• For definitions we kindly refer you to the “whereas” section in our General Terms and Conditions.
  • This policy is an integral part of the User agreement / General Terms and Conditions as published on the main page of the Website.
  • FeeQuotes.com (hereinafter referred to as “FQ”) has created this privacy policy in order to demonstrate how we deal with “personal data” as defined in article 4 of the General Data Protection Regulation https://gdpr-info.eu/art-4-gdpr
  1. Scope

This procedure applies to all personal data that is created, received, stored and/or transmitted by FQ and is applicable for all FQ staff including temporary staff:

Data includes written, printed and recorded materials, as well as electronic records such as e-mails, word/excel documents, database files and other types of digital files.

  1. Personal data

By applying the GDPR definitions of personal data we identified that FQ processes the following personal data in the capacity of “Controller”:

  1. Employee Data

    2. Category 1 Employee Data:

    • Application forms;
    • Resumes;
    • References and Testimonials;
    • Correspondence applicant on employment;
    • Psychological research.

    Category 2 Employee Data (same as category 1 however with extension approval employee):

    • Application forms;
    • Resumes;
    • References and Testimonials;
    • Correspondence applicant on employment;
    • Psychological research.

    Category 3 personal data

    • Employment agreement including all amendments thereto;
    • Correspondence on appointments, promotion and demotion;
    • Correspondence on (involuntary)resignation;
    • Correspondence on early retirement (VUT);
    • Appointments on OR (works council);
    • Copy testimonial after resignation;
    • Appraisal documentation;
    • Reintegration Reports on illness Occupational Health and Safety Agency (ARBO);
    • Correspondence Employee Insurance Agency (UWV);
    • Reports on financial problems employee (salary seizures etc);
    • Reports on problem situations.

    Category 4 personal data

    • Payroll tax declarations;
    • Passport copies/ other legally permitted ID’s;
    • Data on ethicality and origin;
    • ID papers of employees/ consultants that were hired from third parties.

    Category 5 personal data

    • Marital status employee;
    • Name address and other payroll details;
    • Date of start of employment;
    • Income statements employee;
    • Distance declaration (afstandsverklaring) business-private traffic.
  2. ID copies of FQ users (upon registration new account)

    3. FQ may (as per the FQ Know Your Customer and Identity Verification Policy) conduct ID verification on either users that request for services (“Service Requestors”) or users that provide services (“Service Providers”). Should such verification take place we will store the copy ID and our analysis thereof.

  3. Personal Data as registered in User Profile

    4. Within the User profile, we request certain Personal Data for the proper functioning of the website (First Name - Last name - Email address - Phone number

  4. Personal data as included in uploaded documents/ memos

    5.  

  5. Contact persons at vendors (and third parties) including email addresses, phone numbers)

    6.  

  6. Information collected from visitors to FeeQuotes.com (via cookies)

 

  1. GDPR goals of processing personal data

Fair, lawful and transparent processing - Rec.39; Art.5(1)(a)

The requirement to process personal data fairly and lawfully is extensive. It includes, for example, an obligation to tell data subjects what their personal data will be used for.

The purpose limitation principle - Rec.50; Art.5(1)(b)

In summary, the purpose limitation principle states that personal data collected for one purpose should not be used for a new, incompatible, purpose.

Data minimisation - Rec.39; Art.5(1)(c)

The principle of data minimisation is essentially the idea that, subject to limited exceptions, an organisation should only process the personal data that it needs to process to achieve its processing purposes.

Accuracy - Rec.39; Art.5(1)(d)

There are obvious risks to data subjects if inaccurate data are processed. Therefore, controllers are responsible for taking all reasonable steps to ensure that personal data are accurate.

Data retention periods - Rec.39; Art.5(1)(e)

The idea that personal data should not be retained for longer than necessary in relation to the purposes for which they were collected, or for which they are further processed, is key to ensuring fair processing.

Data security - Rec.29, 71, 156; Art.5(1)(f), 24(1), 25(1)-(2), 28, 39, 32

Controllers are responsible for ensuring that personal data are kept secure, both against external threats (e.g., malicious hackers) and internal threats (e.g., poorly trained employees).

Accountability - Rec.85; Art.5(2)

The principle of accountability seeks to guarantee the enforcement of the Data Protection Principles.

