Last updated October, 2018
Expats at Ease (hereafter EaE) is dedicated to protecting the confidentiality and privacy of information entrusted to it. EaE has taken measurements to the appropriate protection and use of personal information (sometimes referred to as personal data). It concerns:
1 the personal information that is provided voluntarily by online visitors
2 the personal information that is provided by you as client of our office
Please review this Privacy Statement ("Privacy Statement") to learn more about how we collect, use, share and protect the personal data that we have obtained.
1. Collection and use of personal data
We obtain personal information about you if you choose to provide it - for example, to contact mailboxes or to register for certain services. Next to this we obtain personal information because we contractor - client relationship. Your Personal data is not used for other purposes, than the purposes for which you have provided the information to us, unless we obtain your permission, or unless otherwise required or permitted by law, professional standards or quality rules, or in case required to improve the quality of our services. For example, if you send us an email message requesting information about EaE, we will use your email address and other information you supply to respond to your request. If you send us a resume or curriculum vitae (CV) to apply online for a position with EaE, we will use the information that you provide to match you with a job available at EaE.
EaE generally collects only the personal information necessary to fulfill your request. Where additional, optional information is sought, you will be notified of this at the point of collection.
The law in the Netherlands allows us to process personal information, so long as we have a ground under the law to do so. It also requires us to tell you what those grounds are. As a result when we process your personal information, we will rely on one of the following processing conditions:
• Performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract;
• Legal obligation: this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency;
• Legitimate interests: we may process information about you where it is in our legitimate interest in running a lawful business to do so in order to further that business, so long as it doesn't outweigh your interests; or
• Your consent: we may occasionally ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so. You may withdraw your consent at any time by contacting EaE at firstname.lastname@example.org.
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EAE only collects "sensitive" personal information when the relevant individuals voluntarily provide us with this information or where such information is required or permitted to be collected by law or professional standards. Sensitive information includes personal information regarding a person's race, ethnicity, political beliefs, trade union membership, religious or similar beliefs, physical or mental health, sexual life or criminal record. Please use your discretion when providing sensitive information to EAE, and under any circumstances, do not provide sensitive information to EAE, unless you thereby consent to EAE's use of that information for its legitimate business purposes and consent to the transfer and storage of such information to and in EAE databases. If you have any questions about whether the provision of sensitive information to EAE is, or may be, necessary or appropriate for particular purposes, please contact EAE at administratie@EaE.nl.
When we have a client - contractor relationship EAE will in general store the personal data longer than the legal statutory period, because EAE is of the opinion that this is in the client's interest for the execution of our (continuous) agreement to provide services on your behalf. In the paragraph Your Rights you can read how to object.
2. Automatic collection of personal information
An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognize and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct website trend and performance analysis.
3. Sharing and transfer of personal data
We do not share personal information with unaffiliated third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards. This includes:
• Our service providers: EAE work with reputable partners, service providers or agencies so they can process your personal information on our behalf. EAE will only transfer personal information to them when they meet our strict standards on the processing of data and security. We only share personal information that allows them to provide their services.
• Courts, tribunals, law enforcement or regulatory bodies: EAE may disclose personal information in order to respond to requests of courts, tribunals, government or law enforcement agencies or where it is necessary or prudent to comply with applicable laws, court or tribunal orders or rules, or government regulations.
• Audits: disclosures of personal information may also be needed for data privacy or security audits and/or to investigate or respond to a complaint or security threat.
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In some instances, EAE may share personal data about you with various outside companies or service providers or vendors working on our behalf to help fulfill your requests or in order to serve you as client of our office.
In addition, EAE may transfer certain personal data across geographical borders to other companies working with us or on our behalf. EAE may also store personal data in a jurisdiction other than where you are based. Personal data transfer by EAE are in accordance with the Dutch Data Protection Act.
EAE may also disclose personal data in order to respond to requests of government or law enforcement agencies or where this is required by applicable laws, court orders, or government regulations. These disclosures may also be needed for data privacy or security audits and/or to investigate or respond to a complaint or security threat. EAE does not sell personal data to any third parties. Also, EAE will not transfer the personal data you provide to any third parties for direct marketing use.
5. Your rights
If you have submitted personal information to EAE, you have the following rights:
• Access and correction: you have the right to access to that data. This is sometimes called a 'Subject Access Request'. If we agree that we are obliged to provide personal information to you, we will provide it to you free of charge. Before providing personal information to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. If the information we hold about you is incorrect, you may ask us to correct any inaccuracies in the personal information.
• Object to processing: you have the right to object to us processing your personal information if we are not entitled to use it any more, to have your information deleted if we are keeping it too long or have its processing restricted in certain circumstances.
You can make a request or exercise these rights by contacting administratie@EaE.nl and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.
6. Data security and integrity
EAE has reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. In addition EAE has concluded a separate Cyber and Data Risk insurance policy. Despite EAE's best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information. We also make reasonable efforts to retain - 8 -
personal information only for so long as the information is necessary to comply with an individual's request or until that person asks that the information be deleted.
7. Links to other sites
8. Changes to this statement
EAE may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the "updated" date at the top of this page. We encourage you to periodically review this Privacy Statement to be informed about how EAE is protecting your information.
9. Policy questions and enforcement
EAE is committed to protecting the online privacy of your personal information. If you have questions or comments about our administration of your personally identifiable information, please contact us at administratie@EaE.nl . You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement.
In any event, you always have the right to file a complaint with the Dutch Data Protection Authority.