WINKLE B.V. PRIVACY STATEMENT

 

1 CONTENT


2 Introduction
3 Security
4 Data that we hold
4.1 Professional Services
4.1.1 Why do we process data?
4.1.2 What data is processed?
4.1.3 How long do we hold data for?
4.2 Respondent personal data
4.2.1 Research panel
4.2.2 Survey and focus group participation
4.3 Business Contacts
4.3.1 Why do we process data?
4.3.2 What data do we hold?
4.3.3 How long do we hold data for?
4.4 Suppliers
4.4.1 Why do we process data?
4.4.2 What data do we hold?
4.4.3 How long do we hold data for?
5 People who visit our offices
6 Job applicants
6.1 Application policy
6.1.1 What information do we collect?
6.1.2 Why do we process personal data?
6.1.3 Who has access to data?
6.1.4 How do we protect data?
6.1.5 Fow how long do we keep data?
6.1.6 What if you do not provide personal data?
6.1.7 Automated decision-making
7 People who use our website
7.1 Why do we process data?
7.2 What data do we hold?
7.3 How long do we hold data for?
8 Sharing personal data
9 Locations of processing
10 Individual’s Rights
11 Complaints
12 Contact information
13 Changes to our privacy statement

 

2 INTRODUCTION


Winkle B.V. respect your privacy and do not sell, rent or loan any identifiable information collected on this site. Any information that you give will be treated in a careful and secure manner. It will not be used in ways to which you have not consented. This statement explains how we may collect and use information about you through our website. If you have any questions about our GDPR privacy policies, want to exercise your right to see a copy of the information that we hold about you, or think that information we hold about you may need to be corrected, please send an email to winkledataprivacy@winkle.eu.

We do not seek to identify individual visitors unless they volunteer their contact details through one of the forms on the site. Various forms on our site invite you to submit your contact details and other information about yourself or your organisation, or to send us emails which may, of course, also identify you. In each case, the purpose for which you are invited to give us information is clear and we also indicate which of the requested information is essential for the relevant purpose and which is optional – fields for essential information are marked with an asterisk.

We will only use your details to send you information from Winkle B.V. that you have specifically requested to receive. If you no longer wish to receive such information, our emails contain a link that will allow you to change or terminate your subscription to our email alerting service.

Personal data is any information relating to an identified or identifiable living person. When collecting and using personal data, our policy is to be transparent about why and how we process personal data.

We process personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose are set out in the relevant sections below.

Our full privacy policy can be found below.

 

3 SECURITY


We take the security of all the data we hold seriously. Staff are trained on data protection, confidentiality and security.

We have a framework of policies and procedures which ensure we regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

 

4 DATA THAT WE HOLD


4.1 Professional Services

We provide services to businesses, non-profits, and other organisations. The exact data held will depend on the services to be provided.

Where we engage with clients for professional services, we may collect and process personal data in order to satisfy a contractual obligation. We request that clients only provide the personal data that is required for us to fulfil our contractual obligation.

4.1.1 Why do we process data?

Where data is collected for professional services, it is used for a number of purposes, as follows;

  • Providing services to clients. Data is processed in accordance with our agreed project scope between clients and us, and may sometimes be further clarified in written documentation supplied before any data processing may occur. We provide a range of professional services to our clients, which includes;
  • Client management. When communicating with and assessing the needs of clients, personal data may be processed in order to ensure that their needs are appropriately satisfied. This may include assessing whether the collection of services are provided to our clients are appropriate.
  • Administration. In order to manage and administer our business and services, we may collect and process personal data. This may include (but is not limited to) maintaining internal business records, managing client relationships, hosting events, administering client facing applications, and maintaining internal operating processes.
  • Regulatory. In order to undertake professional services, we may from time to time be required to collect and process personal data in order to fulfil regulatory, legal or ethical requirements. This may include (but is not limited to) the verification of identity of individuals.

4.1.2 What data is processed?

The data that is processed is dependent on the service that is being provided and on the recipient of this service.

