Privacy Policy

Updated: 28 December 2021

1 Introduction

1.1 This Privacy Policy (hereinafter: “Policy”) is used by Vinden.nl B.V., trading under the name Visymo Universal Search Group, a company with limited liability under the laws of the Netherlands, with its registered office and primary place of business at Stationsdwarsweg 7, 7461 AR Rijssen, the Netherlands and registered in the register of the Netherlands Chamber of Commerce under registration number 06088480 (hereinafter: “ MINCOMM INTERNATIONAL” or “we”)). MINCOMM INTERNATIONAL can be reached via our Contact Page.

1.2 MINCOMM INTERNATIONAL is committed to protecting your privacy. This Policy describes what we do with your data and applies to all information that identifies you or may be used to identify you with (“Personal data”) by MINCOMM INTERNATIONAL, such as but not limited to processing via the MINCOMM INTERNATIONAL websites (hereinafter: “Websites”). The Websites are intended for general audiences over the age of 16 years old. We do not knowingly collect information from children under the age of 16 years old.

1.3 If you are not at least 13 years old in the United States or 16 years old, please do not use the Websites.

1.4 This Privacy Policy is provided in English. Translations to certain other languages may be available and can be requested by contacting us here.

1.5 For ease of reference, each section of this privacy policy is set out below:

• Introduction
• Processing of Personal data
• Purposes of the processing
• Legal basis of the processing
• Recipients of your Personal data
• Retention of your Personal data
• Safeguarding your Personal data
• Your rights
• Amendments and questions

2 Processing of Personal data

2.1MINCOMM INTERNATIONAL is a data controller under the General Data Protection Regulation (GDPR). This means that with regard to any Personal data referred to in this Policy, MINCOMM INTERNATIONAL determines the purpose for which we process this data and we determine the means necessary for the processing of this data. As a data controller, we process the data set out in this section. MINCOMM INTERNATIONAL does not engage in automated decision-making.

Data collected directly from you

2.2 When you access our Websites, we may (automatically) collect the following information about you and/or your device:

• Your anonymous IP address;
• Your (mobile) device identifier;
• Information about your settings, such as screen ratio, screen resolution, language settings, browser information (user agent) and/or operating system;
• Query-string;
• Your Website preferences;
• Your location and time zone.

2.3 If you do not provide us with the aforementioned data, we are not able to provide you with our services.

Data you may provide to us

2.4 Access to the Websites, their content and any web search results generated by using the Websites in general do not require you to submit Personal data to us other than the information listed above. Under certain circumstances, you may wish to provide us with more information about yourself, for example in relation to any enquiry you may want to make with us or in case you apply for a job with us. When you are reaching out to us, we may process the following information about you:

• Your name;
• Your company name;
• Your email address;
• Your website;
• Your professional or employment information and educational records;
• Any other Personal data you provide us with.

2.5 If you choose to provide us with any additional Personal data, we recommend that you limit the provision of such data to the absolute minimum, and we discourage you from providing us with any sensitive Personal data, such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data or data about your sex life or sexual orientation.

Data collected via our partners

2.6 Third parties may be able to process data related to you through our websites in order to provide us with certain products and services. Such third parties may use technologies such as cookies, ad tags or ad beacons to collect information about your interaction with any products and services (such as advertisements) they offer through the Website.

2.7 To deliver relevant search results to you, we may use third party services, such as YouTube for video results. If you watch a video sourced from YouTube embedded in our search results page, then your use of the YouTube service is subject to the YouTube Terms of Service and the Google Privacy Policy.

2.8 Third-parties who provide us with products and services may also place cookies, ad tags and/or beacons that collect the information outlined above in order to provide us with products and services including analytics tools (e.g., Google Analytics) allowing us to analyze the performance of our Services and advertisers and ad networks allowing the delivery of relevant ads. These third parties may also collect information about you from other sources and combine it with other information collected about you from third party websites not affiliated with us. For example, advertiser and advertising networks, as well as data analytics companies who service them, may participate in interest based advertising and track your activity across various sites and/or devices where they display ads and record your activities, so they can show ads that they consider relevant to you. Where necessary, we will obtain your consent for these activities.

3 Purposes of the processing

3.1 Primary purposes for which we process your Personal data are to offer you the best services possible, to optimize our Websites and services and to ensure continuity thereof. More specifically, your Personal data can be used for the following purposes:

• To provide our services: we may need certain information about you in order to be able to provide our services.
• To customize our services: you have the option to customize the Website experience to your needs. In order to be able to remember your customizations, we may process Personal data about you, such as a unique ID and your anonymous IP address.
• To improve our services: our Websites and services are constantly evolving, and we are constantly working on improving your user experience and adding new functionality to our Websites.
• To secure our services: in order to be able to provide your with the best user experience possible, it is necessary to keep out hackers, automated bots or other threats. We are therefore constantly monitoring our services and the use of our services.
• To communicate with you: when you contact us, we process your contact details such as your name and email address and any other Personal data you may provide to us in order to be able adequately revert to you on your enquiry.
• For marketing purposes: data on your visit to our Websites may be used by our advertisement partners in order to serve you with advertisements about our services elsewhere.
• To exercise and safeguard our rights: we may need to exercise our legal rights in case you infringe our intellectual property, engage in fraudulent acts or act in violation of this Policy or our terms of service.
• To compensate our partners: as we show and run advertisements, certain Personal data may be needed in order to calculate the compensation to be paid to or received by or from our partners.
• To comply with a legal obligation: we may be required by law or by a court order to process (and/or transfer) certain Personal data.

