Privacy statement Keylane

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1.1 Introduction

We handle privacy and privacy-sensitive data with care within the limits of the General Data Protection Regulation or other applicable privacy legislation. In this Privacy Statement, we inform you about how we process personal data, for what purposes we process personal data, how you can exercise your privacy rights and other information about how we handle personal data. Personal information is information that can be used to identify an individual or that can be linked to an individual:

Please review the Privacy Statement section relevant for you:

Privacy statement section: Business contact person, supplier, partner, investor

Privacy statement section: Job applicants

Privacy statement section: Website visitors


This Privacy Statement applies to Keylane websites located at www.keylane.com, www.careers.keylane.com, and www.benefits-plaza.nl.

This Privacy Statement applies where Keylane acts as a data controller for third parties. We also process information from our customers as a data processor in which we follow their instructions but that topic is excluded from the scope of this Privacy Statement.

This Privacy Statement applies to all personal data that Keylane collects in connection with the services and products that we offer. References to Keylane in this Privacy Statement mean Keylane Topholding B.V. and any of its group companies.

Please do not hesitate to contact us if you have any questions or concerns related to the processing of your personal data.

1.2 Do we use cookies?

We use “cookie” technology on our website. A cookie contains information that is sent by a website and stored in your hard drive and temporary memory. You may change your cookie settings on your internet browser and/or our website or delete our cookies at any time.

We use necessary cookies, which do not affect your privacy. This includes functional cookies to improve the content, functionality, performance and usability of our website. This also includes limited analytical cookies in order to improve the website, namely to monitor the aggregate usage by website visitors, the types of browsers used and the web traffic routing of our website visitors.

Besides these, we offer the use of optional cookies. These would allow us to track the behavior of our visitors, and of embedded services, by which we can adjust the service and information supply of third parties accordingly.We always want to offer our business partners, job applicants and other website visitors the best information and service.

1.3 Google Analytics

This website also uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States.

Google may use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

For more information on the use of Google Analytics and how it collects and processes data please see the section “How Google uses data when you use our partners’ sites or apps”, located at https://policies.google.com/technologies/partner-sites.

1.4 Links to other websites

Please be aware that this website contains links to other websites on the internet that are owned and operated by third parties. The information practices of those sites linked to this website is not covered by this Privacy Statement, and we are not responsible for the privacy policies or practices of third parties operating those websites. If you provide any information to third parties operating sites to which this website links, the rules (if any) of the linked website regarding the collection and use of your personal information will apply. We strongly suggest you review such third party’s privacy policies before providing any data to them. These other websites may send their own cookies, collect data or solicit personal information. We cannot control this collection of information. You should contact these companies directly if you have any questions about their use of the information that they collect.

1.5 Contact

If you have a question or comment, please contact us at privacy@keylane.com or in writing to: Keylane B.V., attn: Data Protection Officer, Varrolaan 60, Postbus 13097, 3507 LB, The Netherlands.

1.6 Modifications

We may modify this Privacy Statement at any time and will notify you by posting an amendment to the Privacy Statement on our website.  Such modifications will become effective on the day they are posted. We encourage you to frequently review this Privacy Statement for any modifications.

This Privacy Statement has been created on 18 May 2018 and has been last updated on 11 November 2020.

Privacy Statement: Business contact person, supplier, partner, investor

What does this Privacy Statement cover?

This Privacy Statement provides information about personal data which are processed by Keylane Topholding B.V. and any of its group companies in relation to representatives and contact persons of customers and/or potential customers, vendors, distributors, investors, (individual) contractors and other business partners.

This Privacy Statement explains what personal data is processed, for which purposes, how long we hold the personal data for, how to access and update your personal data and where to go for further information.

What is the personal information that we collect?

We collect and use:

  • information that you or your company present to us such as: name, job title/ business function, organization, business address, telephone numbers (including mobile numbers) and e-mail address. In order to comply with legal and regulatory obligations, to protect our assets, employees, contractors and specifically to ensure that we can comply with trade control, anti-money laundering and/or bribery and corruption laws and other regulatory requirements, we may carry out screening on existing business counterparties and potential business counterparties pre-contract and on a need basis post-contract. The screening does not result in any automated decision making in relation to our counterparties or potential counterparties.
  • If you visit our offices and facilities, we may collect and use personal information stored in security badges and recorded by cameras on our premises. We do this for safety and security reasons. This footage may include sensitive personal information such as your race and ethnic origin.

