Privacy Policy

Effective date: 16-02-2026

Introduction

At GloPros, we are committed to providing you with the best community platform experience while respecting your privacy and protecting your personal data. Over the years, we have consistently prioritised the security and responsible use of your data. As we continue to expand our services and meet your evolving needs, we are enhancing our data protection policy to ensure transparency and clarity. We have made significant efforts in the following areas to further safeguard your data. The users of our platform consist of 

GloPros' Approach to Data Protection:

We have engaged a specialised freelancer in personal data protection to collaborate with us. Together, we are updating our data processing operations register to establish a comprehensive overview of all data processing activities conducted by GloPros. This includes identifying the software and service providers involved in processing personal data of our employees and users.We have taken steps to ensure that all our service providers share our commitment to protecting personal data. Our contracts with them include specific clauses pertaining to the safeguarding of personal data. To facilitate the exercise of your rights, such as accessing, rectifying, opposing, and requesting the swift and effective deletion of your personal data, we have developed a user-friendly procedure. You can find detailed information on this procedure in the menu section of our platform.For any future features that may involve personal data, we are currently implementing a Personal Data Protection Impact Assessment procedure. This means that data protection considerations are integrated into the design of new features from the outset. We have appointed a dedicated data protection officer who will serve as your primary contact person. If you have any inquiries or concerns regarding the protection of your personal data at GloPros, please reach out to them at privacy@glopros.com.

Do you have more questions? 

We encourage you to review our complete privacy policy, which outlines our approach to handling personal data. These updates to our policy came into effect on April 8, 2023. By continuing to use our services on or after this date, you indicate your acceptance of these revisions.

If you have any remaining questions, our legal experts are available to assist you.

Thank you for placing your trust in GloPros.

The GloPros Team

Data privacy policy

Effective Date: 8th of June 2023 

In order to protect your personal and professional data we are committed to collecting only the data that we need to provide you with the best possible service, to ensuring its confidentiality and security, including when we use service providers, and to making it easy for you to exercise your rights regarding your data. Capitalised terms have the meaning set forth in the GloPros Terms and Conditions of Use. Our primary commitment is to comply with applicable data protection legislation.

We comply with the obligations of the General Data Protection Regulation (also known as "GDPR") and all national laws implementing this regulation in the states in which we operate. In particular, we ensure compliance with the so-called "Law on IT and Freedoms" of 6 January 1978, as amended, for France, the Federal Data Protection Act (BDSG) for Germany, the Law on the Protection of Individuals with regard to the Processing of Personal Data of 30 July 2018 for Belgium, and the Spanish Organic Law 3/2018, of 5 December 2018, on the Protection of Personal Data and Guarantee of Digital Rights, and Personal Data Protection Act 25 892 of 7 June 2000 for the Netherlands.

Here we describe what we do with your data. 

This policy describes the personal data we collect, how it is used and, if applicable, shared, and your rights concerning this. It applies to all users of GloPros services. We advise that you read it carefully. We have done our utmost to make it clear, easily understandable, and accessible at any time while using the website.

At GloPros, we value your privacy and are committed to protecting your personal data in accordance with the General Data Protection Regulation (GDPR). This Data Privacy Policy outlines how GloPros collects, uses, and stores personal data in the context of our AI-powered HR systems. We strive to ensure transparency, security, and compliance throughout our data processing activities. Please read this policy carefully to understand how we handle your personal data.

1. Data Controller

GloPros BV, with its registered office at Herengracht 52-F 1015BN, Amsterdam, The Netherlands, is the data controller responsible for the processing of your personal data.

2. Purpose and Legal Basis for Processing

GloPros collects and processes personal data for the following purposes:

• Recruitment and Selection: Assessing qualifications, evaluating job applications, and conducting interviews.
• Employment and Performance Management: Facilitating the onboarding of the professional, managing work performance, and providing feedback.
• HR Analytics and Insights: Utilising aggregated and anonymized data to analyse workforce trends and improve HR processes.
• Legal Obligations: Complying with applicable labour laws, tax regulations, and other legal obligations.
• Financial Management: Creating invoices, 

3. The legal basis for processing personal data includes one or more of the following:

• Performance of a Contract: Processing personal data necessary for the performance of a freelance, interim or employment contract.
• Legitimate Interests: Pursuing our legitimate interests while respecting your rights and freedoms.
• Consent: Obtaining explicit consent for specific processing activities when required by law.