  1. GDPR Definitions

In bold all defining terms as laid down in article 4 of the GDPR:

    1. ‘ personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
    2. ‘ processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
    3. ‘ restriction of processing’ means the marking of stored personal data with the aim of limiting their processing in the future;
    4. ‘ profiling’ means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;
    5. ‘ pseudonymization’ means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;
    6. ‘ filing system’ means any structured set of personal data which are accessible according to specific criteria, whether centralized, decentralized or dispersed on a functional or geographical basis;
    7. ‘ controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
    8. ‘ processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
    9. ‘ recipient’ means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of an inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall follow the applicable data protection rules according to the purposes of the processing;
    10. ‘ third party’ means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data;
    11. ‘ consent’ of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
    12. ‘ personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed;
    13. ‘ genetic data’ means personal data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that natural person and which result from an analysis of a biological sample from the natural person in question;
    14. ‘ biometric data’ means personal data resulting from specific technical processing relating to the physical, physiological or behavioral characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images or dactyloscopic data;
    15. ‘ data concerning health’ means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status;
    16. ‘ main establishment’ means:
      • as regards a controller with establishments in more than one Member State, the place of its central administration in the Union, unless the decisions on the purposes and means of the processing of personal data are taken in another establishment of the controller in the Union and the latter establishment has the power to have such decisions implemented, in which case the establishment having taken such decisions is to be the main establishment;
      • as regards a processor with establishments in more than one Member State, the place of its central administration in the Union, or, if the processor has no central administration in the Union, the establishment of the processor in the Union where the main processing activities in the context of the activities of an establishment of the processor take place to the extent that the processor is subject to specific obligations under this Regulation;
    17. ‘ representative’ means a natural or legal person established in the Union who, designated by the controller or processor in writing pursuant to Article 27, represents the controller or processor about their respective obligations under this Regulation;
    18. ‘ enterprise’ means a natural or legal person engaged in an economic activity, irrespective of its legal form, including partnerships or associations regularly engaged in an economic activity;
    19. ‘ group of undertakings’ means a controlling undertaking and its controlled undertakings;
    20. ‘ binding corporate rules’ means personal data protection policies which are adhered to by a controller or processor established on the territory of a Member State for transfers or a set of transfers of personal data to a controller or processor in one or more third countries within a group of undertakings, or group of enterprises engaged in a joint economic activity;
    21. ‘ supervisory authority’ means an independent public authority which is established by a Member State pursuant to Article 51. For FQ this is the Autoriteit Persoons Gegevens - https://autoriteitpersoonsgegevens.nl/en
      • ‘ supervisory authority concerned’ means a supervisory authority which is concerned by the processing of personal data because:
      • the controller or processor is established on the territory of the Member State of that supervisory authority;
      • data subjects residing in the Member State of that supervisory authority are substantially affected or likely to be substantially affected by the processing; or
      • a complaint has been lodged with that supervisory authority;
    22. ‘ cross-border processing’ means either:
      • processing of personal data which takes place in the context of the activities of establishments in more than one Member State of a controller or processor in the Union where the controller or processor is established in more than one Member State; or
      • processing of personal data which takes place in the context of the activities of a single establishment of a controller or processor in the Union, but which substantially affects or is likely to substantially affect data subjects in more than one Member State.
    23. ‘ relevant and reasoned objection’ means an objection to a draft decision as to whether there is an infringement of this Regulation, or whether envisaged action in relation to the controller or processor complies with this Regulation, which clearly demonstrates the significance of the risks posed by the draft decision about the fundamental rights and freedoms of data subjects and, where applicable, the free flow of personal data within the Union;
    24. ‘ information society service’ means a service as defined in point (b) of Article 1(1) of Directive (EU) 2015/1535 of the European Parliament and of the Council (¹);
    25. ‘ international organization’ means an organization and its subordinate bodies governed by public international law, or any other body which is set up by, or based on, an agreement between two or more countries.
  1. Types of Data and Retention terms
  1. Employee data (legally defined in the laws on income taxes (uitvoeringsregeling loonbelasting 2011) retention terms

    2. Category 1 (see article 2A)      4 weeks

    NB. When an applicant is not hired also any documentation pertaining to this application is to be destroyed with 4 weeks

    Category 2 (see article 2A)      1 year as from start employment

    Category 3 (see article 2A)      2 years as from start employment

    Category 4 (see article 2A)      5 years as from start employment

    Category 5 (see article 2A)      7 years as from start employment

  2. ID copies of FQ Service Requestors (upon registration new account)

    3. 3 years as from the moment they closed their account at FQ.

