Privacy statement

1. General

Insocial - Feedback Solutions allows you to use our Insocial service to support your business activities. The operation of the Insocial service is explained on the website www.insocial.eu. Through this website and our services (whether or not because you provide this personal data to us yourself), we obtain personal data from you. Our services offered include conducting customer satisfaction surveys on behalf of our clients.

We believe that protecting the privacy of the users, visitors, customers and subscribers of our websites/services is of great importance to our operations. We therefore attach great importance to protecting the privacy of you, our users, visitors, customers and subscribers. We therefore handle the personal data we obtain with care and act as well as process such personal data only in accordance with applicable privacy laws and regulations. This includes the following:

• we clearly state the purposes for which we process your personal data;
• we limit the (collection of) processed personal data to only those data that are really necessary;
• we first ask your explicit and specific permission to process your personal data in cases where your permission is required;
• we take appropriate organizational and technical security measures to protect your personal data and require the same from parties processing personal data on our behalf (if applicable).

In this Privacy Statement, we explain what personal data we collect and use, as well as for what purposes and on what grounds we do so. It also explains how long we keep your personal data, whether we share this data with third parties, how your data is secured and how you can contact us.

2. What personal data we collect and process

To optimize our website and to be able to offer and deliver our services in the best possible way, we process Personal Data, which is any information about an identified or identifiable natural person. For the purposes listed in this Privacy Statement, we process the following Personal Data:

• Basic information: name (including initials), title(s), gender, date of birth;
• Contact information: e-mail address, address (business and/or personal), phone number(s);
• Position and occupation;
• Company and organization;
• Your contact person at [company name];
• Data related to your visit to our website, such as a URL, IP address, browser type and the duration of your visit (see 'What are cookies');
• Personal data you provide us with in relation to job applications, such as name and address, date of birth, telephone number(s), nationality, marital status and other personal information you provide yourself in your application;
• Personal data you provide to us in relation to attendance at meetings or events organized by [Company Name];
• Any other personal data or information that you provide to us or that we obtain in connection with the purposes and grounds mentioned under 3. above;
• Data about interests of you as a user of one or more of our websites (see also 'What are cookies').

We collect this information and data because you provide it to us or because you give us your consent to do so. This is the case, for example, when you enter into an agreement with us, when you voluntarily provide these data to us, when you enter data on the website, when you give us your business card, when you accept our cookie notification, or when you submit a job application. We may also collect this data from other sources such as the Chamber of Commerce, the Land Registry or through other publicly accessible sources (including social media).

3. Purposes and grounds for processing your personal data.

We only use the personal data we collect from you for the purposes described in this Privacy Statement, unless we have obtained your explicit prior consent for other purposes.

The purposes of our data processing are:

1. Use of our services: in order to use our services, it is necessary that you provide us with personal data. The services we provide are all services that you can reasonably expect from the provider of customer satisfaction surveys (with or without additional information, adjustments to needs and wishes and etc.). We process your personal data thereby by virtue of your given consent or by virtue of necessity for the execution of the (order) agreement given by you and accepted by us.
2. To fulfill our legal and regulatory obligations; an example is our tax obligations.
3. Marketing and business activities: we collect and process personal data for sending, for example, news updates, invitations to events, responses to our contact form and other communications that might be of interest to you (offers).
4. Application procedures: We collect and process applicant data for the purpose of the application process directly or through forms and/or attached CVs whether or not through third parties or via email.
5. Website: We also process personal data relating to the use of our website. For example, we use this to analyze the use of our website. This allows us to make the website even better and also better suited to our target groups and marketing.
6. To enable you to post and exchange information on one of our websites, or if our websites offer that possibility, to contact other users.

We process your personal data on one or more of the following grounds:

• Necessary for the performance of the agreement
• Necessary for the representation of legitimate interests
• Necessary for the fulfillment of a legal obligation
• Your consent (if required)

We do not use automated decision making or profiling. In addition, you are not obliged to share personal data with us. However, this may result in us being less able to serve you.

4. Retention period personal data

Unless otherwise stated in this Privacy Statement, your personal data will not be kept longer than is necessary for the use in accordance with the purposes for which the data have been provided or collected, or in order to comply with applicable laws and regulations (the applicable laws and regulations have both maximum and minimum retention periods).

With regard to job applications: your personal data will be deleted no later than 4 weeks after the end of the application process if, unfortunately, you did not get the job. If we have received your permission to retain the data longer, for example because suitable positions may become available in the future, this retention period will be one year.

5. Your personal data and third parties

We only use third parties to process personal data for the purposes described in this privacy statement if this is necessary and/or if you give us your consent. In doing so, if third parties are engaged, we will always take appropriate measures to ensure that your data is adequately secured and used only for the purposes specified in this Privacy Statement.

In performing our services and activities, we use, among others, the following third parties with whom we may share your personal data (the following list is not exhaustive):

• Third parties relevant in the context of the performance of our offered and provided services: for example, our clients, Facebook, Google etc.;
• Third parties with whom we interact in order to comply with our legal obligations, such as supervisory authorities and other bodies, as well as the accountant (for our business records), pension administrators, etc;
• Other third parties in relation to the processing of personal data for the purposes described in this Privacy Statement, such as ICT providers, communications providers and other organizations to whom we outsource some 'support services'.

Third parties to whom we provide your personal data are themselves responsible and liable for their actions and must ensure that they comply with applicable laws and regulations. We are neither responsible nor liable for the processing of your personal data by third parties. If a third party is engaged to process personal data, we will always enter into a processing agreement as referred to in the AVG with the party in question. We never give a third party permission to share your data with others.

