Privacy Policy

Table of Contents

1 General

2 Application

3 Processing of personal data and responsibilities

4 Purposes

5 Security

6 Disclosure of data to third parties

7 Rights of the data subject

8 Cookies and websites

9 Retention periods

10 Contact Us

11 Modifications

lefreQueBV, with registered office at Hoge Geeren 2, 3828 TJ Hoogland, registered in the Chamber of Commerce under number 522838512; (‘lefreQueBV’) considers the protection of privacy to be of the utmost importance. lefreQueBV wants to inform, respect and give its customers and the users of its services as much as possible control over what happens to their data. lefreQueBV wants to manage and use its customer data safely, respectfully and with due care in order to better serve its customers and offer the best possible experience. lefreQueBV therefore starts from the principle that everyone should have control over his or her personal data. Below you will find information about what data lefreQueBV collects, why, for how long and how you can control this. lefreQueBV invites its customers to take the time to read this Privacy Policy carefully, together with the Terms and Conditions and any other terms and conditions that may apply to its products and services.

This Privacy Policy applies to all our customers (current, former and future) and to all visitors to the lefreQueBV website(s). The European General Data Protection Regulation 2016/679 of 27 April 2016 (“General Data Protection Regulation”), and its implementing decrees, as well as any future amendments thereof, govern the protection of your personal data. lefreQueBV strives to comply with its obligations and respect the rights of the customer every time lefreQueBV processes your personal data. For more information about this, lefreQueBV would like to refer you to the website of the Dutch Data Protection Authority (https://autoriteitpersoonsgegevens.nl/)

“Personal data” means any information relating to an identified or identifiable natural person (“data subject”), it being understood that an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physical or physical identifier or the natural person, the personal information provided by the  physiological, genetic, psychological, economic, cultural or social identity of that natural person. The personal data that lefreQueBV collects and processes primarily concerns the data that the customer enters himself via the various pages of our website(s) and that lefreQueBV obtains through your use of our website(s) and/or our products and/or services. lefreQueBV acts as the controller for the processing of personal data of its customers for the purposes described in this Privacy Policy. This does not alter the fact that the customer has a number of obligations in connection with the processing of personal data that allows the customer to use lefreQueBV’s products and services. In that capacity, lefreQueBV must always obtain the legally required consents of the end users for the processing of their personal data by lefreQueBV insofar as necessary in the context of the products and services of lefreQueBV.

lefreQueBV processes personal data for various purposes, each time only processing the data that is necessary to achieve the intended purpose. For example, we use personal data:

• When we have received permission;
• In the context of the preparation or performance of our contract;
• To comply with the legal or regulatory provisions to which we are subject; and
• When lefreQueBV has a legitimate interest in doing so, such as, as the case may be, conducting direct marketing, preventing fraud, managing internal administration or monitoring appropriate network and information security, in which case we always strive for a balance between that interest and respecting the privacy of the data subject.

 

Subject to consent

Insofar as required, lefreQueBV collects personal data for the following concrete purposes:

 

To process the request for our products and services.

If you visit our website to collect and/or request information about our products and services or when you sign up for lefreQueBV’s newsletter, for example, lefreQueBV will need your address details. All information that lefreQueBV receives about you in this pre-contractual phase will only be used by lefreQueBV to provide you with the requested information, in the way you wish. Even if you ultimately decide to become a customer of lefreQueBV, lefreQueBV will ask you for a number of personal data such as name, address, telephone number, e-mail address, customer number, and lefreQueBV may also assign certain data to you such as for example (and in case relevant), login details.

 

To offer the best service and to inform about possible uses

lefreQueBV uses personal data to set up, maintain and support products and services and for administrative purposes.

 

To inform about (new) products and services of lefreQueBV, lefreQueBV can use personal data to offer (in writing, by telephone or electronically) new products, services or special promotions that lefreQueBV believes may be of interest to you. You can unsubscribe from these types of messages, see below.

 

To monitor performance.

lefreQueBV may use personal data and consumer profiles to evaluate its products and services. This includes, but is not limited to: soliciting feedback on services (e.g. through market research), data obtained during responses to customer inquiries, detecting fraud and quality assurance.

 

To comply with legal obligations.

In many cases, lefreQueBV is legally obliged to retain and/or communicate certain personal data to government agencies, for example in the light of general tax and accounting obligations. In the context of a police or judicial investigation, lefreQueBV may be obliged to communicate certain data confidentially to the necessary authorities.

