Privacy Statement

This privacy statement applies to the processing of all personal data of website visitors, clients, suppliers and job applicants by We Can Track B.V. (Chamber of Commerce number: 73567493), with its registered office at Purcellstraat 92, 1323 ME Almere, as the data controller. Hereinafter referred to as “We Can Track”. Please note that this Privacy Statement is not applicable to the services offered to We Can Track’s clients. If you want to find out more about the data that We Can Track processes for its clients, please read the Privacy Policy of the relevant client (affiliate publisher) or We Can Track’s Data Processing Agreement, which contains a general overview of the data that is being processed.

We Can Track values the protection of your privacy. We therefore take our responsibility to protect your personal data seriously. We Can Track has therefore, among other things, prepared this privacy statement for website visitors, clients, suppliers/partners and applicants.  

The purpose of this privacy statement is to be transparent about how We Can Track collects, uses and protects your personal data. We also explain how we comply with privacy legislation, such as the General Data Protection Regulation (“GDPR”). Please read this statement carefully to understand how we handle your personal data.  

What is personal data?

Under the GDPR, personal data is any information about an identified or identifiable natural person. This means that that information relates to a natural person who can, through this information, be identified, directly or indirectly.

About us

We Can Track is a controller within the meaning of the GDPR for the personal data we process from you.  

For what purposes do we process personal data?

We process your personal data only for specified, explicit and legitimate purposes. Below you will find more information about the different purposes. We process personal data of:

I. Visitors to our website and social media channels;
II. Clients;
III. Suppliers and partners; and
IV. Applicants.

I. VISITORS TO OUR WEBSITE AND SOCIAL MEDIA CHANNELS

1. For client service: handling questions/comments/complaints.

What does this purpose entail?

You can find our contact details on our website. When you contact us, for example by phone or e-mail, we process your personal data. We do this in order to answer your questions and process your comments and/or complaints. 

What is the legal basis for processing this personal data? 

The legal basis for this processing lies in our legitimate interest to carry out your request/answer your question (Article 6(1)(f) GDPR). 

What personal data do we process for this purpose?

We process only the personal data you provide to us, such as your name, contact details and any information you provide to us during our contact. 

2. Cookies and similar techniques: for analysis and to develop our website, products and services

What does this purpose entail? 

We also process personal data about you when you visit our website. In fact, our website uses cookies and similar techniques for functional, analytical and marketing purposes. The functional cookies are necessary for the use of the website.

What is the legal basis for processing this personal data? 

The legal basis is consent, which you give by agreeing to our cookie terms in the cookie banner on the website (Article 6(1)(a) GDPR) or, if they are functional cookies, we have a legitimate interest in a properly functioning and secure website (Article 6(1)(f) GDPR).

What personal data do we process for this purpose?

Through the use of cookies, we collect location data, your IP address or app ID’s, Internet browser and device type, and website language. 

International transfer

To process personal data by means of cookies, we use Google in the United States. This means that there is an international transfer. We have implemented appropriate safeguards through the model contract as approved by the European Commission (Standard Contractual Clauses, C(2021)3972) with our processor.

3. Sending our newsletter

What does this purpose entail?

Sharing our knowledge is important to us. For this reason, we process your personal data, for example, when you sign up for our newsletter through our website.

What is the legal basis for processing this personal data?

The legal basis is your consent (Article 6(1)(a) GDPR).

What personal data do we process for this purpose?

We process your first name, e-mail address and company name.

4. Schedule an appointment for a Demo

It is possible to schedule an appointment for a Demo to become acquainted with the We Can Track software. In order to schedule this appointment, we process your personal data.

What is the legal basis for processing this personal data?

The legal basis for this processing is our legitimate interest to schedule an appointment for a Demo with you (Article 6(1)(f) GDPR).

What personal data do we process for this purpose?

We process your name, e-mail address, telephone number, employer and job title, organization type and country.

