[Company name B.V.] (“we”, “us” or “our”) develops and manufactures high-tech unmanned aerial systems (drones) and related systems for defence and government customers. We are the controller, within the meaning of the General Data Protection Regulation (Regulation (EU) 2016/679, the “GDPR”), of the personal data described in this Privacy Statement.
You can contact us at [Company name B.V.], [street and number], [postal code and city], the Netherlands, by email at [privacy@company.com] or by telephone on [telephone number]. Our Chamber of Commerce (KvK) number is [number]. (Optional) Our Data Protection Officer can be reached at [dpo@company.com].
This Privacy Statement applies to the processing of personal data of:
A separate internal privacy statement applies to our own employees.
We only process personal data where we have a legal basis under Article 6 of the GDPR. The processing may be necessary for the performance or preparation of a contract, for compliance with a legal obligation, or for the purposes of a legitimate interest pursued by us or by a third party. You may also have given us your consent. Where we rely on legitimate interest, we always carry out a careful balancing of interests, and we will provide further information on this balancing on request.
When you visit our website, we process technical data such as your IP address, browser type, device information, the time of your visit and the pages you visit. We do this to operate and secure the website and to prevent and investigate misuse and cyberattacks. The legal basis is our legitimate interest. As permitted by law, we place analytical cookies that have little or no impact on your privacy without asking for your consent. All other non-essential cookies are placed only with your prior consent, in accordance with Article 11.7a of the Dutch Telecommunications Act (Telecommunicatiewet). For more information, please see our Cookie Statement.
When you contact us, we process your name, company name, job title, contact details and the content of your message. We use this data to respond to and follow up on your enquiry. The legal basis is our legitimate interest in handling business enquiries. If your enquiry may lead to a contract, the legal basis is the preparation of that contract.
For contact persons at our customers, partners, suppliers and subcontractors, we process their name, company name, job title, business contact details, correspondence, and data relating to quotations, contracts and orders. We use this data to prepare and perform contracts, maintain the business relationship and issue invoices. The legal bases are the performance of a contract and our legitimate interest. We retain financial and administrative data because tax legislation requires us to do so.
As a manufacturer of defence equipment and dual-use items, we are subject to export control and sanctions legislation. This includes Regulation (EU) 2021/821, the Dutch Sanctions Act 1977 (Sanctiewet 1977), EU sanctions regulations and Dutch legislation on strategic goods. For this reason, we screen business relations, their directors, ultimate beneficial owners and contact persons against sanctions lists and restricted-party lists, and we verify the end user of our products. For this purpose, we process name, company name, job title, date of birth and nationality where necessary, the information contained in end-user statements, and the outcome of the screening. The legal bases are a legal obligation and our legitimate interest in supplying our products only to authorised end users.
We process the information that applicants provide to us, such as their name, contact details, CV, cover letter, education, work experience and references. We use this information to assess the application. The legal bases are the preparation of an employment contract and our legitimate interest in finding suitable candidates. We only contact referees with your agreement. We retain your details for future vacancies only with your consent.
Some positions are designated as positions involving confidentiality (vertrouwensfuncties), because they involve working with classified information or on defence contracts. Under the Dutch Security Screening Act (Wet veiligheidsonderzoeken), these positions require a Certificate of No Objection (Verklaring van Geen Bezwaar, VGB). The screening is carried out by the Dutch Military Intelligence and Security Service (MIVD), which is itself responsible for the data it processes during the screening. We only provide the information needed to request the screening. We receive only the outcome and have no insight into the content of the screening. For other positions, we may ask for a Certificate of Conduct (Verklaring Omtrent het Gedrag, VOG), of which we only record that you have submitted a valid one.
We process criminal data only to the extent permitted by Article 10 of the GDPR and the Dutch GDPR Implementation Act (Uitvoeringswet Algemene verordening gegevensbescherming, “UAVG”). If a position requires security screening or a VOG, we will always tell you in advance.
When you visit our premises, we record your name, company name, time of arrival and departure, and the person you are visiting. We do this for access control and to protect our premises, employees and information. The legal bases are our legitimate interest and, where applicable, the security requirements imposed on us by law or by contracts with our customers. We may ask you to show an identity document.
We do not make a copy of it unless required by law, and we never record your citizen service number (BSN). (Optional) We use camera surveillance on and around our premises to protect people, property and classified information and to investigate incidents. This is indicated by signs, and the footage is only accessible to authorised staff.
