At Partners Network, we value your privacy. In this privacy statement (the “Privacy Statement”), Partners Network informs you about its practices with respect to the collection, storage and use of your personal data within the meaning of the EU General Data Protection Regulation (“GDPR”)(“Personal Data”).
This Privacy Statement is adopted by all affiliates and subsidiaries of Partners Network Holding B.V. that operate under the Partners Network brand. A list of the relevant entities can be found here. In the following, the use of “Partners Network”, “us” and “our” refers to the Partners Network entity that acts as your data controller.
TO WHOM DOES THIS PRIVACY STATEMENT APPLY?
This Privacy Statement applies to every individual whose Personal Data is processed by Partners Network, for example:
- visitors of the website www.partnersnetwork.com (the “Website”);
- individuals who apply for a job with Partners Network;
- the customers (and their employees) of Partners Network;
- the suppliers (and their employees) of Partners Network;
- other third parties that correspond (in whatever way) with Partners Network.
Partners Network aims to offer each individual the protection afforded by the GDPR, regardless of whether our processing of your Personal Data falls within the scope of the GDPR. However, should the GDPR not apply to the processing of your Personal Data by Partners Network, this may affect how we can deal with requests relating to (the exercising of) your rights under the GDPR.
WHO IS YOUR DATA CONTROLLER?
In general, the Partners Network entity that you contract with or with which you interact, is the data controller with respect to the processing of your Personal Data. For certain processing activities the data controller is designated or specified below:
- Use of the Website. The Website is registered to, is made available to you and is operated by, Partners Network Holding B.V. Accordingly, for all your Personal Data processed in connection with your visit to or use of the Website, Partners Network Holding B.V. is the data controller.
For your convenience, the Partners Network entities have collectively designated a single point of contact for all privacy related queries. If you have any questions regarding this Privacy Statement, or if you wish to exercise any rights under this Privacy Statement, you can contact us by e-mail at [firstname.lastname@example.org] or by phone at [+31 341 270 571]. We may ask you to provide proof of your identity, to ensure that your Personal Data is disclosed only to you.
WHEN DOES PARTNERS NETWORK COLLECT YOUR PERSONAL DATA?
Partners Network may collect your Personal Data:
- when you visit the Website;
- when you contact Partners Network with regard to, for example, information requests, job applications, questions, comments or complaints;
- when you are a customer or supplier of Partners Network.
Partners Network can collect your Personal Data whether it is provided directly by you, or through third parties or public databases.
WHAT KIND OF PERSONAL DATA DOES PARTNERS NETWORK COLLECT?
Partners Network may collect the following Personal Data:
- information about you: your name, (business/private) address, phone number, date of birth or age, and documents and information that certify your identity;
- information about your relationship with Partners Network: including but not limited to sales and purchase information relating to you or your organisation, information about your payment method (such as credit card number, bank account number or financial or payment information), IP addresses assigned to you or any other information related to your account with us, any correspondence, calls, chat records or other records of any contact you have with Partners Network;
- information related to your use of the Website: including but not limited to browser type and language, access times, IP-address, user-agent string and click stream behaviour;
- information related to your education or employment history: curriculum vitae and information provided by you in this respect.
Partners Network does not -and will not- collect sensitive personal data. Sensitive personal data is defined by Partners Network as data pertaining to someone’s religion, personal convictions, race, political affiliations, health, sexuality and sexual life, membership of unions, and/or criminal past, as defined in the applicable data protection laws and regulations.
Through the Website, Partners Network may also collect certain aggregate information, such as the total number of visitors of the Website, the number of visitors to each page of the Website, IP address and browser type. This aggregate information cannot be used to identify an individual and, as such, does not qualify as personal information.
ON WHAT LEGAL GROUNDS DOES PARTNERS NETWORK PROCESS YOUR PERSONAL DATA?
To process your Personal Data as described above, Partners Network relies on the following legal grounds:
- Performance of a contract: the use of your Personal Data is necessary to perform the contract you have with us.
- Legitimate interests: the processing is necessary for the purposes of the legitimate interests pursued by us, namely for security reasons (e.g. system integrity and fraud detection), administrative and legal purposes. Partners Network also wants to provide you with the best suitable content of the Website, emails and newsletters, to improve and promote its products and the content on the Website.
- Consent: Partners Network may rely on your consent to use your Personal Data for certain direct marketing purposes.
WHY DOES PARTNERS NETWORK PROCESS YOUR PERSONAL DATA?
