Privacy and Data Protection Policy

Introduction
Individual privacy and personal data security is important to Black Pine Ventures, which ensures that all personal data is processed correctly and in accordance with applicable data protection legislation. This privacy policy (“Privacy Policy”) is a consent document that describes how Black Pine Ventures processes personal data. Please read this Privacy Policy carefully before sharing personal data with us.

2. Scope of the Privacy Policy 

2.1 Who this policy applies to:
This Privacy Policy applies to candidates, employees, customers, suppliers, and other stakeholders. Different sections will be relevant depending on your relationship with Black Pine Ventures.

2.2 What this policy covers:
This Privacy Policy governs how Black Pine Ventures collects and processes personal data in relation to our services, including recruitment, consulting, and related activities (“Service”).

2.3 When the policy does not apply:
Sometimes, Black Pine Ventures services are advertised on third-party websites not owned or operated by Black Pine Ventures. This Privacy Policy does not apply to personal data processing on such external websites.

3. Processing of Personal Data

Black Pine Ventures's handling of personal data is described below based on your relationship with Black Pine Ventures.

3.1 For Candidates or Employees

3.1.1 Purpose of Processing Personal Data

Personal data is only processed for the purposes described in this Privacy Policy. If you choose not to provide certain personal data, it may affect the Service. Black Pine Ventures processes personal data only to the extent necessary for the Service or for other purposes outlined below. This also applies to sensitive personal data.
Black Pine Ventures processes job applicants' and employees' personal data to: 

a) provide the Service to Black Pine Ventures's customers and offer you the opportunity to be a part of the Service;
b) manage our relationship with you;
c) handle any claims of alleged discrimination, resolve disputes, and handle complaints against you or Black Pine Ventures's customers and suppliers; and
d) conduct internal demographic studies and optimize Black Pine Ventures's operations.

3.1.2 Personal Data

By accepting this Privacy Policy, you consent to Black Pine Ventures processing your personal data in accordance with this Privacy Policy. If you do not consent to such processing, you should not provide us with personal data. Below is information on the types of personal data Black Pine Ventures processes and how Black Pine Ventures may obtain this information.

3.1.2.1 Candidate

The personal data that Black Pine Ventures processes about you as a candidate is based on the information you provide to Black Pine Ventures via Black Pine Ventures's website or through contact with Black Pine Ventures personnel for the provision of the Service. Black Pine Ventures will not process your personal data unless you have first provided your consent by accepting Black Pine Ventures's Privacy Policy.
The personal data we may process about you includes, among other things, your name, address, email address, personal identification number, qualifications, certifications, education and work experience, photograph, test results, information from background checks, drug test results, references (such as feedback and health information, including notes about sick leave), and data necessary for follow-up on the Service, etc.
If you agree to be photographed or voluntarily provide a photograph of yourself without prompting from Black Pine Ventures, you consent to Black Pine Ventures processing such a photograph.

You may be asked to consent to additional terms regarding the processing of your personal data in connection with tests that are requested by us.
Due to the high security requirements set by some of Black Pine Ventures's clients, Black Pine Ventures may need to conduct background checks, credit checks, health checks, and/or drug tests on you. Such checks may involve sensitive personal data, and you will be asked to provide explicit consent before a background check, credit check, health check, or drug test is carried out.

As part of a background check, Black Pine Ventures may ask you to provide a criminal record certificate. You must request this certificate from the relevant authority yourself. It is always your decision whether to request a criminal record certificate. Choosing not to provide one may affect your eligibility for the Service. The certificate will be opened by you together with Black Pine Ventures and/or Black Pine Ventures’s client. The information in the criminal record certificate will be handled with the utmost confidentiality and will never be processed by Black Pine Ventures. However, Black Pine Ventures may verbally confirm the results with the client to provide the Service.
In certain situations, it may be necessary for Black Pine Ventures to obtain your consent to request a credit report from an external credit reporting agency.
Black Pine Ventures may also ask you to provide additional personal data, but in such cases, you will be specifically asked to consent to this. Any personal data provided and processed based on such consent will also be covered by this Privacy Policy.

3.1.2.2 Employees

The personal data we will process about you includes, in addition to the data specified under section 3.1.2.1 (Candidate), contact details for next of kin, salary, and bank account information.
Black Pine Ventures may also need to process sensitive personal data about you, such as health information. Health data may need to be processed to allow Black Pine Ventures to fulfill its obligations as an employer.