Why do we collect this personal information?

  • Business execution – We use this personal information for business initiation, execution, after sales activities and management of the business and the commercial relationship. This includes identifying and following-up new business opportunities, responding to your enquiries, concluding new or updating existing commercial agreements, executing agreements, customer communication, direct marketing and after sales activities. Only employees in designated departments have access to your personal information for performing these tasks. In addition, we also have a legitimate business interest in furthering and strengthening our commercial and business relationship with you. We may for instance send you communication to introduce new products and services.
  • Legal and/or regulatory compliance – We may also disclose personal information to auditors, law enforcement agencies, governmental and supervisory authorities. This personal information may be used for preventing, preparing for or engaging in dispute resolution, legal proceedings and to protect us, our employees and the public against injury, liability, fraud, bribery or abuse. We may use this personal information also for complying with legal obligations.
  • Organisation and management of the business – Keylane may sell or purchase assets during the normal course of our business. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset and may be sold or transferred to third parties. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use any personal information provided through the website in a manner that is consistent with this Privacy Statement.
  • (Other) legitimate interest –  including security measures, e.g. authentication, which aim to ensure confidentiality, integrity, and availability of (personal) data and processes. .

We do not profile nor do we make use of any big data application.

We do not sell or rent your personal information to third parties.

Do we transfer your personal information to third parties?

We disclose personal information to certain third party service providers only if such disclosure is necessary for the purposes we describe in this Privacy Statement and then only if we are satisfied that it is legally permissible or required to provide the personal information. The third party service providers can include, e.g. recruitment agencies, IT systems providers, compliance program administrators, distributors, marketing representatives, transport companies, insurance companies, financial consultants, professional advisers and law firms.

We may give access to personal information to certain designated colleagues working for affiliated companies of Keylane. We only do so for the purposes listed above. Unless this Privacy Statement stipulates otherwise, we do not transfer personal data to companies based outside of the EU.

We may also store personal information in the cloud. This means that on our behalf, cloud service providers store your personal information across various locations worldwide. We require our cloud service providers to enter into suitable Data Processing Agreements, and take adequate organisational and technical measures to protect your personal information.  

How do we keep your personal information secure?

We maintain reasonable physical, technical, and organizational security measures to protect personal information against accidental or unlawful destruction, or accidental loss, alteration, unauthorized disclosure or access and will update these measures as new technology becomes available, as appropriate. We intend to keep personal information accurate and up-to-date. We also retain personal information no longer than is necessary to serve the purposes described in this Privacy Statement and taking into account specific legal requirements.

What are your rights?

You may at any time request to be informed of personal information that we process or have access to. If the personal information that we process contains inaccuracies or is incomplete, you may ask us to correct these inaccuracies or complement the personal information. These requests will be answered in a timely manner in accordance with applicable law. We will contact you and may ask you for additional information to verify your identity. In most cases, we will update the information as requested. In some cases, however, we may limit or deny your request if permitted or required by law or if we are unable to verify your identity. If you are not satisfied with the way we have responded to your request or if you do not agree with the processing of your personal information, you may file a complaint with the supervisory authority in your country of residence. 

You also have additional rights (subject to restrictions and exceptions):

  • The right to be forgotten. If such a request is granted, we will delete your data from our systems. We will inform third parties that process your data to do the same.
  • The right to restrict (also temporarily) the continued processing of personal information.
  • The right to have certain personal information transferred in a machine readable format.
  • You can also object to the processing of personal information for direct marketing purposes.
  • In so far the processing of your data is based on your consent, to withdraw your consent.

Privacy Statement: Job applicants

What does this Privacy Statement cover?

This Privacy Statement provides information about personal data which are processed by Keylane Topholding or any of its group companies. in relation to individuals who apply to work for, or who attend a recruitment event or undertake an assessment with Keylane. This includes prospective employees, interns and contractors.

This Privacy Notice explains what personal data we process about you, why we are processing your personal data and for which purposes, how long we hold your personal data for, how to access and update your personal data, as well as the options you have regarding your personal data and where to go for further information.

What is the personal information that we collect?

