Privacy Policy Delta Boat Center B.V.

date 22-5-2018

Version 01







1.1 General



1.2 scope



1.3 Purpose






2.1 roles, tasks and powers



2.2 Processes



2.3 Implementation/processors









4.1 demonstrability



4.2 obligation to inform



Revoke consent 4.3












7.1 information



7.2 Time information



7.3 processing for other purpose



7.4 exception information duty






8.1 right to inspect



8.2 right to rectification



8.3 right to oblivion



8.4 right to limitation of the processing



8.5 right of transferability



8.6 right to object



8.7 notification obligation















12.1 report to the Executive Board



12.2 notification to competent authorities



12.3 Message to data subject



12.4 documentation of personal data breaches


























Annex 1



Annex 2










1. introduction

1.1. General

Delta Boat Center B.V. processed in the framework of its business contacts and personal data of legal persons, people. Delta Boat Center B.V. Stresses the importance of carefully with this personal information will be used and that it be kept confidential. Delta Boat Center B.V. recognizes that the privacy of the natural (legal) persons whose data are processed and that they deserved protection from its social role and statutory objective is to contribute thereto.


1.2. scope

This privacy policy applies to the processing of all personal data within Delta Boat Center B.V.

This privacy policy applies to all processing of personal data wholly or partly by automatic means within or on behalf of Delta Boat Center B.V. privacy policy applies to the entire company and its related companies.


1.3. objective

The privacy policy is a key element of the legal requirements for the protection of personal data. The policy aims to protect personal data against abuse and against the processing of incorrect data. In addition, the policy aimed to process personal data in accordance with laws and regulations and to ensure the rights of the data subjects.




The Executive Board shall lay down the methods on which Delta Boat Center B.V. control and decision making around privacy has organized and which roles are invested. Each role has specific duties, responsibilities and powers. The interplay between these roles ensures that the privacy policy is anchored within Delta Boat Center B.V.


2.1. Roles, tasks and powers


The Executive Board is responsible for establishing and realizing of the privacy policy of Delta Boat Center B.V. the Directorate is primarily responsible for the implementation of the established privacy policy and subsequent measures. The Executive Board shall ensure compliance with the privacy policy. The role of ' data protection Officer ', as referred to in the AVG, lies with the management. Accessorise the management care for sufficient awareness among the employees.


At least once a year, the privacy policy on the agenda of the Executive Board and determines whether new activities are necessary to meet the policy principles.



Associates may use personal information only to the extent necessary for the purpose for which Delta Boat Center B.V. processes personal data and as necessary to carry out their work. The employee is responsible for carefully handle personal data, compliance with the privacy policy, their procedures. The employee, any (possible) incident or issue regarding personal data to report incidents in accordance with the procedure (Chapter 12).


2.2. processes

Protection of personal data is an integral part of business processes and provision of information. Through the planning and control cycle is guaranteed that adequate protection of personal data is safeguarded and remains.



The privacy policy is the starting point in the implementation of the privacy policy. On this basis a determination of which measures need to be implemented, which activities are needed and which roles are involved.




The privacy policy is reviewed by the Executive Board at least once a year. This takes into account:

  • Laws and regulations;
  • Incidents of the past year (information security incidents, data leaks);
  • Results of risk analyses;
  • Findings and recommendations from the periodic review
  • New trends (cybercrime, risk third parties etc.); and
  • New standards (including ISO standards).


Adjustment and implementation

The evaluation of the privacy policy may cause existing measures in the field of protection of personal data should be modified or additional measures should be taken. This must then be implemented in the organization.


2.3. implementation/processors

Delta Boat Center B. V. can appoint an implementing organization and/or processor (s) in carrying out its work. If an implementing organization is appointed, may also the roles, duties, responsibilities and powers are invested in the implementing organization. Then Delta Boat Center b. v. and the implementing organization clear agreements regarding cooperation and the Division of roles, tasks, responsibilities and authority. The ultimate responsibility rest always at Delta Boat Center B.V.



The processing of personal data must meet at least one of the following bases. In the registry is recorded on what basis the processing is based:

  • the consent of the person concerned;
  • the processing is necessary for the execution of objective of Delta Boat Center B.V., in accordance with its articles of association as known to the Chamber of Commerce;
  • the processing is necessary for the purposes of the legitimate interests of Delta Boat Center B.V., except when the interests or fundamental rights and freedoms of the person concerned outweigh those interests.


Delta Boat Center B.V. does not process ' sensitive personal data '.



4. consent of DATA SUBJECTS

4.1. Demonstrability

If a processing is based on consent, can demonstrate that the person concerned Delta Boat Center B.V. has given permission for the processing of his personal data.