4. Data Recipients and Transfers

GloPros may share your personal data with the following recipients:

• Internal Staff: Authorised employees and departments involved in HR processes.
• Service Providers: Third-party service providers who assist GloPros in HR-related tasks and comply with GDPR regulations.
• Legal and Regulatory Authorities: Sharing personal data when required by law or in response to legal requests.

When transferring personal data outside the European Economic Area (EEA), GloPros ensures appropriate safeguards are in place, such as using standard contractual clauses or relying on data transfer mechanisms recognized by the European Commission.

5. Data Security and Retention

GloPros implements appropriate technical and organisational measures to protect personal data from unauthorised access, loss, or alteration. Access to personal data is restricted to authorised personnel with a legitimate need for access.Personal data is retained only for as long as necessary to fulfil the purposes outlined in this policy or as required by applicable laws and regulations. When personal data is no longer required, GloPros securely disposes of or anonymizes it to prevent identification.

6. Data Subject Rights

As a data subject, you have rights under the GDPR. These include:

• Right of Access: Requesting access to your personal data and obtaining information about its processing.
• Right to Rectification: Requesting the correction or update of inaccurate or incomplete personal data.
• Right to Erasure: Requesting the deletion of personal data, subject to legal obligations.
• Right to Restriction of Processing: Requesting the limitation of processing under specific circumstances.
• Right to Data Portability: Requesting a copy of your personal data in a commonly used and machine-readable format.
• Right to Object: Objecting to the processing of personal data based on legitimate interests or direct marketing.
• Right to Withdraw Consent: Withdrawing

consent provided for specific processing activities.

To exercise your rights or for any inquiries regarding your personal data, please contact GloPros' Data Protection Officer (DPO) at:

privacy@glopros.com

Herengracht 52-F, 1015BN Amsterdam, the Netherlands 

+31611388811

7. Automated Decision-Making and Profiling with AI

GloPros may use automated decision-making processes, including profiling, to analyse or predict certain aspects related to selecting and processing resumes and vacancies, such as performance evaluation or career development. Such decisions are subject to human review, and you have the right to contest automated decisions and request human intervention.

8. Contact Information

If you have any questions, concerns, or requests regarding the processing of your personal data or this Data Privacy Policy, please contact our Data Protection Officer (DPO) at the provided contact details.

9. Updates to this Policy

GloPros may update this Data Privacy Policy from time to time to reflect changes in data processing practices or legal requirements. GloPros will notify you of any significant changes through appropriate communication channels.

This version of the Data Privacy Policy was last updated on 8th of June 2023.

By using GloPros' AI-powered HR systems and providing your personal data, you acknowledge that you have read, understood, and agreed to this Data Privacy Policy.

The GloPros team

Artificial Intelligence privacy policy 

In order to protect your personal and professional data we are committed to only use Artificial Intelligence  to provide you with the best possible service. The following privacy considerations and requirements are continuously carried out for the implementing our AI systems:

1. Data Minimization: Our AI systems only collect and process the minimum amount of personal data necessary to achieve their intended purpose of matching the professional and personal data of a professional to the vacancies of the hiring companies. We avoid unnecessary data collection and retain data only for as long as needed within the GDPR requirements .

2. Lawful Basis for Processing: We ensure that there is a valid legal basis for processing personal data under applicable data protection regulations, such as the GDPR. This may include obtaining consent, performing a contract, or pursuing legitimate interests.

3. Transparency: We inform all users of the GloPros platform and  individuals about the processing of their personal data by AI systems. Therefore we provide clear and concise explanations of the purposes, methods, and potential consequences of AI processing.

4. Data Security: We’ve Implement appropriate technical and organisational measures to protect personal data from unauthorised access, disclosure, alteration, or destruction. This involves encryption, access controls, regular security assessments, and employee training.

