Privacy statement
Your privacy is very important to us. How Company B.V. (hereafter: How Company) respects and protects the privacy of all its participants and future participants. Privacy has been an important aspect in How Company programmes in and outside the training room since our inception in 2003, so you can be confident that the formal privacy policy is something we take very seriously.
The legal relationship between you and How Company is governed by Dutch law and the processing of personal data is therefore in accordance with applicable Dutch laws and regulations covering privacy, in particular the General Data Protection Act. In this document we have formalized our privacy policy regarding your data.
Our vision
We believe everyone has the right to experience their maximum potential.
What we stand for
To make this possible, How Company provides services in the area of personal effectiveness, leadership and cultural change, with the aim of creating a more resilient and contemporary society. The assertiveness and authenticity of our trainers encourages our participants to become groundbreaking in both word and deed. We bring values, potential and organizational ambition together on an everyday level, where people make the difference.
In order to provide these services, How Company stores both personal data and non-personally identifiable data of the individuals who use its services. This data may contain personal information such as a name, e-mail address, telephone number, etc.
Personal information within How Company
How Company collects personal data when you:
- Request information about How Company or its programs directly or via third parties (or other digital platforms)
- Register directly for a How Company program
- Are registered for a How Company program by an organization you are connected to.
How Company collects, stores and uses your personal information for the following purposes to you can use our services:
- Creating personalized training materials
- Creating certificates Registration of participation (in order to qualify for follow-up programs)
- Creating an account within the online learning platform LearningStone.com Communication with you as (candidate) participant about our programs.
Only users of the online learning platform LearningStone receive digital reminders from the automated system. LearningStone has drawn up a separate privacy statement for this and How Company signed a processor agreement with LearningStone for verified and secure data processing on May 23, 2018.
Who sees which information?
7 back office employees have access to the data relevant to them for:
- Preparing the training materials and making the online tools accessible
- Invoicing, planning and control
- Personal contact with you as a participant
The trainer (s) who provide or take care of the program in which you participate will receive your name, surname, telephone number, gender and (in order to personalise our training material) whether you write with your left or right hand, as well as, if relevant, the name of the organization you are connected to.
Rights under privacy legislation
Under the General Data Protection Act you have different rights with regard to your personal data. We explain below how we have incorporated these rights in our business process.
Right to data portability:
If you want to transfer your data, you can send an e-mail with a request to info@howcompany.nl. We deliver the requested information within four weeks in Excel or CSV format.
Right to be forgotten:
You can send an e-mail to info@howcompany.nl with the request to be forgotten. How Company will respond to the request within four weeks. Four weeks after this message, How Company will delete all data related to you (with the exception of information that we are legally obliged to keep.) Once we have done so, How Company will inform you by e-mail.
Right of inspection:
If you would like to see what we have registered about you, please contact us via info@howcompany.nl We will make an appointment with you to provide you with access to the relevant parts of our registration system, on or off location. As far as the online learning platform LearningStone is concerned, we refer you to LearningStone.
Right to rectify and supplement:
If you dispute the accuracy of the information registered by How Company, you can request us to correct this at any time. Please contact us via info@howcompany.nl. We will make an appointment with you, on or off location, to provide insight into the relevant parts and to make changes to our registration system.
Right to restriction of processing:
You can send an e-mail to info@howcompany.nl. We will respond within four weeks to the request to limit the processing of specific personal data. How Company will implement the requested restriction no later than four weeks after this message. As soon as this has happened, we will send you an e-mail about this.
Rights regarding automated decision-making and profiling:
We do not process personal data where automated decision making and profiling are the goal.
Right to object to data processing:
You can send an e-mail to info@howcompany.nl. We respond within four weeks to the request to limit the processing of specific personal data. Four weeks after this message, How Company will implement the requested restriction. As soon as this has happened, we will send you an e-mail about this. In addition to these rights, you have the right to file a complaint with the Dutch Data Protection Authority at all times.
Security of your data
How Company ensures the appropriate technical and organizational measures are taken to protect your personal data against loss and against any form of unlawful processing. Explanation of these measures can be found in the How Company security policy. You can request this policy via info@howcompany.nl.
Providing your data to third parties How Company does not sell or rent out your personal information. For certain services, part of your data can be provided to third parties (read: subprocessors). This processing is necessary for an optimal experience of the learning process. Sub-processors do not have access to all your personal data, but only to the information they need to perform their function. A detailed overview of which personal data parties receive, can be requested via info@howcompany.nl.
Below an overview of the categories of recipients of your personal data.
For our open programs:
- Online learning platform: 'LearningStone.com'
- Training location: 'de Baak Seaside'
The How Company website contains links to third party websites. How Company is not responsible for compliance with privacy laws by these third parties, but has made every effort to ensure that your data is secure.
How Company reserves the right to provide (part of) your information in the event of a transfer of ownership, for example through a merger or takeover by another company. How Company will endeavor, if your details are provided to the acquiring company, to inform you of this, for example by e-mail, by a message on the website or an advertisement in a national newspaper.
Use of Cookies
Cookies are used on the websites of How Company. A cookie is a small text file that is placed on your computer by the system of the website you are visiting. A cookie contains information about your visit to the platform. The cookies that How Company places can never be traced back to your personal details, such as your name e-mail address or name. The cookies that How Company places on your computer are used for the following purposes:
- Remembering sessions and user names
- Improving the website by gaining insight into the use of the website
- Protecting against automated registrations It is possible to block cookies or not to consent to the use of cookies.
The way in which you can do this depends on your browser, see for example the explanation of the consumer union. By disabling cookies certain parts of the How Company website will function less well or not at all.
Google Analytics
How Company uses Google Universal Analytics to analyze how its online platform is used. Through Google Universal Analytics, How Company collects information about the number of users that visit the website. The information we collect contains no personal data and can in no way be traced back to individual users. For the collection of data in Google Universal Analytics, we place Javascript tracking code on our website that sends information to Google to Google servers in the United States. Read the Google Privacy Policy for more information.
Hotjar
How Company uses Hotjar to analyze how its website is used. Hotjar collects data about the general use of the online platform, and is not intended to trace individual data about a user. Through Hotjar, How Company collects heat maps of pages with information about which buttons are clicked and where they are scrolled.
Changes to this privacy statement
If How Company decided to change its privacy statement, these changes would be immediately included in the privacy statement on www.howcompany.nl. We therefore recommend that you regularly consult this privacy statement so that you are aware of any changes. At How Company we have no Data Protection Officer as described in the AVG. We do not meet one of the three criteria requiring this. If you have questions or requests about this privacy statement, please let us know by sending an e-mail to info@howcompany.nl.
How Company B.V.
Amsterdam, May 23, 2018