Privacy statement

1.    Introduction Intospace Management B.V.

Here you will find the privacy statement of Intospace Management B.V. (intospace® and CLIC). Intospace Management B.V. respects your privacy and personal data and ensures that the personal data provided to Intospace Management B.V. or otherwise obtained by Intospace Management B.V. are treated confidentially and carefully. We clearly explain how we store your data, how long it is stored and what exactly the purpose of the data processing is. In addition, we give you clear insight into how you can exercise your rights concerning data processing.

What does Intospace Management B.V. do?

Intospace® and CLIC are part of Intospace Management B.V.. Although we speak of Intospace Management B.V. in this privacy statement, we would like to explain what both organizations are involved in. Intospace® is a logistics real estate developer in 's-Hertogenbosch that builds logistics real estate solutions for future generations. CLIC is a concept of intospace®, which stands for City Logistics Innovation Campus, which forms the logistics innovation campus for the Amsterdam Metropolitan Area.

Want to know more about our companies? Here you can find more information about intospace® and CLIC. Although this privacy statement relates to intospace® and the CLIC project, the data processing mainly takes place from intospace®. If CLIC processes data, this is explicitly stated.

All articles in this privacy statement are following the applicable General Data Protection Regulation (GDPR). This European privacy legislation has been applicable in the Netherlands and the European Union since 25 May 2018.

Do you have questions about the privacy statement of Intospace Management B.V.? Please feel free to contact us via the intospace® contact form or the CLIC contact form. Or send an e-mail to backoffice@intospace.eu.

2.    What kind of personal data is collected?

If you use the services of Intospace Management B.V. or start working at Intospace Management B.V., you leave certain information with us. This may include personal data such as your name, address, date of birth, telephone number and e-mail address. Personal data are data that can be traced back to a natural person. The GDPR legislation also places certain company data under Personal Data. Think of the e-mail address sofie.janssen@bedrijf.nl.

We only store and use the personal data that are provided directly by you or of which it is clear that they are provided to us for processing. The personal data that we can process about you are:

  • First and last name;
  • Address;
  • Business address;
  • Date of birth;
  • Telephone number;
  • Citizen service number;
  • Bank account;
  • (Personal) e-mail address;
  • (Possibly) Certificate of Good Conduct;
  • CV, diplomas, and other documents of the personnel file, copy of identity document, marital status, e-mail address and nationality.

 

Not all personal data is relevant for both companies. CLIC only collects first and last names, e-mail addresses and telephone numbers.

Please note: Depending on the processing purpose, not all of the aforementioned data about you need to be processed. Under  'Basis and purposes for data processing', it is further explained which data we process per processing purpose.

3.    Basis and purposes for data processing

Based on the GDPR legislation, we base all processing on a lawful basis. The following legal processing bases may apply to Intospace Management B.V., this differs per purpose:

  • Consent to the processing of personal data ( 6 para. 1 lit. a GDPR);
  • The necessity of the processing for the fulfilment of a contract (Article 6 paragraph 1 sub b GDPR);
  • The necessity of the processing to comply with a legal obligation (Article 6 paragraph 1 sub c GDPR);
  • The necessity of the processing for a legitimate interest ( 6 para. 1 lit. f GDPR).
  • Use of special personal data because of consent granted (Article 9(2)(a) GDPR)
  • Use of special personal data by obligations arising from labour law, social security law and social protection law (Article 9 paragraph 2 sub b GDPR).

 

Special personal data are personal data that reveal race, ethnic origin, political opinions, religious or philosophical beliefs or membership of a trade union. This also includes the processing of genetic data for unique identification, data about health, sexual behaviour or sexual orientation. The BSN is also mentioned below.

In some cases, Intospace Management B.V. processes special personal data, these special personal data are only processed with your explicit permission in strictly necessary situations.

Article 13 paragraph 1 sub c of the GDPR then requires us to indicate for which  'processing purposes' the personal data are intended, so below is an overview of the various processing purposes. These processing purposes are also the 'reasons' why we need to process your personal data.

