Privacy Statement – Pallas Athena Group BV
Transparency and digital security are important principles of the service of Pallas Athena Group. Those aspects come back in this Privacy Statement. We attach great value to create a clear picture regarding your personal data as we shall inform you about these subjects in this Privacy Statement.
Article 1 – Definitions
1.1 Privacy Statement: this privacy statement.
1.2 Website(s): pallasathenagroup.nl, athenastudies.nl, athenastudies.de, athenadocs.nl, athenastudies.de en athenacareer.nl.
1.3 User: every user of our Website(s) and our services.
1.4 Responsible company: Pallas Athena Group is the controller and located at the Herengracht 450, 1017CA Amsterdam. You can reach us by e-mail on email@example.com.
1.5 Personal Data: the information specified in this agreement with regard to the identifiable natural persons.
Article 2 – Safe transmission of data
All the Personal Data we collect is always well secured. With the Secure Socket Layer (SSL) and the HyperText Transfer Protocol Secure (HTTPS), we have put in place appropriate technical and organizational measures for the use, extermination, loss, alteration, abuse or distribution of your Personal Data by unauthorized parties. Furthermore, Pallas Athena Group encrypts your Personal Data by using safe and stable systems and services.
Article 3 – Who is covered by this Privacy Statement?
This Privacy Statement applies to persons whose Personal Data is processed by Pallas Athena Group, these are:
- All persons who contact Pallas Athena Group
- All persons who fill in our feedback form/complaint form
- Clients of Pallas Athena Group
- Employees of Pallas Athena Group
- Potential clients which Pallas Athena Group have been or is going to be in contact with
- Receivers of Pallas Athena Group his e-mails
- Visitors to our Website(s)
Article 4 – The collection of Personal Data
4.1 Pallas Athena Group processes Personal Data of a User, which are received by visiting our Website, using our services, read our e-mails and by remaining correspondence.
4.2 Pallas Athena Group processes the following, by you provided, Personal Data:
- Contact details and other Personal Data which are necessary for the enforcement of our provision of services
- Contact details and other Personal Data which are filled in at our Website or within forms presented on the Website
- Contact details and other Personal Data which are acquired during introduction meetings and events
4.3 Pallas Athena Group processes the following Personal Data, which are acquired or created by our Website and other electronic technologies:
- Your IP-address
- Your surfing behavior on our Website
- Our behavior towards newsletters and other e-mails
4.4 Pallas Athena Group processes Personal Data, which are acquired from other sources:
- Personal Data present on publicly accessible social media platforms and business websites
- Personal Data present on national registers, such as the chamber of commerce
4.5 Through use of one or multiple of our Websites, we collect the following data:
- Bought products and/or services
- Phone number
Article 5 – Use of Personal Data
5.1 Pallas Athena Group is using your Personal Data for different purposes, which are outlined in this article.
5.2 Your Personal Data is being used to achieve the (automated) services wherefore you have hired us.
5.3 Your Personal Data is being used to send informative digital messages about new products and/or services. With those messages we keep you informed about the expansion and improvement of our products and services. Unsubscribing is straightforward and possible at anytime through My AthenaStudies or by using the ‘Unsubscribe’ link that every email contains.
5.4 Your Personal Data is being used to maintain the contact with you about products or services that have been purchased at Pallas Athena Group or going to be purchased in the future.
5.5 Your Personal Data is being used to optimize our products or services, for that reason we can request you to fill in a feedback form, participation is of course voluntary.
5.6 Your Personal Data is being used to adhere to our legal obligations.
5.7 Your Personal Data is being used to schedule business appointments at our office or another location.
Article 6 – Legal ground of the processing
6.1 We will never randomly process Personal Data. We always collect on the basis of one of the elaborated legal grounds as mentioned in the article.
6.2 We process your Personal Data on the basis of consent. The given consent for the processing of Personal Data may be revoked at any time. You can contact us at any time to revoke your consent.
6.3 We process your Personal Data on the basis of an agreement or as per your request before the closing of a final agreement. Such an agreement is entered into when you are going to use our products and/or services.
