Privacy Policy

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Chapter Privacy Policy

Your privacy matters to us. That’s why we handle your personal data with care and adhere to the General Data Protection Regulation (GDPR). This privacy policy explains what data we process, who is responsible for it, and what your rights are. If you have any questions, don’t hesitate to reach out—we’re happy to assist.

Who We Are

Our official name is Chapter Holding B.V., but we’re simply known as Chapter. We’re located at Fred Roeskestraat 115, 1076 EE, Amsterdam, and registered in the Dutch trade register under KvK number 84477733. Chapter is responsible for collecting, processing, and transmitting your personal data in compliance with the GDPR and all applicable privacy laws. This document outlines how we do that.

When Does This Privacy Policy Apply?

This privacy policy applies to all data we collect, use, and store from users of our website and app.

Exception: Sometimes, our website or app contains links to third-party websites. If you click on one of these links, the third party is responsible for processing your data on their website. This privacy policy does not apply to such third-party websites.

This policy is current as of February 2023. Chapter reserves the right to update its privacy policy. The latest version will always be available on our website www.chapter.works and within our app. If there are significant changes, we’ll notify you through other channels, such as email or the app.

What Data Does Chapter Collect and Process?

We collect personal data at various points, including when you (either directly or through your employer or client):

  • Create a Chapter account
  • Pay for your membership
  • Use our learning and development modules
  • Participate in our community, workflows, and games
  • Create a skills profile or resume in our app
  • Interact with potential partners for job matching
  • Contact our customer service or advisors

We collect the following types of data:

Data You Provide
This includes information you provide when creating an account, such as your email address, login credentials, and phone number. As you build your profile, create a resume, or use our learning modules and workflows, we may collect additional details about your work and educational background, extracurricular activities, work behavior, and a possible photo. When you interact with other users, partners, or our advisors, you may share further information to help facilitate those interactions.

Automatically Collected Data
To ensure our app and website function properly, we also collect automatically generated information, such as your IP address, browser type and version, Internet Provider, date and time, and clickstream data (pages visited before and after our site).

Why Does Chapter Process My Data?

We only process your data for the following purposes:

  • To grant you access to the platform
  • To optimize your use of the platform
  • To provide insights to your employer or client for mutual benefit
  • To connect you with partners for coaching, learning, and development modules
  • To match you with the best job opportunities
  • To maintain contact with you
  • For marketing and communication purposes

What Legal Grounds Allow Chapter to Use My Data?

Under the GDPR, Chapter can only process data if there is a legal basis for doing so. We process data based on the following grounds:

  1. Your Consent
    By creating an account on our app, you consent to the processing of the data you provide. You can withdraw this consent at any time. See Section 10 for details about your rights.
  2. Performance of a Contract
    When you create an account, you enter into a contract with Chapter. Our Terms and Conditions also apply (https://www.chapter.works/terms). To fulfill this contract and ensure continued access to the app, we process the data you provide.
  3. Legitimate Interest
    In some cases, Chapter’s legitimate interest justifies processing your data, such as for sending marketing emails or ensuring the security of our website and app.
  4. Legal Obligation
    In certain cases, we are legally required to share information, which may include your data, such as during an investigation by regulatory authorities.

Cookies

Our website uses cookies—small files sent along with web pages or Flash applications and stored on your computer’s hard drive. These files allow information to be sent back to our servers during future visits. For a detailed overview of the cookies we use, please refer to our cookie policy.

Who Has Access to My Data?

Your privacy is important to us. We only share your data under special circumstances:

  1. Payment Service Providers
    To process payments for our app, we may work with third-party payment providers. You may notice their name on your bank statement. These providers also assist in fraud detection.
  2. Subcontractors and Trusted Service Providers
    We have detailed agreements with these parties to protect your data. Examples include coaches you interact with in the app, companies providing learning modules, your employer, or potential hiring organizations.
  3. Regulators, Tax Authorities, or Law Enforcement Agencies
    If legally required, we may share your data with these entities.

Even when transferring data outside the European Union, we ensure your privacy is safeguarded, such as by using European model contracts designed for such purposes.

How Does Chapter Protect My Data?

We employ technical and organizational measures to store your data securely and protect it from loss or unauthorized access. Our systems and applications comply with information security standards, and we hold our subcontractors and service providers to the same standards (see Section 7 above).

How Long Does Chapter Retain My Data?

We retain your data only as long as necessary for the purposes outlined in this policy or as required by law. For example, if you delete your account, we will also delete the personal data you provided. If you have questions about specific retention periods, please email us at info@chapter.works.

What Are My Rights?

You have control over your data. You can:

  • Access the data we’ve stored about you
  • Request corrections or deletions of your data
  • Object to how we process your data

To exercise these rights, email us at info@chapter.works with a clear description of your request. Please include a valid ID for verification, ensuring your Social Security Number and photo are obscured for security reasons.

If you’re dissatisfied with how we’ve handled your privacy request, you can file a complaint with the Dutch Data Protection Authority.

Have More Questions?

For further inquiries about our privacy policy, contact us anytime at info@chapter.works.