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Purpose and Scope

1.1 Objective.
Cyberr is committed to protecting the privacy of its users (“Users”), whether they are individuals working for recruiters, candidates looking for work, independent contractors, or individuals working for umbrella companies or similar entities providing temporary workers or contractors.
The purpose of this privacy policy (“Privacy Policy”) is to demonstrate this commitment and to inform Users about how Cyberr processes the personal data (i.e., any information relating to an identified or identifiable natural person) of the Users of Cyberr.

Cyberr is committed to complying with all obligations under applicable data protection laws when processing personal data. Cyberr will continuously monitor the legal framework and, if necessary, update this policy to ensure its compliance with applicable data protection laws in the future.

1.2 Scope.
This policy applies to all Users of the Cyberr online platform.

Data Controller

The data controller is Cyberr, a Luxembourg company with the following address:

16, Rue Beck, L-1222 Luxembourg
Registered with the Luxembourg Trade and Companies Register under number B222843.

Data Protection Officer – Contact Information

The contact details of Cyberr’s Data Protection Officer are as follows:
(ADDRESS; EMAIL ADDRESS)

Purposes, Personal Data and Legal Bases of Processing

Cyberr processes personal data for the purposes listed below and relies on the corresponding legal bases. Where applicable, the legitimate interest is also mentioned.

The legal bases are as follows:

  • Performance of a contract between Cyberr and the data subjects (i.e., the terms and conditions governing the use of Cyberr) (Art. 6(1)(b) GDPR);

  • Legitimate interests of Cyberr (Art. 6(1)(f) GDPR);

  • With regard to special categories of personal data, explicit consent of the data subjects (Art. 9(2)(a) GDPR).

No. 1

Purpose of Processing: Creation and management of online accounts; operation of the Cyberr online platform.

  • Legal Basis: Performance of a contract and, in the absence of any contract, the legitimate interests of Cyberr.

  • Legitimate Interest: Cyberr’s legitimate interest to provide a well-functioning platform at the request of Users and to manage online accounts requested by Users.

  • Personal Data Processed:

    • Identification data: name, email address, address, registrant details (for individuals working for client companies), IP address, connection logs.

    • Personal characteristics: gender, nationality.

    • Education and training: area of expertise, job title, professional biography, expected salary, type of training and qualifications, CV, languages spoken.

    • Profession and employment: current profession, CV data.

    • Photos on the website.

No. 2

Purpose of Processing: Offering of work-finding and recruitment management services to Users.

  • Legal Basis: Performance of a contract and, in the absence of any contract, the legitimate interests of Cyberr.

  • Consent Required: For processing disability status data.

  • Legitimate Interest: Cyberr’s legitimate interest to provide the services to Users.

  • Personal Data Processed:

    • Identification data: name, location, nationality, email address.

    • Personal characteristics: gender, nationality.

    • Education and training: area of expertise, job title, professional biography, expected salary, type of training and qualifications, CV, languages spoken.

    • Profession and employment: current profession, CV data.

    • Photos on the website.

    • Disability status (only with consent).

Collection of Personal Data

Personal data is collected directly from Users when registering with Cyberr or by using the online platform. Generally, Users are not required to provide personal data, except where indicated in the registration form. In such cases, it is a contractual requirement and Users cannot benefit from the Services without providing such data.

Recipients of Personal Data

5.1 Processors
Cyberr shares Users’ personal data with service providers who process personal data on behalf of Cyberr and according to its instructions, such as:

  • Data Hosting Provider (OVH).

5.2 Third Parties
Cyberr may share Users’ personal data with the following third parties:

  • Other Users: identification data and products ordered, only to perform services between Users on Cyberr. This includes umbrella companies or similar entities providing temporary workers or contractors, but only to manage such workers.

Transfers to Third Countries

Cyberr may transfer personal data to countries outside the EU/EEA, particularly where candidates apply for positions within companies based outside the EU/EEA.

In such cases, Cyberr will ensure that Users’ rights are adequately protected, either because the European Commission has decided that the destination country ensures an adequate level of protection (Art. 45 GDPR), or because the transfer is subject to appropriate safeguards through the use of EU Standard Contractual Clauses (Art. 46 GDPR), unless an exception applies (Art. 49 GDPR).
Where necessary, Cyberr will also agree on additional measures with the recipients to ensure an adequate level of protection.

Copies of the Standard Contractual Clauses may be requested at [EMAIL ADDRESS].

Retention of Personal Data

Cyberr retains Users’ personal data as follows:

  • Personal data relating to the creation and management of online accounts, as well as the operation of the online platform (Processing No. 1), is kept until the deletion of the User’s account.

  • Personal data relating to the provision of work-finding and recruitment management services (Processing No. 2) is kept for the duration of the services and deleted thereafter.

Users’ Rights as Data Subjects

8.1 Right of Access. Users may request information about the processing of their personal data and obtain a copy of the personal data, provided this does not infringe the rights and freedoms of others.

8.2 Right to Rectification. Users may request correction of inaccurate data and/or completion of incomplete data.

8.3 Right to Erasure. Users may request deletion of their personal data, particularly when:

  • The data is no longer necessary for the purposes for which it was collected,

  • The User has objected to the processing and no overriding legitimate grounds exist,

  • The data has been unlawfully processed,

  • Erasure is required by law.
    (Exception: the right does not apply if processing is necessary for compliance with a legal obligation or for the establishment, exercise, or defense of legal claims.)

8.4 Restriction of Processing. Users may request restriction of processing in certain cases, e.g., while accuracy is being verified, when processing is unlawful but the User prefers restriction over erasure, when data is needed for legal claims, or when an objection is pending.

8.5 Right to Data Portability. Users may request to receive the personal data they provided in a structured, machine-readable format and transmit it to another controller, or request a direct transfer where technically feasible.

8.6 Right to Withdraw Consent. Users may withdraw consent at any time when processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal.

8.7 Right to Object. Users may object, on grounds relating to their particular situation, at any time to processing based on Cyberr’s or third parties’ legitimate interests.

  • Cyberr will stop processing unless it demonstrates compelling legitimate grounds overriding Users’ interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.

  • Users may object at any time to processing of their data for direct marketing purposes (including profiling related to such marketing).

8.8 Right to Lodge a Complaint. Users may lodge a complaint with a supervisory authority in their Member State of residence, place of work, or place of the alleged infringement if they believe processing of their data infringes the GDPR.

Requests to exercise rights under Sections 8.1–8.7 may be sent to: (EMAIL).

Contact Person

For any questions or concerns regarding this policy or data protection matters in general, please contact: (EMAIL).

Changes to this Policy

Cyberr reserves the right to amend or modify this notice at any time to ensure compliance with applicable laws. Users will be informed of any substantial changes to this policy.