5. Data Accuracy and Quality: We continuously take measures to ensure the accuracy and quality of the data used for AI training and decision-making processes. Our employees regularly review and update data sets to mitigate biases and inaccuracies that could impact individuals' rights and freedoms.

6. User Rights: We respect individuals' rights to access, rectify, erase, restrict processing, and obtain their personal data in a portable format. Therefore we’ve provided mechanisms for individuals to exercise these rights and respond promptly to their requests. Every user can change their personal data by changing their personal settings. 

7. Data Sharing and Transfers: If personal data is shared with one of our third parties or transferred across borders we ensure appropriate safeguards are in place. This may involve implementing data protection agreements, using standard contractual clauses, or relying on other recognized transfer mechanisms.

8. Ethical Considerations: To assess the potential ethical impacts of AI systems on privacy and individuals' rights we continuously conduct impact assessments to identify and mitigate risks related to bias, discrimination, privacy infringement, and other potential harms.

9. Accountability and Documentation: We maintain records of AI data processing activities, including the purposes, legal basis, and security measures in place. We have a designatea data protection officer and have established internal policies and procedures to ensure compliance with privacy requirements.

4. Data we process

Summary:

Within the context of your use of our services and your navigation of our website, GloPros processes several categories of data, which are detailed below. This data originates from:

• Information that you provide to us ;

• Information resulting from your use of our services.

We do not process certain categories of data (sensitive data), such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic data, biometric data, data concerning health, or data concerning people's sex life or sexual orientation.

4.1 Professional data 

We will inform you when requesting data whether the information is mandatory.

‍

4.3 Statistical information regarding your use of our services

For example, we collect statistics:

• Relating to the use of the secure messaging system we offer (percentage of messages answered, response time);

• Relating to end-of-assignment evaluations (comments left by clients and freelancers, average ratings);

• Statistics based on user login and navigation data;

• On the use of the search engine and the Freelancer contact form;

• On your use of the different modules such as the quotation tool, the contract module, the payment module; the features made available to companies (reporting, team pages, barometer);

• Relating to commercial data, such as the number of assignments completed, business volumes by freelancer category, or by client category.

4.4 Data anonymisation service

We, GloPros BV, are committed to protecting the privacy of our users and ensuring the confidentiality of their personal information. This Privacy Policy outlines how we collect, use, disclose, and safeguard the data processed through our anonymization product. Short explanations

1. Information We Collect and Anonymise

   - Resumes: Our anonymization product processes resumes uploaded by professionals. These resumes may contain personal information such as names, contact details, work history, and other relevant data. Via our anonymisation process we are able to make the content available without disclosing specific personal information about the professional or his/her clients or employers.

2. Purpose of Data Processing:

- Anonymization: Our anonymization product is designed to transform personal information within resumes into non-identifiable or non-recognizable data. The purpose is to ensure the privacy and protection of personal information while maintaining the usability of the anonymized resumes. The anonymization process is developed and performed exclusively by our in-house team, and no third-party developers are involved in modifying the anonymization algorithms.

3. Data Security:

- Confidentiality: We take the utmost care to protect the confidentiality and security of the data processed through our anonymization product. Access to the data is strictly limited to authorised personnel who require it for the purpose of anonymization.

- Encryption: We employ industry-standard encryption protocols to safeguard the data during transmission and storage.

- Data Retention: We retain the processed anonymized data for the duration required to fulfil the intended purpose and comply with legal obligations. After this period, the data is securely deleted.

4. Data Sharing and Disclosure:

- No Third-Party Involvement: We do not engage any third-party service providers or share the anonymized data with external parties. The anonymized data remains within our secure systems and is used solely for the purpose of providing our anonymization services.

5. User Rights and Choices:

 - Access and Correction: Users may request access to their personal information and request corrections if necessary.

- Data Deletion: Users may request the deletion of their personal information from our records, subject to legal and contractual obligations.

- Marketing Communications: Users have the option to opt-out of receiving marketing communications from us.

6. Updates to Privacy Policy:

- We reserve the right to update this Privacy Policy as needed to reflect changes in our practices or legal requirements. We will notify users of any material changes through prominent notifications or direct communication.

If you have any questions or concerns regarding our privacy practices or this Privacy Policy, please contact us at security@glopros.com].