II. CLIENTS (and third parties engaged by clients).

We process personal data of clients, their employees, contact persons and third parties engaged by them. The client is responsible for informing third parties engaged by the client of the contents of this privacy statement. A copy of this privacy statement can be found on our website. 

1. Execution of the agreement (day-to-day operations)

What does this purpose entail?

We process personal data for the execution of our agreement, such as for administrative purposes, to be able to contact you, to enable you to use our software, and to send you our invoices.

What is the legal basis for processing this personal data?

The legal basis for this processing is the performance of our contract (Article 6(1)(b) GDPR).

What personal data do we process for this purpose?

We process your name, position, telephone number, Chamber of Commerce number, employer, e-mail address, address details, account, billing details and VAT numbers and other relevant information provided during the execution of the agreement.

2. For client service: handling questions/comments/complaints.

What does this purpose entail?

When you contact us, for example by telephone or e-mail, we process your personal data. We do this in order to answer your questions and process your comments and/or complaints. 

What is the legal basis for processing this personal data? 

The legal basis for this processing lies in our legitimate interest to be able to contact you and provide our clients with thorough client service (Article 6(1)(f) GDPR). 

What personal data do we process for this purpose?

We process your name, address, telephone number, e-mail address, possibly position and any information you provide to us during our contact.

3. Marketing, including sending newsletters

What does this purpose entail? 

As a client, you have purchased a certain product/service from us. We are happy to inform you about other interesting products or services that might be relevant to you.

We also find it important to share our knowledge through our newsletter, which you can sign up for through our website.

What is the legal basis for processing this personal data? 

The processing of personal data for this purpose is based on your consent (Article 6(1)(a) GDPR) and We Can Track’s legitimate interest for marketing purposes in order to offer similar products and services to its clients (Article 6(1)(f) GDPR). 

What personal data do we process for this purpose?

We process your name, e-mail address, telephone number, employer, position and e-mail pixel for this purpose.

III. SUPPLIERS AND PARTNERS

1. For processing orders and assignments (daily business operations)

What does this purpose entail?

For the execution and settlement of our orders and assignments with you as a supplier (carrying out our daily business) we process personal data of (employees of) the supplier. This personal data helps us to provide you with the correct information for placing an order. We may also process personal data for financial processing. For example, if you act from a partnership. 

What is the legal basis for processing this personal data? 

The legal basis for processing personal data for this purpose is the conclusion or performance of a contract (Article 6(1)(b) GDPR). 

What personal data do we process for this purpose?

We process your name, position, telephone number, Chamber of Commerce number, employer, e-mail address, address details, account, billing details and VAT numbers and other relevant information provided during the execution of the agreement.

2. Communication purposes

What does this purpose entail?

In order to communicate with you as a supplier or partner, we process personal data from you. We do this to make the contact with you run smoothly. 

What is the legal basis for processing this personal data? 

The processing of personal data for this purpose is based on We Can Track’s legitimate interest to communicate with you (Article 6 (1)(f) GDPR). 

What personal data do we process for this purpose?

We process your name, address, telephone number, e-mail address and possibly position for this purpose.

IV. APPLICANTS

1. For a responsible, effective and efficient recruitment and selection process

What does this purpose entail?

For the recruitment and selection of new employees or temporary employees (freelancers), we process personal data. We do this to assess whether the applicant is suitable for the open position and vice versa. This personal data is stored by default for up to two months after the closing date of the vacancy. In this way, we can still provide you with substantive information if you have questions about the outcome of your application during this period. If the application leads to an appointment, the personal data will be stored in accordance with our retention policy.

What is the legal basis for processing this personal data? 

The legal basis is We Can Track’s legitimate interest in carrying out the recruitment and selection process efficiently (Article 6(1)(f) GDPR).

What personal data do we process for this purpose?

We process only the personal data you provide to us. This entails your contact details (such as name and address, e-mail address and telephone number), the personal data from your resume and your cover letter, diploma’s, a report of the interview, a salary proposal (if applicable), results of assessments (intelligence and personality), and in some cases the data we collect as a result of calling the references you provided.

