Privacy

1.    Which Personal Data do we collect, and why?

When you interact with HNK, either directly and/or through our website, HNK may collect Personal Data and other information from you, as further described below:

Personal Data that you provide: we collect basic details when you provide such information, like your name, address, and residence and further contact details like your email address, postal address, and telephone number;

Setting up an (Membership) account via de website: when setting up an account via de website, we will collect your Personal Data from you such as your username and password;

Copy of your identity document, if requested by HNK: HNK will collect a copy and/or data of the identity document of the legal representative and/or ultimate beneficial owner of the Member, provided that the CSN and picture are made unrecognisable. Insofar saving of the copy is required, the copy is saved in a secure manner.

Aggregated Personal Data: in an ongoing effort to better understand and serve the Members, we conduct research on user demographics, interests and behavior based on the Personal Data and other information provided to HNK. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with our affiliates, agents and business partners. This aggregate information does not identify you personally. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

2.    Purpose and statutory ground

a.       In order to conclude a Membership;

HNK requires Personal Data in order to conclude a Membership with you in person or with your company. For example, we need to conduct an investigation before we can accept you as a Member (Customer Due Diligence). Or to determine whether you may represent your company. We may also request a copy of your identity document or copy its details when we enter into a legal relationship with you / with your company.

b.       Carrying out our obligations and providing services;

We require Personal Data to enable HNK to carry out its obligations arising from any contracts and to provide you with the information and services that you request from HNK, including obligations towards the users assigned as such by you. We also secure our buildings, including by installing security cameras.

c.       Receiving newsletters, attending seminars or meetings, etc.:

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, to inform you about seminars and/or meetings HNK is organising, for customer satisfaction research and/or for other forms of communication;

d.       Customer support, improvement of products and services

We may use Personal Data to enable us to respond to an enquiry or other request you make when you contact us via our Website, including for customer services support, to enable us to issue a notice or corrective action to you in relation to the Membership, if required and to help us improve the content and functionality of our website and products and services.

e.       Statutory obligations;

We are bound to statutory obligations. Insofar applicable, and based on the Dutch Act on Prevention of Money Laundering and Financing of Terrorism (“Wwft”), for example, for certain forms of services we must first conduct specific checks as part of the customer acceptance process and/or initiate an investigation in case of unusual transactions. Based on the governance rules and regulations applicable to HNK, HNK also conducts specific checks and/or initiates an investigation as part of the customer acceptance process. In this context, we must also identify the ultimate beneficial owner of a company. For this purpose, we can engage third parties who share data about you with us. We may also be required to share data about you with a government body, such as a supervisory authority in or outside of the Netherlands.

In all of the above cases, HNK processes your Personal Data based on one or more of the following legal grounds:

·         The execution of a contract;

·         Compliance with a statutory obligation;

·         Legitimate interest;

·         Your permission.

3.    How long will we retain your data?

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

 To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

 4.    With whom do we share personal data?

HNK is not in the business of selling your Personal Data. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

 .         Business Transfers: Business Transfers: as the business of HNK is developing further, HNK might sell or buy businesses or assets (including properties used pursuant to the Membership). In such an event, Personal Data may be part of the transferred assets.

g.       Related Companies: HNK may also share your Personal Data with our affiliates for purposes consistent with this Privacy Policy.

h.       Agents, Consultants and Related Third Parties: HNK, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include IT suppliers, the operator of our website and accompanying (software) products and services, mailing information, maintaining databases and processing payments. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function.

i.         Legal Requirements: HNK may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or properties (assets) of HNK, (iii) act in urgent circumstances to protect the personal safety people using the properties of HNK or the public, or (iv) protect against legal liability.

Insofar as a third party is provided with your Personal Data in the capacity of a processor for HNK, HNK will conclude a processor agreement with this third party which meets the requirements set out in the GDPR.

5.    How do we secure your personal data?

HNK has taken steps to ensure that your Personal Data receives an adequate level of protection where it is processed and your rights continue to be protected from loss, misuse, and unauthorised access, disclosure, alteration, or destruction. However, HNK cannot guarantee the absolute security and/or error free processing of Personal Data. Therefore, you should take special care in deciding what information you provide to HNK (especially on a voluntary basis).

6.    Cookies

A cookie is a small text file that is saved on your hard drive by our webpage server. You can accept or reject the use of cookies by changing the settings of your browser. Further information and request for consent, if applicable, is requested by using the website of HNK.

7.    Your rights / Compliance Officer

You may have the right to request

a.       access the to your Personal Data we hold about you;

b.       request we correct any inaccurate Personal Data we hold about you;

c.       request we delete any Personal Data we hold about you;

d.       restrict the processing of Personal Data we hold about you;

e.       object to the processing of Personal Data we hold about you; and/or (

f.        receive any Personal Data we hold about you in a structured and commonly used machine-readable format or have such Personal Data transmitted to another company.

We may ask you for additional information to confirm your identity and for security purposes, before disclosing information requested to you. We will process any request in line with laws and our policies and procedures.

You also have the right to submit a complaint to the Dutch Data Protection Authority. To do so, we refer you to www.autoriteitpersoonsgegevens.nl.

For questions and/or requests, you can contact our Compliance Officer at complianceofficer@nsi.nl

8.    The contents of the Privacy Statement can be amended at any time

We reserve the right to amend the contents of this Privacy Policy at any time. The latest version of this Privacy Policy can be found at www.HNK.nl.

9.    Contact

If you have questions about this Privacy Policy, the security of your Personal Data or if there are signs of abuse, please contact us at complianceofficer@nsi.nl.