In appropriate cases, the transfer of personal data to countries outside the European Union will only take place if those countries offer an adequate level of protection for the processing of personal data in accordance with the relevant legislation, for example the US/EU Privacy Shield, if the transfer is necessary and if one of the processing grounds mentioned in this agreement allows for this.

6. The security and protection of your personal data

We have taken appropriate technical and organizational measures to protect your personal data against loss and breach or against any form of unlawful processing, access, modification, etc.

These measures include, but are not limited to:

• all information is kept confidential and everyone who comes into contact with personal data is bound by a (contractual) duty of confidentiality;
• our employees only have access to the data they need to carry out their work;
• all information and personal data are stored on secure servers;
• we ensure that our network connections are secure;
• regular backups are made of all the systems we use;
• our premises are properly secured (with alarm) to prevent theft;
• regular security checks of the applications and systems we use are performed by an external party (pen tests & server scans);
• all our employees are aware of the great importance of privacy protection;
• Access security (both in the company premises and in Insocial's systems);
• Encrypting, pseudonymizing or anonymizing personal data as much as possible, including when transporting this data.

For more information about our security, please contact us using the details below (see 13.).

7. Your rights

You have the right to ask us to provide you with access to (all) of your personal data and/or to correct, supplement, otherwise amend, delete and/or protect these data. If processing is based on your consent, you are entitled to withdraw this consent at any time (without retroactive effect). Furthermore, you are entitled to request the export of your personal data, to object to the processing of your personal data (if substantiated), to object to the exchange of your personal data and to request the restriction of the processing of your personal data (also substantiated). In addition, you are entitled to file a complaint with a relevant privacy regulator (in the Netherlands this is the Authority Persoonsgegevens).

To exercise these and/or other rights and corresponding requests, please contact us (see 13.). In your request, you must state on what grounds you are making the request and provide sufficient information on the basis of which we can verify your identity.

Your requests may in some cases be refused by us. You will be informed of this, stating the legal basis for refusing your request. The reason for this may include a legal obligation imposed on us or the excessive or unreasonable nature of one or more requests.

In the case of exceptionally complex requests, or an excessive number of requests, instead of a refusal of the request, an appropriate administrative fee for the execution of the request may also be charged to the requester. You will be notified of this in advance.

8. Cookies

Insocial's website as well as the websites/weblinks we set up, maintain and use for the benefit of its clients use cookies to function properly. You can specify in the settings of your web browser whether you want to allow these cookies or not. You only have to indicate this once (until you delete your temporary files). However, this may limit the functionality of the website.

9. Which cookies?

We use two types of cookies:

• Necessary cookies: these are cookies necessary for the proper functioning of our website. For example, your choice in whether or not to accept cookies or remembering data entered on the website. These cookies are not shared with third parties. Your permission is not required for these cookies.
• Analytical cookies: These cookies are used to analyze our websites and their statistics, so that the website (its use and findability) can be optimized. Among other things, we use the Google Analytics tool for this purpose. For the use of these cookies we ask your prior consent through our cookie floater. We have concluded a processing agreement with Google for this processing. Google may provide personal data to third parties if Google is legally required to do so, or insofar as these third parties process the information on Google's behalf. We have no influence on this. We have not allowed Google to share the obtained information with others. We also use cookies from other Google services, such as Google Adwords and Google Remarketing, and cookies from: Mouseflow, Linkedin and Facebook, if you give us your permission to use cookies (for an overview see the table below). If you do not give permission for the use of these cookies, we will only use cookies from which we cannot derive any personal data from you. You do not need to give permission for these cookies. An example of this are the privacy-friendly Google Analytics cookies. We have concluded a processing agreement with Google for these as well. We have deactivated data sharing with Google and anonymized your IP address for the use of Google Analytics. Google may provide personal data to third parties if Google is legally required to do so, or insofar as these third parties process the information on Google's behalf. We have no influence on this. We have not allowed Google to share the information obtained with others. We do not use other Google services or other cookies if you have not given us permission to use cookies (see table below for overview).
  
  
  

10. Other

This Privacy Statement does not apply to third party websites linked to our website. We cannot guarantee that these third parties will handle your personal data in a reliable or secure manner. We encourage you to read the privacy and cookie statements of these websites before using them.

We conduct customer satisfaction surveys for and on behalf of our clients. The personal data we obtain in the process are not our property. Such personal data is therefore not subject to the provisions of this (our) Privacy Statement. Instead, the privacy statements of our clients and the processing agreements entered into between us and the clients apply to that personal data. This means that if you have questions or comments regarding this personal data, or if you wish to exercise the rights mentioned in paragraph 8 with respect to this personal data, you should contact our client itself. We will actively support you in this, including by forwarding your questions, comments or requests to our client concerned.

11. Changes to this Privacy Statement

We reserve the right to modify this Privacy Statement at any time and for any reason and therefore recommend that you regularly check this section of the website.

12. Complaints

Do you have a complaint about the processing of your personal data? Then we would like to discuss this with you. Pursuant to privacy legislation, you also have the right to lodge a complaint about incorrect processing of your personal data with the Authority for Personal Data. For more information please contact the Authority for Personal Data. For other types of complaints, please refer to our complaints procedure.

Contact details of the data protection officer
Harold Renssen
dpo@insocial.nl

13. Questions

For all your questions and/or comments and/or complaints and/or requests, whether or not about the processing of your personal data or this privacy statement, please contact Insocial by Spotler B.V., located at Henri Faasdreef 312 in The Hague, via: s ervicedesk@insocial.nl