Privacy statement

INTRODUCTION AND SCOPE

This is the Privacy Statement of Tenpu B.V., a private company with limited liability, with registered office in Amsterdam, The Netherlands, and principal place of business in Amsterdam, The Netherlands, registered in the Dutch trade register of the Chamber of Commerce under number 89925858 and the organisations directly associated with it (Tenpu).

This Privacy Statement applies to all persons who have contact with Tenpu, except for its employees. More specifically, this means that this Privacy Statement applies to:

• clients, visitors, job applicants, principals, contractors (including self-employed persons without employees and suppliers, to the extent the latter are natural persons) and other contacts of Tenpu;
• visitors to the website of www.tenpu.eu or a domain name associated with this domain name;

All of these persons are referred to collectively hereinafter by ‘you’ and ‘your’. The words ‘we’, ‘us', and ‘our’ refer to Tenpu. Chapter 1 defines several terms. Those terms are capitalised in the Privacy Statement.

It is important to us that your Personal Data are handled with all due care. Needless to say, we comply with all statutory rules, including the General Data Protection Regulation (GDPR) and exercise due care to adequately secure your Personal Data.

We ask you to review this Privacy Statement carefully. For the sake of readability, we have divided the general portion of the Privacy Statement into chapters. You will find a table of contents below.

This Privacy Statement was most recently amended on, and has applied since, 01-01-2024.                                                                                                    

CONTENTS

1. DEFINITIONS
2. THE PERSONAL DATA PERTAINING TO YOU WHICH WE CAN PROCESS
3. WHY DO WE PROCESS YOUR PERSONAL DATA?
4. GROUNDS ON WHICH WE PROCESS PERSONAL DATA
5. SHARING PERSONAL DATA WITH THIRD PARTIES
6. SHARING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA
7. SECURITY
8. YOUR RIGHTS
9. COOKIES AND SIMILAR APPLICATIONS
10. RETENTION PERIODS
11. CONTACT DETAILS / QUESTIONS / COMPLAINTS / COMMENTS
12. AMENDMENTS

1.        DEFINITIONS

2.        THE PERSONAL DATA PERTAINING TO YOU WHICH WE CAN PROCESS

Below, we explain which of your Personal Data Tenpu can process.

Data you have provided yourself, such as:

• your contact details (name, address, city/town of residence, email address, telephone number);
• your gender and date of birth;
• personal username and job title;
• data collected from you in a telephone conversation;
• data collected from an email from you;
• payment details;
• data from your CV or about your employment history.

Data we have received via our websites, newsletters, and emails:

• information about the device you used to visit our website;
• your surfing behaviour on the website, such as:
• which data/which of our web pages you have viewed;
• how you navigate the website;
• whether you open a newsletter or email and which parts of it you click on;
• the dates and times of your visit to the website;
• the operating system you are using;
• your browser type and IP address;
• your Internet provider;
• the Internet address of the website to which the link is made;
• the geolocation;
• the data you downloaded from the website.

Data we have received from other sources, such as via:

• data available from public sources and apparently published by you, such as those on social media and commercial websites;
• data obtained from the Trade Register of the Chamber of Commerce and the Land Register and other governmental or public registries;

3.        WHY DO WE PROCESS YOUR PERSONAL DATA?

We use your Personal Data for the following purposes:

• to verify your identity;
• to improve our services (and the safety of those services), including by conducting checks;
• to inform you about news and developments at Tenpu and about Tenpu's products and services;
• to inform you about the products and services you use or have purchased from or through Tenpu;
• to notify you about any disruptions to our services;
• to enable us to evaluate, study, and develop our services;
• to contact you for newsletters, if you have signed up for them;
• for internal quality purposes;
• to manage, secure, adjust, and improve our websites;
• for marketing/commercial purposes;
• for recruitment and selection;
• to comply with a statutory obligation imposed on Tenpu;
• to be able to contact you and respond to any questions you have submitted;
• to deal with your requests for information and to settle complaints;
• to prevent theft, misuse, vandalism, or other criminal conduct;
• for educational purposes;
• to enable us to conduct satisfaction surveys.

