Knowledge, expertise and trust are important pillars of the service of PNO Consultants B.V. and the other group companies affiliated to the PNO-group, which mainly operate under the names PNO Consultants, CiaoTech, PNO Participation and PNO Innovation. We are committed to giving you clarity on how we handle your personal data. In this Privacy Statement we inform you about our approach to handling and processing of personal data.

1. Contact details

PNO Consultants B.V. (PNO Consultants) is the controller and is located at the Laan van Zuid Hoorn 15, 2289 DC in Rijswijk. By telephone you can reach us on +31 (0) 88-838 13 81, by e-mail at gdpr@pnoconsultants.com.

2. Who is this Privacy Statement applicable to?

This Privacy Statement applies to all persons whose PNO Consultants processes personal data, with the exception of persons working at PNO Consultants. Personal data are all data that contains information about persons with which those persons are identifiable.

This Privacy Statement applies to:

• clients of PNO Consultants,
• potential clients with whom PNO Consultants has made or wants to make contact,
• visitors to the website of PNO Consultants,
• recipients of newsletters and commercial e-mails from PNO Consultants, and
• any other person who contacts PNO Consultants or whose personal data is processed by PNO Consultants.

This Privacy Statement does not apply to employees, temporary workers, temporary workers, student trainees and applicants.

3. Which personal data do we process?

PNO Consultants respects your personal data and ensures that the personal information provided to us or otherwise obtained is treated confidentially. Personal data is all information about a person. Data that indirectly says something about someone is also personal data.

By processing personal data we mean: collecting, recording, organising, storing, updating, modifying, retrieving, consulting, using, providing by means of forwarding, distribution or any other form of posting, bringing together, linking together, and to protect, erase or destroy your personal data.

We process personal data that you have provided to us, personal data generated during your visit to our website and reading newsletters and personal data that we have derived from other sources, such as business social media platforms and business cards.

Personal information provided by you:

• contact details and other personal data necessary for the handling of your assignment by a consultant,
• contact details and other personal data entered on contact forms or other web forms, and
• contact information provided during introductory talks, events, seminars, etc., such as information on business cards.

Personal data obtained through or generated by our website, electronic newsletters, commercial e-mails or related technologies:

• IP number,
• your surfing behavior on the website, such as data about the first visit, previous visit and current visit, the pages viewed and the way in which the website is navigated, and
• whether you open a newsletter or commercial e-mail and on which parts you click.

See our cookie statement https://www.pnoconsultants.com/cookie-policy

Personal data obtained from other sources:

• personal data available on public business social media platforms such as LinkedIn,
• personal data obtained from the Commercial Register of the Chamber of Commerce, and
• personal data available on public business websites.

Our website may contain hyperlinks to websites of other parties and social media buttons. We are not responsible for the content of those websites or the services of relevant social media platforms. Nor is PNO Consultants responsible for the privacy policy and the use of cookies on those websites and social media platforms.

4. What are we using your personal data for?

We use your personal data for different purposes. We put them for you in a row:

• The execution of an agreement in which you have commissioned us to provide innovation and financing consultancy services by our consultants.

If you hand over an assignment to a consultant, at least your contact details are requested. Other personal data may also be necessary for the handling of the assignment, depending on the nature of the assignment. Furthermore, the data is used for invoicing the services provided.

• Compliance with legal obligations.
• The collection of fees.
• Recruitment and selection (job application).
• Maintaining contact with you.

Your contact details are kept in EU relationship management systems and can be used for sending newsletters, updates, invitations to events and seminars and sending information that you have requested from us.

• Improving our product and service information and carrying out targeted marketing campaigns.

We find it important to approach you with information that is relevant to you. To make this possible, we combine and analyze the personal data available with us. On that basis we determine which information and channels are relevant and which moments are most suitable for providing information or establishing contact. In marketing campaigns we do not process any special personal data and also no confidential data. If we would like to create a personal, individual customer profile, we will ask for your prior permission. If you would like to withdraw this consent later, this is always possible.

We analyse the following data:

• Interaction data: Personal data obtained from contact between PNO Consultants and you. For example about your use of our website or supported applications. This also applies to offline interactions, such as how often and when there is contact between PNO Consultants and you.
• Behavioral data: Personal data that PNO Consultants processes about your behavior, such as your preferences, opinions, wishes and needs. We can derive this data from your surfing behavior on our website, reading our newsletters or because you have requested information. But also through contact, incoming telephone calls and e-mail contact with our employees. Information obtained through tracking cookies, we collect and use only with your permission, which you can always withdraw.
  See our cookie statement https://www.pnoconsultants.com/cookie-policy
• Performing and analysing research into client satisfaction.
  Sometimes we ask clients to cooperate in a client satisfaction survey. This is done through an online questionnaire. Participation in this is voluntary. Prior to each client satisfaction survey you will receive further information about the working method and the way we deal with the information obtained.
• Improving and securing our website www.pnoconsultants.com
• Creating user statistics.
  The user statistics of the website enable us to get a picture of the number of visitors, the duration of the visit, which parts of the website are being viewed and the click-behavior. It concerns generic reports, without information about individuals. We use the information obtained to improve the website.
• Access control and company security.
  If you visit our office, we will note your name on arrival. In addition, camera images can be made on the outside of the office, at the reception desk and at the entrance to the meeting rooms. We do this to know in case of calamities who are in the building and to ensure that unauthorised people do not have access to the office. Camera images are in principle destroyed after 10 days.

