This privacy notice provides you with details of how we collect and process your personal data through your use of our site sunshine-aupair.com
- WHAT DATA DO WE COLLECT
Personal data means any information capable of identifying an individual. It does not include anonymous data. We may process the following categories of personal data about you:
- Contact Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
- Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, BSN number billing address, delivery address email address, phone number, contact details, income details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
- Sensitive Data We collect the following sensitive data ONLY if the services requested by you needs such data: Sensitive data refers to data that includes details about youthnicity, religious or pr race or ehilosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect sensitive data from our host families but may in certain cases be collected from au pairs for purposes of screening.
We require your explicit consent for processing sensitive data, so when you submit your details, we will send you a further communication asking for you to confirm your consent to this processing.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary.
- HOW WE COLLECT YOUR PERSONAL DATA
We may collect data about you by you providing the data directly to us (for example by filling in forms on our site, by sending us emails, or during conversations).
- HOW DO WE USE YOUR INFORMATION
We may use the information we collect from you when you register, make a contract with us, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:
- To process your request for service
- To send periodic emails regarding your service or other service related updates.
- To send to the IND for processing and periodic checks
- To send certain contact details to service providers such as insurance services or other service providers. For this explicit verbal or written consent is elicited.
- To follow up with them after correspondence (live chat, email or phone inquiries)
- MARKETING COMMUNICATIONS
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.
Before we share your personal data with any third party for their own marketing purposes we will get your express consent. You can ask us or third parties to stop sending you marketing messages at any time by emailing us at email@example.com at any time.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.
We do not specifically market to children under the age of 13 years old (COPPA (Children Online Privacy Protection Act))
- THIRD PARTY DISCLOSURES
We may have to share your personal data with the parties set out below:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers
- Government bodies that require us to report processing activities.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
We do not include or offer third-party products or services on our website.
- INTERNATIONAL TRANSFERS OF DATA
We are subject to the provisions of the General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:
- We may transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
- If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place; or
- Where we use certain service providers who are established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
- DATA SECURITY
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorization. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential. In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur: we will notify you via email within 1 business day.
- DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We are obligated to keep the data of host families and au pairs for 5 years for IND.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances we may anonymize your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
- DATA LEGAL RIGHTS
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at: https://autoriteitpersoonsgegevens.nl/nl/onderwerpen/avg-nieuwe-europese-privacywetgeving/rechten-van-betrokkenen
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Autoriteit Persoonsgegevens, the Dutch supervisory authority for data protection issues (https://autoriteitpersoonsgegevens.nl/). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
- THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
- CONTACT DETAILS
Our full details are:
Full name of legal entity: Sunshine Au Pair B.V.
Email address: email@example.com
Postal address: IJmuidenstraat 30, 2586 VA Den Haag, The Netherlands.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at firstname.lastname@example.org