4.        GROUNDS ON WHICH WE PROCESS PERSONAL DATA

In order for us to use Personal Data, we must have a ground to do so based on the GDPR.

We use the following grounds:

• you have given Tenpu your express consent;
• the use is necessary to performing or entering into a contract with you;
• the use is necessary to comply with a statutory obligation;
• in emergency situations: the use is necessary to protect your vital interests or those of another person;
• we have a legitimate interest in the use, unless this interest is outweighed by your interest, or a Third Party's interest, in privacy.

Tenpu can invoke the following legitimate interests:

• the protection of your safety;
• the protection of the safety of our clients and/or others, as well as the security of the buildings and property of Tenpu;
• quality and training;
• the advancement of IT management and the improvement of security;
• the analysis and improvement of the services and content of our websites;
• the supply, improvement, adjustment, support, research, and analysis of our services;
• the advancement of the quality and security of our services;
• communication with you and other contacts of Tenpu;
• the prevention and combating of fraud, unauthorised use, and violations of our general terms and conditions and policy rules or other harmful or illegal activities.

5.        SHARING PERSONAL DATA WITH THIRD PARTIES

We share your Personal Data with Third Parties only if this is necessary because those Third Parties perform work at the instruction of Tenpu and then only for the purposes described in this Privacy Statement. If a Third Party is engaged, Tenpu will ensure that this Third Party maintains the same level of security and confidentiality as we do.

Tenpu may engage contractors from the following categories:

• CRM platform;
• IT management;
• website management;
• website hosting;
• email communication.

Tenpu remains responsible for the processing of your Personal Data. Tenpu enters into contracts with Third Parties to ensure that your Personal Data are properly secured.

Tenpu may, as the result of a merger, acquisition, or sale, of all or part of its organisation, share your Personal Data with a Third Party, such as a potential buyer or seller. Naturally, we will inform you of this via email and/or a clearly visible notification on our website, and we will inform you of your rights in such a situation.

6.        SHARING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA

It may sometimes be necessary to transfer your Personal Data to Third Parties established outside the European Economic Area (‘EEA’). In accordance with the GDPR, Tenpu will only transfer your Personal Data to countries outside the EEA if:

1. the European Commission has decided that the third country offers an adequate level of protection; or
2. appropriate safeguards are offered, you have enforceable rights, and you have effective legal remedies; or
3. the transfer is necessary for the performance of your contract with Tenpu; or
4. you have expressly consented to the transfer after being informed of the risks that such transfer entails; or
5. the transfer is necessary for important reasons of public interest; or
6. the transfer is occasional and required by the compelling interests of Tenpu and Tenpu has implemented appropriate safeguards and has informed the Dutch Data Protection Authority of these.

In situations in which Tenpu transfers your Personal Data outside the EEA, we take measures to ensure that your Personal Data remain adequately protected.

7.        SECURITY

Tenpu takes the protection and security of your Personal Data very seriously and takes continuous measures to afford your Personal Data optimum protection against unlawful use. We have taken the following measures, among other things:

• access to the Personal Data is restricted to authorised persons, whereby this number is kept as low as possible;
• all employees of Tenpu have signed a confidentiality agreement, whereby they undertake to observe complete confidentiality with regard to all information (including Personal Data);
• the electronic transmission of Personal Data always takes place via a secure connection;
• the website is secured via https;
• we ensure that your Personal Data are only shared with Third Parties if we have agreed appropriate security measures with these Third Parties.

In addition, Tenpu ensures that all of its user settings, programs and services are designed from the very beginning of development to maximise your privacy protection. With regard to the provision of information and services, Tenpu applies the 'opt-in' rule by default: information or services are only provided if you have expressly consented to this. This can be done, for example, by ticking a box on the website.

8.        YOUR RIGHTS

If any of your Personal Data are processed, you have a number of rights, which are set out below. You may exercise these rights by submitting your request in writing to Tenpu or by sending an email to valentin.zberea@tenpu.eu. Tenpu verifies your identity before your request can be met.

