Full policy

Owner and Data Controller

Brobs
Laan van meerdervoort 766
2564AP The Hague
www.brobs.eu

Owner contact email: info@brobs.eu

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies, Usage Data and email address.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics, Interaction with external social networks and platforms, Managing contacts and sending messages and Handling payments.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

• Analytics

  The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

  Google Analytics (Google Inc.)

  Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
  Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

  Google Analytics with anonymized IP (Google Inc.)

  Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
  Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
  This integration of Google Analytics anonymizes your IP address. It works by shortening Users’ IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

• Handling payments

  Payment processing services enable this Application to process payments by credit card, bank transfer or other means. To ensure greater security, this Application shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
  Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

  PayPal (PayPal Inc.)

  PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: See the PayPal privacy policy – Privacy Policy.

• Interaction with external social networks and platforms

  This type of service allows interaction with social networks or other external platforms directly from the pages of this Application.
  The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network.
  This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

  Google+ +1 button and social widgets (Google Inc.)

  The Google+ +1 button and social widgets are services allowing interaction with the Google+ social network provided by Google Inc.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

• Managing contacts and sending messages

  This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
  These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

  MailChimp (The Rocket Science Group, LLC.)

  MailChimp is an email address management and message sending service provided by The Rocket Science Group, LLC.

  Personal Data collected: email address.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

Further information about Personal Data

• Mollie

  As a financial institution Mollie processes a large amount of data from our customers, who are using the services provided by Mollie, and our customers’ customers (consumers). Both the customer and the consumer are invaluable to Mollie. Therefore it is extremely important to Mollie to ensure careful and secure processing of the customer’s and the consumer’s data, in particular personal data.

  1. Personal data processed by Mollie

  Mollie processes your personal data because you use Mollie’s services and/or because you provide this information to Mollie yourself. An overview of the personal data processed by Mollie, depending on the service you use, is shown here below.

  If you use Mollie’s services as a customer the following personal data are processed:

  Your first and last name;
  Your date of birth;
  Your place of birth;
  Your nationality;
  Your address details;
  Your telephone number;
  Your email address;
  Your IP address;
  Your internet browser and device type;
  Other personal data that you actively provide, for example by creating a profile on this website, in correspondence and by telephone.
  If you use Mollie’s services as a consumer the following personal data are processed:

  Your payment details (e.g. bank account number or credit card number);
  Your IP address;
  Your internet browser and device type;
  In some cases, your first and last name;
  In some cases, your address details;
  In some cases, information about the product or service that you have purchased from our customer;
  Other personal data that you actively provide, for example in correspondence and by telephone.
  If you use Mollie’s websites, the following personal data are processed;

  Your location data;
  Your details about your activities on the websites;
  Your IP address;
  Your internet browser and device type;
  2. Does Mollie process special and/or sensitive personal data?

  Unlike the processing of payments, Mollie’s websites and services are not aimed at activities that require special and/or sensitive personal data to be processed. Mollie therefore requests that you do not provide this information. Furthermore, Mollie has no intentions at all of collecting information about website visitors who are minors, even if they have permission from their parents or guardians. Unfortunately, Mollie cannot check whether a visitor is a minor and therefore Mollie advises parents or guardians to be involved in their children’s online activities in order to prevent minors’ data from being processed by Mollie.

  Should you, in spite of the above, be convinced that Mollie unlawfully processed special or sensitive data, Mollie requests you to contact us at info@mollie.com or +31 20 820 20 70. Mollie will then delete this information as soon as possible.

  3. Why are your personal data processed?

  Mollie only processes data insofar as this is necessary for its services. Your personal data will therefore only be processed for the following purposes.

  If you use Mollie’s services, your personal data are processed:

  To assess your application;
  To draft and perform the agreement;
  To process payments;
  To send information about your product or service and changes to it;
  To ensure the safety and integrity of the financial sector, for example by identifying, investigating, preventing and actively countering (attempted) criminal/illegal conduct;
  To perform analyses for statistical and scientific purposes;
  To train and assess Mollie employees;
  To record evidence;
  In order to establish that Mollie actually does have contact with you as a customer or one of your (duly authorized) representatives, for example by telephone or in written correspondence;
  In order to comply with legal obligations as a financial institution, for example under the Dutch Financial Supervision Act (Wft) and the Dutch Money Laundering and Terrorist Financing (Prevention) Act (Wwft).
  If you use Mollie’s websites, your personal data are processed:

  To create a personal environment (dashboard) on Mollie’s websites;
  To provide access to your personal environment;
  To analyze your behavior on Mollie’s websites in order to improve the websites and to tailor the range of products and services to your preferences;
  To analyze your browsing behavior on Mollie’s websites based on which Mollie tailors products and services to your needs;
  To perform analyses for statistical and scientific purposes;
  To ensure the safety and integrity of the financial sector, for example by identifying, investigating, preventing and actively countering (attempted) criminal/illegal conduct;
  In order to comply with legal obligations as a financial institution, for example under the Dutch Financial Supervision Act (Wft) and the Dutch Money Laundering and Terrorist Financing (Prevention) Act (Wwft).
  If Mollie wants to process your personal data for other purposes than described above, for example for commercial purposes, Mollie will only do this after your explicit permission has been requested and obtained. You can withdraw this permission at any time without providing a motivation.

