Privacy statement “In Corde Meo”

1. Introduction

In this privacy statement, we explain what data we process from Clients when we have, want to have or have had a business relationship with Clients. We also explain why and for how long we process Clients’ data and what the rights of Clients are in relation to any processing. 
In addition, we provide information about the parties we work with and our security policy, among other things. It is important to us that our services are reliable and transparent. We therefore handle your personal data with discretion and care and we ensure that any processing of your data complies with applicable laws and regulations.

2. Controller of personal data processing

3. Privacy Manager

We have appointed a Privacy Manager. This is not a ‘data protection officer’ as referred to in Article 37 of the GDPR. However, it is someone who ensures that your data is processed in accordance with the law. The Privacy Manager’s work includes monitoring and handling queries and complaints. Our Privacy Manager’s contact details are:

4. The personal data we process

Depending on your relationship with our organisation and the purpose for which we process data, we record (always some of) the following data:

• Name and contact details of the Client
• Name and contact details of the Administrator(s)
• Name and contact details of the Recipient(s)

5. For what purpose and on what basis we process personal data

We process your personal data for the following purposes:

• processing and carrying out orders, as described on the “In Corde Meo” website. The processing grounds are those referred to in Article 6 of the GDPR (consent, agreement or legitimate interest).

6. Automated decision-making

We do not make decisions based on automated processing on matters that could (significantly) affect individuals. These are decisions made by computer programmes or systems, without a human being (e.g. one of our employees) being involved.

7. How long we keep personal data

In general, we do not keep your data for longer than necessary for the purposes for which we collected your data. The retention period may vary from case to case. For example, we need to keep some documents for a minimum period for tax or administration purposes. In such cases, we will keep only that data which is necessary to fulfil our legal obligations. After the legal retention periods, we will delete or anonymise your data.

8. Sharing personal data with third parties

We do not share your personal data with third parties, unless this is done in the context of executing an agreement with you and in order to comply with a possible legal obligation. Insofar as these third parties are to be considered processors, we have concluded a processing agreement with those third parties which regulates, among other things, security, confidentiality and your rights. We remain responsible as processors for these processing operations. We engage third parties in the above manner and grounds in the following categories of processing:

• processing and executing orders
• storing data on servers and backing them up.

9. Cookies, or similar techniques, that we use

We use cookies on our website. This is a small text file that is stored in the browser of your computer, tablet or smartphone the first time you visit this website. We use the following cookies:

• cookies with a purely technical functionality. These ensure that the website works properly and that, for example, your preferred settings are remembered. These cookies are also used to optimise the website.

10. Your rights (access, modification, deletion, etc.)

The following explains your rights in relation to the processing of your data.

• Right of access: You have the right to access your own data. This includes what the purposes of processing are, to which parties the data is provided and what the retention periods are.
• Right to rectification: You can ask us to have your data rectified immediately. You also have the right to make incomplete data complete by, for example, sending us an e-mail.
• ‘Right to be forgotten’: You have the ‘right to be forgotten’. Upon request, we will delete your data without unreasonable delay. However, we may not always delete all your data. Sometimes the processing is still necessary, for example, for complying with legal obligations or establishing, exercising or substantiating claims.
• Right to restriction of processing: In principle, you have the right to have the processing of your data restricted, for example if you believe that your data is inaccurate or unnecessary.
• Notification of rectification, deletion or restriction: Unless it is impossible or requires disproportionate effort, we will notify recipients of your data of any rectification, deletion or restriction of processing.
• Right to portability of your data: You have the right to data portability. This means that you can make a request to receive your data. You can then save this data for personal re-use. You have this right only in relation to data that you have provided to us and if the processing is based on consent or an agreement to which you are a party.
• Withdrawal of consent: If data processing is based on consent, you have the right to withdraw that consent at any time. However, the processing of your data from the period before the withdrawal remains lawful.
• Right of objection: In principle, you have the right to object to the processing of your data. After your objection, we will in principle stop processing your data.
• Complaint to the Autoriteit Persoonsgegevens (Personal Data Authority) or to court: If you believe that the processing of your data violates the law, you can contact our Privacy Manager, but you also have the right to lodge a complaint with the Autoriteit Persoonsgegevens (AP) or go to court.
• Restrictions on your rights: Sometimes we may restrict your rights, for example in the context of preventing, investigating, detecting and prosecuting criminal offences, such as fraud. Any request can be addressed to our Privacy Manager. To make sure that a request is made by you, we ask you to attach a copy of your proof of identity with the request. In this copy, blacken your passport photo, MRZ (machine-readable zone, the strip of numbers at the bottom of the passport), passport number and social security number. This is to protect your privacy.

11. How we secure personal data

We take the protection of your data seriously and take appropriate measures to prevent misuse, loss, unauthorised access, unwanted disclosure and unauthorised modification. If you have the impression that your data is not properly secured or there are indications of misuse, please contact our Privacy Manager.

12. Changes

We may amend this statement if developments give rise to it, for example in the event of new forms of processing. You can find the most up-to-date privacy statement on our website. We recommend that you consult this privacy and cookie statement regularly so that you are kept informed of any changes.