A. Privacy Principles
This policy applies to all NetExpat sites and services including, but not limited to: netexpat.com, the NetExpat Community and NetExpat Community events, PartnerJob Explorer, the ExpAdviser, support programs and services, as well as other uses and functions of the NetExpat intranet (collectively “NetExpat Services” or “Services”).
B. General Information
NetExpat collects, processes, and uses data and/or information (“Personal Data”) about its candidates and their NetExpat accounts in accordance with the applicable laws and statutes of data protection of Belgium, the European Union, and the United States of America.
NetExpat uses Personal Data exclusively to provide users with NetExpat Services. NetExpat will not rent, sell, or otherwise provide Personal Data to any third party for the purposes of advertise or marketing without the User’s consent. The User acknowledges that in some instances, as described below, NetExpat does provide Personal Data to third parties in furtherance of its Services.
A. Personal Data collected by NetExpat
1. NetExpat Services and Intranet
In order to provide services to its candidates and users, NetExpat collects certain Personal Data from the ordering entity (“clients” or “the Client”). This information may include (but is not necessarily limited to): full name, address, email address, gender, date of birth, nationality, country and city of origin, street, postal code, and country of residence, phone number, host country, and information related to the Candidate’s employment history.
When a Candidate receives coaching through NetExpat (i.e. Career Continuation Coaching, Cultural Induction Training, Job Search Coaching, etc.), NetExpat and its affiliated consultants (“Consultant” or “Coach”) record Personal Data including the Candidate’s employment history and goals, international experience, notes regarding coaching sessions, Candidate feedback, and Candidate survey results. This information is used to provide and enhance NetExpat Services.
In addition, in order to gain access to NetExpat’s intranet services (including PartnerJob Explorer, ExpAdviser, etc.), the User must choose a password. The User’s name and password are never visible to any other NetExpat User or third party.
2. NetExpat Community Profile Information and User Content
Users who register with the NetExpat Community must provide their name, email address, location, and password. Users may provide additional information about him/herself (e.g. biographical information, professional background, social media sites, etc.) Providing information beyond what is required at registration is optional and provided at the User’s discretion, but such information may allow the User to enjoy better NetExpat services. Additionally, the User can upload, publish, display, or share comments, photos, messages, blogs, notes, texts, information, music, videos, and other content as outlined in the Terms and Conditions (“Content”) on or through the NetExpat Community. The User may also maintain relationships with other users, perform searches, form or join groups, and form or join events hosted by NetExpat or posted on the NetExpat Community. NetExpat retains all aforementioned data in order to provide the User with NetExpat Community Services and features. For example, messages are retained so the User can continue to view these messages at each log-in. Event information is retained so NetExpat can communicate with the User about event information, address, etc. When a User removes other Personal Data, NetExpat usually retains a backup copy of the prior version for a reasonable period of time.
3. Cookies and Log files
4. History, Logs, IP Addresses
Due to the communications standards on the internet, when the User visits NetExpat websites, NetExpat automatically receives the URL of the site from which the User came and the site to which the User visits after leaving NetExpat sites. NetExpat also receives the internet protocol (“IP”) address of the User’s computer (or the proxy server the User use to access the internet), computer operating system, web browser, email patterns related to NetExpat communications, as well as mobile device data including operating system, ISP, and mobile carrier (where applicable). NetExpat uses this information to analyze overall trends to help improve its Services. This data is not shared with third parties except as described below.
B. Sharing Personal Data with Third Parties
1. Other NetExpat Community Users
Profile information the User submits on the NetExpat Community is available to other NetExpat Community users. The User has the ability to limit what profile information is visible to other Users under the NetExpat Community Privacy settings.
2. Newsletters, Emails, and other Notifications
NetExpat regularly sends out newsletters, event invitations, and other NetExpat Services-related communications and emails (“User Communications”) to NetExpat Candidates. User Communications inform the User, among other things, about upcoming events, content, new features, messages, etc.
Some User Communications are facilitated by a third party marketing service. NetExpat provides User names and email addresses to this service in order to deliver personalized and relevant messages. Users have the option to opt-out of these emails.
Users can choose which NetExpat Community-generated emails they receive under their personal settings.
3. Information sharing with other Third Parties
NetExpat does not provide Personal Data or other User information to third-party marketers or advertisers. NetExpat shares Personal Data, User Content, and other information with third parties in limited circumstances where NetExpat believes sharing such information is reasonably required to offer NetExpat Services, legally required, or permitted by the User.
For example, NetExpat may share Personal Data with third party service providers when required for NetExpat Community technical development or the delivery of other NetExpat Services (including event hosting). Where NetExpat uses third party service providers who have access to User Personal Data, NetExpat implements reasonable contractual protections to keep the Personal Data confidential.
NetExpat may be required to disclose User Personal Data in order to comply with legal obligations and requests (i.e. court orders or subpoenas). NetExpat will not disclose any Personal Data unless legally required to do so or unless disclosure is necessary to protect the interests of property of NetExpat, to prevent fraud or other illegal activity perpetrated through NetExpat Services or sites, or to prevent imminent bodily harm. This disclosure may include sharing information with other companies, lawyers, agents, or government bodies.
NetExpat may use User Personal Data for purposes of aggregating data regarding the interest, success, use, and marketing of NetExpat Services. Any use of Personal Data in these instances would be anonymous and the individual User would not be identified.
4. Miscellaneous provisions
NetExpat sites including the NetExpat Community may contain links to outside websites not affiliated with NetExpat. NetExpat is not responsible for the privacy of these websites.
c. Changing or Removing Information
d. Terms of Conditions, Notices, Revisions
III. User Acknowledgements and Consent
Users acknowledge that when they post Content through the NetExpat Community and communicate with other members on the site at the User’s own risk. NetExpat allows the User to set privacy options that limit the visibility of his/her profile on the NetExpat Community and additionally protects User Personal Data and profile information from being viewed by non-NetExpat Community members and unauthorized parties by using industry standard protocols and technology. Likewise, NetExpat implements industry standard protocols to protect all User Personal Data. The User should be aware that that no security measure is impenetrable. It is therefore possible, though not likely, that the User’s Personal Data will become publicly available. Moreover, although all NetExpat Community members must agree to the NetExpat Community Terms and Conditions, NetExpat cannot control the actions of other NetExpat Community Users with whom User chooses to share Personal Data. Therefore, NetExpat cannot and does not guarantee that Personal Data, User Content, and other information posted to the NetExpat Community will not be viewed by unauthorized persons. NetExpat is not responsible for circumvention of any privacy settings or security measures contained on the NetExpat websites. The User understands and acknowledges that, even after Personal Data and Content are deleted from the NetExpat Community and other NetExpat sites, that information may be retained and viewable on cached and archived web pages or in the event that other Users have copied and stored this data and information. In accordance with the NetExpat Terms and Conditions, the User should not post sensitive information (home address, phone number, social security number, etc.) to the NetExpat Community. Users who post such information do so at their own risk.