By using our platform, you agree to the terms and conditions outlined in this Privacy Policy of our anonymization product.

5. Cookies

We use authentication cookies, security and site integrity cookies, location cookies, cookies relating to site functionality and services, analytics and search cookies, and cookies to deliver advertising messages. You can accept, decline, or set your cookie choices when you first log into the Marketplace, and you can amend your choices at any time by visiting the cookies section in our data protection centre, available here: www.glopros.com./about/privacy/cookies. You will also find a more detailed description of the cookies we use.

6. Legal Foundations and Aims

Summary:

GloPros processes most of your personal data as part of the service agreement you entered into when you registered on the site, by accepting our terms and conditions. However, we may process certain data relating to you on the basis of your consent, on account of legal obligations, or in line with our legitimate interest in the processing of this data.

The data we collect allows us to provide, manage, protect, and improve our services, to develop new services, and to protect both our users and ourselves against potential fraudulent use of our Marketplace.

Details:

In particular,

6.1 Data processing to execute the service contract

Based on the execution of the service contract you entered into when registering on the site, by accepting our terms and conditions of use (if you wish to review our terms and conditions of use again, you can find them at www.glopros.com/legal), by which we are bound, we use your data to provide you with our services.

In particular, within the context of the execution of the service contract, we process your data:

- To create and manage your account;

- To allow you to use the services offered on the site;

For the Freelancers:

• For the verification of your company based on your legal documents (see below for further information);

• In order to optimise your search engine listing;

• To ensure that the proposed assignments are relevant (lead moderation, anti-spam policy);

For the Customers:

• In order to offer you the most relevant search results;
• To suggest a Freelancer's profile in response to a client's specific search: GloPros may transmit the personal data of freelancers registered with the Marketplace to client companies, to assist them in their search for Freelancers or to introduce them to freelancers that meet their requirements. Therefore, if, following a request from one of our clients, the profile of a freelancer corresponds to his/her search, we may transmit the respective profile information to the client.
• To allow the client to consolidate ongoing assignments with freelancers within a dedicated interface (GloPros Insight);

For all the Users:

• To enable communication between users (freelancers and clients) regarding an assignment, through the provision of an integrated secure instant messaging system;
• To send you communications concerning your actions within the Marketplace (transactional emails);
• To keep your documents (invoices, contracts, etc.) available in your GloPros account;
• To enable the payment of your assignments directly through the Marketplace and via our partner, Mangopay. As such, your data is processed to ensure the management of the cash flow running through the Marketplace and, in particular, the invoicing of assignments and payments as well as, in accordance with the law, the fight against terrorism and money laundering;
• To enable your use of the factoring and advance payment service offered by our different payment providers;
• To allow you to leave a review/comment at the of the Assignment;
• To assist you in the use of the platform by providing a client/freelancer service to respond to your requests.

6.2 Data processing to ensure GloPros’s legitimate interest

To ensure our legitimate interest, we use your data in order to :

• When registering with GloPros, we ask that Freelancers provide a number of documents relating to their identity, as well as legal documents concerning their legal structure. This data and these documents serve two purposes:

- To facilitate contact between Freelancers and Customers by presenting the Freelancer's pre-verified legal structure to the Client. In fact, under French law (only), Customers using a service provider must satisfy a vigilance obligation, in other words, they must ask the freelancer for a document attesting to his/her registration (extract 'K bis' or trade directory card) and a certificate of vigilance, issued by the URSSAF, which should state the number of employees and the total remuneration that the freelancer has declared at its last payment date. This document also attests to their compliance with the obligations regarding the declaration and payment of social security contributions. By pre-verifying these documents, GloPros prevents you from having to do, thus allowing you to focus on assignment-related communications.

- To accelerate the payment of Assignments by having the verification information concerning your legal structure forwarded to our provider, MangoPay, ahead of time: when you use GloPros as a freelancer, you benefit from an online payment service that allows you to receive payments from your clients. This payment service is provided to you by our payment solution provider, Mangopay SA, an authorised payment institution. In this capacity, Mangopay SA has legal vigilance obligations in terms of the fight against fraud, the funding of terrorism, and money laundering. In accordance with the requirements of the regulations that apply to Mangopay, when creating your account and using the payment service, the payment provider must identify you and verify your identity. GloPros therefore requests details relating to your identity and that of your legal structure on behalf of the payment provider, Mangopay.