We collect and use:

  • information that you submit to us such as: name, (e-mail) address, telephone and mobile number, date and place of birth, salary indication, and all other information you may include in a resume and/or copies of certificates, educational and professional background and recommendations. We may process limited sensitive personal information via a submitted photograph or other details revealed in a resume. In some instances, we may also receive information relating to you from references you have submitted.
  • If you visit our offices and facilities, we may collect and use personal information stored in security badges and recorded by cameras on our premises. We do this for safety and security reasons. This footage may include sensitive personal information such as your race, ethnic origin or health.

Why do we collect this personal information?

  • Human Resources, personnel management, business process execution and internal management – We use this personal information for responding to your enquiries and deciding on your application (via e-mail, phone or on paper). Access to your personal information is limited to HR employees, managers and members of the hiring committees. We will request your consent only if legally required. In those cases where processing is based on consent, and subject to applicable local law which provides otherwise, you have the right to withdraw your consent at any time. This will not affect the validity of the processing prior to the withdrawal of consent.                                                                                 
  • Management reporting and analysis – including statistical analysis and surveys regarding the quality of the recruitment process.
  • Legal and/or regulatory compliance with law and/or with company policies and procedures. We may also disclose personal information to law enforcement agencies, governmental and supervisory authorities. This personal information may be used for preventing, preparing for or engaging in dispute resolution, legal proceedings and to protect us, our employees and the public against injury, liability, fraud, bribery or abuse. We may use this personal information also for complying with legal obligations.
  • (Other) legitimate interest –  including security measures, e.g. authentication, which aim to ensure confidentiality, integrity, and availability of (personal) data and processes.

We do not profile nor do we make use of any big data application.

We do not sell or rent your personal information to third parties.

Do we transfer your personal information to third parties?

We disclose personal information to certain third party service providers only if such disclosure is necessary for the purposes we describe in this Privacy Statement and then only if we are satisfied that it is legally permissible or required to provide the personal information. The third party service providers can include, e.g. recruitment agencies, IT systems providers, compliance program administrators, distributors, marketing representatives, transport companies, insurance companies, financial consultants, professional advisers and law firms.

We may give access to personal information to certain designated colleagues working for affiliated companies of Keylane. We only do so for the purposes listed above. Unless this Privacy Statement stipulates otherwise, we do not transfer personal data to companies based outside of the EU.

We may also store personal information in the cloud. This means that on our behalf, cloud service providers store your personal information across various locations worldwide. We require our cloud service providers to enter into suitable Data Processing Agreements, and take adequate organisational and technical measures to protect your personal information.  

How do we keep your personal information secure?

We maintain reasonable physical, technical, and organizational security measures to protect personal information against accidental or unlawful destruction, or accidental loss, alteration, unauthorized disclosure or access and will update these measures as new technology becomes available, as appropriate. We intend to keep personal information accurate and up-to-date. We also retain personal information no longer than is necessary to serve the purposes described in this Privacy Statement and taking into account specific legal requirements.

What are your rights?

You may at any time request to be informed of personal information that we process or have access to. If the personal information that we process contains inaccuracies or is incomplete, you may ask us to correct these inaccuracies or complement the personal information. These requests will be answered in a timely manner in accordance with applicable law. We will contact you and may ask you for additional information to verify your identity. In most cases, we will update the information as requested. In some cases, however, we may limit or deny your request if permitted or required by law or if we are unable to verify your identity. If you are not satisfied with the way we have responded to your request or if you do not agree with the processing of your personal information, you may file a complaint with the supervisory authority in your country of residence.  

You also have additional rights (subject to restrictions and exceptions):

  • The right to be forgotten. If such a request is granted, we will delete your data from our systems. We will inform third parties that process your data to do the same.
  • The right to restrict (also temporarily) the continued processing of personal information.
  • The right to have certain personal information transferred in a machine readable format.
  • You can also object to the processing of personal information for direct marketing purposes.
  • In so far the processing of your data is based on your consent, to withdraw your consent.

Privacy Statement: Website visitors

What does this privacy statement cover?

This Privacy Statement covers all information gathered with respect to visitors of websites located at www.keylane.com,www.careers.keylane.com, andwww.benefits-plaza.nl. This Privacy Statement explains what personal data is processed, for which purposes, how long we hold the personal data for, how to access and update your personal data and where to go for further information.

What is the personal information that we collect?

