Privacy Statement TSM

This is the privacy statement of The Square Mile Public Sector Training B.V., Chamber of Commerce (KvK) number 50384708, and The Square Mile Private Sector Training B.V., Chamber of Commerce (KvK) number 50384872, hereafter referred to as “TSM.” In this statement, we explain what personal data we collect and use and for what purposes. Should any discrepancies arise between the English and Dutch version of this statement, the Dutch version takes precedence at all times.

Our contact information is provided at the end of this privacy statement.

Whose Personal Data Do We Process?

TSM collects personal data in the context of its services from:

• Customers: our clients and their representatives
• Course participants
• Individuals interested in TSM or its services (potential course participants, job applicants, new trainers)
• Website visitors
• Trainers we employ for providing training
• Our employees

General Basis for Processing

We process data of the aforementioned individuals based on the following legal grounds:

• If you use our services: to perform a contract we have with you or (if the contract is concluded with your employer) based on your employer’s legitimate interest, or with your consent.
• If you ask a question (via our website) or apply for a job: based on your consent.
• If you subscribe to our newsletter: based on your consent.
• For relationship management and other processing activities (such as monitoring behavior on our website): because it is necessary for our legitimate interests, namely monitoring and improving our services, maintaining website security and accessibility, and maintaining contact with our relationships.

Necessity of Processing

If you use our services, providing personal data is a contractual obligation to enable the execution of the agreement. In other cases, providing personal data is a necessary condition to answer your question, send a newsletter, or pursue the mentioned legitimate interests. If you do not provide the data, we may not be able to serve you properly or at all.

Processed Data and Purpose

Below, we summarize the data we generally process for the aforementioned individuals and for what purposes:

• Customers: name, address, phone number, email address, and other data provided by the customer. This data is processed for maintaining contact with the customer, entering into and executing agreements or orders, collecting debts, evaluating and improving our services, and other internal management activities.
• Course participants: name, address, phone number, email address, and other data provided by the participant. This data is processed for maintaining contact with the participant, executing the agreement, evaluating and improving our services, and other internal management activities.
• Interested parties: name, address, phone number, email address, and other data provided by the interested party. This data is processed for answering the interested party’s questions, providing information, conducting relationship management, and other purposes, depending on the reason for the interest shown.
• Website visitors: IP address, any cookies placed by us, and data about the device used to access the website. This data is processed to analyse website visits, maintain website security and accessibility, enable the use of our online services, improve the website, and provide targeted advertisements or banners. We also use Online Success software to offer website visitors a better and personalized experience. This software creates a profile when you interact with our website (such as downloading a whitepaper or clicking through from an email received from us to an article on our website). Online Success automatically enriches this profile with publicly available information and social profiles (such as LinkedIn, Twitter, etc.). This is done through a cookie called ‘logger,’ which is only placed when you accept it. The content of this cookie is linked to your Online Success profile when you interact with TSM’s website. This way, your activities are visible, and TSM can offer you a better and personalized experience on its website. Your Online Success profile is unique to TSM, available only to you and TSM, and is never shared with third parties. You can access, modify, and/or delete your Online Success profile at any time, and you can also activate ‘do not track’ so that the Online Success software does not record your visits.
• Trainers: Name, Address, Place of residence, Date of birth, Email address, bank account. This data is processed for entering into and executing the agreement with the trainer, paying fees, executing the agreement with the customer, etc.
• Employees: Name, Address, Place of residence, Date of birth, Email address, Copy of passport, Citizen service number (BSN). This data is processed for entering into and executing the employment contract, salary payments, tax and premium remittance, etc.

We will not use personal data for other purposes unless you have given prior consent or we are legally allowed or required to do so.

Sources of Personal Data

We collect data in the following ways:

• Data provided by you to us
• Data obtained through your use of our services or the visit to this website

Retention Periods

TSM will not retain your personal data longer than strictly necessary to achieve the purposes for which your data is collected. Personal data is kept as long as necessary to provide our service to you and as long as legally required. If you are subscribed to our newsletter, the data is retained for a maximum of 2 years after the last activity. Participant data is anonymized 4 years after the last contact.

Newsletter

If you have given consent, we may contact you by email and send our newsletter. Each communication via this method includes an unsubscribe option.

Disclosure to Third Parties

We do not disclose personal data to other parties (third parties) unless:

• It is necessary for executing the agreement
• It is necessary to comply with a legal obligation
• It is necessary to report criminal offenses

With companies that process your data on our behalf, we conclude a data processing agreement to ensure the same level of security and confidentiality of your data. If data is transferred to parties outside Europe, we ensure an appropriate level of protection.

Security

We take appropriate measures to prevent misuse, loss, unauthorized access, unauthorized disclosure, and unauthorized alteration of your data. If you believe your data is not properly secured or if there are indications of misuse, please contact us (contact details are at the bottom of this privacy statement).

Rights

You have the following rights:

• Right to information: you can ask TSM if your personal data is being processed and have the right to information about these processes. This information is summarized in this privacy statement.
• Right of access: you can access the data collected about you by TSM. Upon request, TSM provides a copy of the processed personal data, provided there are no data of others in it.
• Right to rectification: If it becomes clear that the data is incorrect, you can request TSM to correct it.
• Right to be forgotten: In various cases, you have the right to have personal data deleted, for example, if the data is no longer needed for the purposes for which it was collected and there is no legal obligation or other basis for further processing, or if data has been processed based on the consent of the data subject and this consent is withdrawn, and there is no other legal basis for processing.
• Right to restrict data processing (temporarily), for example, to verify the accuracy of the data or for an extended period, for example, if data should not be deleted yet or if it is still needed for the establishment, exercise, or defence of a legal claim.
• Right to data portability: if data is processed based on consent or to perform a contract with you, you can request TSM to provide the data you have provided in a structured and machine-readable format or transfer it to another party.
• Right to object: you have the right to object to the processing of your personal data. TSM will cease processing unless there are legitimate or legal grounds for processing. When you object to processing for direct marketing purposes, personal data will no longer be processed for these purposes.
• Right to object to individual decision-making, including profiling: you have the right not to be subject to a decision based solely on automated processing (including profiling) if that decision has no “legal effects” and has no other significant consequences. This does not apply to TSM.

To exercise these rights, you can submit a request to us; contact details are at the end of this privacy statement. To ensure that the request for access is made by you, we ask you to include a copy of your ID with the request. In this copy, we ask you to black out your photo and Citizen Service Number (BSN) to protect your privacy.

TSM will respond to your request as soon as possible but within one month. If you have other questions about your privacy and our privacy policy, you can also contact us.

Contact Information

You can reach us via:

Mailing address: PO Box 1002, 2302 BA Leiden

Phone number: 071-5323356

Website: www.thesquaremile.nl/en/

Email address: info@thesquaremile.nl

Data Protection Authority

Of course, we are happy to assist you further if you have complaints about the processing of your personal data. You also have the right to lodge a complaint with the Data Protection Authority regarding these data processing activities. You can contact the Data Protection Authority for this purpose.

Changes to this Privacy Statement

We reserve the right to make changes to this statement. Changes will be published on this website. It is recommended to check this statement regularly to stay informed about these changes.

This privacy statement was last updated on January 17, 2020.