HOW DO WE USE THIS INFORMATION?

We are entitled to use personal information for the following purposes:

To check your identity and to create and manage your account.

To allow us to render our services and provide information related to these services, we need to verify your identity for the purpose of creating your customer account. We also need this information to effectively manage your account and to ensure that you receive the best possible service from us. This may also involve third parties conducting credit or identity checks on our behalf. This is something in which we have a legitimate interest; however, such use of your personal data is also required to enable us to know who you are, especially as we are required by law to meet certain regulatory “know your customer” obligations.

To provide you with products and services or information about these products and services, and to review your changing needs.

As soon as you open an account with us, subscribe to updates or sign up for a webinar, we will need your personal information in order to provide our services and meet our obligations to you. We also have a legitimate interest in ensuring that we provide you with the best products and services. As a result, we may periodically review your needs to ensure that you are benefiting from the best possible products and services.

To improve our products and services, including our customer service, and to develop and market new products and services.

From time to time, we may use personal information obtained from you through your use of our services and/or through customer surveys to improve our products and services. We have a legitimate interest in using your personal information in this way to ensure that we provide you with the best possible products and services and continue to be a leader in our industry.

To assemble a profile of you.

From time to time, we may use personal information about you to draw up a personal profile so that we can get to know you and provide you with the best possible products and services. On the basis of automated profiling or credit checks, we may also make decisions that may affect your ability to use our services. It may be that we are required do so in order to comply with legal obligations, or that we have a legitimate interest in using your personal information in such a manner.

To investigate or handle inquiries or disputes.

We may need to use the personal information we collect about you to investigate problems and/or to settle disputes between you and us, since it is in our legitimate interest to investigate and resolve issues and/or disputes as quickly and efficiently as possible.

To comply with applicable laws, judicial orders, other activity of the judiciary or the regulations of relevant regulatory authorities.

Under certain circumstances, we may need to use your personal information to comply with applicable laws, judicial orders or other activity of the judiciary, or with the requirements of a relevant regulatory authority. We do this not only to fulfil our legal obligations, but also because this may be in our legitimate interest.

To provide information about you.

From time to time, third parties, such as credit agencies, may approach us and ask for credit information as part of a credit or identity check. It may be in our legitimate interest to comply with our legal obligations, or we may be required to provide such information in order to comply with a legal obligation. If we are not sure, we will always talk to you before providing any information.

To send you surveys.

From time to time, we may send you surveys as part of our customer feedback process. It is in our legitimate interest to ask for feedback, to make sure we are providing the best possible service. However, we may occasionally ask you to participate in surveys for other purposes. If you agree to participate in such surveys, we will need your consent to use the personal information collected. All responses to a customer feedback survey or other survey sent by us are aggregated and anonymised before the survey results are shared with third parties.

Data analysis.

Our web pages, apps and emails may contain web beacons, pixel tags or other similar data analysis tools that allow us to track the receipt of correspondence and count the number of users who have visited our website or opened our correspondence. Where your personal information has been completely anonymised, we do not require a legal basis for doing so, because the information no longer constitutes personal information. However, if your personal information is provided in a non-anonymised form, we have a legitimate interest in continuously evaluating this personal information to ensure that the products and services we offer are relevant to the market.

Marketing by us.

We may use your personal information to send you marketing communications via email, telephone or other means (including social media campaigns) to ensure that you are always up-to-date with our current products and services. When we send you marketing communications, this is either because we have a legitimate interest in doing so or because we have obtained your prior consent.

Internal business purposes and keeping records.

We may need to process your personal information for internal business purposes, research purposes and/or for the purpose of keeping records. Such processing is in our legitimate interest and is required to meet our legal obligations. This may also affect the communication that occurs between you and us regarding the services we provide to you and our relationship with you. We also keep records to ensure that you fulfil your obligations pursuant to the contract concluded between you and us.

Restructuring of the company.

If our business is undergoing a restructuring, or if all or part of the business is taken over by a third party, we may need to use your personal information in connection with this restructuring or acquisition. Your data may be disclosed as part of a due diligence process. We have a legitimate interest in using your information in this way, provided we comply with any legal obligations we may have towards you.

Security.

If you enter our business premises, we may film you with our video cameras for security purposes. We also have the right to record your data for the purpose of documenting who has entered our business premises on a particular day. We have a legitimate interest in doing so in order to maintain a safe and secure working environment.

THE PERSONAL INFORMATION ABOUT YOU WE HOLD IN OUR POSSESSION

For more information on the rights you may have in relation to the personal information we hold about you, please see below.

Access

At your request, we will inform you as to whether we are processing your personal information and, if necessary, provide you with a copy of the personal information concerned (together with certain other information). If you need additional copies, we may require a commensurate processing fee.

Rectification

Should the personal information we hold about you be incorrect or incomplete, you have a right of rectification. If we have shared your personal information with third parties, we will, where possible, inform them of the rectification as well. At your request, we will also, as far as is possible and permissible, tell you with whom we have shared your personal information so that you can contact them directly.

Deletion

Under certain circumstances, you may request that your personal information be deleted, such as when we no longer need it or when you (where applicable) revoke your consent, provided we are not legally required to retain the information. This request is subject to any retention periods with which we must comply with in accordance with applicable laws and regulations and in accordance with the section “HOW AND FOR HOW LONG DO WE STORE PERSONAL INFORMATION?”. If we have shared your personal information with third parties, we will, where possible, inform them of the deletion. At your request, we will also, as far as is possible and permissible, tell you with whom we have shared your personal information so that you can contact them directly.

Processing Restrictions

You may request that the processing of your personal information be “blocked” or restricted under certain circumstances, for example if you contest the accuracy of the personal information or if you object to its processing by us. However, this does not prevent us from storing your personal information. We will inform you before we lift a restriction. If we have shared your personal information with third parties, we will, where possible, inform them of any restrictions. At your request, we will also, as far as is possible and permissible, tell you with whom we have shared your personal information so that you can contact them directly.

Data Portability

Pursuant to the General Data Protection Regulation (679/2016), you have the right, under certain circumstances, to receive from us the personal information that you have provided to us (in a structured, standard and machine-readable format) and to use it in other places. You may also ask us to provide this information to a third party of your choice.

Objections

If you request us to discontinue the processing of your personal information, we will do so as long as: our processing of your personal information is based on a legitimate interest of ours or of any other person, unless we can provide compelling legal grounds for processing; we are processing your personal information for direct marketing purposes; we are processing your personal information for research purposes, unless the processing is necessary to fulfil a task that lies in the public interest.

Automated decision making and profiling

If, on the basis of an automated process (e.g. an automated profiling process) alone, we have made a decision that affects your ability to use the services or has any other significant influence on you, you may request that you are not subject to such a decision unless we can prove to you that this decision is necessary for the conclusion or performance of a contract between you and us. Even if a decision is necessary for the conclusion or performance of a contract, you may contest the decision and request human interventions.