1. Introduction

WorkBoost B.V. (hereinafter WorkBoost) takes extreme care with the personal data of visitors and users of its website, app and services. This privacy statement describes how WorkBoost handles the processing of personal data and its security.

If you have entered into a (user) agreement with WorkBoost or are bound by agreements in the capacity of coach, partner or supplier, those agreements made and any associated processing agreement take precedence over the provisions of this privacy statement.

Use of WorkBoost’s website(https://www.workboost.eu) and mobile application (“app“) is subject to this Privacy Statement. For its operation, WorkBoost processes data about you that consists of “personal data.“ Much of this is software-based. Therefore, prior to the first use of the app (registration), we ask you to agree to our data processing practices as described in this privacy statement.

WorkBoost takes great care in processing personal data of visitors and users of its website, app and services. WorkBoost collects only those personal data strictly necessary to enable the provision of services.
WorkBoost never processes your personal data for commercial purposes, such as sending advertisements or making offers to third parties. WorkBoost also does not become an “owner” of the personal data we collect: You remain in full control of the data you provide to WorkBoost. If this information is transferred to your coach, consultant and/or teacher with your consent, they too must respect your control.

WorkBoost does not retain personal data collected longer than necessary for the purpose for which WorkBoost collects or processes it.

WorkBoost observes applicable privacy laws when processing, storing and managing personal data. WorkBoost monitors the various processes and processing that involve personal data. WorkBoost is committed to a clear and transparent privacy policy. Any complaints or suggestions can be sent to privacy@workboost.nl.

This privacy statement may be updated from time to time to reflect current practice, application improvements and the development of privacy law. The latest version can be found on our website: https://workboost.nl/privacy . As a user of the app, you are automatically notified of a change.

2. Responsible

WorkBoost is a so-called data controller within the meaning of the General Data Protection Regulation (GDPR). This means that WorkBoost decides which personal data are processed, for what purpose and in what manner.
WorkBoost is responsible for ensuring that your personal data is processed in accordance with the AVG and in a proper and careful manner.

3. Contact details

WorkBoost B.V.
Notenstraat 29
2555ZN Den Haag
https://www.workboost.eu
privacy@workboost.nl

4. Processing personal data

WorkBoost processes personal data within the meaning of Article 4(1) of the AVG. Personal data is any data that can provide information about an identified or identifiable natural person.

• First and last name
• Email address
• Usage/progress/credits
• Login information

WorkBoost uses the name and e-mail address to maintain contact. The other optionally given information, completed assignments and answered questions, is useful for optimal operation of supporting learning and development processes. The login information serves to prevent unauthorized access by third parties.

Beyond the personal data listed, WorkBoost processes all responses, reports and other input only if you provide them to it yourself. That happens when you perform commands within the app. You thereby give WorkBoost permission to process the data in the manner described in this statement and to share it with your coach, consultant and/or teacher.

5. Processing special and/or sensitive personal data

WorkBoost does not ask you for any special and/or sensitive personal data when using its App. ‘Special personal data’ refers to; data on racial or ethnic origin, political opinions, religious or philosophical religion or belief, genetic and biometric data, health, sexual life, trade union membership and personal data under criminal law. If you nevertheless share such data in the completed assignments, it may (depending on the other usage agreements) be visible to your coach, consultant and/or teacher. WorkBoost will retain this data (unknowingly) for the aforementioned purposes.

6. Basis of processing.

WorkBoost must be able to base the use of this personal data on one of the bases in Article 6 of the AVG. WorkBoost uses your data exclusively for carrying out its activities aimed at supporting learning and development processes. The bases for the processing of personal data is the implementation of the WorkBoost development methodology, the fulfillment of a legal obligation, or for the representation of the legitimate interests of WorkBoost in data exchange with its application manager to improve functionalities of the app, website and services.
In addition, personal data may be used for communication, such as about changes in functionality of the operation of the app or website and updated terms and conditions.
In all of this, of course, your interests, fundamental rights or fundamental freedoms are weighed heavily. Finally, WorkBoost collects anonymized data to inform and inspire other users.
WorkBoost explicitly requests your prior consent for processing according to this statement.

7. Purpose of processing

WorkBoost processes personal data for the following purposes:

• Managing the relationship between you and your coaches, consultants and/or teachers;
• Being able to provide WorkBoost’s services to you in an optimal and secure manner;
• management of the technical infrastructure;
• answering questions and complaints;
• Providing intelligence and information to you;
• Conducting analytics on the use of the website and app on an anonymous basis.

