5 September 2022
We believe it is important that our services are transparent, personal and reliable. In that context, we think it is important that you know exactly which personal data we collect and how it is used and shared.
This privacy statement applies to all personal data that we process in the context of our services. This may concern data that we receive directly from you, for example when you visit our website or register for our newsletter.
We describe this in a structured manner in this privacy statement. With this privacy statement, Clever Strategy B.V. informs all parties involved about the way in which we process personal data. This privacy statement may change from time to time if new developments give cause to do so.
What is personal data?
The General Data Protection Regulation (GDPR) states that personal data is any information about an identified or identifiable natural person. This means that information is either directly about someone or can be traced back to this person.
Clever Strategy B.V. (“Clever Strategy”), located at Rivium Promenade 100, 2909 LM in Capelle aan den IJssel, is responsible within the meaning of the GDPR for the data we receive from you.
For what purposes do we process personal data?
We only process your personal data for carefully determined purposes. We receive personal data directly from you, for example because you visit our website.
- Fulfilling your order
When executing your orders, we need (personal) data. For example, your name, address and contact details such as telephone number and e-mail address. The legal basis is performance of the contract, Article 6(1)(b) GDPR and legitimate interest, Article 6(1)(f) GDPR.
- Execution of our services
In order to carry out our assignments, we sometimes need (personal) data. For example, your name, position and contact details such as telephone number and e-mail address. In some cases, we also process your date of birth in order to send you a nice present on your birthday. The legal basis is execution of the contract, Article 6 (1) (b) of the GDPR and legitimate interest, Article 6 (1) (f) of the GDPR.
- For your registration to webinars and other events we organise
If you register for a webinar or other event (for example via www.clevercampus.nl) we will process your name and e-mail address. But possibly also your function and employer. This is necessary for the conclusion or execution of a contract (Article 6 para. 1 sub b GDPR) and/or our legitimate interest (Article 6 para. 1 sub f GDPR).
- For marketing purposes and newsletters
You can sign up for our newsletter via our website. In addition to our newsletter, you will only receive marketing messages from us when you
i. have given us permission to do so or
ii. asked for that or
iii. you’re a customer and you are known to us as a contact person and have not indicated that you do not wish to receive the marketing messages.
Would you rather not receive any newsletters or emails any longer? You can unsubscribe by clicking on “unsubscribe” at the bottom of the email. The legal basis is our legitimate interest (Article 6(1)(f) GDPR).
We also process a limited amount of data without you noticing it immediately. For example, if you read our digital newsletters. We collect this data by means of email pixels. Using the email pixels, we know if and when an email was opened and which links were used in the email. This allows us to make our newsletters more relevant to you.
Our email package does not give us the option to turn this on or off on a personal level. If you do not want us to use an email pixel when sending our digital newsletter, you can unsubscribe from our newsletter. The legal basis is our legitimate interest (Article 6(1)(f) GDPR).
- To perform analysis and development of our website, products & services
It concerns the following data:
• Location data
• IP-adress or app IDs
• Internet browser and device type
• Website language
The data from the analytical and marketing cookies are not linked to other data. We refer to our cookie statement for more information about cookies. The legal basis is permission, which you give by agreeing to our cookie terms and conditions in the cookie banner on the website (article 6 paragraph 1 sub a GDPR).
You have the right to be well informed about what we do with your data and why we need your data. We do this by means of this privacy statement. In addition to the right to be transparently informed, you have the following rights:
• Right of access (if you want to know what data we collect from you);
• Right to rectification (we are happy to correct any data that is no longer correct);
• Right to be forgotten (in some cases you can ask us to delete your data);
• Right to restriction of processing (in some cases you may ask us to restrict the processing of your data);
• Right to data transferability (if you wish, we can transfer your data to another party or give you a copy of your data);
• Right to object (in some cases you may object to the use of your data).Wil je gebruik maken van one of your rights, you can contact us by emailing email@example.com. We always respond to your request within a month. Prior to processing your request, we may request additional information to verify your identity.
If we need your permission
If we process your data on the basis of consent, you always have the right to withdraw your consent. You can easily do this by sending an email to firstname.lastname@example.org. If we have no other basis for the data that we process on the basis of consent, we will no longer use and delete this data.
With whom do we share data and where do we store it?
In a number of cases we provide your data to third parties. For example, processors who help us process your personal data. However, we will never sell your data to other parties.
Processors who help us process your personal data may only use your data on our behalf and for the performance of the relevant services they provide to us. They are not allowed to use or pass on your data independently.
Information collected through cookies may be shared with the parties that place these cookies. Read more about this in our cookie statement. In some cases, we may be legally obliged to provide your information. For example to government agencies. In all cases, we only share strictly necessary data.
We work with different applications to obtain and store certain data. To guarantee your privacy, we choose our suppliers carefully and these applications are subject to strict rules. Most data is stored within the European Union.
For data that is processed outside the EU, we only work with parties that offer sufficient protection according to European rules. If we (possibly via our external service providers) process your data outside the EU, we ensure adequate protection of your personal data. For example, by using special contracts to ensure this (e.g. EU Standard Contractual Clauses).
How long do we store your data?
We will store your data for as long as your account remains active, unless you ask us to delete data or delete your account via email@example.com. You can always view and/or change part of your personal data in your own account.
How do we protect your data?
Pursuant to Article 32 of the GDPR, we are obliged to take appropriate technical and organizational measures to prevent the loss and/or unlawful processing of personal data.
We pay a lot of attention to properly securing personal data. For example, the (personal) data that you enter on the website when sending is encrypted and the (personal) data is sent via a secure connection.
All our employees and external service providers have signed a nondisclosure agreement. We handle information that you entrust to us with care. That is why only certain employees have access to your data.
We maintain a high level of security for your data. The data is, among other things, stored on a secure server. This server is only accessible to persons who have expressly given permission for this. The building where the server is located is also well secured.
Contact and complaints
If you have any questions about this privacy statement or if you want to exercise your rights as a data subject, you can contact us at firstname.lastname@example.org.
In case of complaints about, for example, the way in which we use your data or how we respond to privacy-related questions, you can submit a complaint to the Dutch Data Protection Authority.
Explanation of the technologies we use:
We use Google Analytics to track how visitors use our website. We have concluded a processing agreement with Google. This contains strict agreements about what they are allowed to keep track of. We have not allowed Google to use the Analytics information for other Google services. We have Google anonymise the IP addresses.
You can opt out of the creation of a user profile, the storage of data about your site usage and the use of tracking cookies by Hotjar by following this opt-out link.
You may opt out of the creation of a user profile, the storage of data on your site usage and the use of tracking cookies by Squeezely by following this opt-out link.
We use SharpSpring software to analyse and measure our online activities. This gives us insight into how a visitor uses the website. For example, the referral source, the duration of the visit, a previous visit, pages viewed and whitepaper downloads. This allows us to better respond to the interests of the visitor and optimise our online activities. For more information, please visit: https://sharpspring.com/legal/privacy/