Privacy Policy

Transformcity understands that being open and transparent about how we manage, use and process your personal data is of the upmost importance. We are committed to protecting your personal data.

How do we ensure your data is protected and what are your rights?
Privacy Notice  – whether you’re a client, supplier or business partner this Privacy Notice explains how and why we collect and use your personal data. It also outlines your rights on how to obtain, review or withdraw your data. We may change this Privacy Notice from time to time. Any such changes will be posted here, and any material changes will be made prominent. We encourage you to review this page from time to time.

Cookie Policy – explains why & how we use cookies including types of cookies and how to manage your own cookie preferences.

Contact Us:
For privacy related queries incl. rectification requests, access requests and complaints please contact info@transformcity.com.

Business Contact Privacy Notice

1. General
This Privacy Notice is applicable to the processing of all personal data of Business Contacts of Transformcity BV. ‘Business Contact’ or ‘you’ means each individual whose personal data is processed by Transformcity in its role as controller. This is when you work at a client, supplier or business partner of Transformcity, when you are a recipient of commercial messages of Transformcity or when you have another business relationship with Transformcity. This also includes employees of third parties providing services to Transformcity.

2. How do we collect personal data?
We collect your personal data both online and offline. Most commonly, we receive your personal data:
– From your direct interaction with us, either when doing business with you or when you visit our events or website.
– From your employer when your employer is our client, supplier or business partner, so we can perform our services and work with you.
– From public data sources like sanction lists, trade registers and LinkedIn, for instance where we need such personal data to verify your identity before we do business with you.

3. Purposes for which Transformcity processes your personal data
Transformcity processes your personal data for the purposes as set out below. We also inform you of the legal ground on the basis of which we process your personal data (as required by the EU General Data Protection Regulation). Where we rely on legitimate interest as a legal ground, we will always seek to maintain a balance between our legitimate business interests as described below and your privacy.
If Transformcity processes personal data for other purposes than as listed in this Privacy Notice, you will be informed thereof separately where required and consent will be sought if applicable local law so requires.
3.1. Assessment and acceptance of clients, conclusion and execution of agreements with clients, suppliers and business partners. This purpose includes processing of personal data that is necessary in connection with the assessment and acceptance of clients, suppliers and business partners, including confirming and verifying the identity of relevant Business Contacts (this may involve the use of a credit reference agency or other third parties) and conducting due diligence and screening against publicly available government and/or law enforcement agency sanctions lists (e.g. for compliance requirements). This purpose also includes the processing of personal data necessary to conclude and execute agreements with clients, suppliers and business partners, including required screening activities (e.g. for access to Transformcity’s premises or systems), delivery of client services, and to record and financially settle delivered services and projects to and from Transformcity.
The legal grounds for these processing activities are:
the fact that the processing is necessary for the performance of a contract to which you are a party;
compliance with a legal obligation to which Transformcity is subject; or
our legitimate interest.
3.2. Development and improvement of Transformcity’s services. This purpose addresses processing of personal data that is necessary for the development and improvement of Transformcity services and for research and development. This includes processing of business contact personal data for surveys, reviews and research. The legal ground for these processing activities is our legitimate interest.
3.3. Relationship management and marketing. This purpose includes processing of personal data that is necessary for activities such as maintaining and promoting contact with clients, suppliers and business partners via marketing communications, account management, client services, execution and analysis of market surveys and marketing strategies.
The legal grounds for these processing activities are:
your consent;
the fact that the processing is necessary for the performance of a contract to which you are a party;
or our legitimate interest.
3.4. Business process execution, internal management and management reporting. This purpose includes processing of personal data that is necessary for the management of company assets, conducting audits and investigations, reviewing and monitoring compliance with internal policies and procedures, finance and accounting, implementing business controls, providing central processing facilities for efficiency purposes and managing mergers, acquisitions and divestitures. This purpose also includes processing personal data for management reporting and analysis, archiving and insurance, legal or business consulting and preventing, preparing for or engaging in dispute resolution.
The legal grounds for these processing activities are:
the fact that the processing is necessary for the performance of a contract to which you are a party;
compliance with a legal obligation to which Transformcity is subject; or
our legitimate interest.
3.5. Health, safety, security and integrity purposes. This purpose includes the processing of personal data that is necessary for the protection of the rights, interests and assets of Transformcity and its employees, clients, suppliers and business partners and activities such as those involving health and safety. It also includes the authentication of client, supplier or business partner status and access rights.
The legal grounds for these processing activities are:
the fact that the processing is necessary for the performance of a contract to which you are a party;
compliance with a legal obligation to which Transformcity is subject; or
our legitimate interest.
3.6. Compliance with the law. This purpose includes the processing of personal data that is necessary for the performance of a task carried out to comply with a legal obligation to which Transformcity is subject, including the disclosure of personal data to government institutions or supervisory authorities.
The legal ground for these processing activities is compliance with a legal obligation to which Transformcity is subject.
3.7. Protection of the vital interests of Business Contacts. This purpose includes the processing of personal data that is necessary to protect the vital interests of you as our Business Contact.
The legal ground for these processing activities is protection of the vital interests of an individual.

