Introduction

We are committed to safeguarding the privacy of our clients, contacts, and website visitors. With respect to this Privacy Policy “Policy” we are acting as a data controller with respect to the personal data of our clients, contacts, and website visitors; in other words, where we determine the purposes and means of the processing of that personal data.
This Policy does not apply to the collection and use of Personal Data in market research studies that we conduct. In these cases, kindly direct your privacy-related inquiries to our team that is conducting such specific project research. We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.
In this Policy, “we”, “us” and “our” refer to SKIM Group B.V. (“SKIM”) and its affiliates company. For more information about us, see “our details” section.

What information we collect

In this section we have set out:

  • the information that we may collect;
  • in the case of information that we did not obtain directly from you, the source of that data.

We collect and process the personal data that you give us when you’re contacting us, meeting us in person, or supplying to us in the event that you report an issue on our website, or through form submissions on our website. This personal data may include, but is not limited to:

  • Profile data such as first and last name, company name, job title, country, email address and phone number;
  • Correspondence data such as inquiry types and messages;
  • Preference data such as opting-in to our marketing communication;

In addition to personal data, we also automatically collect other data when you visit our website through our analytics tracking system. For this purpose we use Google Analytics with anonymized IP (see here for the Privacy Policy of Google Analytics) and HubSpot (see here for the Privacy Policy of HubSpot). This data may include, but not limited to:

  • anonymized IP address,
  • browser type and version,
  • operating system,
  • referral source,
  • length of visit,
  • page views, and
  • website navigation paths.

Where we store your personal data

We may transfer and/or store the personal data outside of your territory. The personal data might also be processed by employees of our suppliers or a SKIM entity based outside of your territory. The territory referred to in this policy is an area of land that is connected to you and where you are currently located. In all these situations, we will take all necessary additional precautions to protect your personal data as required by applicable law(s).. For example, if we proces your personal data of an EU citizen outside of the European Economic Area (EEA) , we ensure that standard contractual clauses would be applied.

Keeping your personal data safe

We take appropriate measures to guarantee that this Policy is followed and that your personal data is handled securely. All information collected by us is kept on safe servers. Furthermore, access to the information collected is restricted to those who are authorized to handle such information properly, including our own staff, contractors, and site service providers. Site service providers and our outside contractors are requested to adhere to the same security and privacy requirements as we do.

Cookies

For more on how we use cookies, please see our Cookie Policy.

How we use your personal data

In this section we have set out:

  • the personal data that we may process;
  • the purposes for which we may process personal data; and
  • the legal bases of the processing.

Profile and correspondence data

We may process your profile data and where applicable correspondence data. The profile data and correspondence data may be processed for the purposes of:

  • communicating with you;
  • enabling and monitoring your use of our website;
  • improving marketing strategy; and
  • for recruitment processes.

We obtain profile and correspondence data from you directly by you using the form on our website. . The processing of this data is based on legitimate interest according to Article 6(1)(f) of the GDPR.

SKIM uses third-party processors to enhance our services. Specifically, we utilize

  • ZoomInfo, our personal data enrichment platform, to improve data accuracy, though we do not share your correspondence data with ZoomInfo.
  • Additionally, we collaborate with a job recruitment platform, SmartRecruiters to manage our job recruitment processes.

Website usage data

We may process data about your use of our website. This usage data may be processed for the purposes of analyzing the use of the website to improve our website and to prevent any fraudulent behavior. The categories of the data that will be collected are detailed and outlined in the ‘What information we collect’ section above. The processing of this data is based on legitimate interest according to Article 6(1)(f) of the GDPR., as processing is important for monitoring and improving our website.

Your data is collected through trusted external partners who play essential roles in enhancing your experience on our website.

  • Google provides analytics and tag management,
  • HubSpot manages our CRM and marketing automation,
  • Hotjar offers heatmapping services,
  • Leadinfo identifies the companies our visitors belong to, and
  • LinkedIn handles social media advertising for those who opt in to advertising cookies

Preference data

We may process your preference data such as your marketing communication subscription. This data may be processed for the purposes of sending you the relevant email communication. We process this data based on your consent and based on our legitimate interest, and the preference data is obtained from you directly. You can always opt out for sharing preference data with us by clicking on the “Manage your subscription preferences here” or “unsubscribe” at the bottom of our marketing emails or contacting us using the details set out here.

Your preference data is collected through HubSpot, our CRM and marketing automation provider.