3.1.3 Retention of Personal Data

The length of time personal data is stored depends on the type of data and the purpose of its processing. The data you register or that Black Pine Ventures registers in Black Pine Ventures’s operating system will be stored as long as it is deemed relevant, during the ongoing contractual relationship, and thereafter, in some cases, for a period prescribed by law. Your data will be stored until Black Pine Ventures has reason to believe that your personal data is no longer relevant, you are no longer employed by Black Pine Ventures, or you have withdrawn your consent for Black Pine Ventures to process your personal data.
Black Pine Ventures will generally retain personal data relating to: 

a) application and recruitment processes, for the current year of the most recent activity and for two (2) years thereafter;
b) employment contracts, for the current year and for ten (10) years thereafter;
c) customer and supplier agreements, as well as business transaction data, such as time reports, participants, assignments, salary, invoices, tax declarations, and financial statements, for the duration of the agreement and for ten (10) years thereafter; and
d) control data, until Black Pine Ventures's pension obligations cease.

3.2 For Customers or Suppliers

3.2.1 Purpose of Processing Personal Data

Personal data is processed only for the purposes described in this Privacy Policy. If you choose not to provide certain personal data, it may affect your use or the provision of the Service.
Black Pine Ventures processes personal data only to the extent necessary for the Service and for the services suppliers provide to Black Pine Ventures, or for other purposes outlined below. This also applies to sensitive personal data.
Black Pine Ventures processes personal data about customers' and suppliers' employees to:

a) allow you to use the Service or provide other services to Black Pine Ventures;
b) manage our relationship with you;
c) enable Black Pine Ventures to fulfill its obligations to you or the relevant individual, handle claims of alleged discrimination, resolve disputes, and handle complaints; and
d) enable future business relationships.

3.2.2 Personal Data

By accepting this Privacy Policy, you consent to Black Pine Ventures processing, where applicable, personal data about your employees and/or suppliers in accordance with this Privacy Policy. You also confirm that you have obtained consent for Black Pine Ventures's processing of personal data under this Privacy Policy from all relevant individuals.
Black Pine Ventures may also request that the individual provide additional personal data beyond what is stated below. Any personal data provided and processed based on such consent will also be covered by this Privacy Policy.

3.2.2.1 Customers

Black Pine Ventures may process contact persons' personal data. Such data includes name, address, email address, job title, areas of responsibility, and other data necessary for providing and following up on the Service, as well as enabling future business relationships.

3.2.2.2 Suppliers

Black Pine Ventures may process the personal data of contact persons and other employees. Such personal data includes the data specified under section 3.2.2.1 (Customers) and 3.1.2.1 (Candidate), as well as other data necessary for providing and following up on the Service, ensuring good service delivery to Black Pine Ventures, and enabling future business relationships.

3.2.3 Retention of Personal Data

The length of time personal data is stored depends on the type of data and the purpose of its processing. Black Pine Ventures does not store personal data for longer than necessary, considering the purposes for which it was collected unless otherwise prescribed by law.
The data you, as a supplier, register in your profile(s) or that Black Pine Ventures registers in Black Pine Ventures’s business system, with your or the relevant individual’s consent, will be stored as long as the respective account is active or during the ongoing contractual relationship. An account is considered inactive if no one has logged into it for an extended period, giving Black Pine Ventures reason to believe that the personal data has become outdated or that consent to the processing has been withdrawn.
Black Pine Ventures will generally retain personal data found in: 

a) application and recruitment processes, for the current year of the most recent activity and for two (2) years thereafter;
b) customer and supplier agreements, as well as business transaction data, such as time reports, participants, assignments, salary, invoices, tax declarations, and financial statements, for the duration of the agreement and for ten (10) years thereafter.

3.3 Personal Data for Marketing Purposes

The consent provided also covers the use of the information you provide to Black Pine Ventures for marketing and market research purposes. This is to provide candidates, employees, customers, and suppliers with a better experience and to improve and optimize the quality of the Service (e.g., by displaying content that may be of interest to you and delivering more relevant information).
If you no longer wish to receive marketing, you can contact us to indicate that you no longer wish to be contacted for marketing purposes.

3.4 Use of Black Pine Ventures's Website and Cookies

For a detailed description of how personal data is processed when you use Black Pine Ventures's website, and for information about Black Pine Ventures's use of cookies, see Black Pine Ventures's cookie guidelines.