4 Legal basis of the processing

4.1 We process your Personal data on the following legal basis:

• Execution of a contract with you: most processing activities are carried out in order to provide you with our services. We provide our services on the basis of our terms of service, a contract entered into with you when using our services.
• Compliance with a legal obligation: we may under certain circumstances be legally required to process your Personal data.
• Our legitimate interests: your Personal data may be processed by us based on our legitimate interest, such as our commercial interests. This may be the case with, among others, (re)marketing and compensation of our partners.
• Your consent: should certain processing activities not be related to our contract with you, a legal obligation or our legitimate interest, then we may process your Personal data on the basis of your consent.

5 Recipients of your Personal data

5.1 MINCOMM INTERNATIONAL may transfer your Personal data to the following categories of recipients:

• Suppliers: when such is necessary to enable the use Websites and services, we may transfer your Personal data to suppliers, subcontractors and business partners, such as our hosting provider that hosts the Websites, the provider of our job application platform, partners that help us to improve the user-experience of our services and providers of IT support, data backup, recovery service and office software.
• Group companies: we may provide Personal data to other companies within the MINCOMM INTERNATIONAL group of companies, if this is necessary for compliance, internal reporting, auditing or security purposes.
• Professional service providers: Our accountant, legal advisers and other professional service providers engaged by us for compliance reasons;
• Advertisement partners: Information on your Website visit may be provided to advertisement partners in order to serve you with (relevant) advertisements on our Websites and elsewhere, and to measure effectiveness of advertisements.
• Marketing partners: we may provide Personal data to third parties that help us to market our services, to create, deliver and measure brand experience and to help us make better strategic decisions.
• Law enforcement agencies: we may be under an obligation to provide your information to law enforcement, regulators, courts or other public authorities in relation to an official (court) order. In addition we may provide your data to law enforcement agencies, regulators, courts or otherwise in order to exercise our rights.
• Fraud prevention: we may engage third parties when we believe disclosure is necessary to investigate, prevent, or respond to suspected illegal or fraudulent activity or to protect the safety, rights, or property of us, our users, or others.
• Third parties: we may transfer data to third parties acquiring or merging with MINCOMM INTERNATIONAL, or purchasing part or all of our assets, or in case of a corporate restructuring.

5.2 The third parties receiving or accessing your Personal data might be located outside the European Economic Area (EEA). When transferring data for which we are responsible to countries outside of the EEA (so-called ‘third countries’), we ensure ‘appropriate safeguards’. More specifically, we contractually bind recipients of Personal data to protect your data using the Standard Contractual Clauses (SCC’s) as approved by the European Commission. We will assess in advance (where necessary, with the help of the recipients in third countries) on a case-by-case basis if the law or practice of the third country diminishes the effectiveness of the SCC’s. In those cases, we will implement supplementary measures that fill the gaps in the protection and bring it up to the level required by EU law.

6 Retention of your Personal data

6.1 We retain your Personal data for as long as necessary in order to fulfil the associated purpose as set out above. After that, we may retain your Personal data if this is required or necessary in order to comply with applicable law or in order to be able satisfy any legal, reporting or audit requirements. Where possible we anonymize or pseudo-anonymize your Personal data or retain it in an aggregated form only.

7 Securing your Personal data

7.1 We highly value the secure processing of your Personal data. Therefore, we may implements security measures, such as but not limited to, as appropriate:

• The pseudonymisation and encryption of Personal Data;
• The ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
• The ability to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident; and
• A process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.

8 Your rights

8.1 You are provided with the following rights:

• Objection: Under certain conditions you have the right to object to the processing of your Personal data and the conditions under which this processing takes place.
• Access: You have the right to request from us, without constraint, at reasonable intervals and without excessive delay or expense, i) a confirmation as to whether or not Personal data regarding you is being processed, ii) information on the purposes for which Personal data is processed, iii) the categories of Personal data concerned, and iv) the recipients or categories of recipients to whom the Personal data is disclosed. You have the right to receive, in an intelligible form, a communication of the Personal data being processed and of any available information as to the source(s). Furthermore, you have the right to knowledge of the underlying logic of the automated processing of Personal data relating to you.
• Rectification, restriction, erasure, blocking or deletion: Under certain conditions you have the right to rectification, restriction, erasure, blocking or deletion of your Personal data that is not processed in compliance with data protection laws and regulations, in particular when the nature of the data is incomplete or inaccurate.
• Data portability: Under certain conditions you have the right to receive your Personal data in a structured, commonly used and machine-readable format to transfer those data.
• Withdraw consent: where we are processing Personal data relating to you on the basis of your prior consent to that processing, you may withdraw your consent at any time. The manner in which you can withdraw your consent to the use of cookies and other technologies can be found in the MINCOMM INTERNATIONAL cookie policy.
• Complaint with relevant authority. You have the right to file a complaint with the relevant data protection authorities, e.g. the Autoriteit Persoonsgegevens in the Netherlands.

8.2 You may exercise these rights by contacting us via our Contact Page, click the “Contact Us” button and then fill out the form.

8.3 In order to fulfil your possible requests pursuant to the rights as stated above, we may request specific additional information from you to identify you with or we may ask you for information to identify you with. We only collect and process such specific data with the purpose of executing your above stated rights insofar this is requested by you.

9 Amendments and questions

9.1 MINCOMM INTERNATIONAL may amend this Policy at any time. In case the Policy is amended, the amended Policy will be made available to you through publication of the amended Policy on the Website.

9.2 Should you have any questions after reading this Policy, or would want to exercise any right as stated in this Policy, please do not hesitate to contact us via the Contact Page.