2. Save your resume for suitable job opportunities in the future

What does this purpose entail?

If you apply to us, you, for various reasons, may not be hired for the position you are applying for. If we do click with you, we may be happy to include your details in our database so that we can contact you as soon as we have a suitable vacancy. We will then keep your personal data for twelve months after the closing of the original vacancy.

What is the legal basis for processing this personal data? 

The legal basis for this processing is your consent (Article 6(1)(a) GDPR).

What personal data do we process for this purpose?

We process your contact details (such as name and address, e-mail address and telephone number), and the personal data from your CV and cover letter.

Your rights

You have the right to be properly informed about what we do with your data and why we need your data. We do that through this privacy statement. In addition to the right to be transparently informed, you have the following rights:

• Right to access (if you want to know what personal data we collect from you);
• Right to rectification (we are happy to amend any personal data that is no longer correct);
• Right to be forgotten (in some cases, you can ask us to delete your personal data);
• Right to restrict processing (in some cases, you may ask us to restrict the processing of your personal data);
• Right to data portability (if you wish, we can transfer your personal data to another party or give you a copy of your personal data);
• Right to object (in some cases you may object to the use of your personal data).

If you wish to exercise any of your rights, please contact us by emailing us at [email protected]. To prevent abuse, we may ask you to adequately identify yourself before we process your request. Circumstances may arise that prevent us from fulfilling or not fully fulfilling your request. If such a circumstance arises, we will notify you. We will always respond to your request within one month. 

With whom do we share personal data?

We Can Track does not sell or trade your personal data to any third party. We Can Track may share certain personal data within the group or with a supplier that requires use or recording of your personal data for the purposes described above in this privacy statement and in accordance with relevant laws. In these limited cases, a specific supplier, partner or service organization may have access to your personal data. 

We Can Track may be required to provide certain personal data to third parties, such as government agencies in accordance with relevant legislation. We Can Track may also need to transfer your personal data to protect We Can Track’s rights, again in accordance with relevant law.

In addition, we engage parties who process personal data on our behalf (so-called “processors”). We conclude processing agreements with them (to the extent necessary). We do this so that when we provide them with personal data, it is properly recorded that they also secure this personal data properly and that they must report to us in a timely manner in the event of a data leak or suspected data leak.                        

In addition, personal data may be shared with:

• Potential new shareholders and their advisors.
• Accounting Firm. To perform our (annual) audits.
• IT service providers. While maintaining, managing and supporting our systems and applications, they may have limited access to various personal data. We will always be consulted in advance.
• Bailiffs and Administrators. To these we provide your name and contact information, financial information and employment information.
• Insurers. To this we leave your name, contact information and financial information.  
• (Legal) Advisors. This may be in the context of a possible transaction or when seeking (legal) advice. To this we leave your name and contact details, for example.

How long do we keep your personal data?

We will keep your personal data for as long as necessary for the purpose for which we use your personal data and/or as long as the law requires us to keep the personal data. Exactly how long varies. From a few months to many years, for example because it is necessary for our accounting purposes.

We will keep your personal data at least as long as your account remains active, unless you ask us to delete personal data or your account by contacting us at [email protected]. You can always view and/or change some of your personal data in your own account.

How do we protect your data?

Under Article 32 GDPR, we are obliged to take appropriate technical and organizational measures to prevent the loss of personal data or unlawful processing. With us, the security of your personal data is well regulated by physical, administrative, organizational and technical measures. 

Only employees authorized by us to do so have access to personal data. They have also signed a confidentiality agreement. We therefore have an appropriate level of protection. We also adjust this level of protection periodically when necessary. 

Our organization is designed to do everything possible to prevent breaches of security, a so-called data breach. If there is a data breach, we will act according to the data breach protocol.

Contact and complaints

If you have any questions about this privacy statement or wish to exercise your rights as a data subject, please contact us at [email protected]. 

In case of complaints about, for example, how we use your data or how we respond to privacy-related questions, you can file a complaint with the Personal Data Authority.

Almere April, 2024