 

To keep track of studies, tests and statistics, for trend analysis, among other things.

lefreQueBV may use anonymous, aggregated data to, for example, report internally and externally on the use of its services. The data used for this purpose cannot be traced back to a specific individual. The information that lefreQueBV obtains from these analyses is used to evaluate the current product and service portfolio and lefreQueBV’s processes and to adapt them to new developments.

lefreQueBV strives to protect personal data and privacy at all times, both in the physical offices and on the network of lefreQueBV. lefreQueBV takes care of appropriate organizational and technical measures to secure personal data. lefreQueBV’s employees are trained to handle confidential data correctly. In privacy-sensitive projects, an assessment is also made in terms of security and the protection of personal data.  For the security of data, lefreQueBV employs specific persons who ensure compliance with legislation and ethical aspirations. lefreQueBV also employs specialized people who are responsible for the security of the network, infrastructure and information systems. In addition, lefreQueBV uses all kinds of technical measures to protect personal data, such as: password protection, hard disk encryption software, firewalls, antivirus, intrusion and anomaly detection. In the event of a data breach adversely affecting personal data, the customer will be personally informed in the circumstances provided for by law.

The number of lefreQueBV employees who have access to personal information is limited and carefully selected. These employees are granted access to personal information to the extent that they need that information to perform their duties properly. Every employee has also signed a confidentiality agreement in his/her employment contract. The existence and content of personal communications that take place via the lefreQueBV network (for example: e-mail traffic, hosting, etc.) are protected by the provisions on telecommunications secrecy. This means that lefreQueBV and its employees are not allowed to take cognizance of the existence or content of such communication outside the exceptions listed by law. lefreQueBV’s websites sometimes contain links to third-party sites (social media) whose terms of use do not fall within the scope of this Privacy Policy. Please read carefully their personal data protection policy.

lefreQueBV does not sell personal data to third parties nor is it passed on to third parties, unless:

 

1) lefreQueBV passes on personal data to any legal successors and affiliated companies (such as subsidiaries and sister companies) for the same purposes as those stated in this Privacy Policy:

2) This is necessary for our services. For some aspects of our products and services, we work with third parties or use subcontractors. These third parties are always carefully selected and there is always an agreement between lefreQueBV and this third party in accordance with the applicable legislation. For example, lefreQueBV uses service providers of domain name registrations, providers of email services, providers of SSL certificates, providers of cloud services, providers of site builder services. For more information about our subcontractors, please contact us using the contact details under point 10. If you purchase an (online) product or service from lefreQueBV from a manufacturer or supplier located outside the European Union, it is possible that additional measures are required to ensure the security of personal data, such as certification under the EU-US Privacy Shield and/or a processing agreement with model clauses drawn up by the European Commission. When a person refuses to have his data transferred, it is possible that some services can no longer be offered by lefreQueBV.

3) There is a legal obligation. lefreQueBV refers to point 4 of this Privacy Policy. 4) There is a legitimate interest for lefreQueBV or the third party concerned. This is only done if the interests or fundamental rights and freedoms of the data subject do not outweigh them.

5) lefreQueBV has received permission from the person concerned. If lefreQueBV would otherwise provide personal data to third parties, this will be done with an explicit communication, in which an explanation is given about the third party, the purposes of the transfer and processing. Where required by law, lefreQueBV obtains explicit and unambiguous consent from the data subject. The person concerned also always has the possibility to object (see below).

6) With regard to the international transfer of personal data, lefreQueBV protects all personal data in accordance with the level of protection required by European regulations. In some cases, lefreQueBV uses anonymous, aggregated data for commercial purposes or for external reporting. This data can never be traced back to a particular individual.

You can exercise a number of rights regarding the processing of your personal data with regard to lefreQueBV, insofar as you have those rights under the applicable legislation.

Privacy Policy – version May 2018 6 lefreQueBV B.V.

You can exercise these rights by using the contact details mentioned under point 10 of this Privacy Policy. lefreQueBV will respond to such requests and may or may not comply with such requests in accordance with applicable law and in principle within a period of one (1) month, also in accordance with applicable law. In order to exercise your rights, and to prevent any unauthorized disclosure of your personal data, you must provide us with proof of your identity. We therefore ask you to preferably add a copy of the front of your identity card to your application. The request can be sent to the details mentioned in point 10 of this Privacy Policy. If you deem it necessary, you can also contact or file a complaint with the Dutch Data Protection Authority (.autoriteitpersoonsgegevens.nl)

Right to object You have the right to object at any time, for reasons relating to your particular situation, to the processing of your personal data that is based on the legitimate interest of lefreQueBV. If you object, lefreQueBV will cease processing that personal data unless lefreQueBV demonstrates compelling legitimate grounds for the processing that outweigh your interests, rights and freedoms, or that are related to the establishment, exercise or defence of legal claims.

