Privacy Policy

1. Introduction

Welcome to the privacy policy of Custom Connect B.V. (hereinafter: “CCI”, “we” or “us”). CCI is specialised in the performance of professional customer contact: both front office (call, mail, chat) and back office activities. CCI is located at Balkweg 4B in ‘s-Hertogenbosch, the Netherlands. More detailed contact information can be found at the end of this privacy policy.

We will start our privacy policy with an explanation of the applicability of this policy and our role in the data processing activities.

CCI as controller

This privacy policy applies to the use of personal data by CCI as a data controller. In these situations, CCI operates its own database and for its own purposes. This is the case, for example, when collecting and processing personal data for contacting our customers about our services and/or contacting our applicants about our vacancies. In addition, personal data may be obtained when you visit our website or when you complete the contact forms on our website. In these cases, CCI determines the purposes and means for which we process your personal data. This also mean that we are your point of contact. We refer to our contact details as provided at the end of this privacy policy (contact details).

CCI as processor

This privacy policy does not apply to the services where CCI acts exclusively as data processor within the meaning of Article 4 of the General Data Protection Regulation (“GDPR”). This is the case when performing customer contact on behalf of our customers. In these situations, the customer is the data controller and CCI processes personal data exclusively on behalf of the customer. CCI also uses subprocessors in the context of its services. CCI, the subprocessor and the customer always conclude a data processing agreement together. In this way, CCI takes appropriate measures regarding the security and confidentiality of your personal data concerned. If you have any questions about your personal data in this context, CCI will refer you to the relevant customer for whom CCI processes your personal data.

CCI encourages you to read this privacy policy. If you have questions about our privacy policy, please contact our Security & Compliance Officer whose contact details are provided at the end of this policy.

2. Our data processing activities

If you are a visitor to our website, an (employee of our) business customer, relation, supplier or subcontractors, if you receive our newsletter or apply for a job with us, CCI determines the purposes and means of the processing of your personal data. In this situation, CCI is the data controller.

CCI cares about your privacy. Therefore, we only process personal data that we need for (the improvement of) our services and we handle the information that we have collected about you with care. In the following, we explain per processing activity for which purposes we use your personal data, which personal data we process, what the legal basis is and how long your personal data are retained.

Website visitors

If you use our website, we (and third parties engaged by us) may process your data. This may also include personal data. For example, if you have questions or comments about our products or services, you can contact us directly via our website(s). To do so, you can simply fill in the contact form.  In that case, we need some personal data to process your request. You are therefore requested to provide the following information:

• first and last name;
• (business) e-mail address;
• (business) telephone number;
• job-related information, such as company name, job title and department;
• other personal data that you provide to us in your request.

In addition, we use cookies, in which case we may process personal data about your visiting behaviour on our website. For more information on our use of cookies, we refer to our cookie policy. Our website may also collect anonymous data in order to improve our services. These data (e.g. your internet browser and operating system) are generally not personal data.

The legal basis for processing your personal data is your consent or our legitimate interest. Your personal data is needed to process your requests and to optimise, improve and secure the functioning of our website, as long as your interests do not prevail.

If you send us a message or contact us in any other way, we will retain your contact details for as long as is necessary to fulfil your request. After that we will delete your data immediately. If we process your personal data on the basis of your consent, you can withdraw your consent at any time. You can make your request by letting us know at the contact details described at the end of this privacy policy.

Business customers, relations, suppliers and subcontractors

If you are an (employee of our) business customer, relation, supplier or subcontractor, we (and third parties engaged by us) may process your personal data. For example, your personal data is needed to call or e-mail you about our services and the invoicing. In these cases, we may process the following information:

• first and last name;
• (business) e-mail address;
• (business) telephone number;
• (business) address details;
• (business) financial information;
• job-related information, such as company name, job title and department;
• other personal data that you provide to us in relation to our services.

The legal basis for the processing of your personal data is the performance of an agreement or to enter into an agreement. The processing of your personal data is necessary in order for us to perform the agreement. In addition, the processing of your personal data may also be necessary comply with a legal obligation, such as keeping records for tax purposes.