4.2. Information obligation

In obtaining consent, the person concerned will be made aware of:

a. the purposes of the processing for which permission is requested;

b. other relevant information that the person concerned need to communicate a conscious decision on the processing of his personal data;

c. the right to withdraw his consent, where the withdrawal of the consent the lawfulness of the processing for revoking the permission.


If the person concerned consents within the framework of a written statement that also on other matters relating to the application shall be presented in such a way that a clear distinction can be made with the other functions.


4.3. Revoking permission

The data subject shall have the right to withdraw his consent at any time.




Delta Boat Center B.V. processes personal data in a way that the data subject in respect of lawful, decent and transparent. Delta Boat Center B.V. does not process personal data which are not necessary for the legitimate purposes for which Delta Boat Center B.V. has obtained personal data.


Delta Boat Center B.V. takes all reasonable steps to ensure that personal data processed are accurate and up to date.




Delta Boat Center B.V. saves personal data in a form which permits identification of the data subject only as long as necessary:

a. having regard to the duration required for the (justified) purposes for which the personal data are processed; or

b. as far as (reasonably) is needed in order to comply with a legal obligation; or

c. having regard to an applicable limitation period; and

d. as far as the person concerned is not relying on the right to be forgotten.


In each registration of personal data is the retention period. After the applicable retention period has expired, the management command to the data:

a. safe to remove or destroy;

b. advantages; or

c. to move to an archive (unless by virtue of legislation or regulations in force for a data retention is prohibited).




Delta Boat Center B.V. shall inform the person concerned in an appropriate manner about the legitimate purposes for which their personal data are processed and all other required information shall be provided by the person concerned with regard to the processing of personal data.


7.1 information

Delta Boat Center B.V. shall provide the person concerned with obtaining the following information:

  • contact details of Delta Boat Center B.V.;
  • purposes of the processing operation;
  • legal basis of the processing;
  • (where appropriate) the recipients or categories of recipients of the personal data;
  • (where applicable) or Delta Boat Center B.V. proposes the data to a country outside the EU or an international organization;
  • (if possible) the period during which the personal data are expected to be stored;
  • that the person concerned has the right to submit a request for rectification or erasing data, or limitation of the processing, as well as the right to object to the processing and the right to data portability;
  • When the processing on explicit consent of the person concerned is based, that the person concerned has the right to withdraw the permission, without affecting the lawfulness of the processing on permission basis for revoking of it;
  • the right to complain to the relevant supervisory authority;
  • or the provision of the personal data a legal or contractual obligation is a necessary condition to reach an agreement, and whether the person concerned is required to provide the personal data and what the possible consequences are When these data are not provided.


7.2. Time information

Delta Boat Center B.V. shall provide the information within a reasonable period of time, but at the latest within one month of the personal data.

If the personal information is used for communication with the person, then provided Delta Boat Center B.V. the information at the latest at the time of the first contact with the person concerned. If is considered the data to another recipient, informed no later than the time at the time the personal data for the first time to that receiver.


7.3. processing for other purpose

When Delta Boat Center B.V. intends to process the personal information for a purpose other than that for which the personal information is collected, provided the person concerned for Delta Boat Center B.V. which further processing information about that other purpose and all the relevant information as mentioned above.


7.4. Exception information duty

The information obligation shall not apply if:

a. the data subject already has the information;

b. providing that information proves impossible or would involve a disproportionate effort would require;

c. obtaining or providing the data is expressly required by legislation; and

d. the personal data should remain confidential under a professional secrecy in the context of legislation.



8. rights of the DATA SUBJECT

8.1. Right of inspection

The person concerned has the right to ask to Delta Boat Center B.V. or of him whether or not personal data are processed and when that is the case, in order to obtain access to that personal data. In the case of such a request, Delta Boat Center B.V. the data subject the following information:

a. the purposes of the processing operation;

(b) the categories of personal data;

c. the recipients or categories of recipients to whom the personal data are or will be provided, in particular recipients in third countries or international organisations;

d. If possible, the expected period of time during which the personal data are stored, or where this is not possible, the criteria for that term;

e. that the person concerned has the right to request Delta Boat Center B.V. that personal data be corrected or deleted, or that the processing of personal data concerning him, as well as the right to raise objections against those processing;

f. that the person concerned has the right to complain to the relevant supervisory authority;

g. when the personal data of the person concerned are obtained, all available information on the source of that data.


8.2. Right of rectification

The interested party has the right to immediate rectification of inaccurate personal data concerning him.

Having regard to the purposes of the processing operation the person concerned has the right to complete of incomplete personal data.


8.3. right to oblivion

The interested party is entitled to erase with regard to personal data concerning him or her. Delta Boat Center B.V. is obliged to erase personal data within a month when one of the following cases apply:

a. the personal data are no longer needed in connection with the purposes for which the data were collected or otherwise processed;

b. the person concerned withdraws his consent and there is no other legal basis for processing;

c. in case of objection of the person concerned;

d. the personal data has been processed unlawfully; and

e. personal data must be erased under a legal obligation.


In case Delta Boat Center B.V. is required to erase the personal data, must be taken to third-party measures that have made public the personal data to inform, that the person concerned has done the request to erase.

The right to erase does not apply if the processing is necessary:

a. for the exercise of the right to freedom of expression and information;

b. for the performance of a legal obligation or task of general interest or exercise of public authority;

c. for the purpose of archiving in the public interest, scientific or historical research or statistical purposes; and

d. for the establishment, exercise or substantiation of a legal claim.


8.4. right to limitation of the processing

The interested party has the right to limitation of the processing of personal data if:

(a) the accuracy of the data is disputed, during the period that this Delta Boat Center B.V. is controlled;

b. the processing is unlawful and the data subject opposes erasing of personal data and asks instead to restriction of the use of it;

c. the data are no longer required for the processing purposes, but only for the establishment of, exercise or substantiation of a legal claim; and

d. in the event of objection to the processing bases, for the period that the interests balance between the importance of Delta Boat Center B.V. and the data subject is reviewed;


Limitation means that the data, with the exception of their storage, only be processed with:

a. the data subject's consent; or

b. for the benefit of the legal action; or

c. to protect the rights of another natural or legal person; or

d. are important reasons of general interest.


A data subject which the processing of personal data is limited, Delta Boat Center B.V. will be notified before the restriction is lifted.


8.5. right to transferability

The person concerned has the right the data relating to him, which he to Delta Boat Center B.V. has provided, in a structured, common and machine-readable form and he has the right that data to another to transfer processing responsible, if:

a. the processing is based on consent or on an agreement as legitimate basis; and

(b) the processing is carried out via automated processes. In the exercise of its right to data portability has the data subject the right that personal data, if this is technically possible, direct from Delta Boat Center B.V. be forwarded to another processing responsible.

If a person uses the right to data portability he can still use his right to gegevenswissing.


8.6. Right to object

Person concerned has the right at Delta Boat Center B.V. to object to the processing of his personal data if the basis for the legitimate interest. If such an objection, the processing Center B.V. Delta Boat will cease unless there is grounds for this processing that outweigh the privacy interests of those involved or related to a legal action.


8.7. Notification obligation

Delta Boat Center B.V. shall inform each recipient, to whom personal data have been disclosed of any rectification or erasure of personal data or of the restriction of the processing, unless this proves impossible or involves a disproportionate effort. If the person concerned so requests, provided Delta Boat Center B.V. the data subject information about the recipients.




Delta Boat Center B.V. has identified the policy and measures to protect personal data from unauthorized access and other unwanted or unlawful processing, including loss or destruction.

The measures take a Delta Boat Center B.V. on the risk aligned to ensure security level include, where appropriate, include the following:

  • the pseudonimisering, anonymisation and encryption of the data;
  • the ability to maintain the confidentiality, integrity, availability and resilience of the processing systems and services;
  • the ability to in the event of an incident the availability of and access to the personal data to restore in a timely manner; and
  • a procedure for periodically testing, review and evaluate the effectiveness of the technical and organizational measures to protect the processing.


When assessing the level of security appropriate Delta Boat Center B.V. shall take into account inter alia the processing risks, especially due to the destruction, loss, modification or unauthorised provision of or unauthorized access to transmitted, stored or otherwise processed accidental or unlawful information.

Delta Boat Center B.V. shall take measures to ensure that every employee or person acting under its authority, as well as the processors, the personal data only in her command processed unless this is authorized by EU law or national law held.




All processing of personal data are registered in a register of the processing operations. In the registry is for any processing include the following:

  • the name of the processing;
  • the name and contact details of the processing responsible;
  • the purposes of the processing operation;
  • a description of the categories of data subject and of the categories of personal data;
  • the categories of recipients to whom the personal data are or will be provided;
  • the proposed time limits for the various categories of personal data must be erased;
  • a general description of the technical and organisational security measures.




Delta Boat Center B.V. holds at the choice and the use of the information systems take account of the data protection principles and will provide the necessary guarantees in the building systems to comply with the legal requirements.

Delta Boat Center B.V. shall take appropriate technical and organisational measures to ensure that, in principle, only necessary personal data are processed for each specific purpose of the processing. Delta Boat Center B.V. ensures that this as standard applies to the amount of collected personal data, the extent to which they are processed, the term for which they are stored and the accessibility thereof.


12. notification of a VIOLATION RELATED to PERSONAL DATA

12.1 Reporting to the Executive Board

If a breach or possible breach of personal information took place or place has been able to find, please notify the employee of Delta Boat Center B.V. this without delay to the Executive Board. In the absence designates the conducting at replacement.


