• We only process your personal data in accordance with the purpose for which you provided it. These goals and the type of personal data are described in this privacy statement.
• We only process the personal data that is necessary for the purposes for which it is provided.
• We ask for your permission to use your personal data, for example through your agreement with us.
• We take appropriate technical and organisational measures to ensure the security of your personal data.
• We only transfer personal data to other parties if this is necessary for the purposes for which they were provided.
• We are aware of your rights with regard to your personal data and will respect them.

1. General

1.1 About the data we process

We have drawn up a record of any processing that has taken place according to legal obligations. This is available on request for individuals whose data we process.

We do not make decisions in a fully automated manner and do not engage in profiling. We also do not use your data for direct marketing.

We do not process the personal data of minors (persons younger than 16 years).

1.2 Security

We have taken appropriate technical and organisational measures to protect your personal data against unlawful processing and against loss, deletion, damage, alterations or publication, for example we have taken the following measures:

• All persons who have access to your data on our behalf are obliged to observe confidentiality.
• We use a username and password policy on our systems.
• We use authorisations for access to systems.
• We make back-ups of the personal data in order to be able to recover these in case of any physical or technical incidents.
• Our employees have been informed about the importance of the protection of personal data.
• If we provide other parties with your data, we will ask them to treat your data with due care by means of agreements.

1.3 Your rights

We store the data that we receive from you in our computer systems. You have the right to submit a request for:

• An inspection of the personal data that we process from you and the transfer of your data in a currently used computer format.
• Rectification of your personal data if you find that there are factual inaccuracies in your data. You can adjust some data yourself if you are able to log in to our system, such as your CV information or your address details.
• Deletion of your data or a restriction of the processing; we cannot always comply with this request because, for example, we may have a legal obligation to process your data or not to delete it.

You can make use of these rights by submitting a request to us via info@pum.nl. If you make such a request to us, we will need to be able to confirm your identity. We will answer your request within four weeks. It is possible that we cannot comply with your request because it, for example, damages the rights of others or is not legally permitted. In that case, we will let you know.

1.4 Questions/comments

If you have any questions or comments about this privacy policy, the way we protect your data or in case you have an indication of misuse, please contact us via e-mail: info@pum.nl. If you think that we do not comply with certain rules, you can report this to the Dutch Data Protection Authority.

1.5 Changes to these regulations

We may change these regulations from time to time. For example, if there are new data processing regulations and these are of interest to you. We keep our clients, volunteers and employees informed of any changes. Furthermore, the latest version can always be found on our website: https://www.pum.nl/en/privacy-statement.

2. Personal data processing details

The information that we ask from you depends on your relationship with us.

We will receive information from you if you register with us as an expert, representative or client, if you enter into a partnership with us or conclude an agreement with us, or if you use our website. Sometimes we receive data through someone else. For example, we receive information from our clients about our experts and from our representatives about our clients. We may also obtain your personal data from other sources, the Trade Register, the Land Registry or by using public sources.

We process the data that is collected. By that we mean that we store, use, transmit and delete it.

2.1 Personal data

Personal data comprise any information relating to an identified or identifiable natural person. We may process, among other things, the following personal data:

• Basic information such as your first and last name, middle name, title
• Contact details such as your email address, postal address and telephone number
• Information regarding the device you use to visit our website, such as an IP address
• Data regarding your visit to our website
• Personal data that you provide to us in the context of attending events or meetings, such as requirements and wishes regarding accessibility and diet
• Personal data that you provide to us for an application, as employee, volunteer or representative, such as your first and last name, date of birth, address, telephone number, nationality, marital status, photo and all other personal data stated in your application, including data on your education, expertise and experience.
• All other personal data relating to you that you provide to us or that we may obtain in connection with the purposes and on the basis of the principles stated below.

2.2 Purposes and bases for processing

We may use your personal data for the following purposes:

• To provide our services to our clients
• To comply with legal obligations
• To implement an employment or volunteer contract or other agreement between you and PUM
• For marketing and business development activities, such as newsletters, invitations to our events and other marketing communications that may be of interest to you
• To process your application or registration for one of our events
• To generate statistics regarding the use of the website and/or to analyze and improve the website.

We process your personal data on the basis of one or more of the following legal bases:

• The execution of an agreement
• Compliance with a legal obligation
• Legitimate interest
• Your consent. If you refuse to provide certain information, this may affect your agreement with us.

2.3 Retention period

PUM does not store your personal data for longer than is necessary to achieve the purposes stated in this Privacy Statement or to comply with laws and regulations.

2.4 Sharing with others

For the purposes described in this Privacy Statement, we may share your personal data with third parties, including, but not limited to:

• Third parties, such as (potential) clients, regulators and other authorities, to comply with legal obligations or to execute an agreement
• External suppliers in connection with the processing of your personal data for the purposes described in this Privacy Statement, such as payroll administrators, accountants, ICT suppliers, suppliers of communication services or other suppliers to whom we outsource certain support services.

Your personal data will only be transferred to the above third parties for the purposes stated in this Privacy Statement and exclusively on the basis of the principles stated in this Privacy Statement.

Third parties to whom we provide your personal data are responsible for compliance with privacy legislation. PUM is not responsible, nor liable for the processing of your personal data by these third parties. To the extent that a third party processes your personal data in the capacity of a data processor of PUM, PUM will enter into a data processing agreement with such a third party that meets the requirements described in the GDPR.

In order to provide our services, we may need to transfer your personal data to a recipient in a country outside the European Economic Area. In that case, we will ensure that such transfer of data is in accordance with applicable laws and regulations.

2.5 Cookies

We collect cookies, see our cookie policy at https://www.pum.nl/en/cookie-policy.

We communicate with you via social media channels such as Facebook, Instagram and LinkedIn. We also use Google Analytics to view which articles are popular on our website and which are not.

Updated and approved May 2024