5. Security level

We protect personal data, taking into account the state of the art, using appropriate technical and administrative security measures to minimize the risk of loss, misuse, unauthorized access, disclosure and modification. You can think of security software such as a virus scanner and firewalls, a secure internet connection, encryption of data and physical and administrative access controls to data and servers.

6. Storage of personal data

We do not store your personal data for longer than is strictly necessary for the execution of the purposes. If legal regulations apply to the storage, the personal data will not be kept longer than prescribed by law.

7. Legal basis of the processing

We process personal data on the basis of one of the following legal grounds:

• Obtained permission
• On the basis of an agreement or in the run up to the conclusion of an agreement
• Legal obligation
• In connection with a legitimate interest.

A controller may only process personal data if this can be based on one of the limitative enumerated legal grounds in the General Data Protection Regulation (GDPR). The four legal grounds on which PNO Consultants relies are:

• Permission:
  If we have requested your permission to process your personal data and you have given this permission, then you also have the right to withdraw this consent.
• Agreement or in the run up to the conclusion of an agreement:
  If you give us an assignment to provide innovation or financing consultancy services, we process personal data if and insofar as this is necessary for the execution of the assignment.
• Legal obligation:
  We only provide personal data to supervisors of investigative authorities if this is legally required. We will take measures in such cases that are reasonably necessary to ensure that your personal data is protected as well as possible.
• Justified interest:
  We may also process personal data if we have a legitimate interest and do not therefore disproportionately infringe your privacy. For example, we use your contact information to invite you for seminars and events.

8. Processors

We may use service providers (processors) for the processing of your personal data that only process personal data in our order. We conclude a processor agreement with these processors that meets the requirements set by the General Data Protection Regulation (GDPR).

For example, we work with service providers that offer SaaS solutions (software as a service) or provide hosting services. Furthermore, there are ICT service providers who offer us support in keeping our systems safe and stable. We also use third-party services for sending newsletters and commercial e-mails. These are examples of parties that can be designated as processors as referred to in the General Data Protection Regulation (GDPR).

9. Share personal data with third parties

We protect personal data, taking into account the state of the art, using appropriate technical and administrative security measures to minimize the risk of loss, misuse, unauthorized access, disclosure and modification. You can think of security software such as a virus scanner and firewalls, a secure internet connection, encryption of data and physical and administrative access controls to data and servers.

• In certain cases, personal data will be provided to third parties in the following cases:
• When processing a file, it may be necessary to share your personal data with third parties. For example in probing or asking for financing to a government, or the conclusion of an agreement involving several parties.
• If a court decision obliges us to provide personal data to third parties, we will have to comply with this.
• Your personal data will not be shared with third parties for commercial purposes. There is one exception to this. Sometimes we organise a joint activity with another organization, such as an event or seminar. In that case, only the necessary contact details are exchanged.
• Personal data can also be provided to third parties, in the event of a reorganisation or merger of our company or the sale of ( a part of) our company.

We never sell your personal data to third parties and do not make automated decisions that could have significant consequences for you.

10. Transfer outside the (European Economic Area) EEA

Under the General Data Protection Regulation (GDPR), personal data may only be passed on to parties outside the EEA if an appropriate level is guaranteed for the protection of the personal data or if a specific deviation applies.

We may pass on personal data to a party outside the EEA if this is necessary for the execution of the contract for the provision of innovation or financing consultancy services.

11. Privacy rights of data subjects

You can send a request for inspection, correction, restriction, resistance, transferability of data, deletion of your personal data

or withdrawal of previously given permission via the contact details below. You will receive further notice from us within four weeks of receipt of your request.

In order to ensure that we provide the relevant personal information to the right person on the basis of your request, we can ask you to provide a copy of a valid passport, driver’s license or identity card for verification purposes. PNO Consultants will only process requests that relate to your own personal data.
For all these questions, please contact us on +31 (0) 88-838 13 81, by e-mail at gdpr@pnoconsultants.com.

12. Complaints

If you have complaints about how we handle your personal data, you can contact us by sending an email to gdpr@pnoconsultants.com or by calling +31 (0) 88-838 13 81. We are happy to help you with finding a solution within a period of four weeks after receiving your request. If that does not work, you can always contact the Dutch Data Protection Authority.

13. Changes

Developments are fast and as a result, there may also be some changes in the personal data we request from you and the way in which we use your personal data. Regulations can also change. In that case, we will adjust this Privacy Statement. We therefore invite you to regularly check the Privacy Statement so that you are kept informed. In the event of major changes, we will also make you aware of this via our website.

Rijswijk, The Netherlands, June  8, 2018