| Release 2021 vs 1.0 |
1 Introduction
1.1 This External Privacy and Cookie Policy (“Policy”) is used by Henkovac International B.V. and its affiliates (hereinafter: “Turbovac”). Turbovac has its registered office in Den Bosch and its principal place of business in (5215 ML) Het Sterrenbeeld 36 ‘s-Hertogenbosch, registered in the Commercial Register of the Dutch Chamber of Commerce under registration number 16048454. Turbovac can be contacted via info@Turbovac.nl.
1.2 On the one hand, the Policy aims to explain why and how data that identifies or could identify natural persons (“Personal Data”) is processed by Turbovac. Unless indicated otherwise, Turbovac is the ‘controller’, as referred to in the General Data Protection Regulation (“GDPR”) for the processing of Personal Data as described in this Policy. On the other hand, the Policy was drawn up to inform you about the use of cookies on the website www.turbovac.nl (hereinafter: “Website”) as maintained by Turbovac.
2 Part I – Personal data
2.1 Turbovac may process your Personal Data in the following situations:
2.1.1 You are (employed by) a customer of Turbovac;
2.1.2 You are (employed by) a prospect of Turbovac;
2.1.3 You are (employed by) a distributor of Turbovac;
2.1.4 You are (employed by) a supplier of products or services to Turbovac;
2.1.5 You are an applicant of Turbovac;
2.2 The Personal Data that Turbovac processes (among others to create an Account) includes:
2.2.1 Your first name and family name;
2.2.2 Your gender;
2.2.3 Company name
2.2.4 Your (business) address details;
2.2.5 Your (business) e-mail address;
2.2.6 Your (business) telephone number;
2.2.7 Additional Personal Data, depending on the nature of your relationship with Turbovac.
2.3 In addition to this Personal Data, there may be other situations whereby you provide further Personal Data to us. This concerns the following categories of Personal Data:
2.3.1 The Personal Data that you provide to Turbovac in the course of doing business with Turbovac, including but not limited to Personal Data needed to perform under any agreement concluded with Turbovac.
2.3.2 The Personal Data that Turbovac obtains through your use of our Website, by contacting us or otherwise communicating with us, whether or not on behalf of a company.
3 Sources
3.1 In principle, Turbovac collects Personal Data from you.
This is not so in the following cases:
3.1.1 If Turbovacc receives your Personal Data from a customer, distributor or supplier which transfers this data to Turbovac. This enables Turbovac to fulfill its obligations pursuant to an agreement with the customer, distributor or supplier concerned;
3.1.2 If Turbovac receives Personal Data from another organization.
4 Legal grounds
4.1 Turbovac collects Personal Data based on the following legal grounds:
4.1.1 The processing is necessary for the execution of an agreement which you, your employer or customer is a party to, or to take measures at your request prior to entering into an agreement;
4.1.2 Based on Turbovac’ legitimate interest as a commercial organization to offer its products and recruit personnel, except if your interests or fundamental rights outweigh these interests;
4.1.3 If required, Turbovac will request your additional consent to process your Personal Data.
5 Purposes
5.1 Turbovac processes Personal Data for the following purposes:
5.1.1 To enable Turbovac to execute the agreement with you, your employer or customer. This includes but is not limited to supplying products.
5.1.2 To enable Turbovac to identify you, communicate with you and supply products to you on location.
5.1.3 To enable Turbovac to conduct direct marketing activities, including but not limited to informing you about our products, events, and options to assess the effectiveness of these activities;
5.2 The provision of the requested Personal Data under Article 4.1.1 is a necessary condition for entering into an agreement with Turbovac. By failing to provide this information, Turbovac may not be able to fulfill its obligations pursuant to any current or future agreements. The provision of the requested Personal Data under 4.1.2 and 4.1.3 is not a requirement, or a necessary condition for entering into an agreement with Turbovac. However, by failing to provide this data, Turbovac may not be able to meet its obligations.
6 Data retention
6.1 Turbovac never stores collected Personal Data longer than necessary for the purpose for which this Personal Data was originally obtained. Personal Data will never be stored longer than the periods indicated below, unless Turbovac is legally obligated to store this Personal Data for a longer period (for tax purposes, for example) and unless you have given your consent to store this Personal Data for a longer period.
6.2 The storage periods for the following categories of Personal Data are as follows:
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- Personal Data of (persons employed by) customers and suppliers: 5 years after the termination of the last agreement with Turbovac;
- Personal Data of (persons employed by) prospects: 5 years after the last contact with Turbovac;
- Personal Data of applicants: 4 weeks after the end of an application procedure, unless you have given us your permission to store this Personal Data for a longer period. In this case, we will store the Personal Data for a maximum of 1 year after the end of the application procedure;
- Personal Data provided by the contact form on our Website or otherwise voluntarily provided to Turbovac: 1 year after the last contact with you.
7 Receivers and transfer
7.1 Turbovac may transfer Personal Data to third parties, so-called ‘receivers’, if this is necessary for the implementation of the purposes referred to in this Policy. The (categories of) possible receivers of Personal Data include:
7.1.1 Our (ultimate) parent company and other companies affiliated with Turbovac;
7.1.2 Our business relations, customers, (Cloud) suppliers and contractors, for the performance of an agreement with Turbovac, or pursuant to our normal business activities with you, your customer or employer;
7.1.3 Our auditors, legal advisors, accountants and other advisors;
7.1.4 Regarding our Website: providers of tools to analyse the use of our Website subject to the conditions included in our cookie policy (see below);
7.1.5 Possible other receivers which you explicitly or implicitly consent to for the performance of services by Turbovac to you, or the company that you work for.
