Cookie Policy

Use of cookies

What is a cookie?
We use cookies on this website. A cookie is a file that is sent while browsing this website and stored by your browser on your computer’s hard drive. The information stored in a cookie can be sent back to our web server when you visit again.

Google Analytics
A Google Analytics cookie is placed on our website. We use Google Analytics to analyse how visitors use the website. Google may provide this information to third parties if required to do so by law or if these third parties process the information on Google’s behalf. We have no influence over this. We do not allow Google to use the analytics data obtained for other Google services. The information that Google collects is anonymised as much as possible. Your IP address is explicitly not provided. The information is stored by Google on servers in the United States. Google states that it adheres to the Privacy Shield principles and is a member of the U.S. Department of Commerce’s Privacy Shield programme. This means that an appropriate level of protection is put in place when any personal data is processed.

Social media
Buttons on our website allow our webpages to be shared on social media such as Facebook, LinkedIn and Twitter. These buttons work using pieces of code from the company in question that places cookies. We have no influence over this. To find out what the various social media do with your data that they process through cookies, please see the privacy policy for the relevant provider. The information they collect is anonymised as much as possible. It is then stored on servers in the United States. LinkedIn, Twitter, Facebook and Google+ state that they adhere to the Privacy Shield principles and are affiliated with the U.S. Department of Commerce’s Privacy Shield programme. This means that an appropriate level of protection is put in place when any personal data is processed.

Right to inspect, rectify or delete your data
You have the right to inspect, rectify or delete your data. To exercise your rights, please contact us using the details found on the website. To prevent fraud, we will ask you to provide identification. If enquiring about inspecting personal data associated with a cookie, please attach a copy of the cookie in question. You can find these in your browser settings.

Enabling, disabling and deleting cookies
For more information about how to enable, disable and delete cookies, please see the instructions or help section in your browser.

Learn more about cookies
The Dutch Consumer Association (Consumentenbond) provides a description of cookies here (in Dutch):

What are cookies?

How to delete cookies

Privacy Policy

Is this privacy policy applicable to you?

This privacy policy applies to you if you are an iTrainee customer, supplier or in any other business relationship with iTrainee, e.g. as a point of contact, director, manager, authorised representative, shareholder, trustee or employee acting on behalf of a customer, a sole proprietorship of a customer, a potential customer, a producer, a recipient of iTrainee’s services, a supplier, a partner company, a haulier or a claimant.

This privacy policy also applies to you if you are sponsored or contracted by iTrainee and if you are a claimant or a visitor to our website new.itrainee.nl or our offices.

All of the individuals above are referred to hereinafter as “business relationships”.

Why and on what lawful basis does iTrainee process personal data?
iTrainee collects, processes and stores personal data about business relationships for the following purposes:

Administration, financial management and customer management
For managing and processing orders, deliveries and invoices.
The following categories of personal data may be processed for this purpose:

contact details – name
phone number
fax number
email address
business address
personal phone number
position
location and shipping address
Chamber of Commerce registration number
VAT number
customer category
website
other company information (such as estimated turnover, number of employees, purchase history and debtors) about suppliers, customers and other recipients of iTrainee services
communication / emails exchanged with contacts
ordering information / information about the order.

The lawful basis for processing this personal data is that this processing is necessary to perform the contract with suppliers, customers and other recipients of goods from iTrainee and/or it is in the legitimate interest of iTrainee to maintain an adequate relationship management system.

‘Know-your-customer’ requirements. For accepting new customers and suppliers and reviewing existing customer and supplier information.

The following categories of personal data may be processed for this purpose:

UBO information – name of the ultimate beneficial owner of customers and suppliers
shareholding (expressed as a percentage) of the ultimate beneficial owner in customers and suppliers
other information – financial background data for risk profiling related to customers and suppliers, compliance and risk profile information about customers and suppliers (such as other companies’ property)
(suspected) convictions and criminal offences
political risk
involvement in tax disputes.

This information comes from external sources, such as LinkedIn, emails, Indeed, Chamber of Commerce and other resources.

The lawful basis for processing this personal data is that this processing is necessary to comply with iTrainee’s legal obligations and/or it is in the legitimate interest of iTrainee to perform risk management.