  • Services to businesses, non-profits, and other organisations. We process the personal data of individuals associated with our clients. Personal data may include any relevant financial or non-financial information necessary for us to provide our services. As an example, this may include contact details, payroll data, employee information (including details about dismissal), lists of shareholders, customers and suppliers and any other specifically relevant data.
  • Services to individuals. Personal data may include contact details and tax identifiers, information about business activities, investments, and other financial interests, payroll and other income, and any other specifically relevant data.

4.1.3 How long do we hold data for?

We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 7 years). We may keep data for longer in order to establish, exercise, or defend our legal rights and the legal rights of our clients.

In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.

4.2 Respondent personal data

Winkle B.V. is a Market Research Agency. We collect data from consumers and/ or respondents and deliver the information necessary to our clients.

4.2.1 Research panel

If you are filling in a survey through a research panel, we will not receive your personal data, because contact details are shared in such a way that we cannot link them to a natural person. Thus the data is not considered personal data under GDPR.

4.2.2 Survey and focus group participation

Sometimes Winkle B.V. does receive personal data from you or third parties. When you participate in our surveys, research communities or focus groups, you do agree to the following:

  • You consent to the collection, use, disclosure and processing of your personal data in the manner described in this privacy policy, including our procedures relating to cookies, IP addresses and log files. You consent to the transfer and processing of your personal data in the European Union (EU), as well as territories outside of the EU, which do not have data protection laws that provide the same level of protection that exists in countries in the EU. Your consent is voluntary, and you may revoke your consent by opting out at any time. You consent to us sharing your personal data with relevant persons working for service providers who assist us to provide our services. At any time you will be allowed to unsubscribe from email lists. The information is voluntarily provided and you have the option to decline to answer any question. All responses given by the respondents will become the sole property of Winkle B.V.
  • When you agree to participate in one of our online communities you unequivocally agree to us using your personal information for market research. As a respondent you will conduct yourself as can reasonably be expected, i.e. you will refrain from abusive language, keep keys or passwords to yourself, and will report misuse of data immediately to us. Respondent will hold Winkle B.V. harmless against all damages, direct or consequential.
  • Winkle B.V. does not sell your personal data to third parties and we do not use any contact details collected in our customers’ surveys to contact survey respondents.
  • On clients request, Winkle B.V. could deliver results of individual respondents, however we make sure that any personal details that may be presented are deleted.
  • By participating in a research community, you agree that clients of Winkle B.V. can observe the discussions in the community. You must choose a ‘Nickname’ and can opt to choose a ‘Profile Picture’ for you community account. When answers and comments are submitted by you as a respondent, ‘Nicknames’ and ‘Profile Pictures’ will show up. You are responsible to choose a ‘Nickname’ and Profile Picture’ that will not reflect your identity.

If sensitive information is being discussed in a survey or community, this will be clearly explained before you start. You have the option to decline to answer any question. By answering the question, you unequivocally agree to Winkle B.V. using this information

4.3 BUSINESS CONTACTS

Personal data from our contacts, which covers both potential and prior customers, as well as potential and prior employees, are held in our customer relationship management tool (CRM tool).

This information is entered into the system after contact is made between a staff member of Winkle B.V. and a business contact individual.

4.3.1 Why do we process data?

Where personal data on business contacts is held, it is used for a number of purposes, as follows;
• Promote and develop our offerings.
• Communication of technical updates.
• Hosting and facilitating of events.
• Relationship management.
• Administration and management.

4.3.2 What data do we hold?

Personal data that may be stored in the CRM tool includes, but is not limited to, name, email address, physical address, job title, and details of the initial meeting.

In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.

4.3.3 How long do we hold data for?

We retain the personal data processed by us for as long as is considered necessary for the purpose(s) for which it was collected.

4.4 SUPPLIERS

We collect and process personal data about our suppliers, subcontractors, and individuals associated with them. The data is held to manage our relationship, to contract and receive services from them, and in some cases to provide professional services to our clients.

