PRIVACY NOTICE RELATING TO THE PROTECTION OF PERSONAL DATA OF JOB APPLICANTS

Last updated on 10 June 2025.

PLUXEE LUXEMBOURG S.A. is a public limited company belonging to the PLUXEE Group (hereinafter, "PLUXEE" or "We"). This Privacy notice ("Privacy notice") contains important information about the processing of your Personal Information when you apply for a job with PLUXEE.

1.Purpose of this privacy notice

The purpose of this Privacy notice is to inform you about how we collect, use and process your Personal Information. This Privacy notice also describes the measures we take to ensure the protection of your Personal Data and specifies how you can contact us so that we can answer any questions you may have about the protection of your Personal Data.

PLUXEE is committed to complying with all applicable regulatory and legislative provisions on the protection of Personal Data such as the General Data Protection Regulation 2016/679 and national data protection laws. PLUXEE wishes to clarify what types of Personal Data are collected, and how your Data will be used and with whom Personal Data is shared. It also sets out your rights in relation to your Personal Data.

In this Notice :

"Personal Data" (hereinafter, "Personal Data" or "Data") means any information relating to an identified or identifiable natural person (hereinafter referred to as the "Data Subject"); an "identifiable natural person" is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity.

"Third country" means any country, territory or defined sector outside the European Union (EU) and the European Economic Area (EEA).

"General Regulation on the Protection of Personal Data or GDPR or Regulation" refers to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of Personal Data and on the free movement of such data, which replaces Directive 95/46/EC.

"Data controller" means the natural or legal person, public authority, agency or any other body which, alone or jointly with others, determines the purposes and means of the processing.

"Processing of Personal Data" means any operation or set of operations which is performed upon Personal Data or sets of Personal Data, whether or not by automatic means, including, but not limited to, collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

2. Scope of this Notice

Addressee of this Notice

This Privacy notice applies to :

  • job applicants who apply via the "Jobs" section of our website;
  • job applicants whose profiles we receive from our partners (temporary employment agencies, recruitment agencies, etc.) and partner recruitment assistance platforms;
  • any job applicant who comes into contact with PLUXEE as part of a job application (e.g. unsolicited applications);
  • any job applicant whose profile is made known to PLUXEE by any other means (references, social networks, etc.).

Insofar as PLUXEE is likely to collect and process Data from third parties that you have communicated to it, we kindly ask you to inform such third parties of the existence of this Privacy notice so that they may be aware of the processing that PLUXEE carries out on their Data and of their rights.

3. Identity and contact details of the Data Controller

3.1 Data controller

As part of its activities, PLUXEE may process your Personal Data in its capacity as Data Controller, insofar as it determines the means and purposes of the processing operation(s).

Details of the Data controller :

3.2.  Data protection SPOC

PLUXEE has appointed a Data Protection point of contact.

You may contact us if you have any questions regarding the processing of your Personal Data and the exercise of your rights.

Contact details:

E-mail: privacy.lu@pluxeegroup.com or via our Request form.

Postal address: 39 Rue du Puit Romain L-8070 Bertrange – Grand-Duché de Luxembourg.

4. Personal Data collected

When a job applicant applies for a job with PLUXEE, the following Personal Data may be collected and processed:

  • Identification data (first name, surname, date of birth, nationality, etc.) ;
  • Contact information ;
  • Education and training ;
  • References ;
  • Details of the interview;
  • Details of professional experience (job applied for, level of function, skills acquired, etc.) ;
  • Information on the applicant's right to work in Luxembourg ;
  • Expected salary and benefits ;
  • Photos and videos (voluntarily communicated by the job applicant via CVs or collected via our surveillance camera system).

In general, the Personal Data that PLUXEE processes will be communicated directly by you, via your resume (curriculum vitae), application letter or during interviews, via preference tests to which you submit yourself or other forms of evaluation.

PLUXEE also collects Personal Data from third parties, such as recruitment agencies or headhunters. Where permitted by regulation or legislation, PLUXEE may also receive information about you from former employers or referees if you give your consent, or from publicly available sources or social networks, such as LinkedIn.

