Privacy Policy

Introduction

We are committed to safeguarding the privacy of our website visitors and service users. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users. In other words, where we determine the purposes and means of the processing of that personal data.

We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website. In this policy, ‘we’, ‘us’ and ‘our’ refer to Blue Umbrella. For more information about us, see under ‘Our details’ at the end of this document.

Credit

This document was created using a template from SEQ Legal (www.seqlegal.com).

Protection and confidentially of your Personal Data

Blue Umbrella undertakes substantial efforts to protect the confidentiality of your personal data consistent with this privacy policy. We continuously invest in security measures to safeguard your personal data. To protect your personal data, Blue Umbrella takes adequate measures in cases of loss, disclosure, misuse, unauthorized access, alteration or destruction.

You should also do your part in protecting your information. Your Blue Umbrella username and password (if such is provided or enacted) are confidential, and we recommend that you not divulge them to anyone.

Purpose of the collection of Personal Data

The purpose of processing your Personal Data is for providing our services, ensuring the security of and communicating with you. For clients seeking tax matters support:

  • to enable Blue Umbrella to file relevant data for various tax purposes, such as income tax return, vat filing, payroll taxes, allowances, motor tax and duties;
  • to enable Blue Umbrella to inform the relevant governmental bodies for tax or allowance purposes;
  • to provide tax or allowance related information to tax authorities or other relevant governmental bodies;
  • to administer membership records;
  • to contact individuals via surveys to conduct research about their opinions of current services or of potential new services that may be offered.

For registrars of the private website pages (‘MyBlue Page’):

  • to enable Blue Umbrella to inform registrar about it’s service and provide advice;
  • to maintain our own accounts and records;
  • to operate the Blue Umbrella and MyBlue Page web site and deliver the services that individuals have requested;
  • to inform individuals of relevant news, events, activities or services provided by Blue Umbrella.

How we use your Personal Data

In this section we have set out the general categories of personal data that we may process. In the case of personal data that we did not obtain directly from you, the source and specific categories of that data, the purposes for which we may process personal data and the legal bases of the processing.

Usage Data

We may process data about your use of our website and service. These data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics tracking system. This usage data may be processed for the purpose of analyzing the use of our website and services. The legal basis for this processing is legitimate interests, namely monitoring and improving our website and services.

Account Data

We may process your account data. The account data may include your name and email address. The source of the account data is you or your employer. These data may be processed for the purpose of operating our website, providing services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and the performance of a contract between you and us and taking steps, at you request, to enter into such a contract.

Profile Data

We may process your information included in your personal profile on our website. The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and the performance of a contract between you and us and taking steps, at you request, to enter into such a contract.

Service Data

We may process your personal data that are provided in the course of the use of our services. The service data may include name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details, employment details, assess ownership, copy of identity and other data points relevant for filing income tax, vat, payroll tax, corporate tax, allowances or other services related to tax matters about you and/or your partner. The source of the service data is you or your employer. The service data may be processed for the purposes of providing our services, ensuring the security of and communicating with you. The legal basis for this processing is consent.

Publication Data

We may process information that you post for publication on our website or through our services. The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

Enquiry Data

We may process information contained in any enquiry you submit to us regarding services. The enquiry data may be processed for the purposes of offering, marketing and selling relevant services to you. The legal basis for this processing is consent.

Customer Relationship Data

The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.

Transaction Data

We may process information relating to transactions, including purchases of services, that you enter into with us and/or through our website. The transaction data may include your contact details, your card details, bank account details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased services and keeping proper records of those transactions. The legal basis for this processing is consent or the performance of a contract between you and us and taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.

Notification Data

We may process information that you provide to us for the purpose of subscribing to our email notifications or newsletters. The notification data may be processed for the purposes of sending you the relevant notifications and newsletters. The legal basis for this processing is consent.

Correspondence Data

We may process information contained in or relating to any communication that you send to us. The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms, questionnaires and other information taking forms. The correspondence data may be processed for the purposes of communicating with you and record keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

Legal Data

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

Insurance and Consultancy Data

We may 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 legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

In addition to the specific purposes for which we may process your personal data set out in this section, 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, unless we prompt you to do so.

Sharing your personal data with others

We may disclose your personal data to any member of our group of companies (our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

We may disclose your personal data to our insurers and professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

We may disclose Service Data to our suppliers or subcontractors identified at www.blueumbrella.nl/subprocessors insofar as reasonably necessary for the purposes of providing our services, ensuring the security of and communicating with you.

Financial transactions relating to our website and services may be handled by our payment services providers, which can be reviewed on our website at www.blueumbrella.nl/subprocessors. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at www.blueumbrella.nl/subprocessors.

We may disclose your enquiry data to one or more of those selected third party suppliers of services identified on our website for the purpose of providing and improving our services and communicating with you. Your personal data will be treated as strictly confidential, and will be shared only with relevant services. Each such third party will act as a data controller in relation to the data that we supply to it.

In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure 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. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

International transfers of your personal data

In this section, we provide information about the circumstances in which your personal data may be transferred to.

We and our other group companies have offices and facilities solely in the Netherlands. The European Commission has made an “adequacy decision” with respect to the data protection laws. Transfers will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from European Data Protection Supervisor.

The hosting facilities for our website are situated in The Netherlands. The European Commission has made an “adequacy decision” with respect to the data protection laws. Transfers will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from European Data Protection Supervisor.

The supplier of data processing services are situated in the Netherlands, Germany, UK, Ireland and Sweden. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from European Data Protection Supervisor.

