Privacy Statement

This is the privacy statement of Besloten Vennootschap met gewone structuur BrightOrange B.V., hereinafter Bright Orange. Bright Orange is registered with the Chamber of Commerce under number 59932341 and is located at Barbara Strozzilaan 201 (1083HN) in Amsterdam. This document explains Bright Orange’s approach to the processing of your personal data. In processing your personal data, Bright Orange exercises the utmost care.

Acquisition of personal data:

If you use Bright Orange’s services, you yourself provide Bright Orange with some personal data, or personal data is obtained from you as part of the agreement. Personal data means any data relating to identified or identifiable natural person.

Categories of personal data

Bright Orange processes the following categories of personal data:

  • Contact and name and address details, including location details, phone number, email address;
  • Company details, including VAT number and Chamber of Commerce number;
  • Different delivery address;
  • Financial data;
  • Account data, which also includes your password and username;
  • Other personal data provided by you.

Purpose of processing

The personal data processed by Bright Orange are for the purposes of:

  • contact you to inform you about the services you have purchased and the performance thereof;
  • perform its services;
  • improve its services;
  • make payments;
  • comply with legal obligations;
  • make marketing and communication statements, including improving the website by analysing visitor behaviour on the website;
  • send newsletters;
  • exchange data with third parties for the purpose of executing the services, insofar as this is necessary.

Basis of processing

The processing of personal data is only possible on the following bases: (i) legal obligation, (ii) performance of the agreement, (iii) (explicit) consent obtained from the data subjects, and (iv) legitimate interest. Personal data are processed during the provision of Bright Orange’s services. Bright Orange only processes data which Bright Orange deems necessary for (the improvement of) the services and treats with care the (personal) data it has collected about you and your use of the services. The basis for processing these data is the agreement you entered into with Bright Orange. Personal data of you may also be processed by visiting the website brightorange.nl if you have given your consent.

Need processing

The processing of your personal data is necessary to perform the services. The services provided by Bright Orange cannot be fully performed without the processing of your personal data. If specific purposes relating to personal data require your explicit consent, you must give your consent separately.

Automated decision-making

If there is any automated decision-making, this decision-making is done by computer systems and/or computer programmes without the intervention of human action. The data subject is himself or herself responsible for the data he or she provides and which are used at the time of automated decision-making. If the data prove to be incorrect or incomplete, any damage resulting from this will be at the expense and risk of the data subject. This also includes the non-, untimely or incorrect execution of the agreement.

Retention period

Personal data processed by Bright Orange shall be retained in accordance with the relevant laws and regulations. If a longer retention period is necessary on the basis of laws or regulations, the personal data will be kept longer in accordance with these requirements. All personal data (obtained) will not be kept longer than strictly necessary.

Third-party processing

Bright Orange only shares personal data with third parties if strictly necessary for the performance of an agreement and to comply with relevant laws and regulations. No personal data are sold. Bright Orange may be under a legal obligation to share personal data with third parties. If personal data is shared with third parties, processing agreements are concluded for this purpose. The third parties with which personal data are shared are:

  • The engaged delivery service(s), for the purpose of execution of the agreement. The categories of personal data processed are contact and name and address details.
  • The Payment Provider, for the purpose of executing an agreement. The categories of personal data processed are financial data.
  • The Bookkeeper, for the purpose of executing an agreement. The categories of personal data processed are contact and NAW data and financial data.
  • Software suppliers, for the purpose of agreement execution. The categories of personal data processed are contact and NAW data.
  • Website operator, for the purpose of execution of the agreement. The categories of personal data processed are contact and name and address details.
  • Engaged third parties, for the purpose of executing the agreement. The categories of personal data processed are contact and name and address details.

Security of Personal Data

Bright Orange takes the protection of your personal data seriously and in this regard, taking into account the state of the art, implementation costs, as well as the nature, scope, context and purposes of processing and the risks to the rights and freedoms of individuals that vary in terms of probability and severity, takes appropriate technical and organisational measures to ensure a level of security appropriate to the risk.

Younger than 16?

If you are a minor, i.e. under 16, you may only consent to the processing of your personal data with the consent of one of your parents or legal guardian. It is then important that your parent(s) or guardian reads this statement. They can also exercise the rights you have in relation to the personal data you leave with us, such as the right to oppose the (further) processing of your personal data or the right to access and correct your data.

Right of data subjects

As a data subject, you have the following rights:

  • Right of inspection;
    As a data subject, you have the right to obtain clarification as to whether or not your personal data are being processed and, where this is the case, to obtain inspection in relation to their processing.
  • Right to rectification;
    You have the right to obtain rectification and completion of inaccurate data.
  • Right to data erasure;
    Without unreasonable delay, a data subject must obtain erasure of personal data concerning him.
  • Right to restriction of processing;
    As a data subject, you have the right to restrict the processing of your personal data. To do so, please contact Bright Orange.
  • Right to data portability;
    A data subject has the right to obtain, in a structured, common and machine-readable form, the personal data relating to him or her that he or she has provided to Bright Orange, in order to possibly transfer this personal data to a third party. A data subject may also instruct Bright Orange to transfer such data directly to a third party.
  • Right of objection;
    The data subject shall have the right to object at any time, on grounds relating to his particular situation, to the processing of personal data concerning him, including profiling on the basis of those provisions. Bright Orange shall cease processing the personal data unless there are compelling legitimate grounds for the processing which override the interests, freedoms and rights of the data subject relating to the exercise, institution or support of legal claims.

Complaint

If you have a complaint about Bright Orange’s handling of your personal data, or wish to exercise any of the above rights, please contact us via the website or by email at . To ensure that you wish to exercise a right, Bright Orange requests that you enclose a copy of your proof of identity. You may hereby black out your passport photo and MRZ (strip of numbers at the bottom) to protect your privacy. Bright Orange will respond to your request as soon as possible, but at the latest within 4 weeks. You can also file a complaint with the Personal Data Authority. This is the competent enforcement authority. You can contact them for this purpose via this link: https://autoriteitpersoonsgegevens.nl/nl/contact-met-de-autoriteit-persoonsgegevens/tip-ons.

Privacy statement changes

Bright Orange may update its privacy statement at any time. The most recent version is published on the website. Therefore always keep an eye on the website for the most recent version. If the new privacy statement affects the way Bright Orange processes data already collected in relation to you, Bright Orange will notify you by e-mail.

This version was last adopted on 14 March 2023.