Privacy Policy HNK

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Personal data refers to information relating to an identified or identifiable natural person. We process personal data that you provide to us or that we obtain from other sources.

A.    Personal data

1.      Basic and contact information, such as your first and last name, address, place of residence, job title, date of birth, nationality, email address, postal address, and telephone number.

2.      Setting up an (membership) account: when you create an account, we collect the data necessary to set up and secure your account, such as your email address and encrypted login credentials.

3.      Copies and/or details of identification documents, if requested by HNK: provided that the submitting party has rendered the BSN (citizen service number) and photo unrecognizable and added a watermark. BSN and other ID details are not recorded in our systems.

4.      Aggregated data: in an ongoing effort to better understand and serve our members, we conduct research based on aggregated data, such as user demographics, interests and user behaviour on the HNK-website. This aggregated information does not identify you personally. The aggregated information can be shared with our affiliates, agents and business partners. When aggregated data is based on personal data collected through our website, we only process that personal data with your consent via your cookie preferences.

5.      Any other personal data that you provide to us or that we can obtain in relation to the purposes stated below.

B.    Purpose and legal ground

·         To conclude and execute an agreement;
We need certain personal details for conducting business with you. For example, when concluding and subsequently executing a membership agreement, a lease agreement or a supplier agreement. We also need personal details following job applications and for entering into an employment agreement.  
Legal basis: Performance of a contract

• To comply with legal obligations:
  Laws such as the Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft) require us to perform client acceptance checks, identify unusual transactions, and determine the Ultimate Beneficial Owner (UBO) of a company.
  Legal basis: Compliance with legal obligation

• To provide quality service:
  If you lease space at HNK or have a membership agreement, your contact details are required to provide operational information, such as maintenance updates or for customer satisfaction surveys. In addition, we may require certain personal details for handling questions and complaints. This includes customer services support, enabling us to issue notices or corrective action in relation to a membership and to help us improve the content and functionality of our website, products and services.
  Legal basis: Performance of a contract
  Legal basis: Legitimate interest, in maintaining and improving the quality and overall customer experience of our services.

·         For information and marketing purposes:
HNK may use your personal data, including contact details provided by you, to inform you about HNK, (new) products and services of HNK (newsletters, press releases, etc.) and about affiliates, agents and business partners of HNK and their (new) products and services and to inform you about seminars and/or meetings HNK is organizing.
Legal basis: Your permission
·         For security and preventative purposes
Video/CCTV footage is captured by security cameras inside or around our properties. The footage is recorded, stored and processed by external service providers acting as data processors, on our behalf.
Legal basis: Legitimate interest. Footage used to prevent and investigate incidents, such as accidents, theft, or vandalism.

C.   Data retention period

We handle your personal data with care and store it only as long as necessary for its intended purpose or following rules and regulations. Specific laws, such as Dutch tax legislation or the Wwft, may require us to retain certain data for up to 5-7 years. Personal data collected during job applications is kept for four weeks after the conclusion of the application process unless explicit consent is given for a longer retention period. If the application process results in employment, personal data is retained for up to two years. CCTV footage is processed and stored by external service providers. The footage is generally retained for a maximum of 28 days. However, the exact retention period may vary depending on the service provider and the type of incident. Footage is retained only as long as necessary to achieve the purposes of security, prevention, or investigation of incidents, and is deleted thereafter.

D.  Sharing personal data

HNK does not share personal data for promotional or commercial purposes. However, it may be necessary to share personal data with:

• Service providers and suppliers, such as IT providers or maintenance providers, as part of operational requirements.

• Business Transfers, as HNK continues to develop, we may sell or acquire businesses or business assets. In such transactions, personal data may be transferred as part of the assets involved.

• Government authorities, when required by law.

·         Related Companies: HNK may also share your personal data with our affiliates for purposes consistent with this Privacy Policy.

Third parties to whom we provide your personal data are themselves responsible for complying with privacy legislation. HNK ensures that any disclosure of personal data to such third parties is lawful. Where a third party processes personal data solely on behalf of and under the instructions of HNK, that party acts as a processor.

E.    Data protection

HNK has implemented technical and organizational measures to safeguard your personal data against unauthorized or unlawful processing, as well as against loss, damage, alteration, or disclosure. Measures include:

• Purpose- and role-based access restrictions for server-stored data.

• Data encryption in certain processes.

• Secure (SSL or TLS) connections for communications.

• Firewalls and VPNs

• Confidentiality agreements

If you have questions about data security or suspect misuse, please contact us at complianceofficer@nsi.nl.

F.   Your rights

Under the GDPR, you have several rights, including:

• Access: you have the right to access your personal data.

• Rectification: you have the right to ask us to change your personal data if they are inaccurate or incomplete.

• Deletion: under certain circumstances, you have the right to have your personal data deleted. We reserve the right, in some cases, to retain personal data to comply with legal obligations or to protect our legitimate interests.

• Restriction: under certain circumstances, you can ask us to restrict the processing of your personal data.

• Objection: you have the right to object to the processing of your personal data if this processing is based on a legitimate interest.

• Portability: you have the right to receive your personal data in a structured, machine-readable format in order to re-use the personal data and to transfer it to another organization.

• Withdraw: you have the right to withdraw your consent at any time This does not affect the lawfulness of processing carried out before the withdrawal.

• Complain: you have the right to file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) via www.autoriteitpersoonsgegevens.nl.

A request can be submitted by sending an e-mail to our Compliance Officer at complianceofficer@nsi.nl.

G.    Miscellaneous

We reserve the right to update this Privacy Policy periodically. The latest version can be viewed at www.hnk.nl/privacy.

H.    Contact

The data controller responsible for the processing of your personal data is:

HNK Services B.V.
Hoogoorddreef 62
1101BE Amsterdam
The Netherlands
+31(0) 800 — 8098