8 Potential receivers and transfers
8.1 In addition to receivers as referred to in Article 7, Turbovac may disclose or reveal Personal Data in the following cases:
8.1.1 If Turbovac is involved in the purchase or sale of a company, in which case Personal Data may be supplied to a prospective buyer, in which case the Personal Data will be provided in accordance with this Policy;
8.1.2 If Turbovac must provide Personal Data pursuant to a legal obligation, or to implement the Policy, the General Terms and Conditions of the agreement with you (or your employer or client), to safeguard the rights, ownership and freedoms of Turbovac or its customers, or others, then Turbovac shall take such action as required.
9 International transfer
9.1 In principle, Turbovac will not transfer Personal Data to countries or international organizations outside the European Economic Area (hereinafter: “EEA”).
9.2 If Turbovac does transfer Personal Data to a country or international company outside the EEA, then Turbovac shall ensure that appropriate safeguards are in place to protect the Personal Data.
10 Technical and organizational measures (security)
10.1 Turbovac attaches great value to protecting Personal Data and has taken appropriate measures and implemented the necessary safeguards. These measures meet the requirements under the GDPR, and include:
- Access security based on ‘need to know’.
- Clear internal rules regarding ICT use and performing random checks on compliance.
- Good backup and recovery procedure.
- Sufficient technical measures such as: firewalls, anti-virus & anti-malware software, secure internet connections, authorizations and passwords.
- Encrypt data and pseudonimize personal data.
- Internal protocol data leaks.
11 Rights
11.1 Depending on the situation and subject to certain conditions, the GDPR gives Data Subjects the following rights:
11.1.1 The right to request permission to inspect the Personal Data;
11.1.2 The right to request rectification of the Personal Data;
11.1.3 The right to request the removal of Personal Data;
11.1.4 The right to request limiting the processing of data;
11.1.5 The right to object against the processing;
11.1.6 The right to data portability;
11.1.7 If the processing is based on permission: the right to withdraw permission at any time without it affecting the legitimacy of the processing prior to the withdrawal;
11.1.8 The right to submit a complaint to a supervisory authority like the Dutch Data Protection Authority.
11.2 To exercise these rights, Turbovac may request specific additional information. This additional information is only processed for the purpose of exercising the aforementioned rights.
12 Questions
12.1 If you have questions about the processing of Personal Data by Turbovac and requests regarding your Personal Data (as referred to in Article 11), please contact Turbovac via the information mentioned in Article 1.1 of this Policy.
13 Part II – Cookie Policy
13.1 Cookies are small data files that are sent to your browser and stored on the device with which you are visiting different locations on the Internet. Turbovac uses these cookies to make sure that the Website can be used as intended by Turbovac.
13.2 When first using the Website, you will be requested to agree to the use of cookies which Turbovac uses via the Website. If you wish to withdraw your permission, please notify us and remove the placed cookies via your browser settings and cease using the Website.
14 Purpose
14.1 Turbovac uses cookies on the Website for the following purposes:
14.1.1 Ensuring an optimal functioning Website;
14.1.2 Developing and improving the Website;
14.1.3 Enabling contact with Turbovac via the Website;
14.1.4 Analyzing use of the Website, including analyzing what companies visit Turbovac’ website based on IP-addresses;
14.1.5 Creating statistics on the use of the Website;
15 Which cookies are used
15.1 Below follows a list of the cookies that are placed, what they do and how they work.
| Placed by | Cookie name | What does the cookie do | How long |
| Google, Inc | Google Analytics | Analytical Cookie. Monitoring and storing analytics of use of the Website. This cookie does not contain or process any Personal Data | 2 years |
15.2 Other cookies
Turbovacc may not always have a clear insight into the cookies placed by third parties via the Website. One example is the use of embedded elements on the Website. These are texts, images or videos that or not stored on Turbovac’ Website but are shown via the Website. If you encounter cookies on the Website that fall under this category and are not mentioned above, please let us know. Alternatively, you can directly contact the third party and ask which cookies they place, and their reasons for placing the cookie, what the storage term of the cookie is and how your privacy is safeguarded.
16 Browser settings
16.1 If you do not agree with cookies being stored on your device and/or computer, you can adjust your browser settings to receive a warning before the cookies are stored. You can change the browser settings to refuse all cookies, or only refuse the cookies of third parties. It is also possible to delete stored cookies. Please note: you must change the settings for each browser and every device that you use.
16.2 It is important to understand that if you refuse cookies, we can no longer guarantee that the Website will function optimally. This could cause the loss of various functions or result in part of the website no longer being visible. Refusing cookies does not mean you will no longer see advertisements, it means you will no longer see personalized advertisements.
16.3 More information on your browser’s settings is available via your browser’s help function.
17 Changes
17.1 This Policy must be adjusted every now and then following changes to rules regarding the Website or cookies. Turbovac reserves the right to change this Policy without notice. This page will always contain the most recent version of the cookie statement.
18 Questions
18.1 If you have any questions about the use of cookies by Turbovac, please contact Turbovac via the information shown in Article 1.1 of this Policy.