Providing your personal data to third party and other use cases

We may disclose and process any of your personal data identified in this Policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our compliance with legal obligation, namely the protection and assertion of our legal rights, your legal rights, and the legal rights of others.

We may also disclose and process any of your personal data identified in this Policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The processing of this data is based on legitimate interest according to Article 6(1)(f) of the GDPR, namely the proper protection of our business against risks.

In addition to the situations specified here, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Please do not supply any other person’s personal data to us

International transfers of your personal data

In this section, we provide information about the circumstances in which your personal data may be stored, processed, and transferred to any country where a SKIM entity or branch is located.

To facilitate our global operations, we transfer information, including but not limited to your personal information, such as profile data, correspondence data, website usage data, and preference data between the different SKIM entities. Our headquarters is located in the Netherlands and we have offices in the United Kingdom, Germany, the United States, Brazil, Costa Rica, and Singapore.

We have taken appropriate safeguards to require that your personal data will remain protected. When we share information about you within and among SKIM’s entities, we make use of standard contractual data protection clauses, which have been approved by the European Commission.

US-EU international transfer

To safeguard the transfer between US and EU, we rely on the EU-U.S. Data Privacy Framework Principles issued by The U.S. Department of Commerce and Adequacy decision EU-US Data Privacy Framework. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/welcome.

UK-EU international transfer

If the information is originated from the UK, the International Data Transfer Addendum to the EU Commission Standard Contractual Clauses shall apply. If the personal data originating from the United Kingdom is transferred to Processor when Processor is located in countries outside the United Kingdom that have not received an adequacy regulation by the UK Secretary of State for the Department for Digital, Culture, Media and Sport, then the International Data Transfer Addendum to the EU Commission Standard Contractual Clauses shall apply in addition to the standard contractual clauses.

Retaining and deleting personal data

This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

Personal data that we store and process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes unless a longer retention period is required or allowed by law.

Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Your rights

You may exercise any of your rights in relation to your personal data by a written notice to us. Please use our details for this purpose. You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to the supply of appropriate evidence of your identity.
Your principal rights under data protection law are:

  • the right to access;
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to object to processing;
  • the rights relating to automated decision-making;
  • the right to data portability;
  • the right to complain to a supervisory authority; and
  • the right to withdraw consent.

You can use the link or the unsubscribe-button provided in our emails or by contacting marketing@skimgroup.com. To exercise any of these rights, you can call the numbers listed or contact the email listed in our website’s “Our details” section.

The right to access

You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data we hold about you and any other details related your the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.

The right to rectification

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

The right to erasure

In some circumstances you have the right to the erasure of your personal data that we hold about you without undue delay. Those circumstances include:

  1. the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  2. you withdraw consent to consent-based processing;
  3. you object to the processing under certain rules of applicable data protection law;
  4. the processing is for direct marketing purposes;
  5. and the personal data have been unlawfully processed.

However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.

The right to restrict processing

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it : with your consent;based on legal grounds set forth in the applicable law.

The right to object to processing

You have the right to object to our processing of your personal data, resulting in that we will cease to process the personal information. Please note that this would mean that we could not in all situations fulfil our obligations towards you. Furthermore, SKIM retains the right to process personal data, where compelling legitimate grounds for the processing exist, which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims

The rights relating to automated decision-making

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

The right to data portability

In certain circumstances, you have the right to ask that we transfer personal information that you have provided to us to a third party of your choice.

The right to complain to a supervisory authority

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

The right to withdraw consent

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

Third party websites

Our website includes hyperlinks to third party websites. Please be aware that each of these websites has their own privacy policy. We have no control over, and are not responsible for, the privacy policies and practices of third parties.

Personal data of children

Our website is not targeted at children below 16 years of age and we have no intention to collect personal data from children. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

Our details

This website is owned and operated by SKIM Group B.V.

Questions regarding this policy, complaints about our practices and access requests should be directed to the SKIM Privacy Officer:

  • via e-mail: dataprotection@skimgroup.com
  • via mail: SKIM Group B.V. att: Data protection officer, PO box 29044, 3001 GA, Rotterdam, The Netherlands.

Please reference the subject of your request where applicable. We will investigate all complaints and attempt to resolve those that we find are justified. If necessary, we will amend our policies and procedures to ensure that other individuals do not experience the same problem.

If you would like to lodge a complaint against us, you may contact your local supervisory authority.

Amendments

We may update this policy from time to time by publishing a new version on our website.

Last updated: 3 Sep 2024