Privacy policy

AppReef B.V. attaches great importance to your privacy and careful handling of your personal data. We therefore make every effort to explain to you in clear and plain language with this privacy statement what personal data we collect from you, what we use it for and what your rights are in this regard.

This version of this privacy statement (version: 3.0) is dated (15/02/2023)

1. TABLE OF CONTENTS

2 Who are we?

3 Scope

4 Why and how do we process your personal data?

Use of our website

Website contact

Customer relationship management

Recruitment and selection

Supplier relationship management

5 Sharing personal data with third parties

6 Transferring personal data outside the EEA

7 How long do we keep your personal data

8 Automated individual decision-making

9 What are your rights and how can you exercise them?

Right of access

Right of rectification

Right to restriction of processing

Right to data portability

Right of objection

Right to exchange data

Right to withdraw your consent

Right to oppose the processing of your personal data in automated individual decision-making

10 Who can I contact with further questions or possible complaints regarding privacy?

11 Adjustments to the privacy statement ​​

2. WHO ARE WE?

‘We’, “us” or ‘our’ means AppReef with registered office at Rithmeesterpark 50-A1, 4838 GZ Breda in the Netherlands and with company number 84805072.

If you have any questions, comments or complaints regarding this privacy statement or the processing of your personal data or wish to exercise any of your rights, please contact us by email to info@appreef.nl

3. SCOPE

This privacy statement applies to this website, our direct marketing activities and the general organisation of AppReef.

4. WHY AND HOW DO WE PROCESS YOUR PERSONAL DATA?

If you visit our website and/or are in contact with us, it is possible that certain personal data may be processed. Below you will find more information on the different processing activities that may apply to you.

4.1 Use of our website
When you visit our website, we may process personal data using online techniques such as cookies, trackers, scripts and similar technologies (hereinafter referred to as “cookies”). These may include (1) essential cookies that are strictly necessary to send a message via an electronic communications network, to ensure the security of our website or to store information about the provision of a service expressly requested by you; (2) functional cookies that further shape your use of our website; (3) analytical cookies to measure and analyse your use of our website; (4) marketing cookies to deliver (personalised) advertisements to you; and (5) other third-party cookies that we allow on our website.

More information on these can be found in our cookie statement.

4.2 Contact via website
Consent - Contact forms are available on our website to get in touch with us. You can also reach us by email or phone at any time. We process this personal data to process your contact request but have no visibility or control over any other personal data you may communicate to us via the open fields. Please do not include any confidential or sensitive data.

This processing is done on the basis of your consent. Please note that you can withdraw it at any time. This withdrawal does not affect the lawfulness of the processing that took place before your consent was withdrawn.

What personal data do we process?

• Identification- and contact details

• Other data as possibly communicated spontaneously in the contact form

• Professional-related data

• Personal details
  …
  How do we obtain this personal data? Directly from you when completing our contact form

  How long do we keep them? Up to 1 year after handling the contact request plus the archiving period of related communications (such as e-mails) to be archived

  With whom may we share this personal data (other than affiliated and associated companies)? Processors (such as, for example, our hosting partner) that we rely on to process data in the context of our website, contact or relationship management

  Is automated individual decision-making involved in these activities? No

  Do these activities involve transfers outside the EEA? No

4.3 Customer relationship management (incl. prospecting new customers)
Legitimate interest - AppReef is always looking for new customers, actively establishing new contacts for this purpose and building relationships with existing customers. As part of this, your personal data are processed (e.g. to invite you to other forms of communication, an event...).

This processing is based on the legitimate interest of AppReef. You can always object to this according to the conditions as described under “right to object” in the chapter “What are your rights and how can you exercise them”.

What personal data do we process? 

• Identification and contact details

• Other data as may come up during further contacts

• Professional-related data

• Leisure activities and interests

• Personal details

  ...

  How do we obtain this personal data? Directly from you via customer relationship management

  How long do we keep them? Up to 7 years after completion of a last assignment or contact

  With whom may we share this personal data (other than affiliated and associated companies)? Processors (e.g. our CRM platform) that we use in the context of our website, contact or relationship management

  Does these activities involve automated individual decision-making? No

  Do these activities involve transfers outside the EEA? No

4.4 Recruitment and selection
Consent for (spontaneous) applications and maintenance of a recruitment reserve -Justified interest for active recruitment -.

When you (spontaneously) apply for a position at AppReef, AppReef processes personal data about you. We do this in function of recruiting and selecting employees for open or future vacancies. This processing (including the creation of a recruitment reserve) is done on the basis of your consent. You have the option of withdrawing the consent given at any time without prejudice to the lawfulness of the data processing up to the time the withdrawal took place.

When AppReef actively recruits itself, AppReef processes personal data about you. This is done only on the basis of data publicly available about you (e.g. on platforms such as LinkedIn and Google) or data provided to us by third parties. This processing is based on the legitimate interest of AppReef. You can always object to this in accordance with the conditions as described under “Right to object” in the chapter “What are your rights and how can you exercise them”.