If you report a vulnerability or security issue, we process your name, contact details and the content of your report. We use this information to investigate the report, resolve the issue and communicate with you. The legal basis is our legitimate interest in the security of our systems. You may also report anonymously or under a pseudonym. We do not share your details with third parties without your consent, unless we are required to do so by law.
For newsletters and events, we process your name, company name, email address and the details you provide when registering. We send newsletters with your consent. If you are already a customer, we may also inform you about our own similar products and services without your prior consent, in accordance with Article 11.7 of the Dutch Telecommunications Act. You can unsubscribe free of charge at any time using the link in every newsletter.
When you visit our company pages on social media, such as [LinkedIn], the platform processes your data in accordance with its own privacy policy. We and the platform are joint controllers for the visitor statistics of our page. The platform is the first point of contact for exercising your rights in relation to that processing. We receive these statistics only in aggregated form.
You are not legally obliged to provide us with personal data. Without certain data, however, we cannot answer your enquiry, process your application, or enter into or perform a contract. For deliveries subject to export control or sanctions legislation, we are legally required to verify and record certain data, and without that data we are not permitted to deliver. The same applies to positions involving confidentiality and to access to secure premises.
We usually receive personal data directly from you. In some cases, we receive it from other sources, such as:
We do not knowingly process special categories of personal data, such as data concerning health, religion, political opinions or ethnic origin, unless this is strictly necessary and a legal exception applies. We only process your BSN where required by law.
Our website and services are intended for professional parties and are not directed at persons under the age of 16. If we discover that we have nevertheless processed the data of a person under 16, we will delete it as soon as possible.
We never sell your personal data. We only share it where necessary for the purposes described in this Privacy Statement. This may involve the following parties:
We aim to process personal data within the European Economic Area (EEA). If data is nevertheless transferred outside the EEA, we put appropriate safeguards in place as required by Chapter V of the GDPR. This may be an adequacy decision of the European Commission, such as the EU–US Data Privacy Framework, or the European Commission’s Standard Contractual Clauses, supplemented with additional measures where necessary. On request, you can receive more information about these safeguards or a copy of them.
We do not keep personal data longer than necessary for the purpose for which it was collected. A longer period applies where the law requires one, or where the data is needed to establish, exercise or defend legal claims. The following retention periods apply:
Given the nature of our work, we attach great importance to information security. We take appropriate technical and organisational measures as required by Article 32 of the GDPR. These include need-to-know access control, encryption, network security, logging and monitoring, physical security of our premises, confidentiality obligations for employees and processors, and periodic review of our measures. If a personal data breach nevertheless occurs, we will report it within the statutory time limit to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) and, where necessary, to the individuals concerned, in accordance with Articles 33 and 34 of the GDPR.
Under the GDPR, you have the following rights:
Right to object. You have the right to object at any time, on grounds relating to your particular situation, to processing based on our legitimate interest. We will then stop the processing, unless we have compelling legitimate grounds that override your interests, or the processing is necessary for legal claims. You may object to direct marketing at any time, and we will then stop it immediately.
You can exercise your rights by contacting [privacy@company.com]. We may ask you to verify your identity. Please do not send us a copy of your identity document for this purpose unless we specifically ask for one. We will respond within one month. For complex requests or a large number of requests, this period may be extended by two months, in which case we will inform you within the first month. Exercising your rights is free of charge, unless a request is manifestly unfounded or excessive.
Your rights may be restricted where necessary for legal obligations, national security or the protection of the rights of others. This only takes place within the limits of Article 23 of the GDPR and Article 41 of the UAVG.
We do not take decisions based solely on automated processing, including profiling, that produce legal effects concerning you or similarly significantly affect you. Automated screening against sanctions lists is always reviewed by a member of staff before any decision is taken.
If you have a complaint about how we handle your personal data, please contact us first. You also have the right to lodge a complaint with the Dutch Data Protection Authority (www.autoriteitpersoonsgegevens.nl), or with the supervisory authority in the EU member state where you live or work, or where the alleged infringement took place.
Our website may contain links to third-party websites. We are not responsible for the content of those websites or for how those parties handle personal data.
We may amend this Privacy Statement, for example because of new legislation or changes in the way we work. The current version is always available on our website, with the date of the last change shown at the top. We will actively inform you of significant changes where appropriate.
This Privacy Statement is available in Dutch and English. In the event of any discrepancy between the two versions, the Dutch version prevails.
All communications are encrypted and handled in accordance with European security guidelines.
Tactical Development & Test Range Base - The Hague
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