We understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who uses our website and we will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”). Please read this Privacy Notice carefully and ensure that you understand it.
This Notice applies where we are acting as a data controller with respect to the personal data of our website visitors; in other words, where we determine the purposes and means of the processing of that personal data. While we assume the role of a data controller for the personal data of visitors to our website, we function as a data processor when delivering services via our platform. For additional details, please consult section 10.
2. Information about us
This website is an initiative of Finventory 21 B.V. a company incorporated and existing under the laws of the Netherlands with registered address at Rietschotten 1 PB 203 4751 XN Oud Gastel The Netherlands , and with company number 66949971. referred to as “Finventory” or “we” or ‘us’).
You can contact our person responsible for privacy matters in writing at the following address: Finventory 21 B.V, for the attention of Client Services –, Netherlands or sending an email to firstname.lastname@example.org.
3.What is personal Data?
Personal data is defined by the by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in section 5 of this Privacy Notice.
4. What are my rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions.
- The right to access the personal data we hold about you. If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any personal data is held). This is known as a ‘data subject access request’.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please note that this right is not absolute and can only be used if (i) we no longer need your personal data for the original purpose, (ii) if you withdraw your consent for processing it, (iii) if you object to us processing your personal data for our legitimate interest, (iv) if we unlawfully process your personal data or (v) if a local law requires us to erase your personal data.
- The right to restrict (i.e. prevent) the processing of your personal data. You have the right to ask us to restrict the use of your personal data if (i) you believe that the personal data which we hold is inaccurate, (ii) if we are processing the personal data unlawfully, (iii) you have objected to us processing your personal data for our legitimate interests or (iv) we no longer need the personal data for the purposes of processing but you want us to keep this for the establishment, exercise or defence of legal claims.
- The right to object to us using your personal data for a particular purpose or purposes. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
- Rights relating to automated decision-making and profiling. You have the right not to be subject to decisions which may legally or significantly affect you and that were based solely on automated processing using your personal data. We will however not use your personal data in this way.
There is in principle no charge for exercising your right. If, however, your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your request within one month after receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. The contact details of your supervisory authority can be found here. You may do so in the country of your habitual residence, your place of work or the place of the alleged infringement. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first.
5. What personal data do we process?
In this section we have set out:
- the general categories of personal data that we may process;
- the purposes for which we may process personal data; and
- the legal bases of the processing.
Depending on your use of our website, we may collect some or all of the following personal data:
Job application data
We may process your information like your contact details, your CV and your cover letter (« job application data« ). The job application data may, depending on the information you submit to us, include your name, address, telephone number, email address, profile pictures, , date of birth, , interests and hobbies, educational details and employment details.
The application data may be processed for the following purposes: assessing your skills, qualifications, and suitability for the role, communicating with you about the recruitment process, and keeping records related to our hiring processes.
The legal basis for processing Job application data is the performance of the contract. The processing is necessary for the execution of pre-contractual measures and the establishment of the contractual relationship between us and you.
We may retain personal data from your CV for as long as it is necessary for our recruitment process but not longer than one year. In case we would like to keep it longer, we will request your consent. You may withdraw your consent at any time by sending an email to email@example.com.
We will always ask for your explicit consent to contact your previous and current employers and/or the contacts you have indicated.
We may process your first and last name, phone number, email address and any information contained in a contact form you submit to us regarding our company and/or our activities or in an email that you send directly to us (“enquiry data“). The enquiry data may be processed for the purposes of responding to your requests. The legal basis for this processing is our legitimate interest.
Customer relationship data
We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.
Supplier relationship data
We may process information relating to our supplier relationships, including supplier contact information (« supplier relationship data »). The supplier relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the supplier relationship data is you or your employer. The supplier relationship data may be processed for the purposes of managing our relationships with our suppliers/partners, communicating with the suppliers, and keeping records of those communications. The legal basis for this processing is our legitimate interests, namely the proper management of our supplier relationships.
Other categories of data
We may process any of your personal data identified in this Privacy Notice where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
We may process any of your personal data identified in this Privacy Notice where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
In addition to the specific purposes for which we may process your personal data set out in this section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Please do not supply any other person’s personal data to us, unless we prompt you to do so.
6. Do you share my personal data?
Use of processor(s)
We are free to rely on data processors. A processor is the natural or legal person who processes your personal data upon request and on behalf of us, the controller. The processor is required to ensure the security and confidentiality of the personal data. The processor will always act on our instructions. We rely on processors for hosting purposes, administrative purposes, marketing purposes, analytic purposes and communication purposes.
With a view to the optimal protection of your personal data, we have made the necessary contractual arrangements with our processors to ensure that they apply the highest privacy standards. In any event, data processors shall be required to ensure the security and confidentiality of the personal data.
Transfer of personal data to third parties
In addition to the specific disclosures of personal data set out in this section , we may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. We may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7. International transfers of your personal data
We will store or transfer some of your personal data within the European Economic Area (the « EEA »). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.
8. How long will you keep my personal data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept until you delete your account or as long as required by mandatory law.
In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on use case and legally allowed retention periods.
Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
9. How do we protect your personal data
The security of your personal data is essential to us. To protect your data, we will take appropriate technical and organisational precautions. This means that we have the necessary policies and procedures and IT security measures in place to ensure the confidentiality and integrity of your personal data. These policies, procedures and measures are periodically updated to keep them in line with regulations and market developments.
Internal access to the personal data is limited on a strict ‘need-to-know’ basis. Only authorized personnel, whose activity will be monitored to prevent any misuse, will be able to access the personal data.
10. Acting as a data processor
In respect of personal data collected when providing the services through our platform, we do not act as a data controller; instead, we act as a data processor. Insofar as we act as a data processor rather than a data controller, this Privacy Notice shall not apply. Our legal rights and obligations as a data processor are instead set out in the contract between us and the relevant data controller.
11. Personal data of children
Our website targeted at persons over the age of 18. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
12. About cookies
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either « persistent » cookies or « session » cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
13. Changes to this Privacy Notice
We reserve the right to change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our website in a way that affects personal data protection and privacy. Every change will be posted on our website. We advise you to consult our Privacy Notice regularly to be kept up to date.
Last update : June 22, 2023