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Privacy Policy

Last updated: 2 June 2026

1. Data Controller

The data controller responsible for your personal data is:

Charmies

Belgium

Email: privacy@charmies.be

Data Protection Officer (DPO): Charmies is in the process of appointing an external DPO as required under GDPR Article 37. In the interim, all data protection inquiries should be directed to privacy@charmies.be.

2. What Data We Collect

We collect the following categories of personal data when you register as a Charmie:

Identity & Contact

First name, last name, date of birth, nationality, civil status, gender, phone number, email address, home address (street, postal code, city).

Identity Documents

Belgian national ID card number, ID card expiry date.
Legal basis: your explicit consent (GDPR Art. 9(2)(a)).

Social Security (SSIN)

Belgian SSIN (National Register Number / NISS) for payroll and social security processing.
Legal basis: your explicit consent (GDPR Art. 9(2)(a)).

Banking Information

IBAN for payment of wages for completed jobs.
Legal basis: performance of contract (GDPR Art. 6(1)(b)).

Family and payroll information

This is necessary for payroll . It's only visible to you and authorized HR staff, and are not used for job matching.
Legal basis: employment administration and legal obligations (GDPR Art. 6(1)(b) and 6(1)(c)).

Physical Measurements (Special Category)

Height, clothing sizes (top, pants, dress, coat, skirt), shoe size, hair colour, eye colour. Used for uniform and outfit matching for jobs.
Legal basis: your explicit consent (GDPR Art. 9(2)(a)).

Profile Photo (Biometric Data)

A photo used to identify you to clients and for job matching purposes.
Legal basis: your explicit consent (GDPR Art. 9(2)(a)).

Professional Information

Work experience, specialties, job preferences, language skills, work regions, availability, student status, education details, social media profiles (optional).

Platform Activity

Job applications, job assignments, contracts, quality reports, training completions, messages sent through the platform, consent records.

3. Purposes and Legal Bases

PurposeLegal Basis
Matching you with job opportunitiesConsent (Art. 6(1)(a)) + Contract (Art. 6(1)(b))
Processing payroll and SSIN for social securityExplicit consent (Art. 9(2)(a)) + Legal obligation (Art. 6(1)(c))
Contract administrationContract (Art. 6(1)(b))
Sharing profile with clients for job matchingConsent (Art. 6(1)(a))
Quality reports and performance trackingLegitimate interest (Art. 6(1)(f))
Communication about job opportunitiesConsent (Art. 6(1)(a))
Identity verification (ID card, SSIN)Explicit consent (Art. 9(2)(a)) + Legal obligation (Art. 6(1)(c))
Retaining financial records for tax purposesLegal obligation — Belgian tax law, 7-year retention (Art. 6(1)(c))

4. Recipients and Data Processors

We share your data only with processors needed to run the platform. Charmies must keep Article 28 Data Processing Agreements in place with these processors before public launch:

Hetzner Online GmbH

EU VPS hosting for the application, database, and file storage. Production infrastructure is hosted in Germany and operated by Charmies.

Supabase software (self-hosted)

Database, authentication, and storage software run on Charmies-controlled infrastructure. Supabase Inc. is not used as the production hosting processor for this self-hosted stack.

Resend Inc.

Transactional email delivery (e.g., notifications, contract emails). Only name and email address are shared.

Job Clients

When you are selected for a job, your name, photo, and relevant profile information may be shared with the client for that job. You consent to this at registration.

We do not sell your personal data to any third party.

5. International Data Transfers

Your production platform data is hosted on Charmies-controlled infrastructure in Germany, within the European Economic Area. Resend may process transactional email metadata outside the EEA; where this happens, transfers must be covered by appropriate safeguards such as Standard Contractual Clauses (SCCs) as approved by the European Commission.

6. Data Retention

Data CategoryRetention Period
Active charmie profileWhile account is active
Anonymized records after account deletion7 years (Belgian tax and accounting obligation)
Job applications (unselected candidates)6 months after job date
Messages2 years (contractual dispute resolution)
Audit logs5 years

7. Your Rights

Under GDPR, you have the following rights. We will respond within 30 days of receiving a verifiable request.

Access (Art. 15)Request a copy of all personal data we hold about you.
Rectification (Art. 16)Correct inaccurate or incomplete data.
Erasure (Art. 17)Request deletion of your personal data (subject to legal retention obligations).
Portability (Art. 20)Receive your data in a machine-readable format (JSON).
Restriction (Art. 18)Request that we limit processing of your data in certain circumstances.
Objection (Art. 21)Object to processing based on legitimate interests.
Withdraw Consent (Art. 7(3))Withdraw consent at any time, without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at privacy@charmies.be. You can also exercise your rights to data access, portability, erasure, and consent withdrawal directly from your account settings at Settings → My Profile → Privacy & Data Rights.

8. Right to Lodge a Complaint

If you believe we have not handled your personal data in accordance with GDPR, you have the right to lodge a complaint with the Belgian supervisory authority:

Autorité de protection des données (APD)

Rue de la Presse 35, 1000 Brussels, Belgium

Website: www.dataprotectionauthority.be

Tel: +32 2 274 48 00

9. Security Measures

We implement technical and organizational measures to protect your data, including:

  • AES-256-GCM encryption for SSIN, IBAN, and national ID card number at rest
  • TLS encryption in transit
  • Role-based access control — only management and admin roles can view your sensitive data
  • Row-Level Security on all database tables
  • HTTP security headers (CSP, HSTS, X-Frame-Options)
  • File upload validation (type, size, MIME checks)

In the event of a personal data breach, we will notify the APD within 72 hours and affected individuals without undue delay, as required by GDPR Articles 33–34.

10. Cookies

We use only strictly necessary cookies for authentication (session management). We do not use advertising, analytics, or tracking cookies. No cookie consent banner is required for strictly necessary cookies under the Belgian ePrivacy Directive.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated by email or an in-app notification. The "Last updated" date at the top of this page reflects the most recent revision. Continued use of the platform after changes constitutes acceptance of the updated policy.

Questions? Contact us at privacy@charmies.be