Tenpu will respond to your request as soon as possible, but at the latest within one month. In principle, your requests will be processed electronically, unless this is not possible or you request otherwise. Tenpu will not charge you for the processing of the aforementioned requests, unless your requests are excessive.

1. Access to Personal Data

You can ask us at any time to indicate which (categories of) your Personal Data Tenpu processes, for which purposes, from which source the data come, and which retention periods are applied.

2. Changing Personal Data

In addition, you can contact us at any time to complete or correct your Personal Data. In the unlikely event that Tenpu has processed and/or provided incorrect Personal Data about you, Tenpu will rectify this immediately. If Tenpu has changed your Personal Data, Tenpu will notify you accordingly.

3. Minimising the processing of your Personal Data

If you do not agree with the content of the Personal Data about you stored by Tenpu, you can submit a request to temporarily minimise the processing of your Personal Data.

4. Withdrawing consent

        You can also withdraw the consent you have given for the processing of your Personal Data. Upon receipt of your letter or email, Tenpu will immediately cease processing of your Personal Data for which you have given your consent. However, the withdrawal of your consent will not affect the processing operations that have already taken place.

5. Right to transfer Personal Data (right to data portability)

You can retrieve the Personal Data about you stored by Tenpu in a structured, commonly used and machine-readable format. After receiving your Personal Data, you are free to transfer this information.

6. Right to be forgotten

If you no longer wish to make use of Tenpu's services, you may submit a request for the deletion of all your Personal Data.

7. Right to object

You have the right to object to the processing of your personal data which Tenpu bases on the grounds ‘legitimate interest of Tenpu or a Third Party' or 'performance of a task carried out in the public interest'. If Tenpu bases itself on these grounds, Tenpu will weigh its interests against your privacy. The right to object entitles you to require Tenpu to repeat this weighing of interests.

8. Right to lodge a complaint / pursue a judicial remedy

We make efforts to join you in working to find a fair solution if you have a complaint or problem relating to our use of your Personal Data. However, if your position is that we cannot assist you with your complaint or problem, you also have the option of lodging a complaint with the Dutch Data Protection Authority or instituting judicial proceedings. You will find the contact details of the Dutch Data Protection Authority (Nederlandse Autoriteit Persoonsgegevens) by clicking here.

9. The right not to be subject to a decision based solely on automated processing

10.     COOKIES AND SIMILAR APPLICATIONS

Tenpu uses cookies and similar applications on its website. Cookies are small pieces of information that are stored on your computer. We use cookies to provide services and ensure that our services function properly. This enables Tenpu to see how its visitors use the website. In this way, Tenpu can customise its website according to user preferences. On a subsequent visit to Tenpu's website, these small pieces will be recognised.

More information about the cookie policy can be found on: https://tenpu.eu/cookie-statement.

11.     RETENTION PERIODS

Tenpu does not retain personal data for longer than is necessary for the purpose of the processing. Tenpu retains your Personal Data as long we consider this necessary to be able to provide you with services, to enable you to use our website, to comply with applicable laws, to resolve disputes with parties, and for other purposes that enable us to conduct our commercial activities.

Tenpu in any case retains your Personal Data during the period in which you are party to a contract with Tenpu. Some Personal Data are subject to statutory retention periods. Tenpu fully complies with these retention periods.

12.     CONTACT DETAILS / QUESTIONS / COMPLAINTS / COMMENTS

If you have any questions, remarks or complaints about the protection of your Personal Data by Tenpu, you can of course contact us. Our contact details are:

• Valentin Zberea
• valentin.zberea@tenpu.eu

We trust that you ensure that your Personal Data are complete, correct, and up to date. Please inform us immediately of any changes or errors in your Personal Data by contacting us.

13.     AMENDMENTS

It may happen that our Privacy Statement will need to be amended. The most recent version is always available on our website. We inform you of any changes to the Privacy Statement by email and/or a clearly visible notification on our website.

***