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Privacy Statement – ADC

Amsterdam Data Collective Holding B.V. and all her subsidiaries (ADC) take your privacy very seriously and will process and use your data in a secure manner in accordance with the guidelines of the General Data Protection Regulation (“GDPR”). This page contains ADC’s Privacy Statement (“Privacy Statement”). We recommend that you read this Privacy Statement carefully. 

1. Who is ADC?

ADC collects the personal data (“Personal Data”) provided by you (“Data Subject”) and uses it for the purpose of performing relevant services (“Service”). Amsterdam Data Collective Holding B.V. is located in Amsterdam at De Ruijterkade 7, and is registered with the Chamber of Commerce under number 84615052. 

Amsterdam Data Collective Holding B.V.
De Ruijterkade 7
1013 AA Amsterdam 
020 800 6053 
info@adc-consulting.com 

2. When is this Privacy Statement applicable?

This Privacy Statement applies to all data that ADC collects and processes from candidates, applicants, customers, employees, clients and users of its website, apps and other services. 

3. What do we mean by personal data?

The General Data Protection Regulation (GDPR) will be enforced as of 25 May 2018. This means that from that date the same privacy legislation applies throughout the European Union (EU). The Personal Data Protection Act (WBP) will then no longer apply.  

The GDPR indicates 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. The fact that it must be a natural person means that data of deceased persons or of organizations is not personal data. 

There are many types of personal data. Obvious data is someone’s name, address and place of residence. But telephone numbers and postcodes with house numbers are also personal data. Sensitive data such as a person’s ethnicity, religion or health are also referred to as special personal data. These are extra protected by the legislator. 

4. What information does ADC collect and process?

In order to be able to use the “Service” that ADC offers, personal data is stored and processed. The personal data that ADC stores and processes are obtained from the person via, for example, a CV, a business card, a personal conversation, or are recorded in a contract with ADC. When receiving personal data directly and indirectly, ADC explicitly asks for your permission to process and store your “Personal Data”. This data is necessary to conclude, administer and execute your agreement with ADC. 

Exactly what personal data is and for what purposes ADC uses this data can be found in clauses 4 and 5 of this Privacy Statement respectively. 

4.1 Automatically generated data

ADC also collects automatically generated information about your surfing behaviour while using the “Service”. This information includes your IP address (the number of your computer that makes it possible to recognize your computer), the date of filling in the “Personal data”, and “cookies”. Insofar as ADC uses this information, it is always anonymized. We do this by masking the last octet of the IP address. 

4.2 Cookies

In order to implement the “Service”, ADC may use cookies that are stored on your computer by your browser. Cookies are small pieces of information that our server sends to your browser with the intention that this information is sent back to our server on your next visit. These small text files are stored on your computer’s hard drive or memory. 

Cookies cannot damage your computer or the files on your computer. Information is stored in the cookies (such as the settings of your PC, preferences indicated by you and the tips and discussions to which you have subscribed) to facilitate the subsequent use of the “Service”. In addition to your masked IP address, this information does not contain name or address details or other “Personal Data”. To find out more about these functions, it is best to consult your browser instructions or the help function of your browser. If you do use cookies, make sure you log out if you have used a public computer and leave. 

This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). ADC has concluded a processing agreement with Google. Google Analytics uses cookies to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your masked IP address) will be transferred to and stored by Google on servers in the United States. Google uses this information to keep track of how you use the website, to compile reports on website activity for website operators and to provide other services related to website activity and internet usage. Google may provide this information to third parties if Google is legally obliged to do so, or insofar as these third parties process the information on behalf of Google. Google will not combine your IP address with other data held by Google. You can refuse the use of cookies by selecting the appropriate settings on your browser. By using this website, you consent to the processing of the information by Google in the manner and for the purposes described above. ADC does not use other Google services in combination with the Analytics cookies. 

The information stored in the cookies is used for the ADC website. You can change your cookie preferences by choosing the options “Yes, accept all” or “No, rather not” in the cookie settings. If you do not agree with “Yes, accept everything”, ADC only places functional and (masked) analytical cookies. 

ADC may use the following cookies: 

4.2.1 Functional Cookies

These cookies are necessary for the website to function and cannot be disabled in our systems. They are usually only set in response to a response from you with which you request a service, such as setting your privacy preferences, logging in or filling out a form. You can set your browser to block or warn you about these cookies, but some parts of the website may not work. 

4.2.2 Analytics Cookies

These cookies allow us to count visitors and their origin so that we can measure and improve the performance of our website. They help us understand which pages are the most and least popular and how visitors move throughout the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you visited our site. 

4.2.3 Marketing Cookies

profile of your interests and show you relevant advertisements on other websites. They work by identifying your unique browser and device. If you do not allow these cookies, you will see less of our targeted advertisements on various websites. These cookies are set by our advertisers on our website. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other websites. They work by identifying your unique browser and device. If you do not allow these cookies, you will see less of our targeted advertisements on various websites. 