4.4.1 Why do we process data?

  • Receiving goods and services. We process personal data in relation to our suppliers and their staff as necessary to receive the services.
  • Providing services to our clients. Where a supplier is helping us to deliver professional services to our clients, we process personal data about the individuals involved in providing the services in order to administer and manage our relationship with the supplier and the relevant individuals and to provide such services to our clients.
  • Administering, managing and developing our businesses and services. We process personal data in order to run our business, including:
    • managing our relationship with suppliers;
    • developing our businesses and services (such as identifying client needs and improvements in service delivery);
    • maintaining and using IT systems;
    • hosting or facilitating the hosting of events; and
    • administering and managing our website and systems and applications.
  • Security, quality and risk management activities. We have security measures in place to protect our and our clients’ information (including personal data), which involve detecting, investigating and resolving security threats. Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails. We have policies and procedures in place to monitor the quality of our services and manage risks in relation to our suppliers. We collect and hold personal data as part of our supplier contracting procedures. We monitor the services provided for quality purposes, which may involve processing personal data.
  • Promoting our services. We may use business contact details to provide information that we think will be of interest about us and our services. For example, industry updates and insights, other services that may be relevant and invites to events.
  • Complying with any requirement of law, regulation or a professional body of which we are a member. We are subject to legal, regulatory and professional obligations. We need to keep certain records to show we comply with those obligations and those records may contain personal data.

4.4.2 What data do we hold?

We will hold supplier’s names, contacts names, and contact details of suppliers.

4.4.3 How long do we hold data for?

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation). Data may be held for longer periods where required by law or regulation and in order to establish, exercise or defend our legal rights.

 

5 PEOPLE WHO VISIT OUR OFFICES


We have security in place at our offices. The only visitors in our offices have a need to be there. The offices in all our locations have a front-door with a lock and key system.
For the privacy of our clients and people we have a strict clean desk policy in place.

 

6 JOB APPLICANTS


6.1 Application policy

As part of any recruitment process, Winkle B.V. collects and processes personal data relating to job applicants. We are committed to being transparent about how we collect and use that data and to meeting its data protection obligations.

6.1.1 What information do we collect?

We collect a range of information about you. This might include:

  •  your name, address and contact details, including email address and telephone number;
  • details of your qualifications, skills, experience and employment history;
  • information about your current level of remuneration, including benefit entitlements;
  • whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process;
  • information about your entitlement to work in The Netherlands;

We collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews.

We might also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers. We will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.

Data will be stored following the GDPR minimisation policy, but will include, on your application record, in HR management systems and on other IT systems (including email).

6.1.2 Why do we process personal data?

We need to process data to take steps at your request prior to entering into a contract with you. It also needs to process your data to enter into a potential contract with you.

In some cases, we need to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant’s eligibility to work in The Netherlands or United Kingdom (depending on entity you send your job application to) before employment starts.

We have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process.

Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom we can offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.

Where we rely on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not.

We process health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.

Where we process other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes.
We will not use your data for any purpose other than the recruitment exercise for which you have applied.

6.1.3 Who has access to data?

Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

We will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. We will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.

6.1.4 How do we protect data?

We take the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

6.1.5 For how long do we keep data?

If your application for employment is unsuccessful, we will hold your data on file for 12 months after the end of the relevant recruitment process. If you agree to allow us to keep your personal data on file, we will hold your data on file for a further 12-month period for consideration for future employment opportunities. At the end of that period, or once you withdraw your consent, your data is deleted or destroyed. If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.

6.1.6 What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.

You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.

6.1.7 Automated decision-making

Recruitment processes are not based solely on automated decision-making.

 

7 PEOPLE WHO USE OUR WEBSITE


When people visit our website, personal data is collected both through automated tracking and interacting with various forms on the website.

