Our Privacy Policy explains how we collect, use, and protect the personal information of our users. It is designed to be clear and easy to understand, so you can feel confident that your privacy is being respected when you use our website or app.
This Privacy Policy describes how Sourceful ICT ("Controller", "we", "us", or "our") processes personal data in accordance with Regulation (EU) 2016/679 (GDPR) and the Dutch GDPR Implementation Act (AVG).
The data controller is:
Sourceful ICT
Mandela Plein 1, 1314 CG Almere, The Netherlands
Email: office@sourceful.nl
This Privacy Policy applies to all users of our website https://sourceful.nl and related services ("Services").
Use of the Services implies acknowledgment of this Privacy Policy. Where required by law, explicit consent is obtained prior to processing.
We may process the following categories of personal data:
Identification data such as name, surname, username
Contact data such as email address, phone number
Professional data such as job title, employer, CV, education, work experience
Communication data including inquiries, correspondence, and chat interactions
Technical data including IP address, logs, device identifiers, and timestamps
Usage data including website interaction and analytics information
Cookie data and consent preferences
Personal data is processed for the following purposes:
Provision and operation of Services
Customer and user communication
Contract performance and pre-contractual activities
Recruitment and candidate evaluation
Marketing and sales activities where permitted
Website analytics and service improvement
Security management and fraud prevention
Compliance with legal and regulatory obligations
Processing is carried out under the following legal bases pursuant to Article 6 GDPR:
Article 6(1)(a) consent
Article 6(1)(b) performance of a contract or pre-contractual measures
Article 6(1)(c) compliance with legal obligations
Article 6(1)(f) legitimate interests, including service improvement, security, recruitment processes, and business operations
Where legitimate interest is used, a balancing test (LIA) is performed.
We process personal data of job applicants for recruitment purposes.
Data may be collected directly from candidates, referrals, or publicly available professional sources.
Processing includes evaluation of applications, communication with candidates, interview management, and selection procedures.
Categories of processed data include CVs, cover letters, contact details, professional experience, education, interview notes, and publicly available professional profiles.
Recruitment data is retained for a maximum of 12 months unless a longer retention period is explicitly consented to for future recruitment purposes.
Personal data may be disclosed to the following categories of recipients:
Authorised internal personnel
IT, cloud, hosting, and infrastructure providers
SaaS and recruitment service providers
Professional advisors (legal, compliance, accounting where applicable)
Public authorities where required by law
All third-party processors are bound by data processing agreements in accordance with Article 28 GDPR.
We do not transfer personal data outside the European Economic Area unless adequate safeguards are implemented in accordance with Chapter V GDPR.
Such safeguards may include Standard Contractual Clauses (SCCs) or adequacy decisions issued by the European Commission.
Personal data is retained only for as long as necessary to fulfil the purposes for which it was collected.
Retention periods are defined based on legal obligations, contractual necessity, and legitimate business interests.
When data is no longer required, it is securely deleted or anonymised unless legal retention obligations apply.
We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including protection against unauthorised access, alteration, disclosure, or destruction of personal data.
Security controls are aligned with recognised industry standards and principles consistent with ISO/IEC 27001:2022.
We use cookies and similar technologies for:
Essential website functionality
Performance and analytics
Security and fraud prevention
Marketing and user experience optimisation
Cookie consent is managed through a consent management platform (Cookiebot).
Users may manage or withdraw consent at any time via browser settings or consent tools.
We use analytics services such as Google Analytics provided by Google LLC (USA).
Where possible, data is anonymised or aggregated. We do not intentionally transfer directly identifiable personal data unless required for service functionality.
We also use Google reCAPTCHA for security and spam prevention. reCAPTCHA may process technical and behavioural data to distinguish between human users and automated systems.
Access and usage of the website may be logged for security, operational stability, and system administration purposes.
Logs may include IP addresses, timestamps, and system activity information.
Data subjects have the following rights under GDPR:
Right of access (Article 15)
Right to rectification (Article 16)
Right to erasure (Article 17)
Right to restriction of processing (Article 18)
Right to data portability (Article 20)
Right to object (Article 21)
Right to withdraw consent at any time (Article 7(3))
Data subjects also have the right to lodge a complaint with a supervisory authority, including the Dutch Autoriteit Persoonsgegevens or the Polish UODO.
We do not engage in automated decision-making, including profiling, which produces legal effects or similarly significant effects within the meaning of Article 22 GDPR.
Personal data is processed strictly in accordance with the principles of data minimisation and purpose limitation as defined in Articles 5(1)(b) and 5(1)(c) GDPR.
This Privacy Policy may be updated periodically to reflect legal, technical, or operational changes.
The latest version is always published on our website.
For any questions regarding this Privacy Policy or data protection matters, please contact:
Sourceful ICT
Email: office@sourceful.nl
