Data controller
7N A/S
Emdrupvej 26, 2.
2100 København Ø
Danmark
Company registration number: 50810216.
This is version 12, last updated 27.10.2023.
1. Introduction
1.1 This Data Protection and Privacy Policy (the “Policy”) describes how 7N A/S and subsidiaries (“us”, ”we” or ”our”) processes personal data in correction with the provision of consultancy services.
When we processes personal data in connection with the provision of consultancy services, we consider ourselves a data processor, as we process personal data on behalf of our customers and in accordance with customer instructions. We then enter into a data processing agreement with the customer containing instructions, terms and conditions for our and the consultant's processing of personal data.
This data protection and privacy policy contains information on our processing of personal data, when we are the data controller for the use of this website and for personal data which we process about consultants and candidates. More information on this may be found below.
1.2 The Policy is prepared and made available to comply with the General Data Protection Regulation (2016/679 of 27 April 2016) (the ”GDPR”) and the rules included herein on information to be provided to you.
2. Collecting personal data with cookies
2.1 By visiting and using our website(s), cookies are collected and used based on your consent. Information in these cookies include ("Cookiedata"):
a) browser type
b) search terms on our website(s)
c) search terms on other website(s)
d) IP address
2.2 We also collect the type of computer and technical information about means of connection to our website or my7N, such as the operating system and the Internet service providers’ utilized and other similar information.
2.3 Cookiedata is used for: improvement of the website(s) and user experience, to deliver our products, services or goods, administration of customer relationships in general such as orders, purchase history, invoicing, etc., customer support.
2.4 Our use of cookies for the purpose of collecting personal data is carried out in accordance with section 3 of the Executive Order (No. 1148 of 9 December 2011).
2.5 If you wish to limit or decline the cookies placed on your computer when visiting our website you can do so at any time by changing your browser settings. However, you should be aware that if you decline or reject cookies it will impact the functionality of the website which means that there are features on the website that you will not be able to see. Any browser allows you to delete cookies collectively or individually. How this is done depends on the browser you use. Remember to delete the cookies in all browsers, if you use several different browsers.
2.6 We disclose and/or share Cookie Data with:
trusted partners like Facebook, LinkedIn, Youtube, Jivo and analytics companies like Google Analytics may also place cookies on your device. Please read our partners' privacy policies to ensure that you're comfortable with how they use cookies.
We use Google Analytics as a web analytics service. This service provides statistical information about users of our website. Google Analytics processes among others IP addresses and information from cookies used on our website to clarify the number of page views, the number of users, which browsers the users use. This information does not contain personally identifiable data.
We use Facebook Pixel to track visitor activity on our Website. This means that Facebook collects the following information:
- Http Headers – Anything present in HTTP headers. HTTP Headers are a standard web protocol sent between any browser request and any server on the internet. HTTP Headers include IP addresses, information about the web browser, page location, document, referrer and person using the website.
- Pixel-specific Data – Includes Pixel ID and the Facebook Cookie.
- Button Click Data – Includes any buttons clicked by site visitors, the labels of those buttons and any pages visited as a result of the button clicks.
Among others, we track the following events: view content, search tracking, lead tracking on form submission, complete registration.
We use Facebook Pixel for the following purposes: Targeted marketing campaigns, including track conversions, remarket/build custom audience based on page visitors and to enhance the targeting of ads.
You can read more about the Facebook Pixel via the following links:
https://www.facebook.com/business/learn/facebook-ads-pixel and
https://www.facebook.com/privacy/explanation.
You can choose not to receive targeted marketing by changing your ad preferences and settings on your Facebook account or by following the link below:
https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen.
For more information about the cookies that we place on your computer, including third-party cookies, please refer to the “cookie declaration” which you will find in the cookie box.
2.7 Below you will see an overview of the duration of the cookies we use:
How long the cookies are stored on your computer varies. For more information about the expiration of the cookies, please refer to the “cookie declaration” which you will find in the cookie box.
3. Types of personal data processed
3.1 We process personal data about you when this is necessary and in accordance with the applicable legislation.
3.2 Website:
In addition, we also process the following types of personal data: IP Address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform or other identifiable personal data only when it is voluntarily submitted.