4. Categories of personal data
The below overview contains the categories of personal data processed by Transformcity for the purposes described in this Privacy Notice. If Transformcity processes other categories of personal data than as listed in this Privacy Notice, you will be informed separately thereof where required and consent will be sought if applicable local law so requires.
4.1. Your personal details: including work e-mail address, work telephone number and work address; private email address, private telephone number, home address; job function or position; job history; picture or video.
4.2. Your company and communication details: correspondence between you and Transformcity; information to check your identity; your relationship with Transformcity; your behaviour towards Transformcity, its employees or clients, suppliers and business partners; credibility of your business; online available information (information on the processing of personal data that is collected via cookies or similar technologies, can be found in the cookie statements on the Transformcity websites).

5. For what period does Transformcity retain your personal data?
In general, Transformcity will retain your personal data for the duration of your business relationship with Transformcity (e.g. during the time Transformcity services are delivered to your employer and you are our Business Contact) and for the time it is necessary to keep your personal data after the end of the services. This period will depend on our purpose of use of your personal data. Examples are:
Where your business contact details are included in our invoices, we will keep your personal data together with our invoices (usually 7 years based on tax legislation).
Where your business contact details are included in our project plans, we will retain your personal data in accordance with our project plan retention periods (usually 10 years depending on the project).
Where we need your personal data for identification and screening purposes, we will keep your personal data for as long as we are required to keep proof of the screening based on local law.
If you are one of our prospects, we will keep your contact details during the time that Transformcity sends you commercial messages you are interested in (such as newsletters) and 24 months thereafter.
Transformcity will deviate from these retention periods if Transformcity has a pressing interest to keep your personal data longer (e.g. in case of ongoing or expected litigation).

6. Personal data access and transfer
6.1. Access to your personal data is only authorised to the extent such access is necessary to serve the intended purpose and for the respective staff to perform their job. Staff that are authorised to access your personal data may include your Transformcity point of contact, and Transformcity personnel such as within Finance, IT and Marketing.
6.2. From time to time, Transformcity may need to make personal data available to unaffiliated third parties, such as service providers (companies that provide products and services to Transformcity such as payment providers, IT systems suppliers), professional advisors (such as accountants, auditors, or lawyers) or public and governmental authorities (entities that regulate or have jurisdiction over Transformcity such as regulatory authorities, law enforcement, public bodies and judicial bodies). Transformcity will put in place agreements with third party service providers and professional advisors to protect your data protection interests.

7. Security
7.1. Transformcity will take appropriate technical, physical and organisational measures to protect personal data from misuse or accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure acquisition or access, that are consistent with applicable privacy and data security laws and regulations. This will include requiring service providers to use appropriate measures to protect the confidentiality and security of personal data.

8. Individual rights and complaints
8.1. Where your personal data are incorrect or incomplete, you always have the right to have your personal data rectified or completed by Transformcity.
8.2. Certain local laws grant you the right of access and deletion of personal data, objection to processing of personal data, restriction of processing of personal data, the right to withdraw consent and the right of data portability. Contact your local Privacy Officer to asses if you have these rights based on local laws or regulations.
8.3. The right of access means that you have the right to request an overview of your personal data processed by or on behalf of Transformcity. The rights of deletion and restriction imply that if your personal data is not processed in compliance with applicable law, you have the right to have this personal data deleted or restricted (as appropriate). The right to object means you can object to processing of your personal data (as appropriate).
8.4. The right of data portability means that a copy of your personal data provided by you to Transformcity will, at your request, be transferred to you in a common machine-readable format or transmitted to a third party without hindrance.
8.5. The right of withdrawal means that if the processing of your personal data was based on consent, you have the right to withdraw such consent. Such withdrawal will not affect the lawfulness of the processing based on consent before the withdrawal.
8.6. You can exercise your rights or file a complaint by contacting us at info@transformcity.com. Transformcity will perform your request in accordance with local law as applicable to you.
8.7. For data protection or privacy related complaints, you also have the right to file a complaint with the applicable supervisory authority.

This statement was updated on: 20 November 2020

Privacy Policy | Transformcity