1 General provisions

Capital H NV, with its registered office at Kasteeldreef 1, 3191 Boortmeerbeek, registered with the Crossroads Bank for Enterprises under number 0599.835.627 (hereinafter, “Capital H”), processes the personal data of users of its website, (hereinafter the “Website”) (data controller)

Capital H processes personal data in accordance with the applicable Belgian and European privacy legislation, including the Act of 8 December 1992 on the protection of privacy in relation to the processing of personal data and the General Data Protection Legislation (2016/679).

Capital H is also known as Twegos.

2. Processing of personal data

2.1 Personal data provided by users

Users of the Website are asked to provide personal data including their first and last name, date of birth, gender and contact details (e.g. e-mail address and telephone number).

3 Purposes of the processing and legal grounds

3.1 Purposes

Personal data are processed for the following purposes:

  • administration and management
  • log-in activities
  • services offered via the website, i.e., the creation of a values-based profile by means of an assessment (test)
  • job searches (matching users with potential employers) including talent management (e.g. internal promotion or a change of position) and recruitment purposes
  • Request information

3.2 Disclosure to third parties

3.2.1 Disclosure to the company (potential employer)

After the user has taken the test (values assessment) and a values-based profile has been created, the user’s first and last name, e-mail address, phone number and his or her (values) fit score with the company will be reported to the potential employer. Contact data can also be shared, even if no value profile is created, if the user has also accepted the privacy policy of the potential employer

By taking the test (values assessment), users agree that their personal data may be processed by Capital H for the abovementioned purposes.

If a fit between the user and the company (potential employer) is established, the company (potential employer) can ask the user to provide his or her complete values profile (full test results). The user is free to decide whether he or she wishes to do so.

3.2.2 Disclosure to partners of Capital H

Personal data (first and last name, e-mail address, phone number and fit score per company) may be disclosed to partners of Capital H, i.e. Jobat, and VDAB, for the purposes mentioned in this privacy policy only with the consent of the person who took the test (values assessment).

3.2.3 Disclosure to the user’s own employer for talent management and recruitment purposes

When an employee is requested by his or her employer to take the test (assessment) for talent management purposes (i.e. with a view to an internal promotion or a change of position; data analysis purposes or building reference groups) or further to the recruitment of a candidate (applicant) who will work directly for the employer (supervisor) concerned, the values profile (test results) and personal data (including the employee’s identity) are disclosed to the employer. By taking the test (assessment), the (future) employee agrees to the processing of his or her personal data by the employer for the abovementioned purposes subject to the data privacy policy of his or her employer.


When an external candidate (job applicant) is asked to take the test (assessment) during a recruitment procedure organized by the potential employer (the company), the values profile (test results) and personal data (including the applicant’s identity and contact data) are disclosed to the potential employer. By taking the test (assessment), the external candidate agrees to the processing of his or her personal data for the abovementioned purposes.

3.3 Legal grounds

By creating an account or using our services (i.e. taking the values test) and/or the Website, the user expressly agrees to the processing of his or her personal data in accordance with this privacy policy.

When creating an account and before taking the test, users will be expressly requested to confirm their consent to the abovementioned processing by ticking a box.

We are required by law to set out in this privacy policy the legal grounds on which we rely in order to process your personal data.

As a result, we process your personal data for the purposes as defined under 3.1 based on: (a) the necessity for the performance of our services and the effective delivery of our services to you; (b) our legitimate interests in the effective delivery of our services to the potential employers; (c) of our legitimate interests in the effective and lawful operation of our business so long as such interests are not outweighed by your interests; (d) of the legal and regulatory obligations that we are subject to or (e) the information is required in order to provide our services to you or to the potential employers.

4. Data retention period

Personal data are stored only for the time necessary to achieve the abovementioned purposes (and provide our services).

5 Rights of users

5.1 Right to access and request the correction of personal data

Users have the right to access their personal data at any time, free of charge, and to request the rectification of any inaccuracies. Users that wish to exercise this right should send an e-mail to [email protected] or a letter to Capital H, Kasteeldreef 1, 3191 Boortmeerbeek, along with a copy of their identity card.

Users are free to decide whether to disclose or not to disclose their personal data to Capital H. Users should be aware, however, that, if they choose not to do so, they will not be able to create an account or take the test. The processing of personal data is indeed necessary to provide services to users. Users are responsible for the accuracy of any information provided to Capital H.

5.2 Right to withdraw consent and object to processing

Users have the right to withdraw their consent (see Article 2.1) at all times, without prejudice to the legality of processing that occurred on the basis of consent prior to the withdrawal. Users have the right to object to the processing of their personal data. An objection to the processing of personal data can result in users no longer being able to make use of our services.

5.3 Right to data portability

Users have a right to data portability. This means that they have a right to obtain their personal data in a structured, commonly used and machine-readable format and to transfer their personal data to another controller (processor).

5.4 Right to erasure

Users have the right to request, free of charge, the erasure of their personal data (see Article 2.1). Anonymized data may be stored for statistical purposes and database relevance.

Requests to delete personal data should be sent to Capital H, Kasteeldreef 1, 3191 Boortmeerbeek, or [email protected], along with a copy of the data subject’s identity card.

Users can delete their account from the Website at any time.

6. Automated individual decisions

Use will be made of automated individual decisions. After creating an account, users can participate in an academically based values assessment (test). The results of the test constitute the user’s values profile which is used for job placement purposes. The test results yield a (values) fit score per company. The goal is to use the values profile to find a relevant fit between the user and a potential employer.

7. Safety and confidentiality

Capital H has developed and put in place security measures to avoid the destruction, loss, falsification, inadvertent disclosure, and unauthorized access to or processing of personal data gathered via its Website.

Capital H cannot be held liable for any direct or indirect damage resulting from erroneous or unlawful use of personal data by a third party.

8. Contact

For further information or comments on this Privacy Policy, please contact Capital H at Kasteeldreef 1, 3191 Boortmeerbeek or [email protected].

In the event of complaints, you can also contact directly the Belgian Privacy Commission ([email protected]).

Capital H reserves the right to amend this Privacy Policy at any time.

This Privacy Policy was last updated and revised on 6 june 2019.

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