Privacy statement Attune 2018

Attune has drawn up the following privacy regulations based on the introduction of AVG. This privacy policy relates to the processing of personal data by Attune in Boxtel. Processing of personal data includes, among other things, the collection, storage, recording, alteration, collection, retrieval, consultation or destruction of personal data. Attune collects personal data from clients, participants, suppliers and visitors to our website.

General Data Protection Regulation The General Data Protection Regulation (AVG), also called GDPR (General Data Protection Regulation), is European legislation that has direct effect within the European Economic Area. As of 25 May 2018, these regulations replace the Personal Data Protection Act.

AVG and protection of personal data As a controller (Attune is responsible for almost all processes; a number of processes including TMA integral Talent Management and LearningStone are executed in a Processor role) Attune has its own data processing administration. All documents are regularly evaluated and updated where necessary. The reasons (also referred to as bases) of Attune for processing personal data are: being able to execute agreements, requesting permission (opt-in) for sending information, a legitimate interest as well as the implementation of the legal obligation (for example to to be able to invoice.

The protection of privacy has traditionally played a very important role in our organization. Attune is a sole trader and the owner Sonja Vlaar is a member of LVSC and international professional associations for coaching and assessments. We therefore comply with the privacy law. In all processing within Attune, she handles personal data and customer information with great care. The principles as set out in the AVG are the starting point here as well as those in professional codes to which Attune conforms or is bound

This means that Attune:

  • inform you in an understandable and transparent manner about how and for what purposes the personal data is processed;
  • processes personal data only for legitimate, well-defined purposes and bases the data processing on the basis stated in the GMS;
  • take appropriate organizational and technical security measures to protect personal data against unauthorized or unlawful processing and against accidental loss, destruction or damage. This means that your data is safe with us.
  • you inform about your rights with regard to the personal data processed by Attune.
  • not processed more or longer than necessary.

In the following chapters we will inform you in more detail. If you have any questions or would like to know exactly what we keep about you, please contact Attune.

Personal data that we process

Attune has a legitimate interest in processing your data because you use our services and / or because you (have) provided it to us yourself: the processing of the data is necessary for the proper processing of your request

Below an overview of the personal data that we process:

  • First and last name
  • Phone number
  • Email
  • Location data

In addition, we process - exclusively for conducting assessments - the following data:

  • Date of Birth
  • Sex
  • Nationality

Special and / or sensitive personal data that we process

Our website and / or service does not intend to collect data about website visitors younger than 16 years. Unless these young people have permission from parents or guardian. However, we cannot check whether a visitor is older than 16 years.

We therefore advise parents to be involved in the online activities of their children, in order to prevent data about children being processed without parental consent. If you are convinced that we have processed personal data from a minor without that permission, please contact us via info@attune.nl and we will remove this information.

Why we need personal information

Attune collects personal data for different purposes and on different bases:

  • For the delivery of products and / or services as agreed with you and / or your employer
  • For pre-contractual activities such as making tenders
  • To be able to call or email you if this is necessary to be able to perform our services
  • Handling your payment
  • Attune also processes personal data if we are legally obliged to do so, such as data that we need for our tax return
  • To be able to distribute the newsletter and analyze the dispatch. The data used for this are obtained with explicit permission. If you have provided your e-mail address for a different purpose, it will never be used for purposes such as the newsletter.
Contact form, marketing and sales activities

With the contact form you can ask us questions or make requests. We use your e-mail address for this. We do this based on your permission. We keep this information until we are sure that you are satisfied with our response.

Attune is happy to inform customers about offers, innovations and other relevant (subject-specific) content with regard to our services, in accordance with the applicable regulations, or because you have given explicit permission for this. We can do this by telephone, e-mail, newsletters or direct personal contact. Of course you always have the right to state that you do not want to (anymore) value this.

You can subscribe to our newsletter. Here you can read news, tips and information about our products and services. You can cancel this subscription at any time. Every newsletter contains a unsubscribe link at the bottom of the page. Your e-mail address is automatically added to the list of subscribers upon registration.

How long we keep data

Attune does not store your personal data any longer than is necessary for the purposes for which the data were collected. The retention period depends on the nature of the information and the purposes of the processing.

Below we list the retention periods of personal data for various purposes and services.