Financial management
For following up on outstanding customer payments owed under invoices for deliveries to trainees and other products or services to customers and processing and settling invoices from suppliers.

The following categories of personal data may be processed for this purpose:

general information – name
address
phone number
Chamber of Commerce registration number
VAT number
customer or supplier bank account number
name and email address of customer’s or supplier’s designated contact.

The lawful basis for processing this personal data is that this processing is necessary to perform a contract with customers and suppliers.

Purchasing
For purchasing various goods and services from suppliers.

The following categories of personal data may be processed for this purpose:

contact details – name
email address
phone number
supplier contact’s department
supplier’s company name.

The lawful basis for processing this personal data is that this processing is necessary because of the legitimate interest that iTrainee has in purchasing goods and services in order to do business.

Communication, advertising and marketing
For communicating with our business relationships and providing them with relevant information, such as brochures, newsletters, magazines, relevant content, product information and event invitations, for information and marketing purposes.

The following categories of personal data may be processed for this purpose:

contact details – name
email address
phone number
relevant business relationship’s company
relevant business relationship’s designated contacts.

The lawful basis for processing this personal data is the consent provided by the business relationship and/or the fact that this processing is necessary to perform the contract with current and potential business relationships and/or the fact that it is in the legitimate interest of iTrainee to maintain relations with its business relationships.

Images
iTrainee may process photos of business relationships and/or their contacts in order to develop and distribute marketing materials.

The following categories of personal data may be processed for this purpose:

personal information – name
position
image of business relationships’ customers and designated contacts.

The lawful basis for processing this personal data is the consent provided by the relevant business relationships and/or contacts. You may be invited to a photo session, which you are free to decide whether or not to take part in. There will be no negative impact if you choose not to take part. You may withdraw your consent at any time, as explained below in this policy (see: ‘What rights can you exercise with regard to your personal data?’). In addition, the processing of personal data for this purpose is necessary because of the legitimate interest that iTrainee has in developing and distributing marketing materials.

Sponsorship
For advertising and marketing by sponsoring athletes, sports activities, cultural activities, and social projects. The following categories of personal data may be processed for this purpose:

contact details – name
address
phone number
athlete’s email address
other information – information about the sports and photos of athletes or other sponsored parties.

The lawful basis for processing this personal data is that this processing is necessary to perform the contract with the relevant business relationship and/or it is in the legitimate interest of iTrainee to carry out sponsorship and marketing.

Security
For ensuring access security to iTrainee’s offices.

The following categories of personal data may be processed for this purpose:

contact details – name
company
supplier’s phone number
visitors
customers
hauliers
contacts
security-related information – reason for access and expected duration of visit
contact with iTrainee, access details (date, time, location and whether access was granted/refused) and video recording.

The lawful basis for processing employees’ personal data is that this processing is necessary on the grounds of the legitimate interest that iTrainee has in securing access to iTrainee’s premises and buildings so as to ensure that iTrainee, its employees and all other people on iTrainee’s sites are protected.

Legal and internal management
For contract management, IP registration, type registration and the settlement of disputes, complaints or legal proceedings.

The following categories of data may be processed for this purpose:

information related to contract management – company name
name
address
date of birth
place of birth of directors/managers and registration codes of contracting parties
IP registration, information about type registration – name, position
information about disputes
complaints or legal procedures – name
address
email address
phone number
position
claimant’s work location
content of complaint.

The lawful basis for processing this personal data is that this processing is necessary to comply with iTrainee’s legal obligations and/or is in the legitimate interest of iTrainee to protect its IP rights and maintain records of its contractual obligations and/or is in the legitimate interest of iTrainee in handling disputes, complaints and legal proceedings.

Who has access to your personal data?
iTrainee may share your personal data with the following parties and individuals under the following circumstances:

iTrainee may share your personal data with data processors, i.e. parties that process personal data on our behalf. In such cases, these third parties may only use your personal data for the purposes described above and only in accordance with our instructions.
iTrainee’s employees may have access to personal data, such as employees working in the administration and sales department. In such cases, access is granted only if necessary for the purposes described above and only if the employee is bound by a duty of confidentiality.
iTrainee may share your personal data as necessary for the purposes above, for example under a contract with research firms to perform a credit check and to fulfil ‘know-your-customer’ requirements, or with patent offices for IP registration.
iTrainee may share your personal data if there is a legal requirement or court order to do so, for example by law enforcement agencies or other government agencies.