Finally, we declare our legitimate interest in passing on your personal data to our affiliated and associated companies as part of our recruitment process. Naturally, we always do this with a view to finding a suitable assignment for you. You can always object to this according to the conditions as described under “Right to object” in the chapter “What are your rights and how can you exercise them”.

What personal data do we process?

• Identification and contact details

• Other data as may appear on your CV:

• Personal characteristics

• Social contacts

• Psychological data (cfr. a description of your personality or character)

• Family composition

• Leisure activities and interests

• Academic curriculum

• Professional competence

• Professional experience

• Membership/participation in professional organisations

• Current job

• Career

• Occupational data (cf. (partial) invalidity)

• Current salary

• Current fringe benefits

• National number

How do we obtain this personal data?

• (Spontaneous) application: directly from you at the time of your application

• Active recruitment: via third parties such as public platforms or intermediaries

How long do we keep them?

• In the case of non-rejected applicants: we retain personal data on your application for up to 1 year after application.

• For applicants within our recruitment reserve: as long as consent is not withdrawn and for up to 3 years after application.

With whom may we share this personal data (other than affiliated and associated companies)?

• Processors (e.g. recruitment agencies) that we use to recruit and select.

Do these activities involve automated individual decision-making? No

Do these activities involve transfers outside the EEA? No

4.5 Management of supplier relationships (incl. prospecting new suppliers)

Legitimate interest - AppReef cooperates with suppliers, actively establishing new contacts for this purpose and building relationships with existing suppliers. As part of this, personal data of employees at our suppliers (e.g. account managers) are processed.

This processing is done on the basis of the legitimate interest of AppReef . You can always object to this according to the conditions as described under “right to object” in the section “What are your rights and how can you exercise them”.

What personal data do we process? 

• Identification and contact details

• Other data as may come up during further contacts:

• Occupational data

• Leisure activities and interests

• Personal details

…
How do we obtain this personal data? Directly from you via relationship management

How long do we keep them? Up to 7 years after completion of a last assignment or contact

With whom may we share this personal data (other than affiliated and associated companies)? Processors (e.g. our CRM platform) that we use in the context of our relationship management

Do these activities involve automated individual decision-making? No

Do these activities involve transfers outside the EEA?

5. SHARING PERSONAL DATA WITH THIRD PARTIES

When you visit our website or use our products and services as a customer, we may use third parties such as partners, affiliated and associated companies and suppliers to whom we transfer your personal data. These third parties help us provide, support, develop and understand the use of our products and services and provide services such as hosting, customer and technical support, marketing, analytics, content delivery and/or execution of online payment(s), among others.

We may also share data (including personal data) with third parties as part of a reorganisation, restructuring, merger, sale or other transfer of business assets. We share information provided by you, automatically collected information and information from others with these third parties to the extent necessary to enable them to provide their services or support. In the activities described above, we indicate for each activity the categories of third parties, other than affiliated and associated companies, with which we share your personal data.

Furthermore, we may have to provide access to your data or transfer your data because of a legal obligation. This to authorities, government agencies or other third parties.

Finally, we may pass on your data if this becomes necessary in the context of your vital interest.

6. TRANSFER OF PERSONAL DATA OUTSIDE THE EEA

AppReef always tries to limit the transfer of personal data to third parties outside the European Economic Area (‘EEA’).

If this should nevertheless be the case, we will, in this situation, ensure as soon as possible that this transfer is brought into line with the AVG (by, inter alia, the presence of an adequacy decision in the country concerned or the establishment of an appropriate alternative, additional measures if necessary, etc.).

We refer to the section ‘Why and how do we process your personal data?’) for specific transfers.

7. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will retain your personal data no longer than strictly necessary to fulfil the purposes for which the personal data were collected or according to the legal obligation imposed on us. We refer to the section ‘Why and how do we process your personal data?’) for the specific retention period.

8. AUTOMATED INDIVIDUAL DECISION-MAKING

European data protection legislation (GDPR/AVG) imposes certain conditions on organisations when making decisions about individuals solely on the basis of processing operations that are fully automated, including profiling, and when these decisions have legal effects or other significant consequences. AppReef does not engage in this type of decision-making.

9. WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?

AppReef considers it important that you always retain control over the processing of your personal data. Below you will find more information on the various rights you have and can exercise in relation to the processing of your personal data:

Depending on the processing and the legal basis of that processing, certain conditions or restrictions may be attached to the exercise of the rights below.

To exercise the above rights, or information about them, please contact info@appreef.nl. We will then also provide more information if certain modalities are linked to your request. Furthermore, we may request additional information to verify your identity so that your personal data is not erroneously deleted or shared with someone who is not entitled to it. We will endeavour to respond to your request without unreasonable delay, but in any event within a period of one month from receipt of your request. If we cannot respond within one month and wish to extend the deadline, or if we will not act on the request, we will notify you.

