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Privacy Policy

Clarusway B.V. must comply with the applicable laws and regulations, including the General Data Protection Regulation. This Privacy Statement sets out which personal data Clarusway B.V. collects and how we process this data. Also, this statement sets out which rights you have and how you can enforce these. This statement applies to all processing of your personal data by Clarusway B.V.

Personal data that is processed by Clarusway B.V.

Personal data is any information relating to an identified or identifiable natural person. Processing of personal data involves all actions that an organization can perform with personal data, such as collection and destruction. Clarusway B.V. processes the following personal data of its students:

Purpose for processing personal data

In order to be able to provide education, Clarusway B.V. will necessarily need to process our students’ personal data. Other purposes for processing personal data are (inter alia) recruitment and selection, research and student administration. This happens, among other things, on the legal basis of the execution of this agreement, but in some cases also on the basis of a legitimate interest.

Security

To secure data, we take appropriate physical, technical and organizational measures. We also regularly evaluate the measures we have taken to secure the data we store. If we use third parties to process personal data, we check whether these parties have an adequate level of security.

Incidents may occur in which the safe processing of personal data is temporarily not guaranteed. Such an in incident may result in a data breach. We report data breaches that lead to a risk of the rights and freedoms of those involved to the Dutch Data Protection Authority. DPA is the independent Dutch data protection authority that supervises the processing of personal data.

Sharing of personal data with third parties

Clarusway B.V. shares your personal information and service data within the Clarusway Group Company (CWGC). Your personal data will not be made available or sold to other parties. However, there are situations in which we may have to share your personal data with third parties, for example for the improvement of the provision of good education or, if you are following one of our courses with help of one of the regional mobility teams (“Regionale Mobiliteitsteams”), we will share your personal data with them. It is also possible that we receive a request for the provision of personal data from law enforcement agencies or a supervisory authority. In such cases, we always check first whether we are legally obliged to comply with the request

If applicable, Clarusway B.V. has written agreements with third parties regarding the processing and security of personal data. We conclude processing agreements and data exchange agreements with external parties so that we can maintain control over the processing of personal data.

We try to have data processed within the European Economic Area whenever possible, but data may also be processed in the United States of America, the European Economic Area (EEA), and other countries where Clarusway B.V. operates. If an exception must be made, we take measures to guarantee an adequate level of protection for the transfer of personal data.

Retention period with regard to your personal data

We will not retain your personal data any longer than is strictly necessary for the purposes for which we have collected the personal data.

Your rights

According to the GDPR data, subjects have various rights to control their personal data. For privacy-related questions, requests, or complaints, please contact [x]. We are obliged to respond to your request by letter or e-mail within one month. Is the request complicated? Or have you sent several requests? In which case, it may take two months longer to properly handle the request.

However, we will inform you within one month that it will take longer and why. We may also ask you for identification, so that we can be sure that the request indeed comes from the person concerned. This prevents personal data being provided to the wrong person or personal data being wrongly changed.

If, in your opinion, your request or complaint has not been dealt with appropriately, you have the option of submitting a complaint to the Dutch Data Protection Authority. Exercising the rights is free of charge, except in the case of abuse. It must be clear from the request which right or rights you are invoking. Below you will find the various rights

1. Right to access

Data subjects have the right to know whether Clarusway B.V. processes their personal data and, if so, what data. 

2. Right to be forgotten

In certain cases, you can request Clarusway B.V. to delete your personal data without unreasonable delay. This right is not absolute, but is subject to conditions. If one of the situations below should arise, you can appeal to this right:

3. Right to rectification and additions

You have the right to amend or rectify inaccurate personal data processed by us that concern you. You can also have incomplete data completed.

4. Right to data portability

As a data subject, you have the right to receive your personal data from a data controller, in a structured form, readable by a computer and in a common format (e.g., csv, xml, json). This right makes it possible to transfer personal data, for example, to a new employer or to another educational institution.

5. Right to object to data processing

You may lodge an objection to the processing of personal data in view of your specific situation. This is possible if Clarusway B.V. processes personal data on the basis of legitimate interests. In this case we will weigh up these interests against those of the rights and freedoms of the data subject. If a data subject objects to the processing of their personal data, we must stop processing the data. Processing can only continue if we provide compelling, legitimate grounds for doing so. These legitimate grounds must outweigh the interests, rights, and freedoms of the data subject or must concern a legal claim.

6. Right to restriction of processing

Under certain circumstances, you can invoke your right to restrict the use of personal data. There are four ways to do this:

7. Right to withdraw prior consent

If any processing by Clarusway B.V. is based on the principle of consent, you have the right at any time to withdraw your consent to the processing of your data. The processing of your personal data prior to the withdrawal of consent will remain lawful.