4. Protection of Personal Data

Black Pine Ventures has taken appropriate technical and organizational measures to protect personal data against loss, misuse, unauthorized access, disclosure, alteration, and destruction. To ensure that personal data is processed securely and confidentially, we use data networks that are protected by firewalls and password protection in line with industry standards. To maintain the integrity of the personal data you provide via the internet, we may use encryption technology when transferring such data over the internet to our servers. Black Pine Ventures employees and suppliers are bound by confidentiality agreements and are required to follow Black Pine Ventures's information and IT security rules, this Privacy Policy, and other internal regulations that further govern the processing of personal data.

5. Sharing of Personal Data Between Companies Within Black Pine Ventures

As a general rule, Black Pine Ventures shares personal data related to candidates, employees, customers, and suppliers' employees with all companies within Black Pine Ventures to provide the Services. Sharing is necessary to quickly and efficiently offer relevant and exciting assignments to candidates and employees and to provide the best expertise to Black Pine Ventures's customers and open new business relationships.

Sensitive personal data is generally not shared between companies. Before sharing sensitive personal data, Black Pine Ventures always assesses whether such sharing is necessary for the purpose for which the sensitive personal data was collected and whether additional consent is required for sharing or if there is legal support for sharing the personal data.

A prerequisite for sharing personal data between Black Pine Ventures companies is that it is carried out in accordance with this Privacy Policy and relevant data protection legislation.

6. Sharing of Personal Data Outside of Black Pine Ventures

Black Pine Ventures will not sell, disclose, or distribute personal data to third parties, except as stated in this Privacy Policy. As part of the Service, personal data may be shared with Black Pine Ventures customers, suppliers, subcontractors, and partners if necessary for the execution and provision of the Service. Black Pine Ventures may also disclose your personal data to other third parties, such as Black Pine Ventures's suppliers for our operations, for example, for payroll administration, technical support, IT system operations, external testing companies, or suppliers managing job applications on our behalf. Parties to whom Black Pine Ventures may disclose personal data may be located outside the European Economic Area (EEA), which means that personal data may be transferred to countries outside the EEA. If Black Pine Ventures discloses personal data to suppliers outside the EEA, we will take measures to ensure that the personal data remains protected and also take the necessary steps to legally transfer personal data to countries outside the EEA.

Additionally, Black Pine Ventures may disclose personal data if required by applicable law, court decisions, or if such disclosure is necessary to assist in a legal investigation. In the event of a reorganization, merger, or sale, Black Pine Ventures may transfer personal data to the relevant third party, provided that the third party commits to processing the personal data in accordance with this Privacy Policy.

7. Black Pine Ventures as a Data Processor

Black Pine Ventures is the data controller for Black Pine Ventures's personal data, but there may be situations where Black Pine Ventures is not the data controller but acts as a data processor for a third party. When Black Pine Ventures processes personal data as a data processor, it does so on behalf of a third party, and Black Pine Ventures is bound by the instructions received from the data controller. In such situations, Black Pine Ventures cannot guarantee that the processing will be carried out in accordance with this Privacy Policy, but Black Pine Ventures will always ensure that the processing is done in compliance with applicable legislation and, as far as possible, in accordance with this Privacy Policy.

8. Your Rights

As an individual, you have the right to receive information, free of charge, once per calendar year, after submitting a signed written request to Black Pine Ventures at the address provided above (under "Data Controller"). You can inquire about the personal data Black Pine Ventures processes about you, as well as the scope and purpose of such processing. As an individual, you also have the right to request at any time that we block, delete, or correct your personal data. You always have the right to withdraw your consent and notify us that you oppose further processing of your personal data.

9. Changes to this Privacy Policy

Black Pine Ventures reserves the right to revise this Privacy Policy from time to time. The date of the latest change is stated at the end of the Privacy Policy. If we make any changes to the Privacy Policy, we will publish those changes on the website. You are therefore encouraged to read this Privacy Policy regularly to stay informed of any changes. If we change the Privacy Policy in a way that significantly differs from what was stated when your consent was collected, we will notify you of these changes and, if necessary, ask for your renewed consent for Black Pine Ventures's personal data processing.

10. Contact Us

If you have any questions regarding this Privacy Policy or our use of your personal data, please contact us at tamas@blackpineventures.com. All policies are evaluated annually and revised as needed.

Tamas Egei
393 Eerste Van Swindenstraat
1093GB Amsterdam
The Netherlands