8. Retention periods

WorkBoost retains personal data only as long as necessary to fulfill the purposes for which data are collected (Article 5, first paragraph, subsection e, AVG), to protect the legitimate interests of WorkBoost and as long as it is required to do so by law or as long as liabilities may arise as a result.

All your personal data, including your input into the app will be completely erased if you use the “delete my account” feature in the app. Your account, including all your personal data will be deleted at the time ordered by the controller, namely your company, organization, training institute or coach.

9. Sharing personal data with third parties

WorkBoost will not sell, share or otherwise transfer your personal information.

The sub-processors required for the provision of services are contractually obligated to protect the confidentiality and security of your personal data, in accordance with applicable law.

Your personal data may otherwise be accessed by transmitted to national and/or international regulatory, enforcement, public or judicial authorities, when WorkBoost are required to do so under applicable laws or regulations or at their request. If sub-processors process personal data outside the EEA for the provision and optimization of their services, this is always done via a secure connection (HTTPS) with at least TLS version 1.2. Questions about this can be directed to our the Privacy Officer at privacy@workboost.nl.

10. View, modify or delete data

Any person has the right to inspect his or her personal data and may request its correction or deletion. Any consent to data processing may be withdrawn at any time. To the extent that the processing is not based on consent, objection to the processing is possible. Deletion and correction of data may be rejected to the extent that a legitimate interest of WorkBoost opposes it. This is the case if WorkBoost’s legal position is harmed by the adjustment. In addition, each user has the right to transfer his or her data to an organization named by that person. This does not affect WorkBoost’s right to delete data if a user does not meet the requirements set for participation.

A request or withdrawal of consent to, or objection to, the processing of personal data is preferably received at: privacy@workboost.nl. The person whose data is involved will then be contacted for verification.

11. Security

Article 32 of the AVG requires WorkBoost to take appropriate technical and organizational measures to prevent the loss of personal data or unlawful processing. WorkBoost takes the protection of personal data seriously and takes appropriate technical, physical and organizational measures to prevent misuse, loss, unauthorized access, unwanted disclosure and unauthorized alteration.

Its purpose is to protect them from accidental or unlawful destruction or alteration, loss, unauthorized disclosure or access and from any other form of unlawful processing.

In addition, WorkBoost complies with the following obligations when processing your personal data:

• we collect and process only personal data that is adequate, relevant and not excessive as required for the above purposes;
• we ensure that your personal data is kept up to date and accurate (for the latter, we may ask you to confirm the personal data we hold about you and we also ask you to notify us on your own accord if your personal circumstances change so that we can ensure that your personal data is kept up to date); and
• we may process sensitive data about yourself that you voluntarily provide in accordance with applicable data protection rules and strictly as required for the relevant purposes stated above, with the data being accessed and processed only by relevant personnel, under the responsibility of one of our representatives who is subject to an obligation of professional secrecy or confidentiality.

If you nevertheless have doubts about this, you can report it to the Privacy Officer at privacy@workboost.nl.

12. Cookies

Cookies are small text files that are sent to your computer when you visit our websites. We use cookies for the purposes stated above and in accordance with this privacy statement.

We do not use cookies to track individual visitors or identify you, but to gather useful information about how our website and apps are used so that we can continue to improve them for our users. Personal data generated through cookies are collected in a pseudonymized form and are subject to your right to object to such data processing, as set forth below.

In particular, we may use the following types of standard cookies:

• user interface customization cookies (i.e. cookies that store your preferences of using our website);
• authentication cookies (i.e. cookies that allow you to leave and return to our websites without having to re-verify your identity);

You can adjust your browser to notify you when cookies are sent to it. If you do not want to receive cookies, you can also refuse them completely by adjusting the appropriate settings in your browser. Finally, you can also delete already set cookies.

For more information on how to manage cookies on your device, consult your browser’s help function or visit www.aboutcookies.org, which contains extensive information on how to do this on a wide range of browsers.

13. Rights and complaints

WorkBoost respects the privacy rights granted to you by law. You have – as far as reasonably possible – the right to access, correct, supplement, delete or block your own personal data. You can also – in some cases – request to be “forgotten” in which case all of your personal data will be deleted/wiped.

Requests can be sent to WorkBoost’s service desk, e-mail address: support@workboost.nl

WorkBoost will, if necessary in consultation with the Data Protection Officer, process a request for access, correction, addition, deletion or blocking. Your identity will be verified before the request is executed. A request to inspect, change or delete a user’s personal data will be handled by WorkBoost within a period of 4 weeks.

If you are not satisfied with the way WorkBoost handles your request or complaint you can contact the Personal Data Authority, www.autoriteitpersoonsgegevens.nl