6.4 We process your Personal Data on the basis of a legal requirement.
6.5 We process your Personal Data on the basis of a justified interest. Based on this, we can invite you to certain events of Pallas Athena Group.
Article 7 – Processing parties
7.1 It can happen that we are using processors for the processing of Personal Data; those processors are always working on our behalf. We always conclude a processing agreement with those parties and such an agreement complies with the GDPR.
7.2 We work together with the following processing parties:
Google Adwords processes Personal data to show targeted search- and display-ads and for the purpose of ad benchmarking.
Google Analytics is used to analyse the traffic on our Websites. It processes data for the pupose of inproving the customer journey. The data includes, but is not limited to, clicks and behavior paths.
PayNL is one of our payment providers that enables payments through IDEAL and creditcard. It processes the required payment data of the customer.
PayPal is one of our payment providers. It processes the required payment data of the customer.
Postmark is our email provider. It is used to send transactional email. This is email that is sent after an agreed transaction, for example after creating an account or after ordering a product from one of our Websites. Postmark only processes the necessary information that is relevant for the customer.
To ensure optimal handling of questions and remark through our Website, we use Intercom. Intercom only processes either the basic Personal Data of logged in customers or the by an unknown customer specified data.
For targeted customer marketing, Mailchimp processes Personal Data. It only processes name and corresponding email address combined with the study where the customer is currently active.
For marketing purposes, MailManager processes Personal Data. It only processes email address.
New Relic is our software analysis tool for the purpose of monitoring our systems. Personal Data may be processed for optimal handling of errors and other problems that can occur in interacting with our Websites.
Part of our data storage is located at True. The storage centers are located within Dutch borders.
Part of our data storage is located at TransIP. The storage centers are located within Dutch borders.
To measure the effectivity of advertising we use Facebook Pixel. It analyses actions performed on our Websites which facilitates personal targeted marketing.
Article 8 – Change/removal of Personal Data
8.1 You have the right to insight, improve, replenish, delete and guard your Personal Data.
8.2 You can contact us in case you want to use one of the rights as described under 8.1 as we will process your request within one month.
8.3 If we cannot process your request within one month, we will pass on the reason why we couldn’t handle your request and we will give you a new time reference for the correct handling.
8.4 The information as described in this article, shall be provided for free.
Article 9 – Transfer to third parties
9.1 In certain cases it can be necessary to share your Personal Data with third parties. In any case, this depends on the circumstances and in such matter, we agree that those parties will be carefully and systematically verified. At any time, such parties will process the Personal Data with due care and attention. Fundamentally we will not share your Personal Data with other parties than the ones mentioned in article 7.2.
9.2 We shall share your Personal Data with third parties if this is necessary for the treatment of an order or process of your request.
9.3 We shall share your Personal Data with third parties if this is necessary for the treatment of a request at the chamber of commerce, the cadastre or another business organization.
9.4 We shall share your Personal Data with third parties if we are obliged by law or a judicial judgment.
9.5 We shall never share your Personal Data with third parties for commercial purposes.
9.6 We work together with Mailchimp en MailManager for our promotional services.
Article 10 – Storage of Personal Data
Your Personal Data will be stored by us as identifiable data, for as long as necessary for the objectives, for which it was originally collected. We shall always maximize our efforts to keep the Personal Data complete and accurate. Personal Data which is inaccurate or irrelevant, shall be cleared. As stated before, it is also possible to revoke your consent for the storage of Personal Data. If you withdraw your consent, we will delete/destroy all of your saved Personal Data.
Article 11 – Cookies
Pallas Athena Group is using cookies. You can find our policy with regard to cookies in our Cookie Statement.
Article 12 – Modification of this Privacy Statement
Pallas Athena Group has the right to change this Privacy Statement at any time. Any adjustment will be announced and explained on this page. We gladly advise you to visit this page on a regular base to check whether modifications have arisen. Whenever substantial changes are made, we will inform you per e-mail.
This Privacy Statement has been amended for the last time on 20 November 2018.