PRIVACY STATEMENT MEMBERSHIP THE SHARING GROUP
- This statement describes the processing of personal data by The Sharing Group N.V. (TSG), which heads various group companies (the Labels or each individually a Label).
- TSG is a collective of different people, brands and investors with the same mission: more social impact, less environmental impact.
- To connect people and companies sustainably to – the Labels of – TSG, TSG offers a membership (the Membership). TSG does this through a digital platform (the Platform). The Platform is accessible to (potential) members through a web application with mobile access. In order to log in to their own environment within the Platform, a (potential) member must first register by creating an account (the Account), whether or not via a Label. In order to then be able to use the various parts of the Membership, a member must (depending on which parts of the Membership are used) complete their profile within the Account with the requested data.
- TSG handles your personal data with care and takes appropriate technical and organizational measures. TSG complies with the applicable privacy legislation, including the General Data Protection Regulation (GDPR) and the Implementation Decree (UAVG).
- Contact with TSG
- If you would like to contact TSG regarding this statement, you can do so via the contact details below.
Mail: Albert Einsteinweg 4, 8218 NH Lelystad
- Personal data
- Depending on which parts of the Membership are used, TSG may process the following personal data about you
- first and last name (contact person);
- company name;
- telephone numberr;
- e-mail address;
- date of birth;
- place of birth;
- bank- and payment details;
- other data, such as login-data and your unique customer ID(s)
- Which specific data TSG processes depends on the services TSG provides and the functionalities of the Platform that you use. At all times, TSG only processes personal data that TSG has obtained directly from you or – in connection with your Membership – from one of the Labels.
- TSG processes the above data for the following purposes:
- executing user agreements, including making it available provision of the Platform and the web application with mobile access;
- executing the parts – and associated agreements – of the Membership that a member uses, including the handling administrative transactions;
- marketing, including sending (commercial) information with relating to (i) the Membership, (ii) TSG products and services and/or the Labels, (iii) newsletters, (iv) announcements or (v) other marketing;
- providing personal data to Labels for commercial and marketing purposes;
- the use and improvement of the Platform, including the web application mobile access; and
- handling contact requests.
- Use of personal data
- When using parts of the Membership and the Platform, you can enter personal data and other data.
- Your personal data is mainly processed by TSG to implement the agreement(s) between you and TSG. TSG also processes personal data when it has the legal right or obligation to do so, when TSG has a legitimate interest to do so or when you have given TSG permission for certain processing.
- You can always withdraw given permission by sending an email to email@example.com. Withdrawal does not affect the lawfulness of the processing of personal data prior to the withdrawal.
- Marketing activities
We ask your permission to send marketing information digitally. We also do this for providing personal data for commercial and marketing purposes to the Labels, and the use of the relevant personal data by these Labels for commercial and marketing purposes. You give this permission online by activating a check mark. You can withdraw consent by unsubscribing from these emails via the link in the email.
- Providing personal data to third parties
- TSG involves third parties in the performance of its services. These may include service providers who have other expertise, but also service providers who provide services that support the Platform, such as Share Council (a Label of TSG), which provides TSG with support services with regard to purchasing and sales processes, financial transactions, etc. the issuance, management and administration of bond(s) and/or share certificates and associated (transaction) documentation. TSG may share personal data with such parties.
- TSG has outsourced certain activities for the performance of its services. In that case, this concerns, for example, parties involved in providing the website, e-mail functionality(s), the storage of e-mails, documents and data and the accountant. It may happen that these parties have access to personal data to perform their tasks.
- If TSG provides your data to a third party, that third party is obliged not to use your data for purposes other than those for which it was provided. This processing of personal data is, when required by law, recorded in a processing agreement.
- TSG will not provide any data to parties other than the parties referred to above or to Labels, unless this is legally permitted or required.
- Legal processing obligation and legitimate interest
It may happen that TSG has a legal obligation to (continue to) process certain personal data, for example for the tax authorities. In that case, TSG will comply with the legal obligation. TSG may also have a ‘legitimate interest’ in processing certain personal data.
- Security and custody
- TSG takes appropriate security measures to limit misuse of and unauthorized access to your personal data.
- TSG does not store your personal data longer than necessary. The specific retention periods depend on the services that TSG provides for you. In any case, TSG does not store your data for longer than seven years after the end of the agreement you have with TSG. If you withdraw your consent, TSG will delete the personal data for which you had given consent. The foregoing does not apply if TSG must or may store your data for a longer period based on a legal obligation. For example, because you still have certificates for shares or bonds.
- Third party websites
The TSG website may contain references to other websites, such as hyperlinks. TSG is not responsible or liable for the processing of personal data by those websites. This privacy statement does not apply to the use of those third party websites.
- Cookies and profiling
11.1 Cookies are small text files that are stored on your computer or mobile device when you visit a website. Cookies are used on the TSG website to provide an optimal user experience and optimize services. For example, you do not have to enter the same information every time and you can navigate through the website in question more easily.
11.2 We ask permission for the use of tracking cookies when you use the website. If you do not grant permission, no tracking cookies will be processed.
11.4 You can change whether or not you allow cookies in the settings of your browser.
- Transfer of data to recipients outside the European Economic Area
When using service providers and possibly passing on data to third parties with your consent, personal data may be transferred to recipients in countries outside the European Union (EU), Iceland, Liechtenstein and Norway (European Economic Area) and processed there. The following countries are considered by the EU to have an adequate level of protection for the processing of personal data in accordance with EU standards (so-called adequacy decision): Andorra, Argentina, Canada (limited), Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland, South Korea, Uruguay United Kingdom and United States. We make agreements with recipients in other countries on the application of EU standard contractual clauses, binding corporate regulations or other permissible mechanisms to create an ‘adequate level of protection’ in accordance with legal requirements.
- Social media
Social media buttons have been included on the TSG website to share pages via various social media networks. If you click on these buttons, your personal data will be processed by the relevant social media network. Read the privacy statements of the relevant parties to see how these networks handle your personal data.
TSG may change this privacy statement from time to time. Changes will be published on our website.
- Your rights: access and change of data
You have the right to object to the processing of your personal data. This includes the right to request TSG to inspect, restrict, rectify or delete your personal data. You can also request that your personal data be transferred to you. After receiving your request, you will receive an answer within four weeks. You can send such a request to firstname.lastname@example.org.
TSG would like to hear from you if you have any complaints about the processing of your personal data. Under privacy legislation, you also have the right to file a complaint with the Dutch Data Protection Authority.
Version 1.1, August 2023