 

Right of access and transparency You have the right to (free) access to the data concerning you and to obtain a copy of this personal data. You can also ask us:

• Whether we process your personal data;
• For what purposes we process it;
• Which categories of personal data we process;
• Which categories of third parties we share your personal data with;
• The origin of the data processed;
• What rights you have.

 

Right to rectification and erasure As a data subject, you have the right to have incomplete, incorrect, inappropriate or outdated personal data corrected or supplemented. To do this, our customer service can be contacted from a registered address or your data can be updated via the online portal “www.lefreQueBV.nl”. In any case, in order to keep your data up to date, we ask you to notify us of any changes, such as in the event of a move.  You also have the right to obtain, without undue delay, erasure of your personal data if and to the extent that:

1. a) the personal data are no longer necessary for the purposes;
2. b) there is no longer a legal basis;
3. c) you object to the processing, and there are no overriding legitimate grounds for the processing by lefreQueBV;
4. d) the personal data have been unlawfully processed or ;
5. e) the personal data must be erased in order to comply with a legal obligation to which lefreQueBV is subject.

lefreQueBV will send you a confirmation message after execution of a request for removal.

 

In the event of partial removal, lefreQueBV will also explain why the request could not be fully complied with. It is possible that, depending on the nature of the request, some services can no longer be offered by lefreQueBV. lefreQueBV cannot always delete all requested data, for example to comply with legal obligations (for example, to meet tax obligations, lefreQueBV is obliged to keep all invoicing data for a maximum of 7 years).

Right to restriction of processing As a data subject, you also have the right to obtain from lefreQueBV the restriction of the processing of your personal data, if and insofar as one of the following elements applies: a) you contest the accuracy of the personal data, in which case the processing will be restricted for a period that enables lefreQueBV to verify its accuracy; b) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead; c) lefreQueBV no longer needs the personal data for the processing purposes, but you need it for the establishment, exercise or substantiation of a legal claim; d) you have objected to the processing, pending the answer to the question whether the legitimate grounds of lefreQueBV outweigh those of the data subject. In case of restriction of processing, the data may still be stored by lefreQueBV.

Right to data portability For personal data that (i) are processed in the context of the execution of the agreement, (ii) were provided by yourself and (iii) are processed via automated procedures, you as a data subject have the right to obtain this data from lefreQueBV in a structured, commonly used and machine-readable format, as well as to request lefreQueBV to transfer this data directly to another party,  if this is technically possible, if you wish to switch to another provider.

lefreQueBV stores and processes your personal data for as long as necessary to achieve the purposes as described in point 4. The retention period can therefore vary per purpose, for example to comply with legal obligations (in order to meet our accounting and tax obligations, lefreQueBV is obliged to keep billing data for a maximum of 7 years) or from the legal necessity to keep certain data as evidence in the event of disputes, for a maximum of 10 years after the termination of your contract. Of course, this archived data is only accessible to a limited extent.

Apart from the data that you voluntarily share with lefreQueBV when using our websites, lefreQueBV also uses cookies and other technological means to collect data. Websites All information, whether in the form of text, files or images or any other form, is made available by lefreQueBV for information purposes only. Any interested person may take note of this information, but lefreQueBV reserves the right to change the rules and conditions regarding access to the use of the website at the time it deems appropriate, without any prior warning, or to subject the entire website or parts thereof to a restriction. Access to such private areas of the website may be subject to the provision of information by the visitor/user of the website. The visitor/user who provides this information expressly agrees that this information becomes the property of lefreQueBV and that by the mere communication of information to lefreQueBV, the latter receives the explicit permission to use information in accordance with the Privacy Policy. Granting access to the private part of the website of lefreQueBV by using usernames and passwords, can be changed or refused by lefreQueBV at any time without this being able to lead to any compensation. Cookies Our website uses cookies or similar technologies that store and/or read information on the device (for ease of reading, all such techniques are referred to here as ‘cookie’). For more information about which cookies we use, why and how, and what your choices are, please consult our cookie policy.

A question or request regarding personal data or this Privacy Policy can be addressed at any time to: lefreQue B.V. to Attn of Data Protection Officer: info@lefreque.com

lefreQueBV reserves the right to amend this Privacy Policy. Changes will always be published on this website prior to their entry into force. It is recommended that you consult this Policy regularly so that you are aware of these changes.