Privacy statement of SBA Holding

This is a privacy statement of SBA Holding B.V. and its subsidiaries, hereinafter jointly referred to as SBA Holding. SBA Holding processes your personal data in order to be able to provide services to you, and to carry out its tasks as efficiently and effectively as possible.

SBA Holding attaches high importance to the proper handling of your personal data. Therefore, we also carefully process and protect them. You can rely on the fact that your data are secure with SBA Holding, and that we comply with applicable legal provisions.

Why has SBA Holding prepared this privacy statement?

This privacy statement describes how we use your personal data. It demonstrates which of your personal data we process, for what purposes, who has access to the data, how we store it, to whom we transfer it, and what control you have in respect of all the processing. Your interests are always our top priority!

What are personal data?

Personal data are all the data that may trace back to a natural person, this being you. Sample personal data include: your first name and surname, address, date of birth, phone number, email address and biometric data. We obtain such data from you, for example, when you fill out a form, send us a letter or email, or when you call us. You also sometimes provide us with your personal data when you visit SBA Holding websites (such as sbaflex.com or sbaflex.pl), for example, in the form of an IP address or a cookie.

When you share your data with SBA Holding or when a third party does, we process the data. This concept of processing is broad and includes, among others, collection, storage, consultation, deletion, use and disclosure of data to third parties. “Processing” also means deletion or destruction.

What does the privacy statement apply to?

The privacy statement applies to all your personal data that SBA Holding processes as part of service provision. 

Whose personal data does SBA Holding process?

We may process personal data of all the persons with whom we deal with or who visit our website. These include, among others, (potential) temporary employees, seconded employees, payroll system employees and customers of SBA Holding. We also process personal data of contact persons of our (potential) clients, business customers, suppliers or business partners. 

Important: if, as an organisation or company, you provide us with personal data of your employees, you are obliged to inform your employees about this under applicable legal provisions. You may provide your employees with this privacy statement. This way, they will know exactly how SBA Holding uses their personal data.

Who is responsible for the processing of personal data?

The data controller of your personal data is SBA Holding B.V., with its registered office in Tilburg, Boogschutterstraat 5. The data controller is the party who officially and legally decides whether or not and how personal data will be processed, for what purpose and in what manner.


What does SBA Holding use personal data for?

SBA Holding may process your personal data only if it has a legitimate interest to do so. 
Legitimate interests comprising the basis for the processing of personal data:

  • your consent. You can withdraw your consent at any time;
  • the processing of your data is necessary for the performance of a contract;
  • the processing of your data is necessary for compliance with a legal obligation;
  • the processing of your data is necessary in order to combat a serious threat to your health; and
  • the processing of your data is necessary for the purposes of legitimate interests of SBA Holding where such interests are not overridden by your interests. 

 SBA Holding processes personal data to carry out its business operations in an efficient and effective manner, in particular as part of the following activities: 

  • analysis and optimisation of online media
    When you visit our website, contact us through social media or use our application, we collect information on the type of your device and browser, and on the manner of use of our website or application. This information helps us improve our website, communication and application, for your convenience as a user, and provide you with the best possible service.
  • provision of HR services
    We collect and process data of job applicants, (potential) candidates and temporary employees in order to provide our HR services, including agency services, secondment, payrolling, recruitment and selection, hiring of employees and placement of third-party employees, personal and employability development, reintegration, career guidance and outplacement, consulting, planning and HR/payroll administration.
  • maintenance of business contacts
    We process personal data of persons working for companies with whom we collaborate in order to present offers and/or information about provided services and other activities to maintain business relationships and enter into and maintain mandate contracts.

Generally speaking, we collect and process your data only for the purpose of performing our tasks as a temporary employment agency and a secondment agency, such as, for example, agency services, secondment, placement, payrolling, intermediary services to the self-employed, recruitment and selection, personal and employability development, payroll administration and personnel management. 

In specific cases, we ask you to provide us with your personal data for the following purposes, among others:

