Privacy Statement Clever Strategy .V.

December 20, 2021

We attach great importance to ensuring that our services are transparent, personal, and reliable. In that context, we believe it is important that you know exactly what personal data we collect and how it is used and shared.

This privacy statement applies to all personal data that we process in the context of our services and/or your job application. This may include data that we receive directly from you, for example when you visit our website, subscribe to our newsletter, or apply for a job.

With this privacy statement, Clever Strategy .V. informs all parties involved about how we process personal data. This privacy statement may change from time to time if new developments give cause to do so.

What is personal data?

The General Data Protection Regulation (GDPR) states that personal data is any data relating to an identified or identifiable natural person. This means that information either relates directly to someone or can be traced back to that person.

About us

Clever Strategy .V. (Clever Strategy), located at Rivium Promenade 100, 2909 LM in Capelle aan den IJssel, is responsible within the meaning of the GDPR for the data we receive from you.

For what purposes do we process personal data?

We only process your personal data for carefully defined purposes. We receive personal data directly from you, for example because you visit our website or are the contact person for your employer (our customer!).

1. For handling questions/comments/complaints via the contact form
   You can call us, email us, or send us messages via the website. To ensure that we can help you immediately, we use your details, such as your name, company, and email address. This is necessary for the conclusion or performance of a contract (Article 6(1)(b) GDPR) and/or our legitimate interest (Article 6(1)(f) GDPR).

2. Performing our assignments/services
   When performing our assignments, we sometimes need (personal) data. For example, your name, position, and contact details such as your telephone number and email address. In some cases, we also process your date of birth in order to send you a nice gift on your birthday. The legal basis for this is the performance of the agreement, Article 6(1)(b) of the GDPR, and legitimate interest, Article 6(1)(f) of the GDPR.

3. For your registration for webinars and other events that we organize
   When you register for a webinar or other event (e.g., via www.clevercampus.nl), we process your name and email address. We may also process your job title and employer. This is necessary for the conclusion or performance of a contract (Article 6(1)(b) of the GDPR) and/or our legitimate interests (Article 6(1)(f) of the GDPR).

4. For marketing purposes and newsletters
   You can sign up for our newsletter via our website. In addition to our newsletter, you will only receive marketing messages from us if you i. have given us permission to do so, ii. have requested this, or iii. your employer is our customer and you are known to us as a contact person and have not indicated that you do not wish to receive marketing messages.

   Would you prefer not to receive any more newsletters or emails? You can unsubscribe at any time by clicking on "unsubscribe" at the bottom of the email. The legal basis for this is our legitimate interest (Article 6(1)(f) of the GDPR).

   We also process a limited amount of data without you noticing it directly. For example, when you read our digital newsletters. We collect this data using email pixels. With the help of email pixels, we know if and when an email has been opened and which links in the email have been used. This allows us to make our newsletters more relevant to you.

   Our email package does not give us the option to enable or disable this at the individual level. If you do not want us to use an email pixel when sending our digital newsletter, you can unsubscribe from our newsletter. The legal basis is our legitimate interest (Article 6(1)(f) of the GDPR).

5. For performing analyses and developing our website, products, and services
   We also process data that you provide to us indirectly. Our website uses cookies for functional, analytical, and marketing purposes. The functional cookies are necessary for the use of the website.
   This concerns the following data:

• • Location details
  • IP address or app IDs
  • Web browser and device type
  • Website language: The data from the analytical and marketing cookies is not linked to other data. Please refer to our cookie statement for more information about cookies. The legal basis is consent, which you give by agreeing to our cookie terms in the cookie banner on the website (Article 6(1)(a) of the GDPR).

6. For a responsible, effective, and efficient recruitment and selection process when you apply for a job with us.
   For this purpose, we process your contact details (such as your name, address, email address, and telephone number), the personal data from your resume, and your cover letter.

   We will forward your resume and cover letter to the hiring manager and to Lincks Personal Recruitment, with whom we collaborate on application procedures. They will retain access to your data until the application procedure ends for you. The end of the application procedure in this case is either a rejection based on the letter or interview, or the offer of an employment contract. In the latter case, the employment phase will commence.