• To protect our freelancers from spam;

• To carry out personalised follow-up so as to send only relevant communications, adapted to your needs directly relating to the site's services (for example: to propose adapted assignments, to invite you to update/complete your profile in order to maximise your chances of being awarded an assignment...).

• To safeguard the glopros.com website and to secure the data and communication taking place on the site;

• To develop our services with a view to offering new features, and to adapt these to your needs: to this end, we compile statistics on the use of our services, based on the tracking of the audience of our website pages and the monitoring of commercial activities and user behaviour in the Marketplace. These statistics are anonymised whenever possible;

• To evaluate your satisfaction and, subject to your consent, to contact you to further discuss matters.

• To guarantee profile quality, to combat fraud, and to verify profile information (e.g. location).

• To combat fraud when sending messages and, in the event of detected anomalies, to issue a reminder of the applicable rules or to block messages you send. We also use automatic ad content analysis technology to detect unsolicited content, including fraudulent content;

• To calculate your average response time to messages sent to you, and to display this to your contacts;

• To assist you in case of difficulty in using the platform or in case of a help request, especially in the event of a dispute with another user.

• To send you notifications concerning your activity on the site for instance, when you have received a message, a quote, or a payment;

• To ask you to participate in surveys (e.g. satisfaction, opinion, study on freelancers in your country or within the European Union). You are free to participate and can decline in accordance with the terms outlined at the time of the survey.

• To communicate with you: GloPros may use the information collected to communicate with you regarding products, services, promotions, studies, surveys, news, updates, and events.

6.3 Data processing based on your consent

We may also collect your consent prior to processing certain data;

• for example, for the reuse of your profile photo, created by our services, on commercial media;

• or if you have not created an account on the Marketplace but wish to receive our commercial offers/newsletter.

6.4 Data processing to ensure our legal obligations

Finally, we process certain data on account of the legal obligations imposed on us within the context of the management of payments made via the Marketplace, and, in particular, with regard to the fight against the funding of terrorism and money laundering.

7. Recipients or category of recipients and transfers to countries outside the EEA

Summary:

GloPros the recipient of personal data collected via the Site.

Some of the services and features made available to you by GloPros require us to share information with other users or with our business partners. We may also share this information for legal purposes or in the event of litigation.

Details:

GloPros is the recipient of personal data collected via the Site.

We will only share your personal data with third party companies, organisations, or individuals in the following circumstances:

7.1 Sharing with clients

Sharing of the freelancer's identifying information and, if applicable, data identifying his company, with clients, when the freelancer sends them a business proposal and legal documents relating to his services and, if applicable, data identifying their company when an assignment is launched.

7.2 Sharing with trusted partners and providers

When necessary, for external processing purposes, and only in this case, we pass on this data to our partners, such as MangoPay and Finexkap, and to trusted service providers; our subcontractors. They will process your data on our behalf, as instructed by us or as contractually agreed, in accordance with this policy and in compliance with any other appropriate security and confidentiality measures.

a) Data localisation

All our servers on which your data is stored are located in Europe. In very exceptional cases, some of our service providers whose principal place of business is in a country outside the European Union may need to transfer your data to that country. In this case, we check beforehand that they are respecting their obligations in terms of the protection of our users' data, and we put in place a "transfer tool", such as standard contractual clauses, to ensure that your personal data benefits from a level of protection equivalent to that offered within the European Union.

b) Our service providers

Below you will find the names of our partners and service providers and, where applicable, the link to their website and their data protection policy, the contact address for data protection issues, the purpose for which they are involved and the location of the data, and the transfer tool used to ensure a level of protection equivalent to that offered within the European Union if they are located outside the European Union or are likely to transfer data outside the European Union.

We will only share your personal data with them for the purposes set out below.

