How and why does Halma Solutions collect personal data?
Halma Solutions collects personal data in the performance of its activities. In most cases, this concerns data that it requests from the data subject or that the data subject provides on its own initiative. Think of an initial telephone conversation between Halma Solutions and a (potential) customer or the situation in which a (potential) customer sends an email to Halma Solutions. Halma Solutions works as carefully as possible when processing personal data.
An essential part of that care is transparency. Halma Solutions believes it is important that third parties and those involved have insight into the way in which it uses personal data and the underlying reasons for this. That is why it has drawn up this statement.
If you have any questions or comments after reading this Statement, please contact Halma Solutions. Of course, this also applies if you would like to exercise one of the rights described below or if you have a complaint. The full address and name of the contact person can be found at the bottom of this statement.
Who exactly is Halma Solutions?
Halma Solutions is responsible for the processing of personal data. She is registered with the Chamber of Commerce under number 62260510, located at Bijsterhuizen 3007-G in Wijchen, available on telephone number +31 (0)24-7470013 and by email at firstname.lastname@example.org.
Does Halma Solutions have a Data Protection Officer?
Halma Solutions has not appointed a Data Protection Officer. It has appointed an employee who acts as the first point of contact when it comes to privacy and personal data. It concerns the lady in Poel. The full address can be found at the bottom of this statement.
Which personal data does Halma Solutions process and why does it do this? Halma Solutions processes different types of personal data, in order to
reasons. The data they process the most are:
• Identification data (name, e-mail address, contact person, telephone number, Chamber of Commerce number)
• Location data (postal and/or business address)
• Financial data (bank account number, payment details).
Halma Solutions processes additional data when applying for a job, namely • Family composition, education and training
If you visit the Halma Solutions website, it also processes other data than indicated above. That can be about:
• Information about the device, location, software usage and the like.
The first main purpose of this processing is to be able to conclude an agreement with the customer. For this, Halma Solutions and the customer must be able to communicate with each other. Think, for example, of making an inventory of the customer’s wishes and drawing up a quotation.
The second main objective is to be able to execute the agreement concluded. Consider, for example, periodic consultations about progress.
The third main goal is to enable invoicing of the work or services, as well as to facilitate payment (and, if necessary, collection).
The fourth main goal is to carry out marketing activities with the aim of getting more customers or increasing brand awareness.
The last main goal is to be able to inform the customer about developments that may be relevant to him or her.
Can Halma Solutions process that data?
Halma Solutions processes personal data if this is necessary to conclude or execute an agreement with a customer and/or a supplier. This is the case, for example, when a quotation is requested, when an order is placed or when Halma Solutions itself place order. Halma Solutions also processes personal data if its own interests justify this. This will be the case if it is reasonably impossible for Halma Solutions to carry out its work without processing that data. Finally, in some cases Halma Solutions (also) asks permission to use the data. The legal ground(s) for processing are therefore
1. that processing is necessary for the performance of a contract to which the data subject is a party, or takes place at the request of the data subject for the conclusion of a contract.
2. That processing is necessary for the representation of the legitimate interests of Halma Solutions (or a third party)
3. That the data subject has given permission for the processing
With regard to category (2), it applies in all cases to processing operations that are necessary for Halma Solutions to be able to realize its services. It simply cannot do its work, it cannot communicate, it cannot make offers, etc. without using the customer’s personal data. It therefore has a legitimate interest in those processing operations. Halma Solutions believes that this interest, when weighed against the interest of the data subject, should take precedence. There are two reasons for this. Firstly, the fact that Halma Solutions knows from experience that such processing usually does not give rise to objections. Halma Solutions therefore takes that as its starting point. Secondly, the fact that Halma Solutions does not keep the data longer than necessary. In order to nevertheless respect the rights of the data subject as much as possible, Halma Solutions only uses the data that is necessary to achieve the purpose.
With regard to category (3), given permission can be withdrawn at any time, without stating reasons.
Do those personal data also end up with others?
Halma Solutions will in some cases share personal data with parties it works with. These are so-called ‘processors’. Halma Solutions has concluded agreements with those processors. These serve to ensure that those processors (just like Halma Solutions itself) handle that data with care. For example, under that agreement, that processor is obliged to ensure proper security, to handle that data confidentially and to destroy the data.
Halma Solutions does not intend to share personal data with parties other than processors. At the most, it provides that, in a single case, information will be shared with (another) employee of the customer or with parties that have a direct relationship with the customer.
Will the personal data remain in Europe?
In this context, reference is made to the European Economic Area (EEA). It consists of the countries of the EU, supplemented by Norway, Liechtenstein and Iceland. All countries outside of this are considered a ‘third country’. Halma Solutions in some cases transfers personal data to third countries, in particular the USA. This only happens if it has been expressly established at European level that an appropriate level of personal data is guaranteed in the country concerned. With regard to the US, we only pass on data to parties that are certified under the EU-US Privacy Shield.
How long will the data be kept?
Halma Solutions stores the data it collects for different periods, depending on the category of data and the way in which it was collected. The precise terms are included in the register of processing activities that Halma Solutions has drawn up.
In determining the applicable terms, Halma Solutions first of all based on statutory (minimum) terms. Think of the legal obligation to keep accounting information. Furthermore, Halma Solutions has sought, where possible, to comply with the retention periods included in the Wbp Exemption Decree. For example, with regard to the customer’s contact details, a retention period that runs for a maximum of one year after termination of the relationship between the parties. Finally, Halma Solutions has been guided by its interests and those of its customers when determining the retention periods. For example, it can be important for both parties that documents in which (further) agreements have been recorded are kept for longer than two years. If such documents (e.g. email correspondence) contain personal data, they will therefore also be retained.
With regard to the data collected via the cookies on the website, the retention periods as described in the Cookie Statement (see elsewhere on this website) apply.
What rights do I have?
By law you are a ‘data subject’ and data subjects have a number of concrete
defined legal rights. You can submit a request to Halma Solutions to view, receive, change or have your personal data removed. You can also object to the (further) processing of your data. If Halma Solutions processes your personal data on the basis of your consent, you can withdraw that consent at any time. For all these matters and for other questions, please contact:
• Halma Solutions
– The lady in Poel
– Bijsterhuizen 3007 G
– 6604 LP Wijchen
– +31 (0)24-7470013
Halma Solutions will respond to your message within one month.
If you believe that Halma Solutions is acting in violation of the applicable laws and regulations regarding personal data, you can submit a complaint to the Dutch Data Protection Authority (PO Box 93374, 2509 AJ THE HAGUE).
Does Halma Solutions have automated decision-making?
There is no automated decision-making at Halma Solutions.
What else do I need to know?
2. Halma Solutions has taken appropriate technical and organizational measures to protect your personal data. A description thereof is also included in the processing register. Halma Solutions periodically assesses whether these measures are still sufficient.
5. From time to time it will be necessary to change this Statement. Halma Solutions has the right to do so. We recommend that you check this Statement from time to time for any changes.
Version 1, dated 29-01-2020