Privacy statement Direction Europe BV
(May 22, 2018)
Preface
Direction Europe BV takes your privacy very seriously and will process and use information about you (the data subject) in a secure manner. In this Privacy Statement we explain which data we process and for which purpose we do so. In addition, in this Privacy Statement you can read about your rights regarding our processing of your personal data. We encourage you to read this Privacy Statement carefully. For questions you can always contact schreurs@dir.nl.
Who is Direction Europe BV?
Direction Europe BV is the limited company Direction Briefings for Business Leaders Europe BV (office: Oude Enghweg 2, 1211 JC HILVERSUM, The Netherlands), registered in the trade register of the Chamber of Commerce under number 30158497.
Direction Europe BV is the controller with regard to the processing of your personal data by Direction Europe BV.
How does Direction Europe BV use your data?
Below you will find an overview of the purposes for which Direction Europe BV processes personal data about you. In doing so, it is always indicated which data Direction Europe BV uses for that specific purpose, which is the legal basis for processing this data and for how long the data is retained by Direction Europe BV. To keep things organized, we have grouped everything by type of data stream.
Services, customer management and financial administration
Purpose: Financial administration
Data: Company name, Invoice address, Bank details (Bank name / IBAN / BIC), Chamber of Commerce number, VAT number and name and gender contact person administration.
Basis: Implementation of the agreement
Storage period: As long as necessary for this purpose and legally required
Purpose: Management of assignment
Data: Name and address details, Delivery address, Invoice address, E-mail address, Telephone number, Payment details, Account number, Order number, Invoice address, VAT number, Customer number, E-mail address and name and gender of the contact person
Basis: Implementation of the agreement
Retention period: As long as necessary for this purpose
Purpose: Handling complaints
Data: Name and address details, Delivery address, Invoice address, E-mail address, Telephone number, Payment details, Account number, Order number, Content of the complaint, Invoice address, VAT number, Customer number, E-mail address and name and gender of the contact person
Basis: Implementation of the agreement
Retention period: As long as necessary for this purpose
Purpose: Invoicing
Data: Company name, Invoice address, Bank details (Name bank / IBAN / BIC), Chamber of Commerce number, VAT number and name and sex contact person administration, Outstanding balance
Basis: Implementation of the agreement
Storage period: As long as necessary for this purpose and legally required
Purpose: To provide the service itself
Data:
feedforward analysis ™: name and address details, e-mail address, position, organization and / or department, data required to provide the service, data generated during the service.
Mindbugs test: First name, surname, gender, email address, completed education level, year of birth, number of FTE organization, sector, discipline, management yes / no, number of years working, country of birth (optional) and data generated during the service.
HPO Insight ™ and HPO diagnoses: Depending on customer requirements: IP address, email, department, job level and data generated during the service.
Basis: Implementation of the agreement
Storage period: As long as necessary for this purpose and legally required
Purpose: Providing the service on the basis of a test
Data:
feedforward analysis ™: name and address details, e-mail address, position, organization and / or department, data required to provide the service, data generated during the service.
Mindbugs test: First name, surname, gender, email address, completed education level, year of birth, number of FTE organization, sector, discipline, management yes / no, number of years working, country of birth (optional) and data generated during the service.
HPO Insight ™ and HPO diagnoses: Depending on customer requirements: IP address, email, department, job level and data generated during the service
Basis: Implementation of the agreement
Retention period: 5 years (feedforward analysis ™, Mindbugs tests and HPO Insight ™ and HPO diagnoses)
Explanation: Our tests
Our tests (HPO Insight ™, feedforward analysis ™ and Mindbugs tests) have been developed together with DataIM (https://www.dataim.nl/kwaliteit/#software quality). Data received during the use of this software is stored on the secure servers of DataIM. For the execution of HPO diagnoses and diversity studies, we use the MWM2 software (https://www.mwm2.nl/over-mwm2/). Data received during the use of this software is stored on the secure servers of MWM2. When we download data from MWM2 or DataIM, this is anonymized (unless strictly necessary for carrying out the research). When the research also asks for personal data (such as email address, first name / surname, telephone number, etc.), the data obtained with the feedforward analysis ™ and Mindbugs software become anonymous within five (5) years after processing and delivery of the report. Data obtained from HPO Insight ™ or HPO diagnoses via MWM2 become anonymous twenty-four (24) months after processing and delivery of the report. The customer is responsible for keeping the reports. After this period we can no longer produce it from the software, so comparisons are no longer possible.
