In this Privacy Statement we explain how Everybody Frank B.V. (FRANK) handles personal data.
- When do we make changes in this Privacy Statement?
FRANK can change this Privacy Statement. We always inform you beforehand about important changes.
- What are personal data?
Personal data are data that say something about a natural person. Consider for example a name, address or telephone number, but also personnel number or function. Appendix 1 lists the categories of personal data that may be processed by FRANK. In this Privacy Statement FRANK explains for which FRANK can process which personal data and on the basis of which.
- What is ‘processing of personal data’?
This includes everything that FRANK can do with personal data. For example, collecting, viewing, destroying or saving.
- How does FRANK deal with personal data?
Your privacy is important to FRANK. FRANK adheres to laws and regulations. For example, the European General Data Protection Regulation (AVG) and the Dutch AVG Implementing Act. FRANK handles personal data responsibly and carefully. FRANK does not sell personal data to third parties.
- Does this privacy statement also concern your personal data?
This Privacy Statement is about personal data of: users, former users, persons who are interested in our services and who are not yet users, employer of users or former users. Where this Privacy Statement refers to personal data of users, personal details of representatives of users or people connected to a company or institution that is our user are also included below.
- How do we protect personal data?
It is very important for FRANK that your and our information is safe. The FRANK employees are bound by strict rules. Our security measures comply with the relevant standards.
- How do we deal with data leaks?
With a data breach, personal data can end up somewhere where they do not belong. We report data breaches to your employer and your employer to the Dutch Data Protection Authority. We do not do this if there is no risk for you or your employer. FRANK also informs you and your employer. FRANK does this when it is necessary in view of the risks you could run. Risks include identity theft or fraud. FRANK then gives you and your employer information about what has happened and what that has or may have consequences. FRANK also tells you about the measures we have taken to limit any negative consequences.
- What can you ask FRANK about your personal data?
Below you can read what you can ask Frank about your personal details. The law determines whether FRANK can cooperate with your request. You must therefore take into account that FRANK can not always help you.
You can ask your question to your employer who then returns it to FRANK. FRANK answers the question from your employer as soon as possible. Your employer answers your question with that. There are no costs associated with the handling of a question, unless the answer constitutes an exceptional charge for FRANK. This would be the case, for example, if your employer repeats a question within a short time. FRANK will inform your employer in advance if we charge costs.
Improvement or addition of personal data
You can ask your employer to correct or supplement personal data if they are incorrect or incomplete. Your employer will in turn ask Frank for this.
Access to personal data
You can ask your employer to view your personal data and to receive a copy of it. You can also ask your employer for information about how we process your personal data (such as the purposes of these processing operations and the categories of personal data). Your employer will in turn ask FRANK for this.
Removal of personal data
You can ask your employer to have personal data deleted. This is possible, for example, if the personal data is no longer needed or if you have withdrawn your consent to the use of the personal data. Your employer will in turn ask Frank for this.
Object to the processing of personal data
You can object to certain processing of personal data at your employer. This is only possible if FRANK bases its processing on the legal basis of ‘legitimate interest’ (in the section ‘For which FRANK processed personal data?’ Is stated if this is the case), if direct marketing is involved or if the personal data are processed for statistics.
Limiting the processing of personal data
You can ask your employer to temporarily pause the processing of personal data. Your employer will in turn ask Frank for this. This can be done, for example, if FRANK looks at your request if personal details are incorrect or incomplete or if FRANK processes personal data without Frank’s permission. You can also ask this if you think you need the data for a legal procedure or if you have objected to the processing.
- What do we process personal data for?
FRANK processes personal data for various reasons. You can read more about this below.
Become an user
Before a person becomes an user of FRANK, his employer has purchased a right of use for the benefit of an employee for a specific period. The employer gives FRANK the e-mail details of the future users and FRANK creates an e-mail with an activation link. FRANK distributes these activation links to future users on behalf of your employer. The user downloads the app, activates the app by clicking on the link. Then they are asked to explicitly accept the conditions.
Being an user
FRANK also processes personal data of the user during the relationship with the user.
To be able to contact the user
During the relationship with the user, FRANK may have contact with the user. For example by e-mail, via the application (app) or by using a chat function on the app. We use personal identification data for that contact. FRANK may process this personal data to the extent necessary for the execution of the agreement with our users.
Implement the agreement
FRANK processes personal data to fulfill the contract with the employer. For example, FRANK needs personal data to send you an activation link, when carrying out analyzes and presentations or to advise the user.
