The private limited liability company Soofos B.V. (hereinafter: “Soofos”) respects the privacy of everyone whose personal data is processed by Soofos, including visitors to and users of www.soofos.nl, the Soofos mobile application and derivatives thereof on which this privacy policy is posted (these, and each of them individually, are hereinafter referred to as the “Platform”).
Soofos considers the careful handling of personal data to be of great importance. Soofos will process your personal data in accordance with the General Data Protection Regulation (GDPR).
Soofos offers its services both to individual users (for example, consumers who take a course on their own initiative) and to users who obtain access through an organisation (for example, through an employer or educational institution).
Note: when creating an account on the Platform, both types of users can log in through the same domain. The way in which you obtained access (personally or through an organisation) determines which privacy rules apply to you.
Soofos processes personal data if and insofar as this is necessary to comply with a statutory requirement or court order, as well as on the basis of the following three legal bases:
This basis applies when you enter into a contract with Soofos or enter into a contract through the Platform with another provider of services or products, or when you have submitted an application or request to do so. Soofos processes personal data under this legal basis in the following cases:
Under this legal basis for processing personal data, Soofos processes your personal data only if and insofar as this is necessary to perform the relevant contract, including providing the Platform functionality agreed with you under that contract and being able to contact you insofar as this is necessary for the proper performance of that contract.
Under a contract entered into with you, personal data may be shared (automatically) with third parties. This occurs in the following situations:
If, as a student, you obtain a certificate or complete a course, users with an account on the Platform who follow you can see these updates on your timeline. It is also possible that others can verify your certificates. The links to them are public on the Platform, and information from your certificate is accessible if someone has the link to the verification URL. The certificate includes your name, the course you followed, and its completion date. Under your account, you can choose whether or not to shield certain data. You can therefore manage your privacy yourself in part under your account.
This basis applies, for example, to:
Your personal data may also be shared with third parties on the basis of a legitimate interest. This applies, for example, to:
The operators of the software referred to above process relevant personal data in order to provide Soofos with the software’s features.
Under this basis, Soofos processes your personal data only if and insofar as this is necessary to serve the legitimate interests referred to above. With regard to newsletters, you can unsubscribe from further receipt in the manner indicated in the relevant messages.
This basis applies when:
Under this legal basis, Soofos processes your personal data only if and insofar as this is necessary to handle your request or carry out that for which you have given consent.
Soofos stores your personal data within the European Economic Area (“EEA”). However, certain personal data collected by Soofos may be transferred to or stored outside the EEA because an external service provider of Soofos is established there. When this occurs, Soofos ensures that your personal data is processed outside the EEA in a secure and lawful manner. In this context, Soofos will therefore take the necessary steps to guarantee that your personal data is adequately protected.
You have the right to ask Soofos for access to, erasure of, and rectification of your personal data, as well as restriction of the processing concerning you. You also have the right to object to the processing and the right to data portability. This means that you can submit a request to Soofos to send the personal data that Soofos processes about you in a computer file to you or to an organisation named by you.
To ensure that you made the request, Soofos asks you to send a copy of your identity document with the request. In this copy, black out the MRZ (machine-readable zone, the strip with numbers on the document), document number, and citizen service number (BSN). This is to protect your privacy. Soofos will respond to your request as soon as possible, but in any event within four weeks.
Insofar as the processing of personal data is based on consent obtained from you, you have the right to withdraw this consent at any time, without this affecting the lawfulness of the processing based on consent before its withdrawal.
You have the right to lodge a complaint with the Dutch Data Protection Authority or, if you live in a country other than the Netherlands, the supervisory authority there.
Soofos retains personal data only for as long as is necessary in view of the purposes for which it is processed. Soofos implements appropriate technical and organisational measures to secure personal data against loss and against any form of unlawful processing. Taking into account the state of the art and the cost of implementation, these measures guarantee an appropriate level of security in view of the risks presented by the processing and the nature of the personal data to be protected. The measures are also intended to prevent unnecessary processing of personal data.
For questions about this privacy policy or questions or complaints about the processing of your personal data by Soofos, you can contact Soofos. Soofos will be happy to help if you have questions or complaints about Soofos’s processing of your personal data or if you wish to change or delete your personal data.