For each processing purpose (reason for processing), it is indicated what the purpose entails and under which principles from the GDPR the purpose falls. This data's retention periods (how long we keep your data stored) are described under  'Period of storage'.

There are several purposes for which Intospace Management B.V. collects your data:

  1. Contact us

If you have contacted Intospace Management B.V. in any way, the data you provide will be stored and used for the course of further contact. Think of first and last name, e-mail address, address, and telephone number.

The corresponding bases for processing are our legitimate interests (we need to be able to communicate with you to be able to handle or follow up on questions and to be able to offer our services).

  1. Newsletter

You can subscribe to the CLIC newsletter. If you sign up for the newsletter, we will in any case process your e-mail address. Data such as your first and last name may be processed.

The bases for processing in this context are your consent (to indicate to CLIC that you are interested in receiving our newsletter), and our legitimate interest (for communication and information about CLIC).

  1. Customer relationship

Intospace Management B.V. needs to store and process your feedback, complaints and wishes in a CRM system. If Intospace Management B.V. needs to contact you further (for example for the follow-up of a complaint), Intospace Management B.V. must be able to do so. We store data such as your name, telephone number and e-mail for this purpose.

The associated grounds for processing are the execution of the agreement (to perform our services properly by having clear contact with the persons and controllers)  and our legitimate interest (to be able to initiate, maintain and maintain the customer relationship; to be able to perform the associated administration, correspondence, and relationship management activities and to be able to perform our services properly).

  1. Execution of agreement/services

Intospace Management B.V. processes your personal data to be able to comply with the concluded agreement (excluding employment contracts) and to be able to perform our services properly. Various personal data can be processed based on the agreement or the specific service. We process at least the following personal data for this purpose: your first and last name, telephone number, e-mail address and other data that may be required, such as address details.

The associated grounds for processing are the execution of the agreement (to fulfil the concluded agreements and to perform our services properly)  and our legal obligation (to have and keep the administration of Intospace Management B.V. in order).

  1. Accounting and invoicing

Intospace Management B.V. is legally obliged to keep a thorough accounting. For this purpose, the data reasonably present on quotations or invoices is stored. Think of your name and, if necessary, bank details.

The corresponding grounds for processing are the execution of the agreement  (in case the agreement has been concluded with the customer); legal obligations  (including our administration and retention obligations, tax obligations and obligations regarding the preparation of annual accounts and annual reports); our legitimate interest (to be able to carry out our regular business activities correctly and effectively; to be able to provide and improve our services, for example, to be able to protect our interests during a dispute or legal proceedings and to prevent fraud, scams or other unlawful behavior).

  1. Employee data

When you start working at Intospace Management B.V., Intospace Management B.V. needs certain information for drawing up an employee profile. Without this information, it is not possible to properly enter into employment with Intospace Management B.V.. Think of first and last name, address details, bank details (for the financial payment of the salary), date of birth, and if necessary, a Certificate of Good Conduct and/or a citizen service number.

The corresponding grounds for processing are your explicit consent (by signing/taking cognizance of the various documents of Intospace Management B.V., including the Personnel Manual of Intospace Management B.V., whereby you indicate that you are aware of and agree to the data processing of certain personal data, including various special personal data), execution of the agreement (being able to draw up an employee file and to be able to meet the obligations of the agreement, including the payment of salary), legal obligation (the obligation to comply with the concluded agreement and our legal obligations regarding the correct hiring of an employee),  and our legitimate interest (the proper performance of our work and the ability to draw up a complete employee profile).

  1. Social media

Intospace Management B.V. uses multiple social media channels. When you try to contact us in this way, the data you provide will be processed for the respective purpose. This information includes your (profile) name and other information that you provide to us.

With the use of social media websites, the terms and conditions and the privacy statement of the relevant social media platform apply. These may differ from our privacy statement. Intospace Management B.V. uses Instagram (privacy policy Instagram) and LinkedIn (privacy policy LinkedIn). If you have created a profile on social media, depending on your settings on the relevant platform, certain personal data of yours may be visible to us when you use a public profile.