We collect and use:

  • Depending on the nature of your access to the website, you may be asked to provide personally identifiable information, which may include your name, address, telephone number, fax number, company name, and e-mail address. This information can be gathered when feedback or e-mails are sent to the website, when you register for certain services, when cookies are set, or directly in response to inquiries on the website.  In all such cases you have the option of not providing us with personally identifiable information, but certain portions of the website may not be available to you.
  • Information about your browser, device and on how you use our website. This information typically includes your Internet Protocol (IP) address, number of times you have visited our website as well as dates for the first and most recent visit, exact time when you accessed and left the website, information on the search engine used, what link was clicked and what search term used.

Why do we collect this personal information?

  • Functionality website – Except as otherwise stated below, we do not sell, trade or rent to others your personally identifiable information collected when you access or otherwise use the website. The information collected by the website is used for recruitment, sales and marketing purposes. We may disclose your personally identifiable information to third-parties for tracking purposes, to improve the functionality of the website, to perform statistical and data analyses, to deliver promotional emails to you, and to deliver information that you have requested from us. Additionally, if you provide us with content for publishing or feedback, we may publish your user name or other identifying data. We may use non-personal “aggregated data” to enhance the operation of the website, or analyze interest in the areas of our website. Moreover, we may in some circumstances disclose personally identifiable information to third parties to enhance your experience on the Site.
  • Legal and/or regulatory compliance – For legal proceedings and compliance with law and/or with company policies and procedures. We may also disclose personal information to law enforcement agencies, governmental and supervisory authorities. This personal information may be used for preventing, preparing for or engaging in dispute resolution, legal proceedings and to protect us, our employees and the public against injury, liability, fraud, bribery or abuse. We may use this personal information also for complying with legal obligations. Your personally identifiable information may be provided to a party if we file for bankruptcy, or if there is a transfer of the assets or ownership in connection with proposed or consummated corporate reorganizations, such as mergers or acquisitions.
  • Organisation and management of the business – Keylane may sell or purchase assets during the normal course of our business. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset and may be sold or transferred to third parties. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use any personal information provided through the website in a manner that is consistent with this Privacy Statement;
  • (Other) legitimate interest –  including security measures, e.g. authentication, which aim to ensure confidentiality, integrity, and availability of (personal) data and processes.

We do not profile nor do we make use of any big data application.

We do not sell or rent your personal information to third parties.   

Do we transfer your personal information to third parties?

We disclose personal information to certain third party service providers only if such disclosure is necessary for the purposes we describe in this Privacy Statement and then only if we are satisfied that it is legally permissible or required to provide the personal information. The third party service providers can include, e.g. recruitment agencies, IT systems providers, compliance program administrators, distributors, marketing representatives, transport companies, insurance companies, financial consultants, professional advisers and law firms.

We may give access to personal information to certain designated colleagues working for affiliated companies of Keylane. We only do so for the purposes listed above. Unless this Privacy Statement stipulates otherwise, we do not transfer personal data to companies based outside of the EU.

We may also store personal information in the cloud. This means that on our behalf, cloud service providers store your personal information across various locations worldwide. We require our cloud service providers to enter into suitable Data Processing Agreements, and take adequate organisational and technical measures to protect your personal information.  

How do we keep your personal information secure?

We maintain reasonable physical, technical, and organizational security measures to protect personal information against accidental or unlawful destruction, or accidental loss, alteration, unauthorized disclosure or access and will update these measures as new technology becomes available, as appropriate. We intend to keep personal information accurate and up-to-date. We also retain personal information no longer than is necessary to serve the purposes described in this Privacy Statement and taking into account specific legal requirements.

What are your rights?

You may at any time request to be informed of personal information that we process or have access to. If the personal information that we process contains inaccuracies or is incomplete, you may ask us to correct these inaccuracies or complement the personal information. These requests will be answered in a timely manner in accordance with applicable law. We will contact you and may ask you for additional information to verify your identity. In most cases, we will update the information as requested. In some cases, however, we may limit or deny your request if permitted or required by law or if we are unable to verify your identity. If you are not satisfied with the way we have responded to your request or if you do not agree with the processing of your personal information, you may file a complaint with the supervisory authority in your country of residence. 

You also have additional rights (subject to restrictions and exceptions):

  • The right to be forgotten. If such a request is granted, we will delete your data from our systems. We will inform third parties that process your data to do the same.
  • The right to restrict (also temporarily) the continued processing of personal information.
  • The right to have certain personal information transferred in a machine readable format.
  • You can also object to the processing of personal information for direct marketing purposes.
  • In so far the processing of your data is based on your consent, to withdraw your consent.