  • Participant data in our administration or marketing system: 5 year after the last registration or activity, so that we can continue to advise and inform you about subsequent development steps based on previous activities. Or, for example, to be able to verify your right to a participation certificate (lost to you), in short: to be able to provide services to you.
  • Your assessment file and test data: 1 year. Only with your own permission will the final report be shared with the client. You can inspect this in advance and you can request further explanation.
  • Coaching data: 2 year.
  • Newsletter: This information is saved until you cancel the subscription for the newsletter in question.
Share with others

As a Controller, Attune can engage other parties to perform an aspect of or part of the services for you; this may involve, for example, an external consultant, trainer or assessment psychologist, or an external test (system) as part of the assessment, or it may be an ICT system or platform with which we provide our services, such as an CRM. system or e-learning platform. To the extent that these third parties require access to personal data to perform these services, Attune has contracted appropriate contractual, technical and organizational security measures to ensure that these third parties use or process your data solely for the intended purposes and in accordance with the instructions that we have agreed with these third parties.

Attune does not sell your personal data to third parties and will only provide this personal data to third parties if this is necessary for the execution of an agreement concluded with you or to comply with a legal obligation. Attune remains responsible for these processing of your personal data.

Share with third parties for legal reasons. We may share your personal information with third parties if we believe that access to and use of the personal information is reasonably necessary to (i) comply with applicable laws, regulations and / or court orders; (ii) to prevent or detect or resolve fraud, (future) security issues or technical issues; and / or (iii) protect the interests, properties, or safety of Attune, our users, or the public to the extent consistent with law.

Cookies

We use cookies on our websites and apps. You can disable cookies for all sites through your browser.

What are cookies? Cookies are small, simple text files that your computer, tablet or mobile phone receives when you visit a website. Cookies make the visit to the website more user-friendly.

Why do we use cookies? Attune uses cookies to anonymously track how many visitors the site receives, which pages are visited and which information requests are made. The cookies that Attune uses do not contain name and address data; Only data regarding your use is stored (pages visited, technical details and IP address). This data is used to analyze usage and visits, so that our websites and apps can be optimized and serve you even better in the future. We will of course handle this information with care.

What happens when cookies are turned off? If you disable your cookies, we will have less insight into (website) use, so that we cannot optimize them in order to serve you even better in the future.

Opt out of cookies. If you prefer not to use cookies, you can disable or delete them at any time via your browser. Instructions for adjusting the browser settings can be found under 'Help' in the toolbar of most browsers.

To give website visitors more choice about how their data is collected by Google Analytics, you can also download the Google Analytics Opt-out Browser Add-on.

View, modify or delete data

You have the right to request us in writing to:

Access to your personal data. You can ask us if we process your personal data. If that is the case, we will explain to you which personal data we process, how we do this and for what purposes. You can also request us for a copy of the personal data that we process about you;

Rectification of your personal data. If you believe that the personal data we process about you is incorrect or incomplete, you can request us to complete or change your data;

Delete your personal data. You can request us to remove the personal data that we process from you. We will retrieve your data from our system without unreasonable delay after receiving a request.

Restriction of the processing of your personal data. In some cases you may wish to limit the processing of your personal data. In that case you can request us to limit the data processing.

Transfer of your personal data (data portability). You can request us for a copy of the personal data that we process about you. You can also express your right to object with us if you do not agree with our processing of your data.

A request for inspection, correction or removal can be sent to info@attune.nl.

To ensure that the request for inspection has been made by you, we request that you send a copy of your proof of identity with the request. We hereby request that you make your passport photo and citizen service number (BSN) black in this copy. This is to protect your privacy. Attune will respond to your request as quickly as possible, but no later than within 4 weeks.

Security

Attune takes the protection of your personal data seriously and takes appropriate measures to prevent abuse, loss, unauthorized access, unwanted disclosure and unauthorized changes. If you have the impression that your personal data is not properly secured or that there are indications of abuse, please contact us via: info@attune.nl.

To file a complaint

It is possible that you have a question, request or complaint. For this you can contact us via the contact form on this website or directly via these contact details: Attune, attn. Sonja Vlaar, Rentmeester 70, 5282 GA Boxtel; sonja.vlaar@attune.nl.

If you then find that we are not helping you in the right way, you have the right to make a complaint to the regulator. This is called the Dutch Data Protection Authority. On www.autoriteit PERSgegevens.nl you can read how to submit a complaint.