Furthermore, we collect technical information about your website visit including Uniform Resource Locators (URL) clickstream, length of visits to certain pages and page interaction information (such as scrolling, clicks, and mouseovers).
Consultants and candidates:
We process the following types of information: Name, address, email address, telephone number, data pf birth, nationality, photographs.
When using my7N, you may provide additional information to create a profile to be used to sell your services as a consultant to potential customers. Information provided may include LinkedIn data, CV, references form former employers, education and credentials, information on services offered, passport number and social security
number and other various information than cannot be speficied beforehand. We will only collect and process your criminal record and social security number with your explicit consent.
In order to administrate the contract with a potential customer, we may need to process the following information: Background check results, contracts, invoices and related documentation, VAT identification number, social/ tax attestations, bank details.
We also process personal data about you when signing up and participating in an event held by 7N. In this connection we process contact information (such as name, email address, phone number) and other information that may be relevant for the specific event.
3.3 Depending on the circumstances and only when it is strictly relevant and necessary, we may process special categories of personal data (so-called "sensitive personal data").
These personal data include:
a) health information of one or more persons (health, illness, diagnosis, etc.)
3.4 We process these sensitive personal data for the following purposes: We may process information about your health if this is relevant (1) in order to administrate your work as a an consultant at 7N or (2) necessary in connection with your participation in an event helt by us.
3.5 When relevant, personal data is collected directly from you or from external sources. If you are a consultant or candidate at 7N, we may collect references from former customers and/or your criminal records if necessary and requested by a potential customer. We may also collect personal data from user profiles from publicly accessible sources, such as LinkedIn.
3.6 If we need to collect more personal data than specified above, we will inform you by updating this Policy.
4. Purposes for processing the personal data
4.1 We will only process your personal data if we have a legitimate purpose and in that case in accordance with the rules of the GDPR. The personal data we collect about you is processed for the following purposes:
a) To deliver products or services.
b) To respond to inquiries or complaints.
c) To improve our products, services, or website.
4.2 In addition to the above, we also process the personal data for the following purpose(s):
- for operation and maintenance purposes, including collecting files that record interaction with this Website and my7N (System Logs or IP Address)
- for legal purposes, including in Court or in the stages leading to possible legal action arising from improper use of this Website, my7N or related services and with respect to my7N,
- in order to create a profile of the consultant and to share this with potential customers for the purpose of selling the users services as a consultant.
- in order to send out invitation to events held by 7N and to facilitate such an event
- administration of 7N Alumni Program
Machine Learning:
As part of 7N’s agents' matching process, our agents have a matching tool available, that employs machine learning technology to ensure the best possible match. This means that the matching tool integrates with 7N's CRM system and my7N databases and creates lists based on CV data (summary, skills, and work experience) as well as information about availability and current assignment. In the end, our agents are
presented with a list of potential consultants suitable for an assignment. The agent can then review this list when matching a consultant with an assignment and/or customer.
5. Legal basis for processing personal data
5.1 We only process your personal data when we have a legal basis to do so in accordance with the GDPR. Depending on the specific circumstances, the processing of personal data is done on the following legal basis:
a) The legal basis for the processing of such personal data is consent, in accordance with GDPR, Article 6(1)(a). You can withdraw your consent at any time by contacting us via the contact details provided at the end of this Policy. If you withdraw your consent, the personal data processed will be deleted, unless it can or must be processed in order to comply with legal obligations.
b) The processing is necessary for the purposes of the legitimate interests where such interests are not overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data in accordance with GDPR, Article 6(1)(f).
c) The processing is necessary for the performance of a contract to which the data subject is a party in accordance with GDPR, Article 6(1)(b), the first indent.
d) The processing is necessary in order to take steps at the request of the data subject prior to entering into a contract in accordance with GDPR, Article 6(1)(b), last indent.
e) The processing is necessary to comply with applicable legislation in accordance with GDPR, Article 6(1)(c).
5.2 When it is strictly relevant and necessary, sensitive personal data (the “special ncategories of personal data”) listed in the GDPR, Article 9(1), may be processed. In such case the processing will only take place when permitted by the GDPR, Article 9(2) to Article 9(4), including but not limited to the following instances:
a) Your explicit consent in accordance with the GDPR, Article 9(2)(a).