  4. How long does Mollie keep your personal data?

  Mollie will not keep your personal data longer than the mandatory statutory period or, if such a mandatory statutory period does not apply, no longer than is strictly necessary for the realization of the objectives for which your personal data were obtained. The personal data that Mollie receives relating to the assessment of your application, the preparation and performance of the agreement and the processing of payments, will not be kept longer than five years after rejection of your application or the termination of the agreement.

  5. Does Mollie share your personal data with third parties?

  Mollie will share your personal data with third parties if this is necessary for the performance of the agreement or if it’s based on legal obligations. Mollie concludes a processors’ agreement with third parties, which process your personal data for Mollie. This means that Mollie ensures that your personal data are always protected to at least the same level of security and that the confidentiality of your personal data is guaranteed. Mollie nevertheless remains fully responsible for these processing operations and will therefore take all reasonable administrative, technical and physical measures to protect your personal data against unauthorized access, unintentional loss or alteration.

  Your personal data may also be shared with third parties which are not necessarily part of Mollie’s services. In that case, Mollie will only do so after requesting and obtaining your explicit consent.

  6. How does Mollie analyze your website visit?

  Mollie uses functional, analytical and tracking cookies. A cookie is a small text file that is stored in the browser of your device such as a computer, tablet or smartphone when you first visit Mollie’s websites. On the one hand, Mollie uses cookies with a purely technical functionality. These cookies ensure that the website works properly and, for example, remembers your preferred settings, so that Mollie is able to optimize the websites. On the other hand, Mollie uses cookies that keep track of your browsing behavior so that Mollie can offer you tailor-made content and advertisements.

  Opt out of cookies
  You can opt out of cookies by setting your internet browser such that it does not store cookies anymore. In addition, you can delete all information previously saved via the settings of your browser.

  Cookies are also placed on Mollie’s websites by third parties, for example advertisers and/or social media companies. More information about Mollie’s use of cookies can be found here: Cookies.

  7. Your rights

  You have the right to view, correct, limit or delete the personal data that Mollie processes, unless Mollie cannot grant these rights based on a legal obligation. You can send your request for access, correction, limitation or deletion to info@mollie.com. However, to establish the legitimacy of your request Mollie does asks you to send a copy of your identification (i.e. a passport or identity card) along with the request. Please make sure that in this copy your passport photo, MRZ (machine readable zone, the strip with numbers at the bottom of the passport), passport number and citizen service number (BSN) have been redacted to protect your privacy. Mollie will then respond to your request as soon as possible, but in any case within fourteen business days.

  Complaints
  If you believe that Mollie has used your personal data unlawfully or if you are not satisfied with Mollie’s response to your request, you have the right to report this to the Dutch Data Protection Authority or to take it to court. More information about this can be found on https://autoriteitpersoonsgegevens.nl/en.

  8. Security of your personal data

  The protection of your personal data is very important to Mollie. Mollie therefore takes all appropriate technical and organizational measures to prevent misuse, loss, unauthorized access, unwanted disclosure and unauthorized modification.

  To report possible problems with the security of Mollie’s systems, a Responsible Disclosure Policy has been made available.

  9. Mollie’s responsibilities

  Mollie acts as the controller as referred to in the General Data Protection Regulation, (EU) 2016/679. Mollie acts in this position because as a financial institution Mollie:

  determines which personal data must be processed for the correct execution of a payment;
  determines for which other purposes the personal data may be processed as long as these purposes are in accordance with the purpose for which the personal data were obtained by Mollie;
  has to comply with its own legal obligations, for example under the Dutch Financial Supervision Act (Wft), the Dutch Money Laundering and Terrorist Financing (Prevention) Act and the Dutch Civil Code;
  has drawn up its own general terms and conditions that are directly applicable to the customer and the consumer.
  The data processing has been reported by Mollie to the Dutch Data Protection Authority under number 1449126.

  10. Data Protection Officer

  Mollie has appointed a Data Protection Officer (DPO). Among other things, the DPO is responsible for supervising the processing of personal data by Mollie, taking stock of data processing and advising on technology and security.

  If, in spite of the above, you suspect that your data is not properly secured, has been misused or if you believe that Mollie does not adequately guarantee the correct processing of personal data, please send an e-mail to: compliance@mollie.com for the attention of Mr. M. Polder.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Application and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.