You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

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 process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We will retain your personal data as follows:

  • Personal data will be retained for a minimum period of 1 year following the date of provision, and for a maximum period of 7 years following the date of provision.

In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

  • rules and regulation of the Dutch tax law;
  • time required to exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

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.

Amendments

We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy. We will notify you of changes to this policy by email or through the private messaging system on our website.

Your Rights

In this section, we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Unless subject to an exemption under the General Data Protection Regulation (also known as the GDPR), you have the following rights with respect to your personal data.

The right of requesting access to your personal data

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, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of 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 first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by visiting www.blueumbrella.nl/myblue when logged into our website.

The right of requesting rectification of your personal data

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 without undue delay. Those circumstances include:

  • the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  • you withdraw consent to consent-based processing;
  • you object to the processing under certain rules of applicable data protection law;
  • the processing is for direct marketing purposes;
  • 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;
  • for the establishment, exercise or defence of legal claims;
  • in compliance the GDPR (AVG) legislation, Blue Umbrella reserves the right charge an administrative fee or refuse an erasure request if it carries a disproportionate expense, requires a disproportional effort or otherwise complicated circumstances arise from the request.

The right to restriction of 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, for a period enabling Blue Umbrella to verify the accuracy of it;
  • processing is unlawful but you oppose erasure and request restriction of their use instead;
  • we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims;
  • 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;
  • for the establishment, exercise or defence of legal claims;
  • for the protection of the rights of another natural or legal person;
  • for reasons of important public interest.

The right to object of processing

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for:

  • the performance of a task carried out in the public interest or in the exercise of any official authority vested in us;
  • the purposes of the legitimate interests pursued by us or by a third party.

If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

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.

You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

The right to data portability

To the extent that the legal basis for our processing of your personal data is:

  • consent;
  • that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

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.

You may exercise any of your rights in relation to your personal data by written notice to us.

About cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies that we use

We use cookies for the following purposes:

  • authentication – we use cookies to identify you when you visit our website and as you navigate our website;
  • status – we use cookies to help us to determine if you are logged into our website;
  • personalization – we use cookies to store information about your preferences and to personalize the website for you;
  • security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
  • analysis – we use cookies to help us to analyze the use and performance of our website and services;
  • cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

Tracking Cookies

We use tracking cookies to track how you use our website. This enables us to give you personal advice, including on our website, in our apps and by e-mail. We only set these cookies subject to your consent.


We may use cookies to modify the content of our websites, apps and e-mails with information that suits your needs and interests. We may, for example, check the following information:

  • Which pages you view on our website.
  • The information you check on our website.
  • Which products you are viewing.
  • Which functionalities you use.
  • What device you are using to visit our website.
  • The e-mails you read from us.
  • The items you click on in our e-mails.

To determine what information suits your interests, we create different groups of users which are highly similar to each other.  Business customers, for example, are interested in other products than consumers. This enables us to determine which products suit your needs and interests, or what questions you might like to ask us.


Note: even if you don’t give us permission to set these cookies, you may still see offers from us, but in this case these offers will not be based on your behaviour.

Social-media cookies

Share Blue Umbrella content on social media – for example, Facebook, Twitter, LinkedIn or Google+ – by clicking the social-media button on the web page are managed by social-media cookies. If you click the button, the various social networks will store cookies on your PC/laptop, phone or tablet. This is why we only use buttons if you give us permission to do so.


These cookies enable these social networks to see what you are doing on the internet. The types of cookies set by these social networks and how long cookies are stored depends on the social network you are using. This is a process which is beyond our control.


We recommend that you read the privacy statements of Facebook, Google, LinkedIn and Twitter:

  • Facebook
  • Google
  • LinkedIn
  • Twitter

Advertising cookies

We may use advertisements cookies to view what pages you visited on our website. We use this information to post advertisements relevant to your interests on other websites you visit. We work together with advertising partners such as Google and Facebook for this purpose. Through these partners, we can also search for other target demographics to whom our advertisements might be of interest. The advertising partners can use advertising cookies to track what other websites you are visiting. We only set these cookies if you give us permission to do so.


If you use our app, we will collect your device’s unique identifier (Advertising identifier on iOS devices and the Google Ad ID on Android devices). We do so for marketing purposes and only with your permission. You can determine how identifiers are used via your device settings. You also have the option of configuring them. The links below provide information on how to manage these settings on the operating systems for which our produces apps:

  • Apple iOS
  • Android 

We measure how many people click on our advertisements and how many of them purchase our product or apply for a job. This is how advertising cookies help us to improve our digital marketing.


Note: even if you don’t give us permission to set these cookies, you may still see offers from us, but in this case these offers will not be based on your behaviour.

Cookies used by our service providers

Our service providers use cookies and those cookies may be stored on your computer when you visit our website. We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. For Google’s privacy policy see our supplier’s website page at www.blueumbrella.nl/subprocessors. We use Zoho to provide campaign and email support. This service uses cookies for tracking email and campaign responses. For Zoho privacy policy see our supplier’s website page at www.blueumbrella.nl/subprocessors.

Managing cookies

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.

Our details

This website is owned and operated by Blue Umbrella Company B.V., registered in The Netherlands, under registration number 34331176. Blue Umbrella Company B.V. is registered office and principal place of business is at Keizersgracht 756, 1017 EZ Amsterdam, Netherlands. You can contact us:

  • by post, to P.O. Box 17208, 1001JE Amsterdam, Netherlands
  • using our contact form at blueumbrella.nl/contact
  • by telephone, on +31204687560
  • by email, using info@blueumbrella.nl

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