6. Disclosure and transfer of personal data
6.1 We only transfer personal data to other entities when legally permitted or required. Our organization is part of a concern or a group of companies where, depending on the circumstances, personal data is shared.
6.2 We transfer personal data to the following recipients from the EU/EEA:
a) Banks (for example in connection with payments etc.)
b) Processors
c) Suppliers
d) Collaborators
6.3 We may transfer personal data to affiliate or subsidiary companies, as well as employees and service providers in charge of or involved in the operation of the Website or my7N (administration, sales, marketing, legal, system administration), as well as agents, and professional advisors.
Furthermore, we may transfer personal data to external business partners, vendors, suppliers in order to deliver a service to us or on the behalf of us, such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies in order to assist in processing the personal data.
If you are a consultant with us, we will share your relevant personal data with a customer in order to sell your services as a consultant to the customer.
6.4 From time to time, we use external entities as suppliers to assist us in delivering our services. The external suppliers will not receive or process personal data unless applicable law allows for such transfer and processing.
Where the external parties are acting in the role of processors, the processing is always based on a data processing agreement in accordance with the requirements under GDPR.
Where the external parties are acting in the role of controllers, the processing of personal data is based on such external parties’ data privacy policy and the relevant legal bases which the external parties are obligated to inform about unless the applicable legislation allows otherwise.
6.5 We transfer personal data to countries or international organisations outside the EU/EEA.
6.6 If personal data is transferred outside of the EEA we ensure an adequate level of security by transferring to countries approved by the European Commission as having an adequate level of protection, or by entering into appropriately-drafted contract between us and the non-EEA entity receiving the data.
7. Erasure and retention of personal data
7.1 We ensure that the personal data is deleted when it is no longer necessary for the processing purposes described above.
However, we retain your personal data to the extent that we are legally obligated, as is the case with for example accounting and bookkeeping materials and records. According to this we store personal data about consultants for up to 6 years from the end of the year in which the consultant's engangement with us terminated.
Personal data about candidates are stored for up to 5 years from our latest contact or business interaction with the candidate.
If you have any questions about our retention of your personal data, you may contact us by using the email mentioned in the last section of this Policy.
8. Data subject rights
8.1 As a data subject under GDPR, you have a number of rights.
8.1.1 You have the right to request access to the personal data we process about you, the purposes we process the personal data, and whether we disclose or transfer your personal data to others.
8.1.2 You have the right to have incorrect information rectified.
8.1.3 You have the right to have certain personal data deleted.
8.1.4 You may have the right to restriction of our processing of your personal data.
8.1.5 You may have the right to object to our processing of your personal data based on reasons and circumstances that pertain to your particular situation.
8.1.6 You have the right not to be subject to a decision based solely on automated means, without human interference unless the decision (1) is necessary for entering into, or performance of a contract between you and the Organization, (2) is authorised by law, or (3) is based on your explicit consent.
8.1.7 If the processing of your personal data is based on your consent, you are entitled to withdraw such consent at any time. Withdrawal of your consent will not affect the lawfulness of the processing carried out prior to your withdrawal.
8.1.8 You are entitled to receive personal data which you have provided to us in a structured, commonly used, and machine-readable format (data portability).
8.1.9 You can always lodge a complaint with the data protection authority.
8.2 Your rights may be subject to conditions or restrictions. Accordingly, there is no certainty that you will be entitled to for example data portability in the specific situation; it will depend on the circumstances of the processing.
8.3 More information about data subject rights can be found in the guidelines of the national data protection authorities.
8.4 Please use you the contact details below if you want to use your rights.
8.5 We try to meet your wishes about our processing of personal data, but you can always file a complaint to the data protection authorities.
9. Changes to this Policy
9.1 We reserve the right to update and amend this Policy. If we do, we correct the date and the version at the top of this Policy. If we make significant changes, we will provide notification by way of a visible notice, for example on our website or by direct message.
10. Contact
10.1 You may contact us at the below specified email if you:
a) disagree with our processing or consider our processingof your personal data infringeson the law,
b) have questions or comments to this Policy, or
c) want to invoke one or more of your rights as a data subject described in this Policy.
If you have questions or comments to this Policy or if you would like to invoke one or more data subject rights, please contact us at info.DK@7N.com
This is version 12, last updated 27.10.2023.
Yours sincerely,
7N A/S