Privacy Policy — Banenbank.ai

Last updated: 16 July 2026

This Privacy Policy explains how De Banenbank B.V. ("De Banenbank", "we", "us", "our") collects, uses, and protects personal data through our recruitment marketing platform Banenbank.ai (the "Platform"), available at ads.debanenbank.nl.

We comply with the EU General Data Protection Regulation (GDPR) and, where applicable, the Meta Platform Terms and Developer Policies.

1. What the Platform does

Banenbank.ai enables employers and recruitment clients ("Clients") to create, publish, and manage job vacancy advertising campaigns on Meta platforms (Facebook and Instagram) via the Meta Marketing API. Candidates who respond to these advertisements can submit their details through Meta Instant Forms ("lead forms"). The Platform retrieves these submissions and makes them available to the relevant Client for recruitment follow-up.

2. Whose data we process

We process personal data of two groups:

• Candidates — individuals who submit a lead form in response to a job advertisement published through our Platform.
• Clients and their users — individuals who create an account on the Platform and connect their Meta business assets to it.

3. What data we collect

3.1 Candidate data

When a candidate submits a lead form, we receive the data fields configured in that form by the Client. In most cases this includes:

• Full name
• Phone number
• Email address
• Answers to qualifying questions in the lead form (for example availability or relevant experience)

We only receive the fields the candidate actively submits. We do not collect additional data about candidates from other sources.

3.2 Client data

When a Client creates an account and connects their Meta assets, we collect and store:

• Account details (name, business name, email address, login credentials)
• Meta Business Manager and ad account connection details
• Access tokens required to operate campaigns on the Client's behalf
• Advertising data associated with the connected assets, including published campaigns, ad creatives, and campaign performance results (such as reach, clicks, and cost metrics)

3.3 Data received from Meta ("Platform Data")

The data described above that we receive through Meta's APIs — lead form submissions, ad account information, campaign data, and performance metrics — qualifies as Platform Data under the Meta Platform Terms. We process Platform Data solely to provide the Platform's functionality as described in this policy and in accordance with Meta's Platform Terms and Developer Policies.

4. Why we process this data and on what legal basis

Purpose	Data	Legal basis
Delivering candidate applications to the relevant Client	Candidate data	Performance of a contract with the Client; candidates provide their data voluntarily via the lead form for the purpose of applying
Creating, publishing, and managing advertising campaigns	Client data, access tokens	Performance of a contract
Displaying campaign results and reporting	Campaign and performance data	Performance of a contract
Account administration and support	Client account data	Performance of a contract
Complying with legal obligations	All categories where required	Legal obligation

For candidate data, De Banenbank acts as a processor on behalf of the Client, who is the controller. The Client determines which fields are collected in the lead form and is responsible for the recruitment process. For Client account data, De Banenbank acts as the controller.

5. Where your data is stored

All data is stored within our own Platform infrastructure, hosted by Hostinger on servers located in the European Union (Lithuania and the Netherlands). Candidate data is not transferred to, or processed by, any external tools or third-party services outside the Platform.

6. Who we share data with

• Clients: candidate data is shared exclusively with the Client whose job vacancy the candidate responded to.
• Meta Platforms Ireland Ltd.: campaign instructions and advertising data are exchanged with Meta as necessary to operate campaigns via the Meta Marketing API. Meta's own processing is governed by Meta's Privacy Policy.
• Hostinger: as our hosting provider, Hostinger processes data on our behalf under a data processing agreement.

We do not sell personal data. We do not share Platform Data with any other third parties, except where required by law.

7. How long we keep data

• Candidate data: retained for as long as necessary for the Client's recruitment process, and deleted upon the Client's or candidate's request. By default, candidate data is deleted no later than 12 months after submission.
• Client data: retained for the duration of the contract. Access tokens are revoked and deleted when the Client disconnects their Meta assets or terminates their account.
• Campaign and performance data: retained for the duration of the contract for reporting purposes.

Data required for legal or tax obligations may be retained longer where the law requires this.

8. How we protect your data

We apply appropriate technical and organisational measures, including:

• Encryption of data in transit (TLS/HTTPS)
• Secure server-side storage of access tokens; tokens are never exposed in client-side code
• Access to personal data restricted to authorised personnel only
• Regular review of access rights and security measures

9. Your rights

Under the GDPR, you have the right to:

• Access the personal data we hold about you
• Have inaccurate data corrected
• Have your data deleted
• Restrict or object to processing
• Receive your data in a portable format
• Withdraw consent, where processing is based on consent

To exercise any of these rights, email sem@debanenbank.nl. We respond within 30 days. Candidates may also contact the Client (the employer) directly, as the controller of their application data. You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

10. Data deletion

You can request deletion of your personal data at any time:

Candidates: send an email to sem@debanenbank.nl stating the name, email address, and/or phone number you used in the lead form. We will delete your data from the Platform and confirm the deletion to you within 30 days.

Clients: you can disconnect your Meta assets from the Platform at any time, which revokes and deletes the associated access tokens. To delete your full account and all associated data, send a request to sem@debanenbank.nl. We will delete your account data and confirm within 30 days.

Deletion via Facebook: if you used Facebook Login for Business to connect to the Platform, you can also remove the app via your Facebook settings (Settings & Privacy → Settings → Business Integrations), select Banenbank.ai, and choose Remove. Following removal, you may request deletion of all data we hold by emailing sem@debanenbank.nl as described above.

11. Cookies and tracking

The Platform uses the following cookies and similar technologies:

• Functional cookies: strictly necessary for the operation of the service, such as session cookies for authentication. These are always active.
• Google Analytics: we use Google Analytics to measure how the Platform is used (pages visited, session duration, general usage patterns), so we can improve our service. This data is processed by Google LLC. We have configured Google Analytics in a privacy-friendly manner and do not use it to process candidate application data.
• Meta Pixel: we use the Meta Pixel to measure the effectiveness of our own marketing and to improve our advertising. Data collected through the Pixel is shared with Meta Platforms Ireland Ltd. and processed in accordance with Meta's privacy policy.

Analytics and marketing cookies are only placed after you have given consent through our cookie banner. You can withdraw or adjust your consent at any time via the cookie settings on the Platform. Lead form submissions by candidates on Facebook and Instagram take place within Meta's environment and are not tracked by our Google Analytics or Meta Pixel.

12. Changes to this policy

We may update this Privacy Policy from time to time. The most recent version is always available at ads.debanenbank.nl/privacy. Material changes will be communicated to Clients directly.

13. Contact

For any questions about this Privacy Policy or our data practices:

De Banenbank B.V.
Veldzigt 73, 3454 PW De Meern, the Netherlands
sem@debanenbank.nl
+31 6 44776005