Privacy statement

1.   Introduction

In this privacy statement we explain what data we process about you if we want to have, or have had, a business relationship with you. We also tell you why and for how long we process your data and what your rights are with regard to each processing. In addition, we provide information about the parties we work with and about our security policy.

We believe it is important that our services are reliable and transparent. We handle your personal data discretely and carefully, and we ensure that processing of your data complies with applicable laws and regulations.


2. Controller of personal data

The Controller is:
elho BV
Atlasstraat 11
5047 RG
+3113 515 7800


3. Privacy Manager

We have appointed a Privacy Manager. That is not a "data protection officer" as referred to in Article 37 of the GDPR. However, this is someone who ensures that your data is processed in accordance with the law. The activities of the Privacy Manager include monitoring and handling questions and complaints. The contact details of our Privacy Manager are:

Romy Bierens
+3113 515 7856


4. The personal data we process

Depending on your relationship with our organisation and the purpose for which we process data, we record (some of) the following data:

a)    First and last name

b)    Phone number

c)    Email address

d)    Location details

e)    IP address

f)      Information about your activities on our website

g)    Video recordings of visits to our company or premises


5. For what purpose and based on which principles we process personal data

We process your personal data for the following purposes:

a)    keeping financial records

b)    processing and executing assignments

c)    sending newsletters

d)    keeping applicant (job vacancy candidates) records

e)    keeping visitor records

f)      conducting camera surveillance

g)    monitoring of website visits

The grounds for processing are those referred to in Article 6 of the GDPR (consent, agreement or legitimate interest).


6. Automated decision-making

We do not make decisions based on automated processing on matters that can have (significant) consequences for people. These are decisions made by computer programmes or systems, without a person (for example one of our employees) involved.

7. How long we keep personal data

In general, we do not store your data longer than necessary for the purposes for which we have collected your data. The retention period can be different from case to case. One example is that we have to keep a number of documents for a minimum term for tax or administration purposes. In those cases, we will only store the data that is necessary to meet our legal obligations. After the legal storage periods we will delete or anonymise your data.

8. Sharing personal data with third parties

We do not share your personal data with third parties, unless this is done in the context of performing an agreement with you and to comply with any legal obligation. Insofar as these third parties have to act as processor, we have entered into a processor agreement with those third parties in which security, confidentiality and your rights are set out. We remain responsible for these processing operations.

The use of third parties in the above manner and grounds we do in the following categories of processing:

a)    processing and executing assignments

b)    organizing (customer events

c)    sending newsletters or mailings

d)    conducting an applicant (vacancies-candidates) administration

e)    conducting a visitor

f)      registration keeping camera surveillance

g)    monitoring of website visit


9. Cookies, or similar techniques, that we use

We use cookies on our website. This is a small text file that is stored in the browser of your computer, tablet or smartphone when you first visit this website.

We use the following cookies:

a)    cookies with a purely technical functionality. These ensure that the website works properly and that your preferred settings are remembered, for example. These cookies are also used to ensure the website works properly and to optimise it.

b)    cookies that keep track of your browsing habits so that we can offer customised content and advertisements. During your visit to our website we have already informed you about these cookies and asked permission for their placement.

c)    cookies placed by third parties. These can be advertisers and/or social media companies.

You can opt out of cookies by configuring your internet browser so that it does not store cookies anymore. In addition, you can delete all information previously saved via your browser settings.


10. Your rights (inspection, adaptation, deletion, etc.)

The following explains what your rights are with regard to the processing of your data.

a)    Right to inspect

You have the right to inspect your own data. This also includes the question of what the purposes of the processing are, to which parties the data is provided, what the retention periods are.

b)    Right to rectification

You can ask us to have your data rectified immediately. You also have the right to complete incomplete data by, for example, by sending an email to us.

c)    'Right to be forgotten'

You have the 'right to be forgotten.' Upon request, we will delete your data without unreasonable delay. However, we cannot always delete all of your data. Sometimes the processing is still necessary for compliance with legal obligations or for setting up, exercising or substantiating claims, for example.

d)    Right to limit the processing

In principle you have the right to limit the processing of your data, for example if you believe that your data is incorrect or unnecessary.

e)    Notification of rectification, deletion or limitation

Unless it is impossible or disproportionate effort, we will inform the recipients of your data of any rectification, deletion or limitation of the processing.

f)      Right to transfer your data

You have the right to transfer data. This means that you can request to receive your data. You can then save this data for personal reuse. You have this right only with regard to data that you yourself have provided to us and if the processing is based on permission or an agreement to which you are a party.

g)    Withdrawing consent

If the data processing is based on consent, you have the right to revoke that consent at any time. However, the processing of your data from the period prior to withdrawal remains legitimate.

h)    Right of objection

In principle you have the right to object to the processing of your data. After your objection, we will stop processing your data.

i)      Complaint to the Authority for Personal Data or to the court.

If you believe that the processing of your data violates the law, you can contact our Privacy Manager, but you also have the right to file a complaint with the Authority Personal Data (AP) or to go to court.

j)      Limitations of your rights

Sometimes we can limit your rights, for example in the context of the prevention, investigation, detection and prosecution of criminal offenses, such as fraud.

You can address any request to our Privacy Manager. To ensure that a request has been made by you, we ask you to send a copy of your ID with the request. In this copy, black out your passport photo, MRZ (machine readable zone, the strip with numbers at the bottom of the passport), passport number and citizen service number (BSN). This is to protect your privacy.


11. How we protect personal data

We take the protection of your data seriously and take appropriate measures to prevent misuse, loss, unauthorised access, unwanted disclosure and unauthorised modification. If you have the impression that your data is not secure or there are indications of abuse, please contact our Privacy Manager.

12. Amendments

We can make amendments to this statement if developments give cause to do so, for example in the case of new processing forms. The most current privacy statement can be found on our website. We encourage you to consult this privacy and cookie statement regularly, so that you are kept informed of the changes.


December 2018