7.3 Sharing with our accountants, and auditors within the context of potential fundraising

GloProsmay share information about freelancers and client employees who are registered with the Marketplace and use our services, in order to respond to requests for information from our investors, accountants, and any auditors, including in conjunction with any fundraising or auditing of the use of funds raised.

7.4 With authorised third parties

We may retain or disclose your information if we believe that it is reasonably necessary to satisfy any legal or regulatory obligation, legal process, or administrative request, to protect the safety of any person, to address any fraudulent, security-related, or technical issues, or to protect the rights or property of our users.

7.5 Group and Partner-companies

GloPros BV belongs to the GlobalProfessionals Group which also includes GlobalProfessionals.com BV (global recruitment and consulting). This privacy policy is also applicable for other companies belonging to the GlobalProfessionals Group and our Partner-companies: Talentportaal BV (www.talentsportal.com) recruitment focused on the Netherlands and TalentProfessionals.com BV (www.talentprofessionals.com), focused on intermediary services for clients in the Netherlands. Data will be exchanged between these companies and the same policies are also applicable for these companies.

Important: GloPros does not resell your data/information and documents you entrust to us to third parties, and we do not disclose personal and private information other than in the instances described in this Data Protection Policy.

8. Retention period or criteria for determining retention periods

As a general rule, we retain your information for the following periods:

• For Users that have completed assignments, GloPros will retain their billing information for a period of 10 years from the closing/deletion of the user account in order to comply with our accounting and social security payment obligations, as well as our reporting and documentation obligations with the tax authorities.

• For Freelancers only, GloPros also retains, for a period of 10 years, the legal documentation enabling the verification of your company in order to meet the legal obligations of Customers (project initiators / principals) to demonstrate that they have satisfied their obligation of vigilance with respect to you, in accordance with the requirements of French law.

Depending on the specific situation, we can retain your personal data for longer periods. In particular, this will be the case if any of the following periods are longer: (i) as long as necessary for the activity or service involved; (ii) any retention period required by law; or (iii) the statute of limitations during which legal proceedings may be brought for the purpose of defending our interests.

9. Data security

We implement appropriate technical and organisational measures to ensure the continued security, confidentiality, integrity, availability, and resilience of our information system and your data, and to protect the personal and other data we process against destruction, loss, alteration, and unauthorised disclosure of / access to data that is transmitted, stored, or otherwise processed.

We undertake to use all available means to ensure the security and confidentiality of this data, in particular:

• We encrypt most of our services using SSL technology;

• We verify your email address when you create your account;

• We conduct internal audits regarding data collection, storage and processing, including physical security measures, to prevent unauthorised access to our systems;

• Access to personal data is strictly limited to GloPros employees and contractors who require access in order to process it on our behalf. These individuals are subject to strict confidentiality obligations and may be subject to disciplinary action, up to and including dismissal, in the event of a breach.

10. Rights

In accordance with the GDPR and the provisions of the French law on the protection of personal data, known as the "Law on IT and Freedoms" of 6 January 1978, as amended, and the applicable national laws on the protection of personal data applicable in the states in which we operate, you have the following rights.

You can find descriptions of each of your rights in the data protection centre, which we make available at www.glopros.com/about/privacy/rights. The means by which to exercise these rights are also outlined there.

10.1 Access rights

You have a right to access the data concerning you that is processed by GloPros. This entitles you to view the data we hold in relation to you and, if you wish, to request a copy, within the limits of respect for the rights of third parties whose personal data may be included in the data concerning you.

10.2 Rights to rectification

Under the applicable data protection regulations, you may request that we correct any personal data concerning you that is inaccurate. You may also request that incomplete personal data concerning you be completed, including by providing a supplementary statement.

In order that you can exercise this right as easily as possible, we invite you to apply these changes and additions directly within your profile. If you feel that other data relating to you requires changing or completion, and you are unable to make this change yourself, we invite you to submit your request directly in the 'Your rights' section in our data protection centre, or by writing to us at privacy@glopros.com.

10.3 Deletion rights

You have the right to request the deletion of personal data concerning you within the shortest possible time frame, subject to our legitimate interest, or any legal obligation requiring us to retain such data.