5. Why does PLUXEE collect this information?

5.1. Selection and recruitment procedure 

PLUXEE collects Personal Data in order to evaluate, examine and process applications for vacancies or spontaneous applications, to contact the applicant and to conclude a possible employment contract. The processing of a job applicant's Personal Data is therefore justified and necessary as part of the recruitment process and for the performance of pre-contractual measures or on the basis of PLUXEE's legitimate interest. 

To this end, PLUXEE may collect and process the categories of Data set out in article 4.

In particular, this Data may be collected from former employers if you have given your consent.

5.2 Storing your Data in a recruitment reserve

PLUXEE retains the data of unsuccessful job applicants in a recruitment pool for a period of two years from the last contact with the said job applicant on the basis of PLUXEE's legitimate interest, which is to be able to contact unsuccessful job applicants in order to offer them new job opportunities as soon as vacancies become available within PLUXEE.

To this end, PLUXEE may collect and process the categories of Data set out in article 4.

Applicants may object to this processing at any time or request that their Personal Data be deleted. 

5.3 Ensuring the safety and security of people and property

PLUXEE uses a surveillance camera system provided by the owner of the building where the offices are located. These surveillance cameras in the building are only intended to ensure the safety of people and property and to prevent any intrusion.

In this context, the following categories of Data will be processed:

  • Images (photos/videos taken via our surveillance camera system).

The images recorded by the surveillance cameras are kept for a specific period of time as mentioned in point 8 of this Privacy notice. 

6. The legal basis for processing Personal Data

The Personal Data mentioned above is processed and collected only insofar as it is necessary to achieve the objectives described in article 5.

In accordance with Article 6 of the GDPR, PLUXEE will only use and process your Data if the following conditions are met:

  • The use of your Data is necessary to carry out the necessary stages of the recruitment procedure and, where applicable, to conclude a contract with you (pre-contractual and contractual phase).
  • You have consented to the use of your Data. Insofar as we process your Personal Data on the basis of your consent, you have the right to withdraw your consent at any time. You can do this by contacting us (see below).
  • The use of your Data during the recruitment process is necessary for PLUXEE's legitimate interests. Where PLUXEE processes your Data to satisfy its legitimate interests, it will ensure that a fair balance is struck between your fundamental rights and freedoms, including your privacy, and its legitimate interest(s).
  • Finally, in certain cases, PLUXEE is legally required to process certain Data by virtue of certain legal obligations, and where applicable to disclose it to the competent authorities. For example, PLUXEE is required to verify the eligibility of a successful job applicant to work in Belgium prior to the commencement of employment.

7. How will your Personal Data be used and shared?

PLUXEE may share your Personal Data with related entities belonging to the Group to which it belongs.

In specific circumstances, PLUXEE may share your Personal Data with third parties who perform functions on our behalf and provide services to us, such as temporary employment agencies or recruitment agencies.

PLUXEE may disclose your Personal Data to comply with its legal obligations or in the interest of safety, public interest or law enforcement. PLUXEE may also disclose Data in connection with actual or potential litigation or to protect its property, safety, employees and other rights or interests.

Your Personal Data will not be sold or rented to third parties.

8. Transfer of your Personal Data outside the EU/EEA

Given the international nature of the PLUXEE group, your Personal Data may be transferred to recipients, whether internal to the PLUXEE group or external, authorised to perform services on our behalf. 

In principle, PLUXEE does not transfer Personal Data outside the European Union (EU) or the European Economic Area (EEA).  If PLUXEE plans to store and/or process it outside the EU/EEA, it must ensure that an adequate level of protection, i.e. equivalent to that applicable within the EU or the EEA, is guaranteed.

If a transfer of your Personal Data must take place to third countries, PLUXEE will take all necessary and appropriate measures to guarantee the security and confidentiality of your Personal Data transferred and thus ensure a level of protection equivalent to that in force within the European Union or the European Economic Area. In particular, any such transfer will be governed by one of the mechanisms provided for in Chapter V of the GDPR (adequacy decision, Standard Contractual Clauses, binding corporate rules, etc.). 

If you would like more information about the international transfers of Personal Data that we may make and the appropriate safeguards in place to secure such transfers, please contact us at privacy.lu@pluxeegroup.com or via our Request form.

9. How long do we keep your Personal Data?

If your application for employment is unsuccessful, PLUXEE will retain your Personal Data for a period of two years from the last contact with the unsuccessful applicant in order to consider other employment opportunities, unless you object.

