WhoVinc Privacy Statement

WhoVinc is responsible for the processing of personal data within the WhoVinc platform.

WhoVinc is currently in its start-up phase. The formal company and contact details of the responsible organisation will be added here once they have been finalised.

For privacy questions, you can use the contact options provided by WhoVinc. A dedicated privacy contact address will be listed here once available.

Account data

To create and secure your account, we may process data such as:

• name
• email address
• account identification
• authentication and security data
• account settings
• information about active sessions

If you use two-factor authentication, we process the information required to link this security feature to your account.

Profile data

You can add professional information to your profile, such as:

• profile picture
• name and professional title
• current and previous positions
• employers
• education
• degrees and fields of study
• skills
• location information you add yourself
• other professional information you provide

You largely decide yourself which information you add to your profile.

Network and activity

When you use WhoVinc, we may process information about connections, connection requests, followed companies, posts, comments, discussions, interactions with content and other activity required to provide the network features you use.

Messages

When you send messages through WhoVinc, we process the message and the information required to deliver it to the intended participant or participants and to provide the messaging service.

Companies, jobs and applications

When you use company, job or application features, we may process company information, job postings, application information, application status and necessary communications.

When you apply for a job, the relevant information may be made available to the company concerned.

Technical and security data

To keep WhoVinc reliable and secure, we may process technical information including sessions and login activity, device and browser data, IP addresses, security events, failed or suspicious login attempts, technical errors and platform abuse.

Providing our services

Many processing activities are necessary to provide the services you request from WhoVinc, including your account and profile, connections, messages, posts, jobs, applications and saved settings.

Where applicable, we rely on the necessity to perform our agreement with you or to take steps you have requested.

Legitimate interests

For certain processing activities, WhoVinc may rely on legitimate interests such as security, fraud prevention, user protection, moderation, reliability, and preventing spam and unwanted behaviour.

When relying on legitimate interests, we balance those interests against the rights and interests of users.

Consent

Where the law requires consent, we ask for it before the relevant processing takes place. This may apply to certain non-essential cookies or similar technologies.

You can withdraw consent. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

Legal obligations

In some situations, we must process or retain information because the law requires us to do so.

WhoVinc is a professional network. Some information is therefore intended to be shared with other users.

Through WhoVinc settings, you can make choices about profile visibility, certain profile information, contact details, discoverability and connections.

We aim to enforce privacy settings technically as closely as possible to the actual processing.

WhoVinc may display advertisements to support the platform and its business services.

Depending on your settings, certain profile or activity information may be used to make advertisements more relevant.

Through Advertising Data in your settings, you can decide whether supported categories may be used for advertising targeting.

This may include information about:

• profile location
• current position
• previous positions
• current employer
• skills
• education
• fields of study
• degrees
• connections
• followed companies
• interests and activity

If you disable a supported category, that category should no longer be used for that advertising targeting.

Advertising preferences are separate from consent for non-essential tracking technologies.

WhoVinc may use necessary cookies and similar technologies to keep users signed in, provide security features, remember settings and operate essential parts of the website.

For non-essential analytics or advertising technologies, we request consent where legally required.

You can manage these preferences through WhoVinc's cookie and privacy settings.

WhoVinc may send emails about activities related to your account, such as connection requests, messages, comments, jobs, applications and business features.

For optional categories, you can change your preferences under Notifications in your settings.

Messages required for security, account management or important moderation matters cannot always be disabled.

WhoVinc does not sell your personal data as a commodity.

Personal data may nevertheless be processed or shared where necessary for WhoVinc to function. This may include:

• other users when information is visible according to the platform's operation and your settings
• companies when you intentionally use a company or application feature
• technical service providers needed for hosting, infrastructure, email, security, analytics or other platform functions
• competent public authorities where WhoVinc is legally required to provide data

Service providers only receive access to data to the extent necessary for their task and permitted by the applicable agreements.

WhoVinc aims to process personal data and important platform services within the European Economic Area as much as possible.

A supplier or technical service may nevertheless process data outside the EEA.

Where personal data is transferred outside the EEA, we ensure a valid transfer mechanism and appropriate safeguards where required, such as an adequacy decision by the European Commission or applicable standard contractual clauses.

We do not keep personal data longer than necessary for the purpose for which it was collected. The exact retention period may differ by type of data.

We consider factors including:

• how long your account remains active
• whether data is needed to provide a feature
• security and fraud prevention
• possible disputes
• legal retention obligations

When data is no longer necessary, it is deleted or, where appropriate, anonymised unless there is a valid reason to retain it longer.

WhoVinc takes technical and organisational measures to protect personal data against loss, misuse, unauthorised access and unwanted modification.

We use different security measures for accounts, authentication, systems and infrastructure.

For security reasons, we do not publish technical details that could be used to bypass security measures.

No online system can guarantee complete security. We therefore continue to evaluate and improve our security measures.

To keep WhoVinc safe and professional, we may investigate content, accounts and activities where there is reason to do so.

This may occur following user reports, suspected fraud, spam, unwanted or prohibited content, account abuse or security incidents.

We aim to use only the data necessary to assess the situation and take appropriate measures.

WhoVinc may use automated techniques to identify security risks, spam, unwanted content or relevant information.

WhoVinc does not currently, as a general practice, make decisions based solely on automated processing that produce legal effects or similarly significantly affect users within the meaning of Article 22 GDPR.

If WhoVinc introduces such systems in the future, we will inform users and provide additional safeguards where required.

The GDPR gives you various rights regarding your personal data.

Depending on the circumstances, these may include the right to:

• access your personal data
• correct inaccurate data
• erase personal data
• restrict processing
• data portability
• object to certain processing
• withdraw consent

Some of these rights can be exercised directly through WhoVinc. Under Data Privacy, you can request a copy of your data, among other things.

For a request, we may ask for additional information where reasonably necessary to verify that the request genuinely comes from you.

If you have a question or objection about how WhoVinc handles your personal data, we appreciate you contacting us first so that we can investigate.

You also have the right to lodge a complaint with a competent data protection authority. In the Netherlands, this is the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

WhoVinc allows users to delete their account.

When an account is deleted, personal data is removed or disconnected from the account insofar as it is no longer necessary.

Some data may be retained temporarily or for longer where necessary for security, fraud prevention, a legal dispute or a legal obligation.

Only post personal data about other people on WhoVinc when you have a valid reason and doing so fits the operation of the platform.

Where WhoVinc does not obtain personal data directly from the person concerned, additional information obligations may apply.

WhoVinc is a platform under development. New features may affect how personal data is processed.

We may therefore update this privacy statement. Where a change is important to how your personal data is used, we will communicate it clearly where appropriate.

The date on which this privacy statement was last updated is shown at the top of this page.

WhoVinc is currently in its start-up phase. Final legal company and contact details will be added here once established.

In the meantime, if you have a privacy question or wish to exercise a privacy right, you can use the contact options WhoVinc provides on the platform.