Types of Data We Collect
We collect information (whether online, by phone, or by paper) that enables CAPE to identify or contact you (“Personal Data”) to carry out its business purposes. CAPE Sites collect this information for a variety of business reasons, including but not limited to, applying for employment, purchasing CAPE products or services, or otherwise interacting with CAPE.
The types of Personal Data we collect include, but are not limited to:
• General data (e.g., names, dates of birth, home and business addresses, email addresses, Internet protocol addresses, and mobile/landline business/personal telephone numbers that are provided by our members/customers);
• Professional data (e.g., technical or professional qualifications of our labor force or counterparties);
• Government-issued identification numbers (e.g., social security numbers, national identification numbers, and tax identification numbers), for example from employees and independent contractors;
• Other identification information (e.g., photographs);
• Financial information (e.g., bank account and credit card numbers, credit reports, passwords, and PIN numbers) for internal administration, external sales, or employment or contracting purposes.
CAPE also receives Personal Data from third parties for CAPE’s use in the administration of its business units, such as information concerning the identity and qualifications of our business counterparts.
We collect information (whether online, by phone, or by paper) that does not directly identify you as you interact with our Sites (“Non-Personal Data”). The types of Non-Personal Data we collect may include, but is not limited to:
• Site usage (e.g., browsing history, number of clicks, referring/exit pages, date/time stamp, time on Site);
• Site pages viewed;
• Computer type, operating system, and platform type;
• Internet service provider.
How We Use Your Data
In addition to the uses described above, we use your Personal Data, sometimes combined with Non-Personal Data, in a variety of ways including, but not limited to the below, in order to:
• Identify you when you visit our Sites;
• Provide service communications such as emails, invoice reminders, contract confirmations, and customer service messages;
• Provide products, information, and services you request or that we think you may be interested in;
• Respond to your emails or other requests for products, services, or information;
• Improve the usability of the Sites;
• Fulfill and/or deliver CAPE products and services.
We use Non-Personal Data to improve the usability of our Sites and for other business reasons. We do not provide Personal Data to third parties with whom we might share your Non-Personal Data. Please note that, when you select a news story link or another link that takes you to sites not operated by CAPE, you may be subject to the privacy policies of these third-party sites.
How We Share Your Data
We may share your Personal Data in a variety of ways including, but not limited to, the below:
• Share data with third parties to fulfill service requests and to perform business functions (e.g., CAPE contracts with third parties to provide services on our behalf such as data hosting services and customer support and consulting services).
• Share data with third parties as required by law or to protect CAPE in the good-faith belief that such action is necessary to: (a) conform to legal requirements or comply with legal process served on CAPE; (b) protect and defend CAPE’s rights or property; or (c) protect the personal safety of CAPE personnel or members of the public in appropriate circumstances.
• Share data with third parties if CAPE and/or its assets (or a portion of its assets) are sold, assigned, transferred, or merged, or if CAPE undergoes some other change including a change to its corporate form as part of a bankruptcy proceeding or otherwise; information may be transferred as part of that transaction or change.
• Share data with third parties in order for us to improve our ability to offer you products and services that may be of interest to you.
• Share data with third parties under other unanticipated situations, but only with your consent.
• Share your email address, but only as permitted by CAPE’s Email Policy, as follows: Your email address will be used only by CAPE and CAPE -related parties or subcontractors who are actively involved in performing or offering CAPE’s services or products. CAPE does not sell or rent email addresses to anyone outside CAPE, nor does CAPE share email addresses with unrelated third parties. CAPE may also share your email address with third parties to enable CAPE to take security measures to help protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data. Finally, CAPE may share email addresses with third parties to respond to your service requests.
How You Can Manage the Processing of Your Data
You can manage your profile and email preferences, including “opting out” of emails from us, by contacting us using the information in the “Contact Information” section below.
Our processing of your data is based upon your consent, contract performance (e.g., your purchase of CAPE products or services), legitimate business interest (e.g., the direct marketing of our goods and services), or compliance with the law. You have the right to object to our processing of your data or to restrict our processing of your data. In addition, if you have consented to the processing of your Personal Data, you have the right to withdraw your consent at any time.
EU’s General Data Protection Regulation (GDPR) and UK GDPR
CAPE guarantees the confidentiality of personal data provided by customers, suppliers, partners, employees, and website users, in accordance with the legislation in force regarding personal data, such as the General Data Protection Regulation (GDPR) and UK GDPR.
Under the General Data Protection Regulation and the UK GDPR, you have a number of important rights:
• access to your personal data and certain other supplementary information that this Privacy Notice is already designed to address;
• require us to correct any mistakes in your information which we hold;
• require the erasure of personal data concerning you in certain situations;
• receive the personal data concerning you which you have provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit those data to a third party in certain situations;
• object at any time to processing of personal data concerning you for direct marketing;
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
• object in certain other situations to our continued processing of your personal data;
• otherwise, restrict our processing of your personal data in certain circumstances;
• claim compensation for damages caused by our breach of any data protection laws.
If you would like to exercise any of those rights, please:
• contact us using our contact details below,
• let us have enough information to identify you,
• let us have proof of your identity and address, and
• let us know the information to which your request relates.
How to complain
We hope that we can resolve any query or concern you raise about our use of your information. The General Data Protection Regulation and the UK GDPR also gives you the right to lodge a complaint with a supervisory authority, in particular (under the GDPR) in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.
California Privacy Rights
Canada Anti-Spam Law
CAPE complies with the Canada Anti-Spam Law. Persons who provide us a Canadian mailing address will not receive unauthorized Commercial Electronic Messages (as defined under the Canada Anti-Spam Law) unless these individuals have “opted-in” to receive Commercial Electronic Messages.
We do not knowingly collect Personal Data from or market to children under the age of 14.
How We Protect Personal Data
User ID and Password
Certain areas of our Sites (for example, shared folders hosted on our web platform) require the use of a user ID, email address, or password as an additional security measure that helps protect your Personal Data. To help you protect your privacy, these Sites have tools to help you log in and log out.
Linking to Other Internet Sites
How You Can Access, Change and Delete Your Personal Data
Cookies and Other Web Devices
Transmission of Data to Other Countries
Your Personal Data is processed principally in The Netherlands. By submitting your Personal Data to us, you agree to the transfer, storage, and processing of your Personal Data in The Netherlands, as well as in the other countries where CAPE and its subsidiaries are located.
For EU and UK residents, CAPE will mostly transfer your data within the European Economic Area. CAPE may transfer your data to countries outside the European Economic Area on restricted and strictly necessary circumstances for the purposes described in this document and in accordance with the GDPR. If you would like to know the measures we have in place to secure personal information transferred outside the European Economic Area and the locations where your data has been transferred, please contact us using the details on the “Contact Information” section below
Right to Complain to Supervisory Authority
You, as the data subject, have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you believe that the processing of your personal data does not comply with legal requirements.
In the event we determine the occurrence of a data security incident, we will notify you by email, postal mail, telephone, or other means as permitted by law.
If you have questions, comments, or complaints concerning our privacy practices or if you wish to change, access, or remove your Personal Data, please contact us as indicated below. We will attempt, where practical, to respond to your requests and to provide you with additional privacy-related information.
9411 SB Beilen
Telephone: +31(0)593 540 470
Effective date: January 27, 2022