Your personal data will not be kept longer than necessary to realise the purposes for which your personal data are collected. In general, your personal data will be kept for seven years in order to comply with our legal obligation. Your personal data can, however, be kept for a longer period of time if this is necessary in the context of, for example, (the preparation of) legal proceedings or disputes.

Newsletter

If you have subscribed to our newsletter, we may process your personal data. Through our newsletter, we will keep you informed about (improvements in) the products and services of CCI and developments within our organisation. We need to process your personal data so we can send you the newsletter. We also record the time when you signed up for the newsletter. If you want to subscribe to our newsletter, we will process the following information:

• first and last name;
• (business) e-mail address;
• your preferences.

If you are our customer, we have a legitimate interest in communicating about our (potential) similar products and services. If you have subscribed to our newsletter, we may also process your personal data on the basis of your consent.

At the bottom of each newsletter, you will find a button that allows you to easily unsubscribe. As soon as you unsubscribe from our newsletter, your personal data will be removed from our database. From that moment on, you will no longer receive our newsletters and your personal data will be deleted. Your personal data will be kept until you have unsubscribed, however, CCI reserves the right to remove non-functioning, invalid and fraudulent email addresses from our database without consent.

Job applicants

When you apply for a job with us, we ask you to provide us personal data. We may need these personal data to evaluate your application and to contact you. The personal data that is requested from you is:

• first and last name;
• e-mail address;
• telephone number;
• address details;
• motivation letter and CV;
• date from which you are available;
• other personal data that you provide to us in relation to your application.

The legal basis for processing your personal data is our legitimate interest. Your personal data is needed to process your job application, as long as your interests do not prevail. In all other situations, we will ask for you consent.

If you have applied for a job at us, your personal data will be deleted after you have requested to do so, or at least four weeks after the application procedure has ended, unless you have given us consent to retain your personal data for one year after the application procedure has ended. Please note that you can withdraw your consent at any time by sending an e-mail to our contact details as provided at the end of this privacy policy (contact details). 

Others

In addition to the situations described above, CCI may also have a legitimate interest in processing your personal data in order to develop and improve its services and to protect and maintain its software systems, or to comply with legal obligations. In any case, your personal data will not be kept longer than necessary to fulfil the purposes for which your personal data are collected.

If you have any questions about our data processing activities, please contact us using the contact details at the end of this privacy policy (contact details).

3. Thirds parties and international data transfers

In the case where CCI is a data controller, we will only share your personal data with third parties if there is a legal or contractual obligation to do so. In all other cases, we will first require your consent. CCI will never sell, rent or otherwise make your personal data available to third parties without your consent, unless we are legally obliged to do so.

In the case where CCI is a data controller or processor, your personal data may be transferred to and processed by (sub)processors located within or outside the European Economic Area (“EEA”). In some countries outside the EEA [please, check here] personal data is sufficiently protected in accordance with European data protection laws and regulations. However, (sub)processors may also be located in countries where there is insufficient data protection. In that case, CCI will (either together with the customer or not) take all necessary measures to ensure that transfers outside the EEA are adequately protected. For example, by using the most recent standard contractual clauses as established by the European Commission. These standard contractual clauses shall be concluded with the relevant (sub)processor. You can request a copy of these standard contractual clauses at any time by contacting us. If you have any further questions on the international transfer of data, if you wish to get in touch with our (sub)processors or if you wish to invoke the standard contractual clauses as a third party beneficiary, please contact us using the contact details as provided at the end of this policy (contact details).

All guarantees stated in this privacy policy also apply to our (sub) processors and third parties. All third parties are bound to secrecy and data protection on the basis of a (data processing) agreement concluded between them and us, an oath or a legal obligation.

4. Website third parties

This privacy policy does not apply to third party websites that are linked to our website. We cannot guarantee that these third parties will handle your personal data in a reliable or safe manner. We recommend that you read the privacy policy of the website concerned before using that website.