The bases for processing in this context is our legitimate interest (to be able to respond to your questions, complaints and contact requests, we process your data so that we can provide you with the best possible service).

  1. Cookies placed via our website https://intospace.eu/

To use the website of Intospace Management B.V. and to make the website function properly, several data are stored. This may include your IP address, geographic location, device information, browser type, referral source, duration of visit, operating system, number of pages viewed, which pages you viewed and similar information. This information may be collected on our behalf by a third-party website analytics service provider and/or may be collected using cookies.

Intospace Management B.V. keeps usage data of the website(s) for statistical purposes. The personal data collected in this way is in principle anonymous. The website of Intospace Management B.V. uses cookies from Google Analytics to, in general, follow user behaviour and general trends and obtain reports. This helps to improve the functioning of the website. Google may provide this information to third parties if Google is legally obliged to do so or insofar as third parties process the information on behalf of Google. By using the website of Intospace Management B.V. you consent to the processing of the information by Google in the manner and for the purposes described above.

Please note: The Telecommunications Act (article 11.7A), also known as the Dutch cookie law, obliges Intospace Management B.V. to inform you about the use of cookies on our website. The cookie statement states, among other things, which cookies are active on the website, which user data they track and how long the cookies are placed. This information about cookies is given in a separate document: our cookie statement.

4.    Period of storage

Above we have indicated for which processing purposes we use your personal data. Based on Article 13 paragraph 2 sub a of the GDPR,  we will indicate the storage period of the personal data. In addition, it is good to realize that all data will in any case be kept for the period that our services are provided and/or an agreement is in force. Every moment of contact between you and Intospace Management B.V. serves as a new beginning of the retention period for the relevant processing purpose.

Data specified and processed for one purpose may be transferred to another purpose. This will start a new retention period for the transmitted data. This is the case, for example, when data is provided via a contact form and eventually a service is provided. When the same data is used, the retention period of this data will transfer to that of the next purpose.

  1. Contact us

If the contact does not lead to the provision of a service or work, the data provided by you will be kept for a maximum period of two (2) years.

  1. Newsletter

We keep the data until the newsletter is unsubscribed. After unsubscribing, the data will be deleted.

  1. Customer relationship

For this purpose, data will be retained for two (2) years after the end of a customer relationship, unless longer is necessary in connection with legal proceedings. In this context, the term of two (2) years is also linked to the possibility that a possible relationship will become a customer of Intospace Management B.V. again.

  1. Execution of agreement/services

To be able to execute the concluded agreements and our services, we store the data for a period of five (5) years after the agreement is no longer in force. If no specific agreement has been concluded, the term is two (2) years after the service has been fully performed.

  1. Accounting and invoicing

To keep sound accounts, we must keep personal data related to financial purposes for a period of at least seven (7) years, possibly plus five (5) years for internal accounting. This is unless a longer storage period is required in connection with legal obligations and/or an expected legal dispute.

  1. Employee data

For this processing purpose, different retention periods are used, whereby the personal data of applicants are deleted immediately after rejection/interview.

Personnel files are kept based on the State Taxes Act for two (2) years after the end of employment.

Personal data processed for our internal administration will be stored for a maximum of seven (7) years.

  1. Social media

Data retention by Instagram and LinkedIn, both its Conversion API and other services, is subject to the terms and conditions of Instagram and LinkedIn. For more information, please read the privacy statement of Instagram and LinkedIn.

  1. Cookies placed via our website https://intospace.eu/

All information regarding cookies and the retention periods maintained by the cookies is explained in detail in our cookie statement.

5.    With whom will the personal data be shared?

Intospace Management B.V. shares personal data with third parties: this only happens when this is strictly necessary. In all cases, Intospace Management B.V. will comply with the GDPR legislation as controller, specifically Article 28 et seq. GDPR. If necessary, Intospace Management B.V. concludes a processing agreement with all parties involved in the processing of personal data. These third parties are therefore also obliged to comply with the GDPR. In addition, every staff of Intospace Management B.V. involved in the processing of personal data signs a confidentiality agreement to ensure the correct processing of personal data within the meaning of the GDPR.

