Privacy Policy

Refelt

The  privacy statement applies to the processing of personal data by Refelt B.V. (Chamber of Commerce 72322926), hereinafter referred to as “Refelt”.

Processing of personal data

For Refelt the protection of personal data is very important. Refelt respects your privacy and ensures that your personal data is treated confidentially and in accordance with the applicable privacy legislation.

Purposes of processing

Refelt processes your personal data for the following purposes:

  1. implementing the agreement or agreements concluded with you;
  2. keeping records, as well as other internal control activities;
  3. calculating, recording and collecting amounts due, including handing claims to third parties;
  4. to enable us to contact you and to respond to your questions;
  5. to inform you about new products and/or services and offers of Refelt;
  6. to handle your request for information;
  7. to be able to send digital newsletters to you by email;
  8. to improve Refelt’s website and services;
  9. to comply with statutory obligations, such as the administrative records and retention obligation;
  10. to deal with disputes and to have an independent certified accountant conduct audits.

Legal basis for processing

The legal basis for the purposes of processing stated above lies in:

  • the consent you have given;
  • at your request, taking precontractual measures and/or implementing the agreement you have concluded with us;
  • meeting the requirements of statutory obligations;
  • promoting legitimate interests of Refelt or of a third party.

For the purposes numbered above as 2, 4, 5, 6, 7, 8 and 10, Refelt relies on the legal basis of the legitimate interest. Refelt’s legitimate interest consists in carrying out normal business operations, providing internal control activities, conducting internal analyses (of the market or otherwise), being able to conduct marketing activities and similar interests of a commercial and a business nature. Naturally, the privacy interest of the party concerned is always taken into consideration.

You may oppose these forms of processing on the basis of your right to object. You will find further information on this right in what follows. 

Mandatory disclosure

When we ask you for personal data, we will inform you per situation as to whether the disclosure of the data is necessary or mandatory and of the possible consequences if the data is not provided. The starting point for this is always that Refelt will not process more personal data than necessary for the purposes described above.

Exchange with third parties

We do not disclose personal data to third parties that will use those for purposes of their own, unless:

  • you have given your advance consent for the disclosure; or
  • we are statutorily obliged to disclose data.

Automated decision-making and profiling

Refelt makes use of profiling. Refelt’s interest in the use of these technologies is to personalise and coordinate information for clients: for example, purchase and sales price lists are sent on the basis of a client’s occupational group. Fundamentally, automated decision-making makes use of the following underlying logic: on the basis of the data you share with us, such as data from the contact form, we create a profile with products and information that may be of interest to you.

Retention period

Your data is retained in conformity with the statutory retention periods. On the basis of our obligation to keep records, we must retain certain data for a minimum of seven years. After those seven years, we retain only data that requires further processing. Personal data that you provide to us if you apply for a job with us is retained for at most four weeks after the application procedure has been completed. If you give us your consent, we may retain the details of your application for a period up to a maximum of one year.

Personal data security

Refelt will take appropriate technical and organisational measures, or have them taken by a third party, in order to secure personal data against loss or against any form of unlawful processing. A number of measures have been taken in that context, such as encryption of data, encrypted communication and treating the data as confidential.

Your rights

Pursuant to the law, you have a number of rights. We will set them out below.

  • Right of access: you have the right to inspect the personal data processed by Refelt;
  • Right to rectification and erasure: the right to have data altered or even removed if the data is not, or is no longer, correct, or if its processing is not, or is no longer, legitimate;
  • Right to object: this means that, on account of your specific situation, you may object to certain personal data processing operations. The right to object to the use of data for direct marketing purposes is absolute. If you unsubscribe from our commercial communications, this is honoured in any event. In cases not involving your consent and direct marketing, Refelt will make a weighing of interests;
  • Right to restriction of processing: to the extent that you dispute the correctness of the data, under certain circumstances you are entitled to restrict the processing of your data. Put briefly, this means that Refelt will temporarily “freeze” the processing of your data;
  • Right to data portability: the right to transfer data concerning you that is stored in our company in a commonly used and machine-readable format, or to ask that they be transferred to another person responsible;
  • Withdrawal of consent: you have this right to the extent that we process your data on the basis of your consent. You have the right to withdraw your consent at all times. We will then immediately cease the processing.

You are always free to submit a complaint to the supervisory authority. The supervisory authority of the privacy legislation is the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). You will find the contact details of the Dutch Data Protection Authority on the website www.autoriteitpersoonsgegevens.nl.

Questions

You are naturally free to ask questions about the personal data we process. For questions about privacy, please contact us using the contact details stated below.

Alterations

This privacy statement may be altered. The alterations will be made known on Refelt’s website.

Refelt may process your data for new purposes that are not yet mentioned in this privacy statement. In that case we will always contact you before using your data for these new purposes in order to inform you of the alterations to our rules for the protection of personal data and to offer you a chance to refuse to participate.

Contact details

If you have any questions about this privacy statement or our privacy policy, or if you wish to rely on one of your legal rights, you can contact us via the details below:

Leemansweg 45
6827 BX Arnhem
info@refelt.nl
026 206 21 02

Oktober 2019