This is the privacy statement of SMEENK’S Top Personal Assistants (hereinafter: ‘SMEENK’S, ‘we’, ‘us’ or ‘our’), with its registered office in Laag-Keppel, the Netherlands, and registered with the Trade Register of the Chamber of Commerce in Arnhem, the Netherlands, under number 09175437. We process personal data in the role of controller as laid down in the General Data Protection Regulation (the ‘GDPR’).
This privacy statement was last modified on February 15, 2024.
1. Which personal data do we process?
Personal data concerns all information through which a natural person (the data subject) can be identified or is identifiable. The personal data we may process from you (i.e. from receiving and storing to adjusting, forwarding and deleting) includes:
a) Basic information, such as your first and last name, title, gender, the company you work for or your position;
b) Contact details, such as postal address, (mobile) telephone number or e-mail address;
c) Additional personal data, such as proof of identity, date of birth, nationality and marital status;
d) Financial information, such as your bank account number;
e) Technical data, such as your IP address, the device you use to visit our website and the pages you view;
f) Personal data that you provide to us as a candidate, such as training and career data;
g) All other personal data that we receive from or about you or that we can obtain ourselves and that we use for the purposes outlined below.
2. How do we obtain personal data?
In most cases, we obtain your personal data from you,for example if you appoint us for a search, if you visit our website, if you fill in a form on our website, if you register with us, if you apply with us, if you give us your business card or from information that we obtain during (telephone) calls and e-mail contact with you. In addition, we may also obtain your personal data in other ways, for example from third parties, such as the Trade Register of the Chamber of Commerce, public sources and websites.
3. For what purposes and on what legal grounds do we process personal data?
Purposes
In all relationships that we enter into, personal data is required to ultimately provide the best possible service and cooperation. We process your personal data for the execution of HR services, including search, recruitment and selection and personal development.
More specifically, we only process the data that is necessary:
a) to record an assignment with the client in an agreement with the client and to maintain and fulfill the agreement with the client;
b) to enter into and maintain a mediation, personnel or employee relationship and to carry out the relevant administration for this purpose;
c) if we have entered into a mediation, or into an employee or personnel relationship with you for compliance with laws and regulations, including but not limited to identification, employment law, tax and social security law, anti-fraud and national and international sanctions law;
d) to make you an offer and / or provide information about our services;
e) to assess your suitability and availability in connection with mediation for an assignment or work, whereby we may also use assessments, diploma and reference checks and social media;
f) to register you for participation in one of our events, to keep you informed of the event in question, to register your presence and to send you a participation certificate;
g) to invite you to a customer satisfaction survey upon completing an assignment or participating in one of our events;
h) to monitor and improve the content and use of our website. We collect and analyze the surfing behavior of visitors to our website. You can sign up for a newsletter on our website. You can also register as a user. You can then manage your newsletter preferences and your possible participation in our events.
Legal basis
We are only allowed to process your personal data if there is a legal basis for this. The above processing takes place on the basis of one of the following legal bases from the GDPR:
• For the execution of an agreement;
• Due to a legal obligation;
• With your permission;
• Because of a legitimate interest.
Use by third parties
We may need to share your personal data with third parties. This can be done in the following cases, such as:
For example, we may engage third parties to outsource activities. Third parties to whom we provide your personal data are also responsible for the processing of that data and for compliance with the GDPR.
If a third party processes your personal data as a processor on behalf of SMEENK’S, we will conclude a processing agreement that meets the requirements of the GDPR.
For our paid events we use the services of Mollie Payments and PayPal. Mollie and PayPal take care of the payment between Smeenk’s and your bank or a credit card company. We do not see your payment details. Mollie and PayPal only let us know whether the payment was successful and transfer the amount to us.
In order to track and improve the content and use of our website, we record the surfing behavior of our website visitors. We do this with Google Analytics, but in a privacy-friendly way: we have concluded a processing agreement with Google, your IP address is anonymized and we do not share the data with Google.
Finally, we may provide your personal data to third parties if we are obliged to do so on the basis of laws and / or regulations, if we are forced to do so as a result of a lawsuit and / or if we consider it necessary to protect our own rights.
4. How long do we keep personal data?
We do not store your personal data longer than is necessary for the purpose for which we collected and recorded it. This means that we will, in principle, delete your data four (4) weeks after the completion of the assignment, unless you give us written permission to keep your data in portfolio for longer. In that case we will keep your data for a year from that moment. If we are required by law to keep your data longer, we use the statutory retention periods of usually seven to ten (7 to 10) years.
5. Where are your personal data stored?
We store your personal data on a secure server in the Netherlands. If and insofar as we provide personal data to third parties who provide services or execute orders on behalf of SMEENK’S, SMEENK’S has agreed with them that they will also optimally protect personal data, in accordance with the requirements of the GDPR.
6. How are your personal data protected?
We have taken appropriate technical and organizational measures to protect your personal data against loss or any form of unlawful processing. Among other things, we use an SSL-encrypted website and an individual password-encrypted SharePoint. For more information about the structure of our security, please contact us at maartje.smeenk@smeenks.com.
7. Your rights
If you wish to view the data that we have recorded about you, you can send us a request for access via maartje.smeenk@smeenks.com. We will respond to your request for inspection within four (4) weeks. If you wish to make changes to the data that you have seen as a result of your request for access, you can request this from us via the aforementioned e-mail address. You also have the right to withdraw your consent to the data processed. You can also make this request via the aforementioned e-mail address. You can also request us to change, correct, supplement, delete or shield your data. We will always respond to your request within four (4) weeks. If we are unable to comply with a specific request, we will of course inform you of this in a motivated manner. You also have the right to obtain and transfer the personal data you provide in a common, structured and legible form. You can also send this request to us via the
aforementioned e-mail address. You also have the right to file a complaint with the supervisory authority (the Dutch Data Protection Authority).
8. Will this privacy statement be changed?
This privacy statement may be changed. We therefore advise you to regularly consult our privacy statement via this page. If our privacy statement changes radically, we will also notify our visitors about this via a clear message on our website. If we want to use your data for another form of processing, we will of course also actively inform you.
9. Questions and feedback
We regularly check our compliance with this privacy statement. If you would like to learn more or if you have any questions or complaints about our processing of your personal data, please do not hesitate to contact us at maartje.smeenk@smeenks.com.