To guarantee good handling of services from Intospace Management B.V., we work together with certain external parties. Think of parties for the financial administration, broker, or notary.

When we share your personal data with third parties in countries outside the European Economic Area (EEA), we always take the necessary measures to protect this data. In doing so, we rely on, among other things:

  • The requirements are based on the applicable laws and regulations;
  • EU Model Clauses.

 

Overview of third parties that receive personal data from you:

  • Accountant

To keep a thorough accounting, personal data may be provided to an accountant. These are strictly necessary data, which are also stated on invoices.

  • Tax authorities/government agencies

To comply with our tax liability and/or any other legal requirement, we share the necessary personal data with the tax authorities and other government agencies, if we are legally obliged to do so.

  • Google Analytics

For the website to function, we use Google Analytics. Google receives data about the use of the website. More information about the data that Google collects can be found in this privacy statement.

  • Social media

By using the social media links on our website, data can be provided to the social media channel, such as the IP address. With the use of social media websites, the terms and conditions and the privacy statement of the relevant social media platform apply. These may differ from our privacy statement. Intospace Management B.V. uses Instagram (privacy policy Instagram) and LinkedIn (privacy policy LinkedIn).

6.    Safety

Intospace Management B.V. has taken various technical and organizational measures to ensure an appropriate level of security to protect your personal data against unauthorized or unlawful processing and loss, destruction, damage, alteration, or disclosure.

Personal data are only accessible to the authorized employees of Intospace Management B.V. who are involved in the processing of your personal data. The devices on which your data is stored are locked with a password and/or fingerprint scan and/or facial recognition and two-factor authentication. This involves the necessary devices, such as computers, laptops, and mobile phones. Physical data within Intospace Management B.V. is stored in a locked cabinet.

For the website or digital data, Intospace Management B.V. uses Firewalls, protected software, and antivirus programs. Your visit to the website of Intospace Management B.V. is also secured by an ''http'' security. This means that your connection with Intospace Management B.V. is private. This ensures that your personal data remains safe during the website visit.

If Intospace Management B.V. uses the services of third parties, such as an ICT supplier, Intospace Management B.V. will record an agreement on adequate security measures in a processing agreement in the context of the protection of personal data.

Furthermore, Intospace Management B.V. has a Data Protection Officer (hereinafter referred to as DPO) who supervises the application and compliance with Intospace Management B.V.’s privacy policy and the legal requirements for the processing of personal data within Intospace Management B.V..

For the sake of completeness, more information about the security of your personal data:

  • All devices that have access to your personal data and are part of the processing of personal data are password protected;
  • Intospace Management B.V. processes your personal data on devices that have security software, such as a firewall and protected software;
  • The DPO supervises the application and compliance with the privacy policy of Intospace Management B.V.;
  • We send your data via a secure internet connection. You can see this in the address bar 'http' and the padlock in the address bar.

 

7. Your rights concerning your personal data

Below are the rights you can exercise regarding your personal data. Although Intospace Management B.V. collects and processes your personal data carefully, we think it is important to point out the rights you have in the context of the GDPR.

  • Right of access (Article 15 GDPR)

You always have the right to view the data processed and stored by Intospace Management B.V.. To exercise this right, you can send an e-mail with your request to backoffice@intospace.eu.

  • Right to rectification (Article 16 GDPR)

If the data stored by Intospace Management B.V. turns out to be incorrect, you have the right to have this data rectified. Intospace Management B.V. will replace the current incorrect data with the correct data.

  • Right to data portability (Article 20 GDPR)

You have the right to have personal data transferred by Intospace Management B.V. to a similar party. This refers to a party that offers and performs roughly the same services as Intospace Management B.V..