  3. Personal Data as registered in User Profile
    First Name Deleted or anonymised as from the moment the User account is either closed, deactivated or declined.
    Last name Deleted or anonymised as from the moment the User account is either closed, deactivated or declined.
    Email address Deleted or anonymised as from the moment the User account is either closed, deactivated or declined.
    Phone number Deleted or anonymised as from the moment the User account is either closed, deactivated or declined.
  4. Personal data as included in uploaded documents/ memos

    5. Each User has a possibility to delete uploaded documents containing Personal Data or other uploaded documents. For as long as the User will not delete these documents, we keep them for training and development purposes (for finetuning services on FeeQuotes.com website) and we share the memos to Service Providers that have purchased the right to issue a FeeQuote.

    If the account of a user is closed, deactivated or declined, respective User is no longer technically able to delete uploaded documents. In such case User can send an email to team@feequotes.com in which case FeeQuotes.com will delete all uploaded (by User) documents.

  5. Contact persons at vendors (and third parties) including email addresses, phone numbers) Vendors

    6. Active vendors

    This concerns contact persons at active vendors. We retain this “personal data” to be able to contact vendors with respect to the services FQ has retained from these vendors. We delete this information only when it is no longer likely we may use this vendor or in case respective vendor has indicated they no longer wish to work with FQ.

    Former vendors

    This relates to contact persons at vendors that we used to work with. Once we need such services (again) we can contact them with these contact details. We delete this information only when it is no longer likely we may use this vendor or in case respective vendor has indicated they no longer wish to work with FQ.

    Potential vendors (that shared contact details/ business card)

    Such vendors concern new contacts that have shared personal data with the purpose of doing business once the opportunity arises. We retain this “personal data” until we need their services. We delete this information only when it is no longer likely we may use this vendor or in case respective vendor has indicated they no longer wish to work with FQ.

    Potential vendors (that have not shared contact details)

    This relates to contact persons that we got via third parties, once we need such services, we can contact them with these contact details. We delete this information only when it is no longer likely we may use this vendor or in case respective vendor has indicated they no longer wish to work with FQ.

    Third party contact persons

    This relates to contact persons with any business partners outside of vendors or clients, f.e.

    Government officials, Tax authorities, Regulators.

    In case of such third-party contacts we retain “personal” data to be able to discuss operational matters and questions on matters which requires involvement of such business partners. Once such matters and questions are solved, we will keep the contact details to follow up on the matter once new information arises subject to which the matter or question needs to be revived.

  6. New Contact persons

    7. Once and to the extent FQ receives feedback from Users, vendors and third parties that the contact person (at an SR/ SP/ vendor/ third no longer represents respective business partner

    (via change in responsibility or by resignation) we will delete contact details and update our database with new contact details for this business partner.

  7. Information collected from visitors to FeeQuotes.com (via cookies)

    8. We use cookies on the website of FQ facilitate Users from using the website in the most efficient manner and to identify fields of interest of website visitors for the purpose of optimising the website and optimise marketing efforts. A User is free to delete cookies that were placed on its computer at any time without losing access to FeeQuotes.com.

    Upon request and to the extent the User has added applicable IP address(es) to its request, FeeQuotes will delete all User data that was collected from respective IP address(es) via cookies.

  1. Storage of Personal Data

Digital storage

Personal data is retained physically (ordners) and digitally. As for digital files FQ stores all its personal data at:

Trans-IP (data processor)

Which data is secured with a 256-bit AES key. Furthermore, the connection with Trans-IP runs (disregarding what client is used) via https so that data traffic is always secured. Trans-IP makes data available via WebDAV end uses server-side encryption of data. This means that the encryption key is in possession of Trans-IP and is stored separate from the storage serves. When data is opened it is decrypted on the fly on the servers where data is made available.

Antagonist (data processor)

We use hosting provider Antagonist for email. Your information may be transferred to and stored on servers in various locations both in and outside of the Netherlands. FQ maintains control of your information. We refer to https://www.antagonist.nl/downloads/informatiebeveiligingsbeleid on details how information stored at Antagonist is secured.

Tilaa.com (data processor)

This company hosts the website of FeeQuotes.com. Tillaa uses various methods to secure Personal Data trusted to them.

    • A secure internal network
    • Physical access control measures
    • Organizational measures for access control
    • Logical access control, using: strong passwords, personal access cards
    • Automatic logging of all operations concerning personal data
    • Random checks for compliance with its policies
    • Purpose-bound access controls
    • Secure Socket Layer (SSL) technology for securing network communication
    • Checks on granted authorizations

Tilaa does not warrant that the security is effective under all circumstances. If any security measure is missing, then FeeQuotes shall use best efforts to ensure a level of security appropriate to the risk considering changes to the industry standards.

Tilaa operates in accordance with

    • ISO 27001
    • NEN 7510, Information security in the health care industry
    • PCI Security Standards
    • ISAE 3402

These standards are considered to meet the demands on information security given current industry standards.

