Privacy statement
1 delaware Consulting and your privacy
In this privacy statement, we explain how delaware Consulting B.V. (“delaware”, “delaware Netherlands”, “we” or “us”) processes your personal data.
Your privacy is important to us. That is why we process your personal data lawfully, carefully, and transparently, in accordance with the General Data Protection Regulation (GDPR) and the Dutch GDPR Implementation Act (UAVG).
Here you can read which personal data we process, why and on what legal basis we do so, and with whom we share this data.
We also explain which privacy rights you have and how you can exercise them. Please contact us at dlwc-nl-dnl_data_privacy@delaware.pro.
2 Scope of this privacy statement and who it is intended for
delaware Consulting B.V. is a company incorporated under Dutch law, with its registered office in Eindhoven and its business address at Hambakenwetering 5J, 5231 DD ’s-Hertogenbosch, the Netherlands, registered with the Dutch Trade Register (Kamer van Koophandel) under number 17105219.
In the situations described in this privacy statement, delaware Netherlands is the controller. This means that we determine why and how we process your personal data.
This privacy statement applies to visitors of our website(s), (prospective) job applicants, customers, suppliers, and other service providers.
Relationship to delaware's group-wide privacy statement
delaware also maintains a group-wide Privacy Statement linked to Delaware Consulting CV, published at https://www.delaware.pro/en-be/privacy. If you visit delaware Netherlands' website, or deal exclusively with delaware Netherlands as a (prospective) job applicant, customer, or supplier, this Privacy Statement applies. If, on the other hand, you visit the sub-domain of another Affiliated delaware company, or apply for a vacancy that is managed group-wide, the group-wide Privacy Statement or that of the relevant Affiliated delaware company may (additionally) apply.
By “applicable privacy legislation” we mean the GDPR, the UAVG, and other applicable laws and regulations on privacy and the processing of personal data.
“Personal data” means any information that directly or indirectly relates to you, such as your name, photo, phone number, e-mail address, or bank account number.
By “processing” we mean everything we do with personal data, such as collecting, storing, using, sharing, adapting, or deleting it.
3 When and why do we process your personal data?
3.1 When you visit the website
When you visit our website, we process personal data that is necessary to make the website function properly. With your consent, we use additional data to improve the website and for analysis and statistics.
More information about cookies, their use, and how to adjust your preferences can be found in our cookie policy: https://www.delaware.pro/en-nl/cookie-policy.
3.2 Organising physical and virtual events
We organise physical and online events, such as seminars, training sessions, and webinars. If you register, we process your personal data to organise your participation and to send you information about the event.
Categories of data | Source | Legal basis | Recipients | Retention period |
First name, last name, company name, phone number, e-mail address, job title | From you, upon registration | Legitimate interest of delaware as organiser of the event | IT service providers; external support services for the organisation of events | Up to 6 months after the event, for administrative processing |
3.3 Downloading e-books and other online marketing material
Via our website you can download marketing material, such as e-books. We process your personal data to send you the material you requested. Only if you have given separate consent for this, we also process your data for marketing purposes. For analysis and statistics, we only process data to the extent a valid legal basis exists for this, including your consent where required.
Categories of data | Source | Legal basis | Recipients | Retention period |
First name, last name, company name, e-mail address, phone number | From you, via the download form | Necessary to fulfil your request to receive the material; for marketing purposes, your separate consent; for analysis and statistics, depending on the processing, your consent or our legitimate interest | IT service providers | Immediately after the material is sent; for marketing purposes: until you withdraw your consent or unsubscribe |
3.4 Direct marketing
If you have given consent, we send you newsletters and other marketing communications about our services, products, and offers. Affiliated delaware companies will only contact you if you have also given consent for this.
Would you like to stop receiving marketing communications? Unsubscribe via the link in the e-mail or contact us at dlwc-nl-dnl_data_privacy@delaware.pro.
Categories of data | Source | Legal basis | Recipients | Retention period |
First name, last name, company name, position, e-mail address, phone number, interests | From you, via the website or by e-mail | Your explicit consent | Marketing service providers; IT service providers; Affiliated delaware companies (if you have given consent for this) | Immediately after you withdraw your consent |
3.5 When you contact us
Via our website you can contact us, for example with a general question or a question about a service or product. We process your personal data to assess, answer, and follow up on your question or request.
