies of the said data, we reserve the right to charge you a reasonable fee.
Right to rectification
Should you determine that the personal data on our records is incomplete or incorrect, you are entitled to notify us in order for the necessary steps to be taken to rectify or add to the said data.
Right to be forgotten You are entitled to request we delete your personal data should the processing not be in accordance with the data protection legislation or should the said processing not fall within the limitations laid down by law.
Right to restriction of processing You are entitled to request we limit the processing of your personal data if:
the accuracy of the personal data has been called into question during the period required to check the accuracy thereof
the processing is unlawful and you do not wish the data to be deleted;
we no longer require the data but you do not request we delete the data because the data is required for the pursuance or defence of legal claims
an objection is made to the processing pending an explanation of the legitimate interests that outweigh your interests.
Right to data portability You are entitled to receive the data you have provided to us in a structured, standard and machine-readable format. You are entitled to request we transfer the personal data to another data controller (directly from us). This is an option when the processing is based on your consent and processing via an automated procedure.
Right to object Where your personal data is processed for direct marketing purposes (including profiling), you remain entitled to object to the said processing.
You are entitled to object to the processing based on a specific situation related to the data subject. The organisation will no longer process the personal data unless the organisation demonstrates compelling legitimate grounds for the processing which outweigh your interests or the interests of the pursuance or defence of legal claims.
Automated individual decision-making The data subject is entitled not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, such as the evaluation of personal aspects related to performance at work, reliability, creditworthiness, etc.
The said right not to be subjected to such automated decision-making processes does not apply where the process is allowed on the basis of a mandatory legal provision.
The data subject is not entitled to invoke this right when the decision is required to enter into, or to execute, an agreement between the data subject and the organisation or is based on the explicit consent of the data subject. In the latter two cases, the data subject is entitled to human intervention by a member of the organisation staff and is entitled to notify the organisation of their position and to contest the automated decision.
For the avoidance of doubt, the AI-supported screening tools and the interview transcripts described in the section “Recruitment, interview recordings and use of AI-supported tools” do not constitute a decision based solely on automated processing within the meaning of this section, because every application is subject to meaningful human review and no decision is taken on the basis of automated processing alone.
Right to withdraw consent If you have consented to the processing of your personal data for a specific purpose of processing, you are entitled to withdraw your consent by sending an email or via your account. If you have consented to the recording and transcription of an interview, you may withdraw that consent at any time, including during the interview, by informing the recruiter or by sending an email to privacy@bluecrux.com; we will then stop the recording and delete it. Withdrawing your consent does not affect the lawfulness of the processing carried out before the withdrawal, nor does it have any consequences for your application.
If you opted in to receiving email messages, newsletters, etc. from Bluecrux when you registered on the website, you can unsubscribe if you change your mind.
Procedure to exercise rights and other provisions We can request you verify your identity to ensure your request is lawful and that we are sending the reply to a person entitled to make such a request and to receive the data. Please note that we may refuse access to your personal data or may not be able to grant your request under specific circumstances when we are entitled to do so under the applicable data protection legislation.
Our privacy team can be contacted by email (privacy@bluecrux.com) to answer questions regarding the processing of your personal data and will respond to your requests to exercise your rights.
You are entitled to file a complaint with the competent supervising authority (for data protection). In Belgium, the Data Protection Authority, Drukpersstraat 35, 1000 Brussels (contact@apd-gba.be).
8. Security
We make every effort to guarantee the security of your data. We have implemented reasonable technical and organisational measures to guarantee your personal data against accidental or unlawful destruction, loss, modification, unauthorised disclosure and/or unauthorised access to the data transmitted, saved or otherwise processed. Please note that the internet is an open network; we cannot therefore guarantee that unauthorised third parties will not be able to circumvent these measures or use your personal data for inappropriate purposes.
This website may include links to third-party websites. We will not be held liable for the content of these websites, nor for the privacy standards and practices of the corresponding third party. You must read and understand the relevant third-party and website privacy policies before accepting cookies and visiting a website, to ensure your personal data is sufficiently protected.
9. Amendments to this policy
Bluecrux may amend or update this policy to ensure the provision of information on how we process your personal data at that time. The updated version of this policy is available on the same website and will take effect upon publication. Please visit this webpage regularly to ensure you remain up-to-date on how we collect and process personal data, how and under what circumstances we use your personal data and when we share your personal data with third parties.
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