Back-Up Digital storage

Daily backups are made of data stored by FQ at TransIP and Tilaa.

  1. Rights of data subjects

Any user or FQ stakeholder wishing to excersize its rights under GDPR (as stipulated in article 15) is welcome to reach out to us (contact details in article 8):

article 15 of GDPR:

Data subjects have a right to obtain from FQ (with respect to any personal data which FQ processes as “Controller”) a confirmation that personal data concerning him or her is processed, and, where that is the case, has the right of access to this personal data and the following information:

    1. The purposes of the processing;
    2. the categories of personal data concerned;
    3. The recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
    4. Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
    5. The existence of the right to request from the FQ rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
    6. The right to lodge a complaint with a supervisory authority;
    7. where the personal data are not collected from the data subject, any available information as to their source;
    8. the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

Where personal data are transferred to a third country or to an international organization, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.

The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.

The right to obtain a copy referred to in the previous paragraph shall not adversely affect the rights and freedoms of others.

  1. FQ Personal Data Representative / Data Protection Officer
Personal Data Representative

With respect to any questions or requests relating to article 15 of GDPR team Users are invited to contact Team FeeQuotes which functions as representative (“Personal Data Representative”):

    • Team FeeQuotes
    • +31.20.235.1121
    • team@feequotes.com

The Personal Data Representative is available for all article 15 requests of data subjects and first point of contact with respect to any personal data queries of the Supervisory Authority with respect to complaints on the processing of such data.

The Personal Data Representative will also provide data subjects (upon request) with all permitted and required information as required in article 13 of the GDPR:

http://www.privacy-regulation.eu/en/article-13-information-to-be-provided-where-personal-data-are-collected-from-the-data-subject-GDPR.htm

    1. The identity and the contact details of the controller (FQ) and the Personal Data Representative;
    2. The contact details of the Data Protection Officer, if any;
    3. The purposes of processing for which the personal data are intended as well as the legal basis for the processing;
    4. Where the processing is based on point f. of Article 6 (1), the legitimate interests pursued by FQ or by a third party
    5. The recipients or categories of recipients of the personal data
    6. The fact that (if applicable) FQ intends to transfer personal data to a third country or international organisation and the existence or absence of an adequacy decision by the Commission ( https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en), or in the case of transfers referred to in Article 46 or 47, or the second subparagraph of Article 49, reference to the appropriate or suitable safeguards and the means by which to obtain a copy of them or where they have been made available.
      7. Data Protection Officer
    7. FQ is not required to have a Data Protection Officer appointed as it does not process personal data on a large scale and it does not process special personal data (religious beliefs, sexual orientation etc.). Reference is made to article 37 of GDPR http://www.privacy-regulation.eu/en/article-37-designation-of-the-data-protection-officer-GDPR.htm
  1. Disposal of data

Data disposal

All FQ Personal data must be destroyed or disposed of when no longer needed in accordance with the Privacy Policy or relevant laws and regulations (in case of a discrepancy between these 2, only relevant laws and regulations are prevailing.

Cessation destruction /disposal

If a lawsuit is filed or imminent or an investigation is underway then destruction of all data must cease immediately. The FQ Personal data representative may suspend this policy to require that data relating to such investigation, lawsuit or other potential legal issue(s) be retained and organized.

  1. Data breaches

As per article 33 of the GDPR, a personal data breach needs to be reported to the supervisory authority within 72 hours after becoming aware of it

The report as mentioned in this article needs to include:

    1. The nature of the personal data breach including where possible, the categories and approximate number of data subjects concerned, and the categories and approximate number of personal data records concerned;
    2. Details of the FQ Personal Data Representative (name and contact details) so the supervisory authority is aware of the contact point where more information can be obtained;
    3. The likely consequences of the personal data breach;
    4. The measures taken or proposed to be taken to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.

Where, and in so far as, it is not possible to provide the information at the same time, the information may be provided in phases without undue further delay.

FQ shall document any personal data breaches, comprising the facts relating to the personal data breach, its effects and the remedial action taken. That documentation shall enable the supervisory authority to verify compliance with Article 33 of GDPR.

In case of a data breach:

The Controller (by means of the Personal Data Representative) shall communicate the personal data breach to the data subject without undue delay when the personal data breach is likely to result in a high risk to the rights and freedoms of data subjects.

  1. Changes to our privacy policy

We may change this privacy policy from time to time. Any updated versions of this privacy policy will be posted on our website. Please review it regularly.

This privacy policy was last updated on 16 October 2019.