Prior Projects considers the protection of personal data essential. We therefore process your data with the utmost care.
With this privacy statement we inform you about how we handle personal data.
1. Who is responsible for the processing of your data?
In this privacy statement, Prior Projects (hereinafter “Prior” or “we”) describes how it handles your personal data as controller.
2. What is personal data?
Information about an identified or identifiable natural person is considered as personal data. Whether certain information should be qualified as personal data depends in part on whether Prior has legal means that can reasonably be assumed to be used to identify a data subject.
3. Personal data that we process
We process personal data about you because you provide us data when entering into an agreement with us, but also when you use our services and provide us data, or enable us to record information about your interests and preferences.
Information provided to us
If you enter into an agreement with Prior, we will need the following personal information from you:
– name (business) and address;
– contact details (telephone numbers, e-mail addresses);
– customer number(s);
– financial data (bank account information, offers, invoices);
– other data relevant to the agreement concerned.
Information about your use of our services and / or products
If you make use of Prior’s services or otherwise contact us, we process – as part of our service – depending on the exact use you make of it – the following data that can be seen as personal data:
customer satisfaction data.
4. No processing of personal data
We do not intend to collect data from website visitors.
5. Processing: foundations and legitimate interests
The processing of personal data takes place on the basis of the following principles from Article 6 of the General Data Protection Regulation:
2) Implementation of an agreement with you;
3) Legal obligation;
4) Fulfilling a task of general interest;
5) Justified interest of Prior or a third party.
Justifiable interests include: marketing, advertising, security, (crime) prevention, IT management, research and analysis into own products or services, business management, legal affairs, internal management.
6. Purposes for the processing of personal data
Prior processes your personal data for the purposes mentioned below. The figure behind each goal corresponds to the basis mentioned in article 5 of this privacy statement.
– Building and maintaining the customer relationship including maintaining a direct relationship between the responsible and related financial service providers, including for commercial purposes [basis: 2, 5].
– Handling assignments (including invoicing), processing in financial administrations and logistic handling [basis: 2, 5].
– Providing customer service including service around services and products and dealing with complaints and requests (basis: 2, 3, 4 or 5).
– In certain cases maintaining communication in order to proactively contact customers (basis: 2 or 5).
– Conducting market research to improve our operations, brands, services and products [basis: 5].
– Approach you with offers or other commercial information. You always have the option to unsubscribe by making an objection. All communication indicates how you can do this [base: 1 or 5].
– Improving the content of our communication by adjusting it to your personal preferences [basis: 5].
– The (further) development and improvement of new and existing products and services [basis: 5].
– Measuring customer satisfaction, providing management information and determining the overall business strategy [base: 1 or 5].
– Compliance with legal obligations, settlement of disputes and enforcement of our rights and agreements [basis: 3, 4 or 5].
– Improving data quality using address validation techniques [base: 5].
– Linking and analysing cookies from our websites to known customer data. We do this in order to adjust the content of our communication as much as possible to your personal preference [base: 1 or 5].
7. Share with third parties
Prior will share your personal data with third parties in the following cases and with accompanying reasons. The figure behind each goal corresponds to the basis mentioned in article 5 of this privacy statement:
– if we are legally obliged or authorized to provide personal data to third parties [base: 3];
– if we suspect a violation of the rights of third parties, of criminal offenses or of abuse, we may provide personal data to third parties with a legitimate interest or to bodies that serve the general interest. These may also be enforcement authorities, such as the Public Prosecution Service or supervisors [base: 3, 4 or 5];
– with parties that assist Prior in its services and are not processors (e.g. accountants, insurers and (legal) advisors) [basis: 5];
– for business economic purposes (such as the sale of business activities or shares or a reorganization) [basis: 5].
Prior also uses services from third parties that act as “processors”. These service providers will only process personal data in accordance with the instructions and under the control of Prior.
8. How long do we retain data?
We retain personal data as long as (i) you are a customer of Prior or continue to show interest in the services of Prior, (ii) we are legally obliged to retain data, or (iii) we are justified in being able to retain data, for as necessary.
9. Register website visit
10. Your rights, including the right to object
You have the right to know what personal data we have recorded about you and to whom we have provided your personal data. You can contact us for this. Prior will endeavour to respond within the legal deadline. Excessive requests can be left out of treatment.
In addition to the right of access, you have the following rights with respect to our processing of your personal data:
– the right to withdraw your consent, insofar as our processing of your personal data is based on it;
– the right to lodge a complaint with the Dutch Data Protection Authority;
– the right to rectify / correct your personal data;
– the right to delete your personal data;
– the right to limit your processing;
– the right to data portability;
– the absolute right to object to direct marketing;
– the right to object to processing that takes place due to the legitimate interests of Prior or a third party (depending on your personal circumstances).
You can only exercise your rights insofar as the law grants you these rights. To make sure that the request for access has been made by yourself, we ask you to send a copy of your proof of identity with this request. We also ask you to make the passport photo, MRZ (machine readable zone, the strip with numbers at the bottom of the passport), passport number and citizen service number (BSN) unrecognizable on this copy.
11. Security and protection of data
Prior applies appropriate security measures to minimize misuse, loss, unauthorized access, unwanted disclosure and unauthorized modification. Prior has taken both technical and organizational measures to protect your personal data. These security measures are periodically reviewed based on threats.
For questions and / or comments regarding this privacy statement, please contact:
4338 PL Middelburg
Tel. +31 (0) 118 674 074
The way we process personal data, and the composition or quantity of data that we process, may change. That is why we reserve the right to change this privacy statement. You will be informed of a change if necessary. This privacy statement always indicates the latest date of change.
This statement was last revised on the 28th of August 2018.