If your application is successful and you are offered a position at PLUXEE, the Personal Data collected during the recruitment process will be transferred to your personal file and retained for the duration of your employment. The period for which your Data will be retained as an employee will be communicated to you in a separate Privacy notice for workers.

Images from surveillance cameras are kept for a period of one month, in accordance with the law, unless otherwise requested by the competent authorities.

10. Data security

Your Data is considered as strictly confidential. To this end, we have taken all appropriate technical and organisational measures to protect it against any accidental destruction, loss or alteration, as well as against any damage, accidental or illicit access or other unjustified processing of the Data.

We take all reasonable steps in accordance with the principles of privacy by design and  by default to put in place the necessary safeguards and to secure the Processing of Personal Data. Depending on the level of risk presented by the Processing, we also carry out a privacy impact assessment in order to adopt the appropriate protection measures and guarantee the protection of the Personal Data of job applicants applying for a job at PLUXEE.

11. Rights of job applicants

You have certain rights in relation to the Personal Data we hold about you:

  • Right to be informed: you have the right to be informed, at the latest at the time of collection of your Data, about the processing that we carry out, your rights relating thereto and how to exercise these rights. To this end, we have drawn up this Privacy notice.
  • Right of access: you have the right to consult the information concerning you and to obtain a copy of the information we hold.
  • Right of rectification: you may ask us to rectify, complete or delete any out-of-date, incorrect or incomplete Data we hold about you.
  • Right to erasure: in certain circumstances, you have the right to obtain the erasure of Personal Data we hold about you, for example where such Personal Data is no longer necessary for the purposes for which it was collected or where you have withdrawn your consent and there is no other legal basis for processing the Data.
  • Right of opposition and restriction: in certain circumstances, you have the right to request the restriction of the processing of your Personal Data. PLUXEE may therefore temporarily and/or partially stop the processing being carried out. You may definitively stop a specific processing operation or all processing operations carried out by PLUXEE on your Personal Data by exercising your right to object.
  • Right to Data portability: At the request of a job applicant and provided that it is technically possible, PLUXEE must provide job applicants with a copy of their Personal Data processed, in a digital, readable and structured format. In this way, job applicants can save them for personal (re)use, or ask the Data Controller to transfer them to another Data Controller. Data protection legislation limits this right to Data that was initially provided to PLUXEE by the applicant.
  • Right to lodge a complaint: You may decide to lodge a complaint with the Data Protection Supervisory Authority in your country of habitual residence. For Luxembourg, this is the National Commission for Data Protection (CNPD). You can contact the CNPD via the following channels:

You may, at any time and without justification, exercise these rights or contact us with any request or complaint relating to the protection of your Personal Data. To do so, please contact us via one of the following channels:

  • Via our Request form
  • By email: privacy.lu@pluxeegroup.com
  • By post: PLUXEE Luxembourg S.A For the Data Protection point of contact39 Rue du Puits Romain L-8070 Bertrange Grand-Duché de Luxembourg

When making your request, please indicate clearly which right you wish to invoke and which Data processing you wish to oppose or limit or which consent you wish to withdraw.

In order to ascertain the identity of the person making the request to exercise a right or to obtain information about their Personal Data, we check the identity of the person making the request in our systems. If there is reasonable doubt regarding the identity of the person making the request, we may ask for additional information to confirm the identity of the person concerned.

Exercising your rights under the GDPR is free of charge unless we consider that the request is manifestly unfounded or excessive (for example, in the case of repeated or untimely requests).

We will respond to your request within the period legally prescribed by the GDPR, i.e. one month from receipt of your request. This period may be extended to a further two months if the request is complex and/or because of the number of requests we have to process. If the said period has to be extended, you will be notified of this and of the reason for the extension.

Please note that in certain circumstances provided for by law, we may refuse access to your information or not comply with your request where we are legally authorised or obliged to do so. In the event of a manifestly unfounded or excessive request, we may also refuse to grant your request(s).

12. Modification of this Privacy notice

We reserve the right to amend or supplement this Privacy notice if necessary.

In the event of significant modifications, the modification date will be updated and a copy of the new Privacy notice will be published on our Website.

We encourage you to consult this Privacy notice periodically to find out how we process and protect your Data.

Updated on 10 June 2025.