Personal data may be collected when individuals fill in forms on our websites or by corresponding with us by phone, e-mail or otherwise. This includes information provided when an individual registers to use our websites, subscribe to our service, make an enquiry, comment on publications, enter a competition, promotion or survey, apply to work for Winkle B.V. and report a problem with our websites.

When individuals visit our websites, certain personal data may be automatically collected. We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies).

Often, individuals who visit our website additionally fall into another category as listed by this privacy statement. For instance, users of our websites may be current clients, business contacts or become clients in the future. Where this is the case, data held and processed for individuals who use our website may also become data that is held and processed for another purpose.

7.1 Why do we process data?

There are a number of reasons why we will process the personal data that an individual may provide to us when visiting our websites. As examples, these include;

  • Administration. To administer our site and to improve internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. For example, we use this data to ensure that the website is presented well for individuals and is optimised appropriately.
  • Functionality. In order to allow individuals to use some functionality of our website, certain personal data must be entered in order for features to work as intended.
  • Security. In order to keep our site safe and secure, we may sometimes collect personal data, for instance login information and other data that can be used to vouch an individual’s identity.
  • Promote and develop our offerings. Some personal data may be used in order to measure or understand the effectiveness of advertising we serve to individuals, and to ensure that only relevant advertising appears.

7.2 What data do we hold?

The data that we hold depends on what data was entered and for what purpose.

Where data was entered in order to engage with functionality of our website, that personal data may include their name, address, e-mail address and phone number, financial and credit card information, personal description and photograph.

Where data is collected automatically, the data that we may collect includes technical information, including the Internet protocol (IP) address used to connect an individual’s computer to the Internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

Other data about an individual’s visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Our website uses cookies to distinguish individuals from one another. This helps us to provide a better experience when individuals browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

7.3 How long do we hold the data for?

We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 7 years).

In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.

 

8 SHARING PERSONAL DATA


We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.

Personal data held by us may be transferred to:

Third party organisations that provide applications/functionality, data processing or IT services to us

We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them.

Third party organisations that otherwise assist us in providing goods, services or information

Happen GP Ltd. and group businesses (Winkle B.V. is part of Happen Group Ltd)

Auditors and other professional advisers

Law enforcement or regulatory agencies or those required by law or regulations

Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

 

9 LOCATIONS OF PROCESSING


Where possible, personal data resides within the UK or NL territory but may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. We will take all reasonable steps to ensure that your data is treated securely, in accordance with this privacy statement.
We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EU are done lawfully. Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU.

 

10 INDIVIDUAL’S RIGHTS


Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights as follows:

  • Individuals may request access to their personal data held by us as a data controller.
  • Individuals may request us to rectify personal data submitted to us or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which they registered.
  • Individuals may request that we erase their personal data
  • Where we process personal data based on consent, individuals may withdraw their consent at any time by contacting us or clicking on the unsubscribe link in an email received from us.
  • Individuals may have other rights to restrict or object to our processing of personal data and the right to data portability.
  • Individuals may request information about, or human intervention into, any automated data processing that we may undertake.

If you wish to exercise any of these rights, please send an email to winkledataprivacy@winkle.eu.

 

11 COMPLAINTS


We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to winkledataprivacy@winkle.eu

We will look into and respond to any complaints we receive.

You also have the right to lodge a complaint with the NL data protection regulator. For NL this is Autoriteit Persoonsgegevens. For further information on your rights and how to complain, please refer to one of these websites.

The Autoriteit Persoonsgegevens website
https://autoriteitpersoonsgegevens.nl/nl/zelf-doen/privacyrechten/klacht-over-gebruik-persoonsgegevens

 

12 CONTACT INFORMATION


If you have any questions about this privacy statement or how and why we process personal data, please contact us at:

Head of Data Privacy NL
ADDRESS: Keizersgracht 477-D, 1017DL, Amsterdam, The Netherlands.
EMAIL: winkledataprivacy@winkle.eu

 

13 CHANGES TO OUR PRIVACY STATEMENT


Updates to this privacy statement will appear on this website. This privacy statement was last updated on May 17th 2018.