9.1 Right of access:

In the event that we process your personal data, you have the right to access your personal data, as well as certain additional information as described in this privacy notice. You have the right to receive from us a copy of the personal data we hold, provided this does not adversely affect the rights and freedoms of others. The first copy will be provided to you free of charge, but on repeated request we reserve the right to charge a reasonable fee.

9.2 Right of rectification:

If the personal data we hold about you is inaccurate or incomplete, you have the right to have this information rectified or, given the purposes of the processing - completed.

9.3 Right to restrict processing:
You have the right to have the processing of your personal data restricted. This means that the personal data may only be stored by us and used only for limited purposes. This right applies if any of the following situations occur:

You contest the accuracy of the personal data, for a period of time that allows us to verify the accuracy of the personal data;

The processing is unlawful but you oppose the erasure of the personal data and request instead that its use be restricted;

We no longer need your personal data for the processing purposes described above but you need it for the establishment, exercise or substantiation of a legal claim; or,

You have objected to a processing and ask us to restrict the processing pending the answer to the question of whether our interests outweigh yours.  

In addition to our right to store your personal data, we can still process it, but only:

• With your consent;

• For the establishment, exercise or defence of legal claims;

• To protect the rights of another natural or legal person; or

• For reasons of public interest.

• Before we lift the restriction on processing your personal data, you will be informed.

9.4 Right to data portability:
If the processing of your personal data is based on your consent, and the processing is carried out through automated processes, you have the right to receive a copy of your personal data in a structured, common and machine-readable form. You also have the right, where technically possible, to have your personal data transmitted directly by us to a third party. This right does not apply where this would infringe the rights and freedoms of others.

9.5 Right to object:

You have the right to object to the processing of your personal data in the activities described above. In the latter case, this is only possible if the activity is related to (1) the performance of a task in the public interest or in the exercise of a task in the context of the exercise of public authority conferred on us or (2) the protection of our legitimate interests or those of a third party.

If you object to the processing of your personal data, we will no longer process the personal data unless we can demonstrate legitimate interests for the processing which outweigh your interests, fundamental rights and freedoms.

If your personal data are processed for the purpose of direct marketing, regardless of whether it is initial or further processing, you have the right to object to such processing at any time and free of charge, including in the case of profiling insofar as it relates to direct marketing. If you raise such an objection, we will stop processing your personal data for this purpose.

9.6 Right to data erasure (right to oblivion):

You have the right to request us to delete your personal data. This means that the personal data must be deleted by us without unreasonable delay. This right applies if any of the following situations occur:

• The personal data are no longer necessary for the purposes for which they were collected or otherwise processed;

• You withdraw your consent on which the processing is based, and there is no other legal basis for processing your personal data;

• Your personal data have been processed unlawfully;

• Erasure of your personal data is necessary to comply with European or Belgian law;

If you request us to erase your personal data, we will erase the personal data unless one of the following situations (exceptions) occurs:

• The processing is in the context of exercising the right to freedom of expression and information;

• Erasure is not an issue given public health reasons;

• The deletion is not in order given the need for archiving in the public interest, or statistical purposes;

• There is a legal obligation to retain the data; or,

• Erasure is not an issue given the institution, exercise or substantiation of a legal claim.

9.7 Right to withdraw your consent:

Where you have given consent to certain processing of your personal data, you may withdraw it at any time. We try to make withdrawing your consent as simple as possible and, as far as possible, as simple as giving your consent.

9.8 Right to oppose the processing of your personal data in automated individual decision-making:

If your personal data is used in the context of automated individual decision-making and if these decisions have legal effects or other significant consequences, you can ask us to stop using your data. If you oppose such processing, we will stop or restrict processing unless there are compelling reasons to do so.

10. WHO CAN I CONTACT IF I HAVE FURTHER QUESTIONS OR COMPLAINTS ABOUT PRIVACY?

10. BIJ WIE KAN IK MET VERDERE VRAGEN OF EVENTUELE KLACHTEN ROND PRIVACY TERECHT?
If, after reading this privacy statement, you have further questions or comments regarding the collection and processing of your personal data, you can always contact us at the following e-mail address: info@appreef.nl.

In addition, you have the right to submit any comments and observations or complaints to the supervisory authority responsible for data protection. You can do this in the EU member state where you reside, the place where you work or the place where the alleged breach took place. In the Netherlands, you can complain to the Data Protection Authority:

Autoriteit Persoonsgegevens
Hoge Nieuwstraat 8
2514 EL Den Haag
088-1805 250

www.autoriteitpersoonsgegevens.nl

As we attach great importance to our mutual relationship, we ask you to always contact us first so that we can work out a solution to what lies at the root of your complaint.

11. CHANGES TO THE PRIVACY STATEMENT

Our organisation and therefore also our website are a dynamic and innovative environment. This privacy statement can be adapted, if our services or applicable legislation so require. This means that we are constantly looking for better services tailored to your needs. It is possible that there will be new applications whereby we will collect or process your personal data in a different way. Naturally, we will inform you when there are important changes to this privacy statement, and we will ask your permission if necessary.