This Privacy Statement provides information on how Explicit Selection processes personal data from clients, suppliers, business associates, visitors to our website, and people who subscribe to our content or download our reports. This Privacy Statement does not concern the processing of the personal data of employees of Explicit Selection.
Our contact details — Explicit Selection B.V., Chamber of Commerce nr. 68205074, Klein Heiligland 10, 2011 EG, Haarlem. Email: info@explicitselection.com.
1. Purposes for which we process your personal data
We process data for the following purposes:
- If you contact Explicit Selection (online or offline), we will use personal data such as your email address, name and telephone number. The basis for this is our legitimate interest in exchanging information with you. We will store your data so that we can exchange information with you in future, should it be necessary to do so.
- Compliance with statutory obligations and protection of Explicit Selection's interests. If you do business with us, or intend to do business with us, we will process your personal data for the purposes of assessment and acceptance, in connection with a contract or its performance, or an audit or legal proceedings. We may also use your personal data when checking whether you appear on a sanctions list or when performing due diligence in relation to existing or future investments by companies connected with Explicit Selection.
- If you download one of our reports or other content, or subscribe to our updates, we will use your name and email address to deliver the material you requested and, from time to time, to send you related Explicit Selection insights. The basis for this is our legitimate interest in sharing relevant professional analysis with the businesses and individuals who have shown an interest in our work. You can opt out at any time using the unsubscribe link in any message, or by emailing info@explicitselection.com, after which we will stop using your details for this purpose.
- When you visit our website and have given your consent through our cookie banner, we use Google Analytics to understand how visitors use the site — for example which pages are read and how people arrive — so that we can improve it. The basis for this processing is your consent, which you can withdraw at any time through our cookie settings. This involves Google LLC acting as our processor and may involve a transfer of data to the United States, which we address in the section on storage below. Google Analytics is configured so that it only runs after you have consented, does not store your IP address, and is not combined with Google advertising products. Further detail on the specific cookies is set out in our Cookie Policy.
- We do not subject visitors, subscribers or prospects to automated decision-making or profiling that produces legal or similarly significant effects.
2. Source of processed data
If we process personal data that we have not obtained from you, then that processing will always take place in connection with an agreement concluded with you or in preparation for a future agreement. That data will be obtained from public sources and registers (for instance from the Chamber of Commerce) or from consultants, in connection with an agreement to which you are party or an agreement with a firm at which you hold a position.
3. Disclosure of your personal data
Our firm will only disclose your personal data to third parties if obliged to do so by law or if necessary for the performance of an agreement that has been concluded.
4. Storage of your personal data
Once an agreement with you has been terminated, we will destroy all data that we are not required to retain by statute or regulations. An exception applies to publicly available information that is relevant for the purposes of any future contact (for example, email address, telephone number, address, LinkedIn details and information published by the Chamber of Commerce).
All personal data collected from individuals within the EEA is processed as much as possible within the EEA. We ensure that our data processing practices adhere to the GDPR's high standards of data protection and privacy. In a few cases personal data could be processed outside the EEA by our Sub-Processors, in that case we make sure we have contractual agreements with these Sub-Processors containing clauses to comply to chapter V of the GDPR (transfers of personal data) and additional recommendation or decision issued in this regard by the European Data Protection Board, European Commission or other competent authority or body under Applicable Law.
For people who have contacted us or subscribed to our content but with whom we have no agreement, we retain name and contact details for as long as you wish to keep hearing from us. You can ask us to stop at any time by unsubscribing or by emailing info@explicitselection.com. We review our contact list periodically and remove anyone who has had no engagement with us for 24 months. Data collected through Google Analytics is retained for 14 months and then deleted.
Where the use of Google Analytics involves a transfer of personal data to the United States, that transfer relies on Google's certification under the EU-US Data Privacy Framework, supported by Standard Contractual Clauses as an additional safeguard."
5. Your rights in relation to the personal data that we process
You have the following rights in relation to the personal data we hold about you: the right to access a copy of it; to have it corrected; to have it erased ('the right to be forgotten'); to restrict or object to our processing of it; to data portability; and, where our processing is based on consent, to withdraw that consent at any time. To exercise any of these rights, email us at info@explicitselection.com. We will respond within one month, as required by the GDPR.
If you are not satisfied with how we have handled your data or your request, you have the right to lodge a complaint with the Dutch data protection authority, the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl), or with the supervisory authority in your country of residence.
6. Data protection
We use various cloud services to store your information. We only use services that operate using secure internet connections and configure database authorisation in such a way that information is only accessible to those who need it.
7. Force majeure, restrictions and complaints
Explicit Selection endeavors to comply with your rights under the General Data Protection Regulation. However, as there are security risks associated with data transfers over the internet that cannot reasonably be eliminated, Explicit Selection is unable to offer any guarantees in this respect. Explicit Selection stores data in systems that comply with generally accepted security standards. We store hard copy data in a locked room that cannot be accessed by unauthorised persons except by forcing entry.
In relation to the data provided under any agreements, we will clearly indicate how that data will be processed and where it will be stored.