5. What will ADC use the personal data for?

ADC will use information about you for the following purposes: 

  1. to enter into, manage and perform your agreement with us and thereby provide the “Service” to you; 

  2. to provide the “Service” to you with your specific consent, without prior consent from you (see clause 6); 

  3. to send information about ADC’s own services and events via, for example, newsletters; 

  4. to maintain contact with you and answer your questions; 

  5. to compile anonymized statistical data and to secure the “Service”; 

  6. to provide your data to third parties on the basis of legal obligations; 

  7. to adapt and improve the “Service”. 

In order to perform the “Service”, ADC may use cookies that are stored on your computer by your browser. Cookies are small pieces of information. Information on the use of cookies can be found under point 4 of this statement. 

The data subject explicitly consents to the processing of your “Personal Data” by ADC. Article 4(11) of the GDPR defines the right of the data subject as any free, specific, informed and unambiguous expression of will by which the data subject, by means of a statement or a clear act, regarding his/her processing of “Personal Data”. For full disclosure of any potential processing usage, see section 7 of this statement for details.

7. Use by third parties

ADC will not provide your “Personal Data” to third parties for direct marketing purposes (e.g. for sending advertisements) without your expressed consent. ADC may provide your data to third parties insofar as this is necessary for the provision of the “Service” to you and/or insofar as this data cannot be traced back to you personally (such as automatically generated information, not being your IP address). ADC can provide your data to third parties if it is obliged to do so on the basis of legal provisions, if it is forced to do so as a result of a lawsuit and/or if it considers this necessary to protect its own rights.

The way data of clients, candidates, and other 3rd parties is processed is documented by ADC in a list of sub-processors, which will be provided upon valid request.

Employee data processed by 3rd parties, and otherwise, is documented by ADC in a registry of processing activities, which is accessible to all current employees, and upon request to former employees.

8. Retention period

ADC does not store your “Personal Data” for longer than is legally permitted and necessary for the realization of the purposes for which your data is processed. How long certain data is kept depends on the nature of the data and the purposes for which it is processed. The retention period can therefore differ per purpose. ADC maintains a list, regularly reviewed by legal professionals, of retention periods, to maintain legal and regulatory compliance.

9. Your rights

Under the General Data Protection Regulation, you have the right to invoke the following requests regarding your “Personal Data”. 

  1. The right to data portability. The right to transfer personal data. 

  2. The right to be forgotten. The right to be ‘forgotten’. 

  3. Right of access. The right to access your “Personal Data” that we process. 

  4. Right to rectification and addition. The right to change your “Personal Data” that we process. 

  5. The right to restrict the processing of your “Personal Data”. 

  6. The right to object to data processing. 

  7. The right to information and the way ADC processes your “Personal Data”. You will find this information in this Privacy Statement. 

Requests to exercise your privacy rights as described above can be submitted in writing by sending an email to gdpr@adc-consulting.com. You may be requested to verify your identity to prevent misuse of this policy.

10. How does ADC protect your Personal Data?

  1. ADC will process your “Personal Data” in a proper and careful manner, and in accordance with the all applicable local and regional legislation. 

  2. ADC requires that you fill in the data with an asterisk (*) after it. It is not mandatory to fill in the data without an asterisk (*) after it. 

  3. ADC will take appropriate technical and organizational measures to protect your “Personal Data” against loss or against any form of unlawful processing. 

  4. ADC will not keep your “Personal Data” for longer than necessary.

  5. Internal processes, consistent with ADC’s annually audited ISO 27001 certification, are used to ensure the protection of all data within ADC. These processes detail:

    • a. Data Masking

    • b. Cryptography

    • c. Information classification

    • d. IT management

    • e. Supplier management

    • f. Retention periods

    • g. Risk management

    • h. Legal context

11. Transfers within the EU

The level of data protection is the same within the EU. This is because all EU member states have adapted their legislation to the European privacy directive. The EU is therefore one jurisdiction in the protection of Personal Data. The organization abroad must only comply with the general requirements of AVG legislation. 

12. Transfers outside the EU

To the extent that Personal Data is transferred to third parties in accordance with this Privacy Statement, and these third parties are located outside the European Union, such transfer will only take place if that country guarantees an appropriate level of security or has been designated as safe by the European Union. Third countries are all countries outside the EU, with the exception of countries in the European Economic Area (EEA). 

13. Company transfers

ADC may merge with, or acquire, third parties, in such eventualities your “Personal data” may be transferred to these third parties. The same obligations and rights detailed within this statement continue to apply.

14. Can this Privacy Statement be amended?

This Privacy Statement is subject to change, and is reviewed annually by ADC management and legal assistance. It is revised as necessary, and the latest approved version is always available on the ADC website and other relevant locations.

15. Questions?

If you have any questions about this Privacy Statement, you can send an email to gdpr@adc-consulting.com. For requests regarding your personal data, verification of your identity may be necessary.