  • to enter into and maintain an employee-employer or personnel/employment agency relationship with you, and to provide financial, personnel, time, absenteeism and/or payroll administration services in this respect.
  • to enter into and maintain a relationship focusing on the acquisition/performance of orders, and to provide financial administration services.
  • to evaluate your suitability for a particular position or performance of an assignment, to record your readiness, and to contact you with a (potential) customer(s) and/or partner(s) or introduce you to them.
  • to act as an agency when you take up a job, to provide career and/or professional development advice and/or other (work-related) services, including, among others, training, in order to place you with clients, assign work performance with clients, or win assignments for you. 
  • to be able to enter into, execute and perform contracts with you, our clients and/or partners.
  • to keep you informed about our services and other activities, so that we can make them more relevant to your wishes and specifications (for example, by sending you notices of job offers).
  • for management purposes, generation of information and management reports, completion of market analyses, (external and internal) checks, audits and checks carried out by expert auditors, and to support and maintain quality and safety in our company.
  • to enable your access and use of our closed web portal using your own account.
  • to comply with applicable laws and legal provisions and/or to apply for grants and reductions of contributions, for example, in the context of identification or payment of taxes and national insurance contributions.
  • to comply with statutory obligations in respect of reintegration and requests from national authorities to help find jobs for those having difficulties on the labour market.
  • to be able to send you personalised messages and special offers that are relevant for your personal interests, based on the information you have shared with us and the information we have collected with cookies or comparable techniques in respect of your use of SBA Holding’s web portals/social media/blogs.
  • to improve our products and services (e.g. via our website and closed web portal) or to resolve (technical) issues that arise when using the website or our services.

We process your personal data only for the specified purposes. 
If your data are used for other (closely related) lawful purposes, we will provide you with further information in this respect and take required measures.


Which personal data do we process?

At the registration:

  • first name and surname, address, place of residence,  email address and other contact data,
  • date and place of birth, age, sex,
  • curriculum vitae (CV), information on education, internships and professional experience,
  • data on training and courses and/or tests you have completed yourself or through us, 
  • data on readiness and holidays,
  • other data that are (or may be) important for the assessment of your work-related suitability, such as references and certificates, passport photo and video (presentation), on a voluntary basis.

When you can start working for us/if you work/worked for us:

  • nationality, identification number (BSN), identification document, work permit,
  • other data related to personal, payroll and absenteeism registration.

How does SBA Holding handle personal data?

In a carefully, secure and confidential manner. This is how we handle your personal data. To this end, SBA Holding has prepared a relevant policy.

Supervision of the processing of personal data

Terms and conditions applicable to the protection of your personal data have been set out in the General Data Protection Regulation. Autoriteit Persoonsgegevens (AP) [Personal Data Protection Authority] supervises observance of this regulation. 

If you believe that we do not or insufficiently comply with provisions of this privacy statement, you have the right to lodge a complaint with the Personal Data Protection Authority. Contact details:

Autoriteit Persoonsgegevens
Bezuidenhoutseweg 30
2594 AV  Den Haag
0900-2001201

Security

In order to protect privacy and confidentiality of your data, SBA Holding takes appropriate technical and organisational measures. We use security measures to prevent abuse and unauthorised access to your personal data, such as access management, firewalls and secure servers, and we encrypt certain types of data, such as financial information and other sensitive data.

In addition to securing our systems, we also strive for restricting the access to all your data within SBA Holding.  Our systems are designed to ensure that employees may only see the information they have the right to see.

Incident reporting

If you suddenly discovered or suspect that the protection of your personal data is insufficient, we will report this to the Personal Data Protection Authority. If a breach of your personal data may have adverse or negative effects to you, we will notify you as soon as possible. 

Confidentiality

We assume that your data are always confidential. Therefore, all employees of SBA Holding are obliged to maintain the confidentiality. This also applies to third parties engaged by SBA Holding or otherwise appointed to perform work. Persons performing technical work on our systems are also obliged to maintain confidentiality. In short, all persons who have access to your data are bound by the confidentiality obligation. 

How long do we store data?

SBA Holding stores your data no longer than is necessary for the purposes for which they are processed, and no longer than is permitted by law. The retention period of certain data depends on the type and purposes for which they are processed. Therefore, the retention period may vary depending on different purposes. 

Disclosure to third parties

We never disclose your personal data to third parties unless this is necessary for the performance of a contract, if we are bound by a statutory obligation to do so, or if you have given your consent in this respect. 
    
SBA Holding may also be obliged to disclose personal data under laws or legal provisions, a decision of a competent court or in the case of fraud or abuse. In this case, you can expect SBA Holding to offer its full cooperation. 

Transfer of your data to countries outside of the European Union 

SBA Holding will not transfer your data to companies or branches situated in countries outside of the European Union, unless a model agreement has been entered into for this purpose or if you have signed a statement in which you have granted your consent to such a transfer. 

Personal contact with SBA Holding

Contacts between you and SBA Holding are often made by phone, forms, email or social media. In doing so, we store your personal data if this is necessary for our services.

Various ways of contact

Customers increasingly contact SBA Holding by email, social media (Facebook, Twitter) or our websites. Sometimes, text messages and chats are also used. Naturally, a lot of information is also exchanged by post and via contact forms. You may be the one to initiate contact with us, but SBA Holding may do this as well. SBA Holding may process personal data provided by you, for example, in order to answer questions, submit offers or improve quality of our services.