Purpose: Do-it-yourself account at feedforward analysis ™, Mindbugs testing and HPO Insight ™
Data: Name, Address, E-mail address, Username, Password, Message content
Basis: Implementation of the agreement
Retention period: As long as necessary for this purpose. Details of respondents and participants: 5 years (feedforward analysis ™, Mindbugs tests and HPO Insight ™)
Purpose: Security do-it-yourself use feedforward analysis ™
Data: Password and username
Basis: Implementation of the agreement
Retention period: As long as necessary for this purpose
Marketing
Purpose: Direct marketing
Data: Name and address details, e-mail address and name and gender of the contact person, telephone number, interest in a product, postal address and function are stored in the secure environment of MailerLite (https://www.mailerlite.com/privacy-policy). We use MailerLite to manage our email marketing subscriber list and to send emails to our subscribers. MailerLite is a third-party provider, which may process your data using industry standard technologies to help us monitor and improve our newsletter. HPO Center BV uses double opt-in data and files that are subject to the person’s consent (Bolddata and HPO Center).
Basis: Justified interest
Relevant interest: Commercial interest
Retention period: As long as necessary for this purpose or contact unsubscribes from our database.
Website
Purpose: Website analytics (via Google Analytics)
Data: The cookie settings on our websites are set to ‘”allow cookies” to give you the best browsing experience possible. Google Analytics cookies are used, but are completely privacy-friendly.
Basis: Justified interest
Relevant interest: User interest based on permission by the visitor.
Retention period: As long as necessary for this purpose
Research & Development
Purpose: Scientific research
Data: Name and address details, E-mail address, Telephone number, Information about the behavior
Basis: Justified interest
Relevant interest: Scientific and practical research for publications. Use data only on the basis of permission by the involved party.
Storage period: 5 years for Direction and the HPO Center
How do we obtain your personal data?
Direction Europe BV has data about you, because you have provided us with information, and / or because Direction Europe BV has obtained data from other parties (including your employer).
What are your rights?
Under the European General Data Protection Regulation (GDPR) you have a number of rights with regard to your data and their processing:
Insight
You can always view your own (personal) data and change it in your account if necessary. If you want to see the personal data that has been recorded about you at Direction Europe BV, you can request access to it.
Modify
If you wish to make changes to the personal data that you have seen as a result of a request for perusal and that you can not change yourself in your account, you can request this from Direction Europe BV. You can request that Direction Europe BV modifies, corrects, supplements, removes or screens your data.
Limiting the processing
You also have the right, under certain conditions, to request Direction Europe BV to limit the processing of your personal data.
Right of objection
If a certain processing takes place on the grounds of the ‘legitimate interest’ of Direction Europe BV or a third party, you have the right to object to such processing.
Data transfer
You have the right to obtain your personal data from Direction Europe BV. Direction Europe BV will provide this in a structured and current form, which can easily be opened in other common digital systems. This way you can also transfer your data to another provider.
Retract permission
In all cases in which the basis for a certain data processing is your consent, you have the right to revoke that permission. This has no consequences for the past, but does mean that we will no longer be allowed to process this data. It is possible that Direction Europe BV can no longer deliver you certain services.
Response by Direction Europe BV
A request can be sent to schreurs@dir.nl. Direction Europe BV will comply with your request as soon as possible and in any case no later than one (1) month after Direction Europe BV has received such a request. If Direction Europe BV rejects your request, we will indicate in our reply why the request is rejected.
Recipients of personal data
The data can be passed on to:
- (sub) processors: DataIM (https://www.dataim.nl/kwaliteit/#softwarekwaliteit) and MWM2 (https://www.mwm2.nl/over-mwm2/) for the implementation of our feedforward analysis ™, Mindbugstest, HPO Insight ™ tool and HPO diagnoses. Avetica (https://www.avetica.nl/2018/03/22/avetica-is-avg-accountable/) for the HPO eCourses. MailerLite (https://www.mailerlite.com/privacy-policy) for our newsletters. Snelstart (https://www.snelstart.nl/hubfs/Downloads/General_conditions/18.001%20-%20BR%20Privacy Policy%20Snelstart_webversie.pdf) for the financial administration. Mollie (https://www.mollie.com) for payment services.
- Parties that are involved in the execution or fulfillment of an agreement between you and Direction Europe BV are our external trainers and experts from the HPO Center.
- It may be that Direction Europe BV is obliged to provide your data to a third party, for example on the basis of a legal obligation.
What are cookies and how does Direction Europe BV use them?
Cookies are small pieces of (text) information that are sent to your browser when you visit the website of Direction Europe BV and then on the hard drive or in the memory of your computer, tablet, mobile phone or other device (hereinafter: “Device”). “) being saved. The cookie settings on this website are set to “” allow cookies “to give you the best browsing experience possible. Google Analytics cookies are used, but are completely privacy-friendly. Check our website for more information about these cookies.
Can this Privacy Statement be changed?
This Privacy Statement can be changed. We therefore advise you to regularly read the Privacy Statement for any changes.
Where can you go with complaints and questions?
If you have any questions about this Privacy Statement and the way in which Direction Europe BV uses your data, you can send an e-mail to schreurs@dir.nl. Even if you have a complaint about the way Direction Europe BV processes your data, you can send an e-mail to schreurs@dir.nl. You can also always contact the competent national supervisor in the field of privacy protection. In the Netherlands this is the Dutch Data Protection Authority.