  • Right to erasure (Article 17 GDPR)

In certain cases, you can request Intospace Management B.V. to have data deleted. You have the option to do so with the right to be forgotten. Below you will find a list of situations in which Intospace Management B.V. needs to delete your data:

  • If the data processed by Intospace Management B.V. are no longer necessary for the relevant processing purpose.
  • If the consent to the use of the personal data is withdrawn by you. For example, using the 'unsubscribe button' for a newsletter.
  • If you object to the processing of your data. In the case of direct marketing, you always have an absolute right to object. If your interests regarding the processing of personal data outweigh those of Intospace Management B.V., you have a relative right. The data deletion will then only occur if it has been demonstrated that your interests outweigh those of Intospace Management B.V..
  • If Intospace Management B.V. processes data unlawfully, you have a direct option to have the data removed by Intospace Management B.V.. This is the case, for example, if there is no legal basis for the processing of your personal data.
  • If a statutory retention period has been exceeded, Intospace Management B.V. is obliged to delete the processed personal data with the exceeded retention period.
  • If you, as a data subject, are younger than 16 years and the consent of a parent or guardian has not been granted for the processing of the personal data. In this case, Intospace Management B.V. will immediately delete your personal data.

There may be exceptions to the right to be forgotten. For more information, you can consult the following page of the Dutch Data Protection Authority.

  • Right to lodge a complaint with the Dutch Data Protection Authority (Article 13 GDPR)

If you think that Intospace Management B.V. does not thoroughly handle your personal data, you always have the right to file a complaint with the Dutch Data Protection Authority. You can do this via this link. The Dutch Data Protection Authority will further handle your complaint.

  • Right to stop data consumption, objection (Article 21 GDPR)

You have the right to object to data processing at any time. Especially in the case of 'direct marketing'.

Furthermore, we would like to point out the following rights:

  • Right to restrict (part of) the processing: under certain conditions, you have the right to obtain from Intospace Management B.V. the restriction of the processing of your personal data. In short, this means that Intospace Management B.V. temporarily "freezes" the processing of the data. You can invoke this right in four situations: (1) pending the assessment of a correction request, (2) if data should be deleted but you do not want deletion, (3) if Intospace Management B.V. no longer needs the data while it is still needed for (the preparation for) a lawsuit and (4) pending the assessment of an objection.
  • Withdrawal of consent: you have this right insofar as we process your data based on your consent. You have the right to withdraw consent once given at any time. This has no consequences for the past, but it does mean that we are no longer allowed to process that data. It is possible that Intospace Management B.V. can no longer offer you certain services.

 

Make use of the above rights?

In most cases, an e-mail to tamara.badenbroek@intospace.eu  is enough to make use of the rights. If we have doubts about the validity of your identity, we can take other measures to find out. For example, by asking you to provide us with a copy of your identity document. This is always done in the manner prescribed by the central government. In most cases, a less intrusive method of identification will suffice. The use of the rights is free of charge; barring abuse.

We would like to point out that the rights described above are not absolute rights. There may be circumstances that prevent Intospace Management B.V.  from responding to a particular request. We will always assess each request on its circumstances. Intospace Management B.V. strives to always provide you with a response to your request within two weeks. If your request is rejected in whole or in part, the rejection will always contain a motivation.

Your requests, as referred to above, can be addressed to:

Intospace Management B.V.
Data Protection Officer: Tamara Badenbroek
E-mail address: tamara.badenbroek@intospace.eu
P.O. Box 3008, 5203 DA | 's-Hertogenbosch
+31 (0) 85 90 28 900

8.    Entry into force and amendments

This privacy statement entered into force on 20 September 2021 and was last updated in June 2023. Intospace Management B.V. has the right to change the content of this privacy statement at any time without prior notice. Changes to the privacy statement will be published on the websites of Intospace Management B.V.. Therefore, consult the website regularly.

9.    Questions and contact

If you object to the processing of certain personal data or if you have any questions about this, you can contact Intospace Management B.V.:

Intospace®
P.O. Box 3008 | 5203 DA 's-Hertogenbosch
backoffice@intospace.eu
+31 (0) 85 90 28 900

Visiting address
Het Zuiderkruis 23C
5215 MV 's-Hertogenbosch

CLIC
P.O. Box 3008 | 5203 DA 's-Hertogenbosch
info@joinclic.nl
+31 (0) 85 90 28 900

Version 2023