For training and quality purposes
FRANK can record the content of email and chat traffic with users for training and quality purposes. Users are informed about this in advance. The content of the communication is recorded to train and guide our employees in the contact with users. FRANK may process personal data for this as it is our legitimate business interest to improve the quality of service. A user can object to the processing of personal data on personal grounds for personal reasons. You can read more about this in the ‘Right of objection’ section.
The relationship between the user / employer and FRANK is or will be terminated
If the relationship with the user / employer is or will be terminated, we will store collected personal data anonymous and irreversibly encrypted (article 29 working group). This can be done for benchmark activities, for internal analyzes or for the settlement of the agreement and the relationship. You can object to the processing of personal data on personal grounds for personal reasons. You can read more about this in the ‘Right of objection’ section.
For promotion and marketing
Our promotional and marketing activities consist of recruiting new main users (employers) and perpetuating the relationship with existing users.
Analysis and research
FRANK processes personal data for analyzes and investigations. These analyzes and investigations aim to develop and improve our products and services and to better serve our users.
For developing and improving products / services and for better user operation
FRANK strives to ensure that our products and services match the needs of users as well as possible. That is why we develop and improve our products and services regularly. In order to determine how FRANK can best do this, we analyze the use of products and services. Where possible, we do not use personal data but anonymised data. If this is not possible, we use personal information we have received from users, such as personal identification data, input data and data about products and services. We may process personal data for this purpose because it is in the interests of us and the user to improve our products and services and to better serve our user. Users can object to the processing of personal data on personal grounds for personal reasons. You can read more about this in the ‘Right of objection’ section.
We also conduct user research through surveys and interviews for this purpose. Personal data such as personal identification data and data about products and services are processed. This personal data is processed with the consent of the user. Permission can be easily withdrawn at any time. The withdrawal of permission has no retroactive effect; the data processing until the moment of withdrawal is lawful.
- Do we provide personal data to third parties?
FRANK does not provide your personal data to third parties.
Support for operational management
It is possible that FRANK engages third parties who support us in our business operations and therefore process personal data for us. These parties are called (sub) processors. FRANK also sometimes uses third parties for user research. With these third parties, FRANK makes arrangements to ensure that the personal data are adequately protected. FRANK selects this third party only after careful investigation. FRANK requires that your personal data are also safe with those third parties. FRANK may provide personal data to third parties to support our business operations because it is in our legitimate interest to optimize our business operations.
- For how long do we keep the personal data?
FRANK uses maximum time limits for the storage of personal data. These deadlines are included in the table in appendix 2. Personal data will be destroyed after the maximum storage periods have expired.
- Does FRANK also process special categories of personal data??
Frank does not process special categories of data.
In our cookie statement at www.everybodyfrank.com/en/cookies-bij-frank you can read how FRANK deals with your personal data that we process with cookies.
14. Do you have complaints or questions?
For general questions or complaints in connection with this Privacy Statement you can contact the Data Protection Officer of your employer via email. If you feel that your rights have been violated by FRANK, you can submit a complaint to the Dutch Data Protection Authority, www.autoriteitpersoonsgegevens.nl.
If you have any other questions, please contact FRANK helpdesk. You can reach us on working days from 8.30 am to 5.00 pm.
From the Netherlands: +31 20 8223793
15. Where do I find more information about the privacy?
More general information about privacy can be found on the website of the Dutch Data Protection Authority, www.autoriteitpersoonsgegevens.nl.
Appendix 1. Categories of personal data that may be processed
Below are the categories of personal data that we can process. The Privacy Statement explains what we can possibly process this personal data for and on the basis of which.
|Category personal data||Example|
|Personal identification data||Name, e-mail adress, phone number|
|Personal characteristics||Employer, Branche, Function, Office location, Team, Division, Reporting line, Age, gender, date of birth, nationality, profession, education, personal interests.|
|Elektronical identification data||IP-adress, cookies|
|Communication data||Contacts by e-mail, app, records of discussions about products and services, records of complaints and questions|
|Special personal data||Data referred to in Article 9 of the General Data Protection Regulation|
|Other personal data||e-mailadress and activation link|
Appendix 2. Retention periods
|Kind of data||Retention period|
|Personal data with respect to user||3 months after termination of contract|
|Anonymous and irreversible encrypted Personal Information (Article 27 Working Group)||> 10 years|
|Data for analyzes, presentations and advice||3 months after termination of contract|
|Answers to questions||3 months after termination of contract|
The abovementioned retention periods can only be extended if after the expiry of the stated retention period there is an ongoing complaint, procedure or (criminal or supervisory) investigation with regard to the (ex-) relationship. The same mentioned storage periods apply to personal data stored with third parties. In our cookie statement you will find the storage periods that are used by the various cookies.