Contact with SBA Holding by phone

Incoming and outgoing phone calls may be recorded. We do this in order to be able to train, evaluate and coach our employees, and to optimise quality of our services to provide you with better service. 

Visits to SBA Holding website

When you visit our website, we store your IP address, visit data and cookies.

What do we do with your IP address?

All Internet users have IP addresses, also when they use the Internet on a mobile phone. It is impossible to use the Internet without an IP address. SBA Holding keeps your IP addresses in order to protect you from Internet frauds.

What do we do with website visit data?

SBA Holding websites store general visit data, such as data regarding the most frequently visited webpages. Thanks to this information, we can further optimise the design of our website. We may also use it to post more targeted information on our website. This way, we may continuously improve our services. We also record how visitors navigate on SBA Holding website. The data are stored and processed in an internal manner only. We use them, for example, for statistical analyses of visits, to prevent frauds and to provide personalised offers.

What do we do with cookies?

We use cookies on our website. A cookie is a simple, small file sent from pages of this website and stored by your browser on your computer, tablet, phone, etc. (“device”).

With your consent, we place “tracking” cookies on your device. We use them to check which pages you visit and then to create your online behaviour profile. This profile is not connected to your surname, address, email address, etc., but it is only intended to enable us to adjust job offers notifications to your profile, so that they are as relevant as possible for you.

As part of the “Analytics” service, Google places cookies via our website. We use this service to learn how visitors use our website, and to receive reports in this respect. Google may also transfer this information to third parties if it is lawfully required to do so or to the extent in which such third parties process the information on behalf of Google. We have no control over this use. Information collected by Google will be anonymised to the maximum possible extent. Your IP address is certainly not provided. This information is provided to and stored by Google on US servers.

De-registration

Before you start using our website, you select which cookies we may use. 
You can change the decision regarding cookie settings in your browser.  

What rights do you have?

If SBA Holding processes your personal data, you have the rights set out in applicable legal provisions. We explain the rights below. 

We inform you of the processing of personal data

Before processing your data, SBA Holding provides you with information on our identity, purposes and methods of data processing, terms and conditions governing the processing, your rights and how you can affect the processing. 

This information does not have to be provided if you are already aware of the data processing or if it is impossible to inform you or this would require a disproportionate effort on our part. 

Access to your data

Persons registered with SBA Holding who would like to see which of their personal data are known to us may exercise their right to access.  In this case, determine the specific personal data you would like to receive. 

Right to rectification 

You have the right to rectify your data that are inaccurate or incomplete. You also have the right to rectify your data if they are not relevant to the purpose for which they are processed or if we process them contrary to applicable laws. 

We will notify you of any potential rectification by third parties that have received your data from us, unless this is impossible or would require a disproportionate effort on our part. 

Right to data erasure

You also have the right to erasure of certain data. For example, if your data are no longer necessary for the purposes for which we received it, if you object to their processing, or if we have unlawfully processed them. However, we may not always be able to erase all of your data because we (may) have an obligation to retain certain data of yours. This applies, for example, to your BSN identification number or a copy of your identification document if you work or worked for us.

Right to restriction of processing

You also have the right to restriction of processing of your data. The right to restriction of processing means that we will not be able to (temporarily) process or change your personal data. This right applies if you challenge the correctness of your data, if you believe that your personal data are no longer necessary for any purposes, or if you think the processing of your personal data by SBA Holding is unlawful. 

Right to object 

You may object to the processing of your personal data by SBA Holding if your data are used for purposes other than those necessary for the performance of a contract or necessary for the performance of a statutory obligation. For example, if you do not want us to use your personal data to provide you with personalised offers. 

Right to data portability 

If you have provided us with your personal data yourself, you have the right to data portability in certain cases. This means that if you request us to do so, you will receive your data in a structured, commonly used and machine-readable format.  

How can you exercise your rights?

If you would like to exercise your rights, you can contact us at any time, using the following contact details, or send us a letter with your first name and surname, address and phone number. We will respond within one month. 

We also request that you present us with a valid identification document. This way, we can check if we provide the personal data to the right person. 

We may refuse excessive requests for information. Excessive requests are those where, for example, you make requests for information more frequently than average and necessary.

About the privacy statement

SBA Holding may amend this privacy statement. It was last amended on 24 May 2018
The latest version is always available on www.sbaflex.com .

If you have any questions or comments regarding our privacy statement, contact us: 

SBA Holding 
Boogschutterstraat 5
5015BX Tilburg
info@sbaflex.com & privacy@sbaflex.com