Adaptfy B.V. headquartered at De Entree 69, 8th floor, Amsterdam, Noord-Holland, the Netherlands (“Adaptfy”, “we” or “us”) is committed to protecting and respecting your privacy and your personal data. Under this Policy Adaptfy would like to let you know which personal data of yours we collect and why, as well as how we use and disclose personal information. There is an index to support you find easier and faster the information you are looking for.

Adaptfy B.V. headquartered at De Entree 69, 8th floor, Amsterdam, Noord-Holland, the Netherlands (“Adaptfy”, “we” or “us”) is committed to protecting and respecting your privacy and your personal data. The present Policy applies to the website adaptfy.com (the “Website”) and helps you understand, among others, what personal information we collect, why we collect it, what we do with it, how we protect it, and what your personal rights are.

It is important for you to know that “personal data” means any information relating to an identified or identifiable natural person (“data subject”) according to the General Data Protection Regulation. So, any reference to “personal data”, “data”, “personal information”, or “your data” in this Policy means information that relates to you and that allows us to identify you directly or in combination with other information we have.

• When you complete our contact form in the Website, we will collect any information you provide to us, and specifically name, surname and email address, so that we respond to your request or questions. Kindly note that the fields marked with an asterisk (*) are mandatory, because we need this information to comply with or respond to your request. Other information you share with us when filling out our contact forms is in your sole discretion.
• When you submit a candidate’s application through our Website for a job post of Adaptfy, we collect the data that are included in your application, such as full name, contact details, CV. Other information you share with us without requested by us is in your sole discretion
• Personal data automatically collected while you browse including but not limited to traffic and location data, IP address, device type, browser, redirection website, company web pages that you visited, visit date and time. The above data is only kept on an aggregated level. As a result, once collected, this information is interconnected with other related information in a way that it is no longer possible to identify the person to whom it relates to
• When you navigate our Website, we also store strictly necessary and performance cookies, in case you accept their storage. For more information see our Cookie Policy.

The use of your data by us as described above is permitted by applicable data protection law because:

• When you use our contact forms or submit a request or contact us by any means, the use of your personal information is based on your consent. Please click here to see “Your rights and how to exercise these?’’ section, so that you know about how you can withdraw your consent.
• We have a contractual relationship with you in effect.
• It is necessary for our legitimate interests in pursuing the purposes set out above (under section 3), and such interests in each case not being overridden by your privacy interests;
• In some cases, it is necessary to meet our legal or regulatory responsibilities, or for establishing, exercising or defending legal claims, such as disclosures to authorities, regulators or government bodies;
• We do not proceed to any solely automated decision including those based on profiling, that have a legal or similarly significant effect on you.

When you use our contact forms or submit a candidate’s application, a request or, in general, contact us by any means, we will retain your information for one year after last contact. However, we may keep your information for the longer of the period required in order to meet our legal or regulatory responsibilities (for example, for establishing, exercising or defending legal claims or compliance cases).

The information we collect in connection with your visit to our Website (such as location and traffic data, date and time of the access to the website, your device, browser, weblogs) for web analysis purposes is only kept on an aggregated level. As a result, once collected, this information is interconnected with other related information in a way that it is no longer possible to identify the person to whom it relates to.

For information about the cookies storage retention, please see our Cookie Policy.

We will only share your personal information with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place as appropriate to protect the data and to comply with our data protection, confidentiality and technical and organizational security standards.
In particular, we share your information with others in the cases below:

• To entities related to Adaptfy B.V. for the proper operation of the website, as well as for the proper and on time respond of your requests, questions and applications.
• To suppliers, contractors and agents, either companies or individuals, that we engage or employ from time to time to perform functions on our behalf (such as, for hosting the website, provide maintenance services, store the information). Such recipients will only have access to your personal information as required by them to perform their functions and are not permitted to use such personal information for any other purposes. These recipients will be subject to contractual confidentiality obligations.
• Service providers for measuring the performance of the website if you agree on this. For more information check our Cookie Policy.
• To government, law enforcement authorities, regulatory agencies as required by, and in accordance with, applicable law or regulations

Your personal information can be transferred and processed in one or more other countries outside of the Netherlands. For more information see section 6 “Do we share your personal information with others?”. We shall only transfer your data outside of the Netherlands to countries which provide adequate level of data protection as defined by the applicable data protection laws, or where Adaptfy has put in place appropriate safeguards to preserve the privacy of your information, including the United States and United Kingdom. We endeavor to take all measures reasonably necessary to ensure that your personal information is treated securely and with regard to this Policy.

You have certain rights over your personal data with regard to their processing by us under the applicable data protection laws.
 
Please see below which are these rights, when they are available and how to exercise them:
 
Your right to access your personal data

You have the right to request confirmation as to whether we process any personal data about you, receive a copy of your personal data held by us and obtain certain other information about how and why we process your personal data.

Your right to correction / rectification of your personal data

You have the right to request for your personal data to be amended or rectified where it is inaccurate or not up to date (for example, if you change your name or email address) and to have incomplete personal data completed.

Your right to erasure / right to be forgotten

In certain circumstances, you have the right to have your personal data erased. You may submit such a deletion request at any time and we will evaluate if your request should be granted; however this right is subject to any legal rights or obligations we may have to retain data. When in accordance with the law, we determine that your request to have your personal information erased must be granted, Adaptfy will delete your data without undue delay.

Your right to restrict processing

You have the right to request the restriction of the processing of your personal data in the following cases:
 (a) when you contest the accuracy of your personal data, and pending verification of the accuracy of your data;
 (b) when you oppose the erasure of your personal data and you request the restriction of their use instead;
 (c) when your personal data are no longer needed for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
 (d) when you have objected to the processing and pending verification that our legitimate grounds for processing override those for which you object to the processing.

Your right to object to processing

You have the right to object to our processing of your personal data in the following cases: our legal grounds for processing is that the processing is necessary for a legitimate interest pursued by us or a third party; or in case, our processing is for direct marketing purposes.

Your right to data portability

You have a right to receive your personal data provided by you to us and have the right to send the data to another organization or ask us to do so, if technically feasible, where our lawful basis for processing the personal data is consent or necessity for the performance of our contract with you and the processing is carried out by automated means.

Your right to withdraw consent (where processing is based on consent)

Where we process personal data based on consent, you have a right to withdraw consent at any time. Withdrawal of your consent will not affect the lawfulness of any processing based on your consent before the receipt of your withdrawal.

If you want to exercise your rights, please email us at privacy@adaptfy.com. We aim to respond to any requests for information promptly, and in any event within the legally required time limits.

You can also lodge a complaint about our processing of your personal information with the data protection authority of the Member State of your habitual residence, of your place of work, or the place of an alleged infringement of your rights. The Autoriteit Persoonsgegevens (“AP”) is the Data Protection Supervisory Authority in the Netherlands. For further information on your rights and how to complain to the AP, please refer to the website of the AP.

The terms of this Policy may change from time to time, for example because our Website or the rules for cookies change. We shall publish any material changes to this Policy on this Website.

Do you have any questions, comments and requests regarding this Policy? You are welcomed and should address these to privacy@adaptfy.com.