Categories of data | Source | Legal basis | Recipients | Retention period |
First name, last name, phone number, e-mail address, country, company, job title, interests | From you, via the contact form | Our legitimate interest in carefully following up on questions, requests, and complaints | IT service providers; the Affiliated delaware company(ies) to which your request (also) relates | 6 months after submission of your request |
3.6 Social media
We may process personal data that you share directly with us or make public via social media, such as LinkedIn, Facebook, or Instagram. We do this to respond to questions or complaints, to monitor our online reputation, and to improve our services and communications. We only use a comment or post in our own communications if, taking into account the context and your reasonable expectations, this is necessary and proportionate on the basis of our legitimate interest, or if we have your consent for this.
Categories of data | Source | Legal basis | Recipients | Retention period |
First name, last name, username, e-mail address, and other personal data that you share with us or make public on social media | From you or from publicly accessible social media | Our legitimate interest in responding, monitoring our online reputation, and improving our services and communications, to the extent this is necessary and proportionate; for the use of public reactions in our own communications, depending on the circumstances, our legitimate interest or your consent | IT service providers; recipients of our communications; Affiliated delaware companies to which the message (also) relates | 6 months after your message or request has been handled |
3.7 When you apply for a job at delaware Netherlands
When you apply for a job at delaware Netherlands, for example via our website or LinkedIn, we process your personal data for the recruitment, selection, and administration of (future) employees.
It is possible that we also use your data to assess whether you are suitable for a vacancy other than the one you applied for. If our Recruitment department believes that a different role would be a better fit for you, we may contact you about that vacancy.
If your application does not result in employment, we retain your personal data for 4 weeks after rejection. With your consent, we may extend this period to a maximum of 1 year. After that, we delete or anonymise your data.
Categories of data | Source | Legal basis | Recipients | Retention period |
First name, last name, e-mail address, phone number, country, education and studies, date of birth, employment history, CV details, information from your cover letter, other data you have shared | Directly via the application form on the website or on LinkedIn; phone calls, e-mails, and interviews; social media; indirectly via recruiters or headhunters | Necessary to take steps at your request prior to entering into an employment contract; our legitimate interest in recruiting and selecting candidates and managing the application process; our legitimate interest in assessing whether you might be a good fit for a vacancy other than the one you applied for; for retaining your data for future vacancies, your consent | Service providers for recruitment purposes; references you have provided; regulated professions where applicable (e.g. lawyers, accountants) | 4 weeks after rejection, extendable to a maximum of 1 year with your consent |
The same categories as above | The same sources as above | Necessary to comply with legal obligations resting on delaware Netherlands during, or immediately prior to, commencement of employment, to the extent those obligations apply to the relevant data | Service providers; government authorities, to the extent legally required | For as long as legally required under the relevant obligation |
3.8 If you are a (prospective) customer of delaware Netherlands or an employee of a customer
We process personal data of contact persons at (prospective) customers to manage the customer relationship, make proposals, perform agreements, protect our business interests, maintain our administration, and issue invoices.
Categories of data | Source | Legal basis | Recipients | Retention period |
First name, last name, phone number, e-mail address, country, company, job title, other data voluntarily provided by you | Directly from you via e-mail, phone, or the website; or via the customer for whom you work | Our legitimate interest in managing the customer relationship and performing agreements | IT service providers; the Affiliated delaware company(ies) with which you, or the company for which you work, have a business relationship | Duration of the business relationship + 7 years (tax retention obligation, Article 52 of the General State Taxes Act (AWR)) |
The same categories as above, to the extent obtained directly from you | Directly from you, in the context of the sale of a product or service | Article 11.7(3) of the Dutch Telecommunications Act (existing customer exception): in connection with the sale of a product or service, we may contact you by e-mail about our own similar products or services, provided that you were able to object to this free of charge and easily when your data was collected, and can also do so with every subsequent message | IT service providers; marketing service providers; the relevant Affiliated delaware company(ies) | Until you object to marketing, or the business relationship ends |
When we collect your data, and with every marketing message you receive from us, you can object free of charge and easily to the use of your data for marketing purposes, for example via the unsubscribe link in the e-mail or by contacting us at dlwc-nl-dnl_data_privacy@delaware.pro.
3.9 If you are a supplier of delaware Netherlands or an employee of a supplier
We process personal data of contact persons at (prospective) suppliers to manage the supplier relationship, perform agreements, protect our business interests, maintain our administration, and process payments.
Categories of data | Source | Legal basis | Recipients | Retention period |
First name, last name, phone number, e-mail address, country, company | Directly from you via e-mail, phone, or the website; or via the supplier for whom you work | Our legitimate interest in managing the supplier relationship and performing agreements | IT service providers; Affiliated delaware companies with which you, or the company for which you work, have a business relationship | Duration of the business relationship + 7 years (tax retention obligation, Article 52 of the General State Taxes Act (AWR)) |
4 How is your personal data shared with third parties?
We only share your personal data as described in this privacy statement.
We may share your personal data with government authorities or the police if this is legally required or necessary for the purposes described above, or to protect our legitimate interests.
5 Is your personal data transferred outside the EEA?
Your personal data is, in principle, stored within the European Economic Area (EEA). If we transfer personal data outside the EEA, or make it accessible from a country outside the EEA, we only do so if a valid transfer mechanism exists for this, such as an adequacy decision of the European Commission or appropriate safeguards such as the European Commission's standard contractual clauses. Where necessary, we take additional technical, organisational, or contractual measures to ensure an appropriate level of protection.
Would you like to know more about international transfers of your personal data, or receive a copy of the applicable safeguards? Please contact us at dlwc-nl-dnl_data_privacy@delaware.pro.
6 How long do we retain your personal data?
We do not retain your personal data for longer than necessary for the purposes described, unless a longer period is permitted or required by law. The main retention periods are:
- Data of rejected job applicants: 4 weeks after rejection, extendable to a maximum of 1 year with your consent;
- Contact details of customers and suppliers: for the duration of the business relationship, and thereafter for 7 years for administrative, accounting, or legal purposes;
- Data processed on the basis of your consent (for example newsletters, marketing communications and other processing activities that require consent): until you withdraw your consent or unsubscribe.
- Other personal data: only for as long as necessary for the purpose for which it was collected (GDPR Art. 5(1)(e)).
The specific retention period per processing purpose is set out in the tables in Chapter 3. These periods are derived from our internal Data Retention Standard.
7 What are your rights and how can you exercise them?
The GDPR grants you various rights. In principle, you can exercise these free of charge. Sometimes a legal restriction applies, for example if your request affects the personal data of someone else, or if we are legally required to retain data.
You can exercise your rights via dlwc-nl-dnl_data_privacy@delaware.pro or by post: delaware Consulting B.V., attn. the Data Privacy Officer, Hambakenwetering 5J, 5231 DD ’s-Hertogenbosch, the Netherlands.
We respond within one month. If we need more time, we will inform you of this within that month. The total period is a maximum of three months. Which rights apply depends on the processing and the legal basis.
7.1 Right of access and rectification
You can ask which personal data we process about you, receive a copy, and have inaccurate or incomplete data corrected.
7.2 Right to object
You can object at any time to the processing of your personal data for direct marketing. If you object to direct marketing, we will no longer process your personal data for that purpose. You can also, because of your specific situation, object to processing that is based on a legitimate interest of ours or of a third party.
7.3 Right to withdraw consent
If processing is based on your consent, you can always withdraw that consent via dlwc-nl-dnl_data_privacy@delaware.pro. This does not affect the lawfulness of the processing before the withdrawal.
7.4 Right to restriction of processing
In certain situations, you can ask us to temporarily restrict processing, for example if you dispute the accuracy of your data.
7.5 Right to erasure
You can ask us to delete your personal data, for example if it is no longer needed, if you withdraw your consent or validly object and there is no other legal basis.
7.6 Right to data portability
If we process your data by automated means on the basis of your consent or an agreement with you, you can receive this data in a structured, commonly used, and machine-readable format, or have it transferred.
7.7 Right regarding automated decision-making
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or otherwise significantly affects you, unless the GDPR allows an exception to this. We do not use such solely automated decision-making in the situations described in this privacy statement.
7.8 Right to lodge a complaint
Are you not satisfied with the way we handle your personal data? You can contact us so that we can review and address your complaint. You also always have the right to lodge a complaint directly with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens), P.O. Box 93374, 2509 AJ The Hague, the Netherlands (www.autoriteitpersoonsgegevens.nl). It is not required that you contact us first before lodging a complaint with the Dutch Data Protection Authority.
8 Does this privacy statement also apply to third-party websites?
If you click on a link to another website, the privacy policy of that website applies. We have no control over these websites and are not responsible for their content or privacy practices. Therefore, always read the privacy policy of the relevant website.
9 What happens if delaware Netherlands changes this privacy statement?
We may change this privacy statement to keep it up to date. In the event of material changes that affect you or your privacy rights, we will inform you of this. You can always find the most recent version at https://www.delaware.pro/en-nl/privacy.
10 How can you contact delaware Netherlands?
Do you have questions, comments, requests, or complaints about this privacy statement or the processing of your personal data? Please contact the Data Privacy Officer of delaware Netherlands:
- by post: delaware Consulting B.V., attn. the Data Privacy Officer, Hambakenwetering 5J, 5231 DD ’s-Hertogenbosch, the Netherlands;
- by e-mail: dlwc-nl-dnl_data_privacy@delaware.pro.