Partners Network processes your Personal Data for different purposes. Please find below the specific processing purposes, linked to the specific Personal Data that is collected in that respect (indicated by a letter corresponding with the section “What Kind of Personal Data Does Partners Network Collect?”) and the specific legal ground(s) therefore (indicated by a number corresponding with the section “On What Legal Grounds does Partners Network Process Your Personal Data?”):
- Processing of orders and provision of products or services: A-B and 1-2.
- Processing your job application: A, D and 1, 3.
- Conducting market research, conducting customer retention and customer satisfaction surveys,conducting marketing activities (including through email newsletters, social media and onsite/offsite and online/offline advertisement), conducting sales activities (including analyzing your Personal Data): A-C and 3.
- Communicating with customers (i) to provide information about the products of Partners Network; (ii) to provide information about offers, orders, provision of products, order status and payment; and (iii) to handle complaints; and (iv) to answer questions from (potential) customers: A-B and 1-2.
- Investigating creditworthiness and risk management, and verifying whether (potential) customers will be able to comply with financial obligations: A-B and 1-2.
- Conducting legal processes, including (i) conducting legal proceedings; and (ii) collecting evidence for civil legal proceedings relating to you: A-B and 2.
- Complying with statutory obligations, including (i) provision of personal data to competent authorities in the context of criminal investigations, (ii) complying with (applicable) data retention obligations, (iii) the provision to third parties of information concerning customers in connection with an infringement of these third parties’ rights; or (iv) complying with any request by you to exercise your rights under this Privacy Statement: A-B and 2.
WITH WHOM CAN PARTNERS NETWORK SHARE YOUR PERSONAL DATA?
PartnersNetwork only shares your Personal Data to the extent (i) such is necessary for the performance of its contracts with you or your organization; or (ii) such is necessary to (legally) protect its legitimate interests in compliance with applicable law; or (iii) required by law.
PartnersNetwork may share your Personal Data with governmental authorities and/or law enforcement officials at their request. Further, each Partners Network entity may share your Personal Data with other Partners Network entities and with other third parties, that will process such data on behalf of Partners Network for the purposes stated above. Third parties will only be permitted to process your Personal Data for specified purposes and under our instructions; and on the condition that they have provided written assurances that the Personal Data shared will be protected in accordance with the provisions of this notice.
WHERE IS YOUR PERSONAL DATA PROCESSED?
As a general rule, each Partners Network entity only processes Personal Data in its own jurisdiction or in the European Economic Area. Where Personal Data is processed outside -or transferred out of- the European Economic Area, and where this is in -or to- a country that is not covered by an adequacy decision of the European Commission, Partners Network shall ensure that your Personal Data is adequately protected under appropriate safeguards. Examples of such safeguards are: the use of European Commission approved standard contractual clauses, an appropriate Privacy Shield certification or so called binding corporate rules. Partners Network will provide you with more detailed information upon request.
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
Partners Network will not store or retain your Personal Data for longer than is necessary in light of the purpose of the processing. Partners Network will periodically review its data retention periods with respect to the different categories of Personal Data, to ensure compliance with the applicable retention periods. All departments within Partners Network are familiar with the applicable retention policies and shall periodically review the Personal Data to ensure that the applicable retention periods are complied with.
HOW DO WE PROTECT YOUR PERSONAL DATA?
Partners Network employs procedural and technological security measures that are designed to help protect your Personal Data from loss, unauthorized access, disclosure, alteration or destruction. Partners Network may use firewalls, password protection and other security measures to help prevent unauthorized access to your Personal Data. Only authorized personnel are permitted to access Personal Data in the course of their work.
WHAT ARE YOUR RIGHTS?
In accordance with the GDPR, you have the following rights regarding your Personal Data and the processing thereof:
- You can request Partners Network to provide an overview of the Personal Data it has collected about you, or to correct it, delete it (right to be forgotten) or restrict the processing thereof;
- You have the right to receive your Personal Data, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit your Personal Data to another controller, provided that the processing is based on your consent or is necessary for the performance of a contract;
- If you have given your consent to the processing of your Personal Data, you can withdraw your consent by giving us written notice;
- You have the right to lodge a complaint with the competent supervisory authority.
Please note that under certain circumstances, Partners Network’s statutory obligations or legitimate interests may take precedence over your rights as described in this section. If this is the case, and if -as a result thereof- Partners Network cannot (fully) comply with your request, Partners Network will inform you thereof. Please also note that our compliance with certain requests may affect our performance towards you.
QUESTIONS AND FURTHER INFORMATION
If you have any questions with regards to this Privacy Statement, please feel free to contact us using the contact information provided above.
SUBJECT TO CHANGE
Partners Network reserves the right to amend or change the privacy statement at any time, at its discretion. This Privacy Statement was most recently changed on [10-04-2019].