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Privacy statement

Privacy statement

1.   Introduction

In this privacy statement we explain what data we process about you if you visit our website and/or social media channels or use our application, we want to have, or have had, a (business) relationship with you. We also tell you why and for how long we process your data and what your rights are with regard to each processing. In addition, we provide information about the parties we work with and about our security policy.

We believe it is important that our services are reliable and transparent. We handle your data discretely and carefully, and we ensure that processing of your data complies with applicable laws and regulations.

We can make amendments to this statement if developments give cause to do so, for example in the case of new processing forms. The most current privacy statement can be found on our website. We encourage you to consult this privacy and cookie statement regularly, so that you are kept informed of the changes.

May 27, 2020

 

Index

  • 1. Who is responsible for your data?
  • 2. Which data do we process from you?
  • 3. For what purpose and based on what legal grounds do we use your data?
  • 4. How long do we save your data?
  • 5. Who has access to your data?
  • 6. Which cookies do we use?
  • 7. What are your rights?
  • 8. How do we protect your data?
  • 9. Whether we make automated decisions?
  • 10. Any questions or complaints?

 

1.  Who is responsible for your data?

We are:

elho B.V.
Atlasstraat 11
5047 RG
Tilburg

Phone number:+3113 515 7800
E-mail: contact@elho.nl

Chamber of commerce: 16033834
VAT: NL00330668B01

 

2.  Which data do we process from you?

Depending on your relationship with our organisation and the purpose for which we process data, we record (some of) the following data:

a)    first and last name
b)    phone number
c)    e-mail address
d)    password
e)    country and preferred language
f)     delivery- and billing address
g)    account information
h)    location details
i)      IP address
j)      information about your activities on our website
k)    details of conversations you have had with customer service about your purchase
l)      video recordings of visits to our company or premises

 

3. For what purpose and based on what legal grounds do we use your data?

We process your data for the following purposes:

a)    keeping financial records
b)    processing and executing assignments
c)    creating and maintaining your account
d)    sending newsletters
e)    providing appropriate customer service
f)     keeping applicant (job vacancy candidates) records
g)    keeping visitor records
h)    conducting camera surveillance
i)      monitoring of website visits

The grounds for processing are those referred to in Article 6 of the GDPR (consent, agreement or legitimate interest).

 

4. How long do we save your data?

In general, we do not store your data longer than necessary for the purpose or purposes for which we have collected your data. The retention period can be different from case to case. One example is that we have to keep a number of documents for a minimum term for tax or administration purposes. In those cases, we will only store the data that is necessary to meet our legal obligations. After the legal storage periods we will delete or anonymise your data.

 

5.  Who has access to your data?

We only share your data with third parties if this is necessary in the context of performing an agreement with you and to comply with a legal obligation. Insofar as these third parties have to act as processor, we have entered into a processor agreement with those third parties in which security, confidentiality and your rights are set out. We also agree that your data will be deleted as soon as it is no longer needed. We remain responsible for these processing operations.

The use of third parties in the above manner and grounds we do in the following categories of processing:

a)    processing and executing assignments
b)    organizing (customer events
c)    sending newsletters or mailings
d)    conducting an applicant (vacancies-candidates) administration
e)    conducting a visitor
f)     registration keeping camera surveillance
g)    monitoring of website visit
h)    monitoring (and/or maintenance) of the application

 

6.  Which cookies do we use?

We use cookies on our website. This is a small text file that is stored in the browser of your computer, tablet or smartphone when you first visit this website. Do you want to know more about cookies we use? Read our cookie policy here.

 

7. What are your rights? 

The following explains what your rights are with regard to the processing of your data.

a)    Right to inspect
You have the right to inspect your own data. This also includes the question of what the purposes of the processing are, to which parties the data is provided, what the retention periods are.

b)    Right to rectification
You can ask us to have your data rectified immediately. You also have the right to complete incomplete data by, for example, by sending an email to us.

c)    'Right to be forgotten'
You have the 'right to be forgotten.' Upon request, we will delete your data without unreasonable delay. However, we cannot always delete all of your data. Sometimes the processing is still necessary for compliance with legal obligations or for setting up, exercising or substantiating claims, for example.

d)    Right to limit the processing
In principle you have the right to limit the processing of your data, for example if you believe that your data is incorrect or unnecessary.

e)    Notification of rectification, deletion or limitation
Unless it is impossible or disproportionate effort, we will inform the recipients of your data of any rectification, deletion or limitation of the processing.

f)     Right to transfer your data
You have the right to transfer data. This means that you can request to receive your data. You can then save this data for personal reuse. You have this right only with regard to data that you yourself have provided to us and if the processing is based on permission or an agreement to which you are a party.

g)    Withdrawing consent
If the data processing is based on consent, you have the right to revoke that consent at any time. However, the processing of your data from the period prior to withdrawal remains legitimate.

h)    Right of objection
In principle you have the right to object to the processing of your data. After your objection, we will stop processing your data.

i)      Complaint to the Authority for Personal Data or to the court
If you believe that the processing of your data violates the law, you can contact our Privacy Manager, but you also have the right to file a complaint with the Authority Personal Data (AP) or to go to court.

j)      Limitations of your rights
Sometimes we can limit your rights, for example in the context of the prevention, investigation, detection and prosecution of criminal offenses, such as fraud.

You can address any request to our Privacy Manager. To ensure that a request has been made by you, we ask you to send a copy of your ID. In this copy, black out your passport photo, MRZ (machine readable zone, the strip with numbers at the bottom of the passport), passport number and citizen service number (BSN). This is to protect your privacy.

 

8. How do we protect your data?

We take the protection of your data seriously and take appropriate measures to prevent misuse, loss, unauthorised access, unwanted disclosure and unauthorised modification. If you have the impression that your data is not secure or there are indications of abuse, please contact our Privacy Manager.

 

9. Whether we make automated decisions?

We do not make decisions based on automated processing on matters that can have (significant) consequences for people. These are decisions made by computer programmes or systems, without a person (for example one of our employees) involved.

 

10. Any questions or complaints?

We have appointed a Privacy Manager. That is not a "data protection officer" as referred to in Article 37 of the GDPR. However, this is someone who ensures that your data is processed in accordance with the law. The activities of the Privacy Manager include monitoring and handling questions and complaints. The contact details of our Privacy Manager are:

privacy@elho.nl
+3113 515 7856