   This personal data is stored for up to four weeks after the closing date of the vacancy. This allows us to respond to any questions you may have about the outcome of your application during this period. If the application leads to an appointment, the personal data will be stored in accordance with our retention policy. The legal basis isStrategy 's legitimate interestStrategy the efficient execution of the recruitment and selection procedure (Article 6(1)(f) of the GDPR).|

7. Saving your resume for suitable job openings in the future.
   It may be that we do not currently have a suitable vacancy for you and you have sent us an open application, or that we have unfortunately chosen someone else for a vacancy. If you give us written permission to retain your data for longer, we will keep your data (including your resume, cover letter, and contact details) in our system so that we can contact you in the future if we think we have a vacancy that may be of interest to you or if we organize (external) recruitment events.
   In this case, we will ask you to give your consent by email to the longer storage of your data. The written consent will then form part of your application file. Once you have given your consent, we will store your data for a maximum of 12 months.

   The legal basis for this is your consent (Article 6(1)(a) of the GDPR). You always have the right to withdraw your consent. You can do this easily by sending an email to info@cleverstrategy.nl. In that case, we will remove your data from our systems as soon as possible and no longer use it for this purpose.

Your rights

You have the right to be well informed about what we do with your data and why we need your data. We do this by means of this privacy statement. In addition to the right to be informed transparently, you have the following rights:

• Right of access (if you want to know what data we collect about you);
• Right to rectification (we are happy to amend any data that is no longer correct);
• Right to be forgotten (in some cases, you can ask us to delete your data);
• Right to restriction of processing (in some cases, you may ask us to restrict the processing of your data);
• Right to data portability (if you wish, we can transfer your data to another party or provide you with a copy of your data);
• Right to object (in some cases, you may object to the use of your data).

If you wish to exercise any of your rights, please contact us by emailing info@cleverstrategy.nl. We will always respond to your request within one month. Prior to processing your request, we may ask for additional information to verify your identity.

If we need your consent

If we process your data on the basis of consent, you always have the right to withdraw your consent. You can do this easily by sending an email to info@cleverstrategy.nl. If we have no other basis for the data we process on the basis of consent, we will no longer use this data and will delete it.

Who do we share data with and where do we store it?

In some cases, we may share your information with third parties. For example, processors who help us process your personal data. However, we will never sell your information to other parties.

Processors who assist us in processing your personal data may only use your data on our behalf and for the purpose of performing the relevant services they provide to us. They may not use or disclose your data independently.

Data collected via cookies may be shared with the parties that place these cookies. Read more about this in our cookie statement below. In some cases, we may be legally obliged to disclose your data, for example to government agencies. In all cases, we only share strictly necessary data.

We work with various applications to obtain and store certain data. To guarantee your privacy, we carefully select our suppliers and these applications are subject to strict rules. Most data is stored within the European Union.

For data processed outside the EU, we only work with parties that offer sufficient protection in accordance with European rules. If we process your data outside the EU (possibly via our external service providers), we will ensure adequate protection of your personal data. For example, by using special contracts to guarantee this (e.g., EU model contract clauses).

How long do we retain your data?

We store your data for as long as necessary for the purpose for which we use your data and/or for as long as we are required by law to store the data. How long that is exactly varies. From a few months to many years, for example because it is necessary for our accounting.

We will retain your data for as long as your account remains active, unless you request us to delete your data or account via info@cleverstrategy.nl. You can always view and/or change some of your personal data in your own account.

How do we protect your data?

Pursuant to Article 32 of the GDPR, we are obliged to take appropriate technical and organizational measures to prevent the loss and/or unlawful processing of personal data.

Safety

We pay a lot of attention to ensuring that personal data is properly secured. For example, the (personal) data you enter on the website when sending is encrypted and the (personal) data is sent via a secure connection.

Confidentiality

All our employees and external service providers have signed a confidentiality agreement. We handle the information you entrust to us with care. That is why only certain employees have access to your data.

We maintain a high level of security for your data. Among other things, the data is stored on a secure server. This server is only accessible to persons who have given their express permission to do so. The building where the server is located is also well secured.

Contact and complaints

If you have any questions about this privacy statement or wish to exercise your rights as a data subject, please contact us at info@cleverstrategy.nl.

If you have any complaints about, for example, the way we use your data or how we respond to privacy-related questions, you can submit a complaint to the Dutch Data Protection Authority.