For security reasons, and to avoid undesired account deletion, we invite you to perform this step independently when logged into your account, by following this link: www.glopros.com/account/cancellation

With respect to your profile data, you should keep in mind that search engines and other third parties may still retain copies of your public profile information for some time after you have agreed to be listed, even after you have deleted the information from the GloPros site or disabled your account. However, GloPros is not responsible for any such processing of your data by third parties. If you wish, you can exercise your right to dereferencing directly with these search engines. For example, to submit such a request to Google, you can use the tool provided by the search engine here.

10.4 Right to the limitation of processing

You may request that GloProslimit the processing of your data (for example, the act of making your profile temporarily unavailable on the site), where any of the following apply:

a) You dispute the accuracy of your personal data. In this case, we will conceal your data for a period of time sufficient to allow us to verify its accuracy;

b) You believe that your data is being processed unlawfully and you object to its deletion, instead demanding the limitation of its use;

c) We no longer require your personal data for the purposes of processing, but it is still required to enable you to establish, exercise, or defend a legal claim;

d) You have exercised your right to oppose under Article 21(1) of the General Data Protection Regulation. We will restrict the processing of your data while we verify whether the legitimate reasons we are pursuing take precedence over your right.

If we decide to lift the restriction on the processing of your personal data, we will inform you accordingly.

10.5 Right to oppose

You can object to the sending of communications, including commercial communications, by GloPros. To this end, we provide an unsubscribe link in all of our emails to you, and you can manage your notification preferences directly in our data protection centre under the 'Your rights' tab, www.glopros.com/about/privacy/rights.

You may also object, on legitimate grounds, to the processing of your data for which GloPros relied on legitimate interest. GloPros will then discontinue its processing, unless there are compelling legitimate grounds for the continuation of the processing (e.g. tax returns, social security returns, etc.) or for the establishment, exercise, or defence of legal claims.

10.6 Right to portability

You can request the portability of your GloPros data at any time. By exercising this right, we undertake to transmit to you, within a reasonable time and in a machine-readable format, the data you have provided to us, whether declared by yourself or generated by your activity within the Marketplace.

10.7 Right to withdraw consent

To the extent that the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. However, this would not affect the validity of your past consent.

10.8 Ability to determine what happens to your personal data after your death

In France, the new Article 40-1 of the Data Protection Act allows individuals to specify directives regarding the retention, deletion, and disclosure of their data after their death.

A person may be appointed to carry out these instructions. The latter shall then be entitled, when the person is deceased, to take note of any directives and request their implementation with the concerned data controllers.

These guidelines are:

• General, when it concerns all the data concerning a person;

• Or specific, when these guidelines only concern certain specific data processing.

When these directives are general and concern all of the deceased's data, they can be entrusted to a trusted third party, certified by the AP.

Where specific instructions are involved, they may also be entrusted to data processors (social networks, online messaging services) in the event of death. They are subject to the specific consent of the person concerned and cannot result from the latter's mere approval of the general conditions of use.

In the absence of directives issued by the individual while alive, heirs will have the opportunity to exercise certain rights, including:

• The right of access, if necessary for the settlement of the deceased's estate;

• The right to object to the closure of the deceased's user accounts and to object to the processing of their data.

10.9 Right to file a complaint with a supervisory authority

GloPros main office is located at Herengracht 52-1, 1015BN, Amsterdam. As such, the supervisory authority competent to deal with any request concerning us, including, if applicable, any user complaints, is the The Dutch Data Protection Authority (AP). However, you may direct your request to any data protection authority, in particular within your country of residence, in the country where you work, or in the country of which you are a citizen, and the latter will forward your request to the AP.

If you wish to submit a request to the AP, you will find the contact information below:

Please note! The AP is not open to the public and does not provide information on site.

If you wish to file a complaint with the CNIL, you can fill out the online complaint form available at https://www.autoriteitpersoonsgegevens.nl/een-tip-of-klacht-indienen-bij-de-ap 

If you have a question concerning your rights and freedoms with regard to data, you can consult the AP website: https://www.autoriteitpersoonsgegevens.nl/  

To contact any other data protection authority in the European Union, you can refer to the European Commission directory. It lists all the contact details of the data protection authorities in EU Member States and is available here:

https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm