Privacy statement

Privacy statement

Twence B.V. is dedicated to a sustainable society. We do this with clever solutions for sustainability and energy, but also with our service provision. In some cases, we will need more information for this. In this privacy statement you will find, among other things, information about what data we collect, for what purposes and for how long this data is stored. We believe it is important that we inform you in a transparent manner about our handling of your personal data.

About us
Twence B.V., with its registered office at Boldershoekweg 51, 7554 RT Hengelo, is responsible for the processing of your personal data as outlined in this privacy statement. If you have a question or would like to comment on our privacy statement, please contact Twence B.V. via:

Per post: Twence B.V.
Postbus 870
7550 AW Hengelo
Telephone +31 (0)74 240 44 44 (put through to Privacy)
Email: privacy@twence.nl

Personal data and processing
The legislation governing the handling of your personal data makes use of such terms as personal data and processing, among others. Personal data refers to all information that can be directly or indirectly traced to a single person. This includes your name, address, place of residence, telephone number and email address, but also your IP address or customer reference number. Everything that is done with this data is called processing. Consider, for example, the collection, storage, viewing, changing and deleting of personal data.

Whose personal data does Twence process?
We process personal data of persons with whom we have direct or indirect contact. Here, you can consider:

• existing or potential clients and their representatives;
• people associated with a company with which we have a business relationship;
• local residents and key figures who participate in a Twence organised (sounding board) group;
• visitors of our website;
• visitors of our location(s).

When does Twente collect personal data?

• If you would like to make use of our services.
• If you visit us at our location(s) or take part in a guided tour.
• If you have a question or a complaint, contact us via the contact form on our website.
• If you visit our website, then we place cookies on the device you used to visit our website. That may be your smartphone, tablet or desktop. More information about these cookies can be found in our cookie policy.
• If you contact our customer and/or complaints service, personal data may be recorded within the framework of the provision of services.
• If you would like to be kept informed of current developments concerning Twence and/or participate in our (sounding board) groups.
• If you visit us on location and want to make use of our wifi network, we will ask you to agree to our rules of conduct, after which you will be granted access to our wifi network.

What personal data does Twente collect?
The personal data that we collect from you depends on the way in which you come into contact with us. You will find an overview below of the personal data about you that we may process:

• First name and surname;
• Address details;
• Phone number;
• Email address;
• Financial data (invoicing service provision);
• Visual material (CCTV surveillance on sites);
• Licence plate (CCTV surveillance on sites);
• MAC and IP address;
• Location details;
• Cookies
• internet browser and device type.

Personal data of minors

• Guided tour
• It is possible for your underage child (minor) to take part in a guided tour of Twence. Prior to the excursion, Twence will receive the names of the participants so that, in case of an incident (for safety reasons), they can be handed over to the emergency services. This data will be irrevocably deleted after participation in the tour. It is also possible that the participants in a guided tour can be seen on the security cameras located on the site.
• Website visit
• Except for the data for the guided tour, we do not collect the personal data of minors without the consent of a parent or guardian. However, it is possible that we have unintentionally collected personal data, for example through a visit to our website by your underage child. After all, we are unable to directly check the age of visitors to our website. In order to prevent the personal data of your underage child being collected by us unintentionally, we recommend that you involve yourself with the online activities of your child(ren).

Purposes of the processing

• To establish and maintain a business relationship with you. If you would like to become a customer of Twence, we will need your personal data in order to provide our services. This will enable us to keep in touch with you, ascertain and verify your identity, and (if you so wish) properly handle the payment for the services with you. As long as you are a customer, your personal data will be subject to processing. This is necessary in order to be able to fulfil the agreement with you and if necessary to offer you support in the form of tailor-made advice. This data is carefully stored in our system with proper security measures to safeguard the confidentiality, integrity and availability of your personal data.
• Handling a question, request or complaint. You can get in touch with Twence in a number of ways. When you contact us, your personal data will only be processed in order to deal with your question, request or complaint. After this, your personal data will be irrevocably deleted.
• To be able to comply with legal obligations. Twence is required to comply with various laws and regulations. Within the framework of those laws and regulations, we have to register certain personal data and, in some cases, also pass these on to government authorities. An example of this is the fiscal obligation to retain financial data.
• In order to protect the safety of visitors, Twence and its employees. Security cameras are present on our sites. The use of cameras is indicated by signs. The use of these cameras is important in order to guarantee your safety, but also that of our employees and for the protection of our property. In addition, every visitor is signed in at the reception desk upon arrival and signed out upon departure. This attendance registration is purely to ensure your safety during your visit.
• In order to make use of our wifi network. You may use our wifi network during a visit to one of our locations. Your data, such as your MAC and IP address, are recorded when registering your arrival and when using the wifi network.
• Sharing developments with and mapping the interests of third parties. As an organisation, we would like to involve local residents and interested parties and keep them informed of current developments at Twence. We do this by providing stakeholders with the requested information and by possibly involving them in (sounding board) groups.
• In order to make sure that the Twence website works well and to tailor information (target group-oriented) to your needs. Twence uses cookies so that the site works properly, to analyse where and when errors occur on the website, and to tailor (target group-oriented) information to your needs.

Which grounds justify the use of your personal data?
We use your personal data on the basis of the following legitimate grounds:

• In order to fulfil an agreement;
• in order to comply with a legal obligation;
• If you have granted your consent. Please note! Regardless of the period of time that your consent is valid, you can revoke your consent at any time. In the event that you withdraw your consent, the withdrawal will take effect from the moment of withdrawal. This specifically means that your consent has no retroactive effect;
• In order to uphold our legitimate interests. In such a case, we will carefully weigh your interests against the interests of Twence. Only if we believe that our legitimate interests outweigh your privacy concern(s), will we process your personal data.

How long do we store your personal data?
We will not store your personal data any longer than necessary to achieve the purposes for which they are collected. In our processing register you will find an overview of the processing and retention periods.

Sharing with third parties
We will not sell your personal data to third parties and will only provide this data to third parties if this is necessary for the execution of our agreement with you or to comply with a legal obligation. If we engage companies that process your data on our behalf, we will always enter into a processing agreement to guarantee the security of your personal data.

Protection of your personal data
As an organisation, we are responsible for treating your personal data with due care and we secure your data by taking appropriate organisational and technical security measures. These measures are designed to ensure that your data is properly protected against abuse, loss, unauthorised access, unsolicited disclosure and unauthorised changes. If you are under the impression that we are not protecting your data sufficiently, or if you would like information about the specific measures that we have taken, please contact us via privacy@twence.nl.

Your rights
Whenever we process your personal data, the General Data Protection Regulation (executive order) provides you with a number of rights. Your rights and the procedure for exercising them are described below.

To exercise any of these rights, the privacy officer will contact you to ascertain your identity. The privacy officer will request for this purpose three personal details which are already known to us and which only the owner of these personal details is able to answer. It is also possible that the privacy officer may ask you for a copy of your identity document. If this is the case, you can use the Dutch government's CopyID application to do this. In this copy, please make sure that your passport photo, MRZ (machine readable zone, the strip with numbers at the bottom of the passport), passport number and Citizen's Service Number (BSN) are blacked out. This is to protect your privacy.

Right of access
You have the right to ask us which personal data of yours we are processing. We endeavour to deal with your request for access as quickly as possible, but at the latest within four weeks.

Right to rectification and erasure
If your data is incorrect or incomplete, you can request us to amend or supplement it. You can also request that your personal data be deleted. We strive to process your request as quickly as possible, but at the latest within four weeks. Please note that we may not be able to delete all your data because we are bound by certain laws, such as the fiscal retention obligation.

Right to restrict processing
You may request that we temporarily stop processing your data in anticipation of another request, such as your request for an amendment. You will receive a detailed response within a maximum of four weeks of submitting your request.

Right to data portability
The law also stipulates that you can make a request to have your data forwarded in a machine-readable form. If you submit such a request, we will endeavour to process it within a period of four weeks.

Right to object
You have the right to object to the processing of your personal data if we base the processing on a legitimate interest. We will consider your objection within one month. In doing so, we will weigh up the interests again, whereby we will take your views into account.

Questions and information
Do you have any questions about this privacy statement or would you like to receive more information about how we handle your personal data? Then please get in contact with us via privacy@twence.nl.

Complaints
Even though we take you and your interests into account as much as possible, it is nevertheless possible that you may not agree with our handling of your personal data. Should this be the case, we would like to discuss this with you in order to find a solution together. You can contact us in several ways, see the heading About us. Alternatively, you also have the option to lodge a complaint with the Data Protection Authority.

Amendments to the privacy statement
It is possible that we may adjust this privacy statement from time to time. We do this if there is a change to the processing of personal data, the law changes, or our policy is amended. For the most recent privacy statement, we recommend that you consult our privacy statement on the website.

This privacy statement was last amended on 10 March 2020.