Privacy Policy

The data controller for personal data processed via this website is Apro BV, operating under the trade name TailorTalents, with registered office at Burgemeester Michel Du Tré-straat 13, 9250 Waasmunster, Belgium. Company number / BTW number: BE 0773.466.716 (RPR Gent, afdeling Dendermonde).

For any privacy-related question, request to exercise your rights, or complaint, you can reach us at:

• Email: info@tailortalents.be
• Postal: Apro BV (TailorTalents), Burgemeester Michel Du Tré-straat 13, 9250 Waasmunster, Belgium
• Phone: +32 483 09 79 47

We have not appointed a Data Protection Officer (DPO) — our processing activities do not meet the thresholds in Article 37 GDPR. The contact above is the responsible privacy point of contact.

This policy applies to personal data processed in connection with our website at tailortalents.com, our operations portal and the TailorTalents mobile app for authorised employees and contractors. It covers visitors, prospects, client contacts, delivery recipients and app users.

Where we process personal data on a client's instructions (including delivery routes, recipient details and installation schedules), the client is generally the controller and TailorTalents acts as processor under the applicable contract and data-processing agreement. Those terms continue to apply alongside this policy.

Data you provide directly

• Contact form submissions: name, role, company, email, phone, message contents
• Email correspondence and call notes initiated by you
• Information you submit when applying for a role (CV, motivation, contact details)

Operations portal and mobile app data

• Account and employment identifiers: name, work email, user and company identifiers, role and authentication records
• Route and order information needed for the job: delivery or collection addresses, recipient contact details, access instructions, materials and status updates
• Operational entries made in the app: route and stop actions, timestamps, notes, checklist results and failure reasons
• Proof of service: photos, signatures and the time and location at which proof was captured
• Precise live location while an assigned route is active, together with accuracy, speed and heading where supplied by the device
• Device push-notification token and platform
• Diagnostic reports: error message, technical stack, app platform, affected screen and, when signed in, user and company identifiers

Data collected automatically

• Server logs: IP address, user agent, requested URL, timestamp, response status (security and operational purpose)
• Strictly necessary cookies (see our Cookie Policy)
• Aggregate, non-identifying usage data (page-view counts) where available

Purposes and legal bases

Where we rely on legitimate interest, we have carried out a balancing test that weighs our interest in B2B commercial relationships against your reasonable expectations and rights. You can request a copy of this assessment at the contact above.

We share personal data only with categories of recipients that are necessary to deliver our services or comply with a legal obligation. Concretely:

• Hosting and cloud infrastructure: Amazon Web Services (AWS) and Microsoft Azure
• Mobile distribution and message transport: Apple, Google/Firebase and Expo Application Services
• Email: Amazon WorkMail
• Accounting and invoicing: our accountant under a strict confidentiality engagement
• Transport and installation subcontractors, only when they are needed to perform a delivery or install you have ordered
• Public authorities, when required by Belgian law

Each external processor that handles personal data on our behalf operates under a written data-processing agreement (Article 28 GDPR) that requires them to act only on our instructions and to apply appropriate security measures.

Some of our processors are based outside the European Economic Area, in particular in the United States. Where this is the case, we rely on:

• The EU–US Data Privacy Framework (DPF) where the recipient is DPF-certified (Amazon Web Services, Microsoft, Amazon WorkMail are all DPF-certified) — Adequacy Decision (EU) 2023/1795 of 10 July 2023
• European Commission Standard Contractual Clauses (SCCs) where the recipient is not DPF-certified, supplemented by appropriate technical and organisational measures

You can request a copy of the safeguards we apply to a specific transfer at the contact above.

We apply technical and organisational measures appropriate to the risk: TLS encryption in transit, access control on a need-to-know basis, written confidentiality engagements with staff and processors, and a defined incident-response procedure for any suspected personal-data breach. We will notify the Belgian APD within 72 hours of becoming aware of a notifiable breach (Article 33 GDPR) and inform affected data subjects without undue delay where the breach is likely to result in a high risk to their rights and freedoms (Article 34 GDPR).

Under the GDPR you have the following rights with respect to personal data we hold about you:

• Right of access — request a copy of the personal data we hold (Art. 15)
• Right to rectification — ask us to correct inaccurate or incomplete data (Art. 16)
• Right to erasure — ask us to delete your data, subject to applicable retention obligations (Art. 17)
• Right to restriction — ask us to limit processing in certain circumstances (Art. 18)
• Right to data portability — receive a machine-readable copy of data you provided to us under consent or contract (Art. 20)
• Right to object — object at any time to processing based on our legitimate interest, including an absolute right to object to direct marketing (Art. 21)
• Right to withdraw consent — at any time, where processing is based on consent, without affecting prior lawful processing (Art. 7(3))
• Right not to be subject to a decision based solely on automated processing producing legal or similarly significant effects on you (Art. 22) — we do not currently make such decisions

To exercise any of these rights, including deletion of TailorTalents mobile-app data, email info@tailortalents.be with the subject 'Mobile data deletion'. Include the work email and organisation linked to the account, but never send a password. We will verify the request, disable or remove the account and device token as applicable, and delete data for which TailorTalents is controller. Route actions, proof photos, signatures and related order records may be retained where the client remains controller or where contractual, legal, claims or audit duties require it; live route position is deleted when the route ends and client-error diagnostics are deleted after 30 days by default. We will respond within one month and may extend this by two months for complex requests, in which case we will tell you why.

If you believe our processing of your personal data infringes the GDPR, you have the right to lodge a complaint with the Belgian Data Protection Authority (Gegevensbeschermingsautoriteit / Autorité de protection des données — APD/GBA):

• Drukpersstraat 35 / Rue de la Presse 35, 1000 Brussels, Belgium
• Phone: +32 (0)2 274 48 00
• Email: contact@apd-gba.be
• Web: gegevensbeschermingsautoriteit.be / autoriteprotectiondonnees.be

We would be glad to address any concern with you directly first — but you can also approach the APD without contacting us, and at any time.

We currently use only strictly necessary cookies. The full list and details are in our separate Cookie Policy.

Our services are directed at businesses, not at children. We do not knowingly collect personal data from persons under 16 (the Belgian age of digital consent under Article 7 of the Act of 30 July 2018 is 13, but our services are not directed at minors).

We may update this policy to reflect changes in our processing activities, in technology, or in applicable law. The version number and 'Last updated' date at the top of this page reflect the current version. Material changes that affect your rights will be communicated through this website and, where appropriate, by direct notice.

Questions about this policy or about how we handle your personal data? Email info@tailortalents.be or write to Apro BV (TailorTalents), Burgemeester Michel Du Tré-straat 13, 9250 Waasmunster, Belgium.