How long does iTrainee process your personal data for?
Unless a specific retention period is required or permitted under the applicable law, for example in fiscal law, iTrainee will only retain your personal data for as long as is necessary to fulfil the purposes described in this privacy policy. This means that, in some cases, we will retain your personal data for a certain period after your contract with iTrainee has ended. As a rule, we retain customer data for up to seven years from the end of the contractual relationship for fiscal and administrative reasons. However, the data will be erased during this retention period, where possible.

If any particular situations arise, such as a dispute or claim, we may store evidence and data for a longer period of time.

Our retention policy reflects applicable local laws and the national legal obligations of iTrainee that govern the limitation period. If you would like more information about iTrainee’s retention policies that apply to your data, please email privacy@iTrainee.nl.

What steps does iTrainee take to protect your personal data?
iTrainee has taken appropriate technical and organisational measures to protect your personal data from unintended or unlawful processing, including by ensuring that:

your personal data is protected from unauthorised access;
the confidentiality of your personal data is guaranteed;
the integrity and availability of your personal data is maintained;
our employees are aware of information security regulations;
actual or suspected data breaches are reported in accordance with the applicable law.

Where does iTrainee store your personal data and where does iTrainee transfer it?
As a rule, your personal data is stored on servers in the European Union. Your data may be transferred to countries where our customers are located.

If personal data is transferred outside the European Union, iTrainee will ensure that appropriate safeguards are in place. In most cases, transfer is subject to a contract based on the standard contractual clauses for data transfers approved by the European Commission.

If you would like more information about how your personal data is transferred to a country outside the EU or about the lawful basis for the transfer, please contact iTrainee.

What rights can you exercise in relation to your personal data?
You may exercise a number of rights in relation to your personal data, which are explained below. To exercise your rights, please contact us using the details below. Please note that, in many cases, your rights are not absolute, and we may not be required to comply with your request.

Right of access
You are entitled to a copy of the personal data we store about you and to know how we use it. Your personal data is usually provided to you digitally.

Right to rectification
We take reasonable steps to ensure that the information we hold about you is accurate and complete. However, if you do not believe this is the case, you can ask us to update or change it.

Right to erasure (‘right to be forgotten’)
Under certain circumstances, you have the right to ask us to delete your personal data, for example if the personal data we collect is no longer necessary for the original purpose or if you withdraw your consent. However, this must be weighed against other factors. For example, we may not be able to fulfil your request due to certain legal and regulatory obligations.

Right to restrict processing
Under certain circumstances, you have the right to request that we temporarily discontinue processing your personal data, for example if you think that the personal data we hold about you may be inaccurate or if you think we no longer need to use your personal data.

Right to data portability
Under certain circumstances, you have the right to request us to transfer personal data you have provided to us to a third party of your choice.

Right to object
You have the right to object to processing that is based on our legitimate interests. If you exercise your right to object, we will stop processing your personal data on that basis, unless we have a compelling legitimate reason for processing. However, we may not be able to provide certain services or benefits if we are unable to process the required personal data for that purpose.

Rights related to automated decision-making
You have the right not to be subject to automated decision-making, including profiling, that has legal implications for you or similar significant consequences. iTrainee does not use automated decision-making.

Right to revoke consent
We may request your consent to process your personal data in certain cases. When we do, you have the right to withdraw your consent at any time. iTrainee will stop processing as soon as you withdraw your consent. However, this does not affect the lawfulness of processing until the time that consent was withdrawn.

What if I have another question or complaint?
Please address any questions or complaints about the processing of your personal data to iTrainee at privacy@iTrainee.nl

You also have the right to lodge a complaint with the data protection authority in the jurisdiction where your company is located, where you live or where there is a suspected breach. You can find a list of the data protection authorities (DPAs) in the European Union on the European Commission website. However, we encourage you to report any concerns or complaints to iTrainee first.

Changes to this privacy policy
iTrainee may update this privacy policy from time to time. If a change has serious consequences for business relationships, iTrainee will actively notify these of any such changes. iTrainee will ensure the privacy policy is up to date at all times.

Version: November 2021