5. Your rights

Under applicable Dutch and European legislation, you have certain rights regarding the personal data processed by us or on our behalf. We explain these rights and how you can invoke them below.

Right to information and access your personal data

In this privacy policy, we explain which of your personal data is processed and for what purposes the personal data is used. However, you can always ask for an extra explanation and you have the right to access the personal data we process (or have processed) from you.

Right to request rectification

You may request the rectification of the personal data we process (or have processed) from you.

Right to erasure

In certain cases, you may have your personal data erased, without unreasonable delay. If your request is granted, we will delete all personal data we have collected about you. However, we must observe certain legal retention periods that may prevent the immediate deletion of these personal data.

Right to restriction of processing

In certain cases, you may restrict the personal data we process (or have processed) from you. For example, in the event of an objection to our data processing, see below.

Right to data portability

In certain cases, you may have the right to transmit your personal data to another party.

Right to object and other rights

Finally, you may at any time withdraw your consent to our data processing and, in certain cases, object to the processing of your personal data by or on behalf of CCI. If you object, we will immediately cease the data processing and await the outcome of your objection. If your objection is well-founded, we will provide you with copies and/or reproductions of your personal data and then permanently cease processing them.

In addition, do not make decisions on the basis of solely automated processing about matters that could have (significant) consequences for those involved. These are decisions made by computer programs or systems, without the involvement of a person (for example an employee of CCI).

If CCI is the data controller involved, you will receive all copies and reproductions of your personal data in a commonly used electronic format or in writing. We will respond to your request(s) as soon as possible, but within no more than four weeks.

We attach great importance to the protection of your personal data; you can always submit the above-mentioned requests to us at any time and we will be happy to find a solution together with you. If, however, you suspect that we are using your personal data in an incorrect manner, you also have the right to lodge a complaint to the Dutch Data Protection Authority or any other competent data protection authority in the European Union.

For the purposes of our trading division in South Africa the provisions of POPIA will apply. You can exercise your right to complain by lodging a compliant with the Information Regulator (South Africa) by directing your compliant via the following communication channels:

If CCI is only the data processor and our customer is the controller, you can contact our customer to exercise these rights. We will also forward any request from you and provide our assistance.

6. Protection of personal data

We take the protection of your personal data very seriously and we therefore take appropriate measures to prevent misuse, loss, unauthorised access, unwanted disclosure and unauthorised modification.

To protect your personal data, we use security software such as a virus scanner and firewall, passwords for electronic systems, a secure internet connection, back-ups, and similar measures. If you have, however, the impression that your personal data is not properly secured or there are indications of misuse, please contact our Security & Compliance Officer: securityofficer@customconnect.nl.

7. Amendments to the privacy policy

CCI reserves the right to make changes to its privacy policy. Please check this page regularly for the most recent privacy policy from CCI. If the new statement affects the way in which we already process your data, we will inform you by e-mail.

8. Clickstream data

Anonymous information from visitors to our website may be collected.

We ensure that the information collected cannot be used to identify you. This information is sometimes known as “clickstream data” or “traffic data”.

The information which may be collected includes:

• Your IP address;
• The search terms you have used;
• The pages accessed on the website and the links you’ve clicked on;
• The date and time you visited the website;
• The referring website (if any) through which you clicked through to our website; and
• The type of website browser you use.

The traffic data is aggregated and not personally identifiable.

Our website analysis will also respect any ‘do not track’ setting you might have on your web browser.

9. CCTV monitoring

Our facilities and premises are monitored by CCTV cameras for crime prevention, quality control and general public safety and this may result in personal data being stored.

10. Data breach response

We have appointed an incident response team within to manage any data breach(es).

If your personal data is compromised because of a cyber-attack or some form of data incident, we will notify you of this as soon as is reasonably possible.

 11. Contact details

Custom Connect B.V.

Balkweg 4B

5232 BV ’s-Hertogenbosch, the Netherlands

Security & Compliance Officer: securityofficer@customconnect.nl and compliance@capabilitybpo.com