12.2. Notification to competent authorities

If an infringement has taken place in relation to personal data, reports Delta Boat Center B.V. this without unreasonable delay and, if possible, not later than 72 hours after knowledge is taken of the infringement to the competent supervisory authority. If the message not within 72 hours, the notification shall be accompanied by a justification for the delay.

This message is only necessary when it is probable that the infringement related to personal information a risk to the rights and freedoms of individuals.


12.3. communication to data subject

When the infringement related to personal data likely to be a high risk to the rights and freedoms of natural persons, shares Delta Boat Center B.V. the data subject the infringement related to personal data without delay.

This communication to the person concerned is not required when one of the following conditions are met:

a. Delta Boat Center B.V. has taken appropriate technical and organisational measures and these measures are applied to the personal data which the infringement related to personal data;

b. Delta Boat Center B.V. post has in place measures to ensure that the risk to the rights and freedoms of concerned are unlikely to be repeated; and

c. the communication would require disproportionate efforts. In this case, there is in place a public notice or a similar measure by which person concerned be informed as effective.


12.4. documentation of personal data breaches

Delta Boat Center B.V. documents all Offences related to personal data, including the facts about the infringement related to personal data, the consequences and the corrective actions taken.




Delta Boat Center B.V. gives in the framework of the processing of personal data only contract to a supplier that offer adequate guarantees with regard to the application of appropriate technical and organisational measures so that the processing to the legal, regulatory, and the rights of the person concerned.

The processing is controlled by the processor in a processing agreement. The processors agreement should ensure that the obligations on Delta Boat Center B.V. also rest by the processor are complied with.

In the processors agreement are the subject and the duration of the processing, the nature and the purposes of the processing, the type of personal data and the categories of data subjects and the rights and obligations of Delta Boat Center B.V. defined.

The following topics are in the processors agreement included:

  • the processor processes personal data solely on the basis of instructions of Delta Boat Center B. V. processor shall ensure an appropriate protection of the personal data;
  • Delta Boat Center B.V. has the ability to carry out audits at the processor;
  • conditions for enabling a subprocessor by the processor;
  • secrecy and confidentiality;
  • transfer of personal data to countries outside the EU;
  • erase, delete, return and destruction of the personal data by processor;
  • the mandatory reporting of data leaks by processor to Delta Boat Center B.V.; and
  • liability.


Delta Boat Center B.V. (a) processors agreement (s) that conforms or comply with any legal requirements that allowed it to happen.



14. transfer to COUNTRIES OUTSIDE the EU

Transfer of personal data by Delta Boat Center e.g. to a country outside the EU or to an international organisation may take place when the European Commission has decided that the third country, a region or sectors in one or more specified that third, the international organization in question ensures an adequate level of protection.

In the event that the European Commission has not decided that the third country or international organisation an adequate level of protection, Delta Boat Center B.V. or its processor will only transfer personal data if it has been established that the relevant country or organization and person concerned about enforceable rights provides adequate safeguards and effective legal remedies.




Delta Boat Center B.V. ensures that staff, both internal and external, who have access to personal data with the data protection and privacy policy.




The legal framework for this privacy policy is laid down in Netherlands in:

  • The European data protection General Regulation (AVG), including related implementing legislation and/or guidelines;
  • Other legislation, such as the fingerende Wwft.




The competent supervisory authority supervises compliance with the laws and regulations for personal data protection. In Netherlands is the competent supervisory authority the authority personal data. See De bevoegde Toezichthoudende autoriteit houdt toezicht op de naleving van de wet- en regelgeving voor bescherming Persoonsgegevens. In Nederland is de bevoegde Toezichthoudende autoriteit de Autoriteit Persoonsgegevens. Zie



18. decision on the

This policy has been established and entered on 22-5-2018


19. Cookies


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Closing remarks

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If you have any questions and/or comments, please contact us.







Special personal data

Special personal data include:

  • Personal data revealing racial or ethnic origin are distracting;
  • Personal data revealing political opinions, religious or philosophical beliefs are distracting;
  • Data on political persuasion;
  • Trade Union membership;
  • Genetic and biometric data in order to uniquely identify a person;
  • Data on health;
  • Data related to one's sexual behavior or sexual orientation;
  • Criminal justice information; and
  • Data on bothersome/wrongful conduct in connection with ban on that behavior.


Biometric data

Personal data that are the result of a specific technical processing in relation to the physical, physiological or related behavior characteristics of a natural person on the basis of which unique identification of that natural person possible or confirmed, such as facial images or fingerprint data.



A natural or legal person, public authority, a service or any other body other than the data subject, the controller, the processor and the persons who, under the direct authority of the controller or the processor, are authorized to process the personal data.


Executive Board

The Director or his or her Deputy Delta Boat Center B.V. Association, with powers as laid down in the articles of Association.


Data on health

Personal data relating to the physical or mental health of a natural person, including data on health services that provided information about his State of health is given.


Infringement related to personal data

A security breach that inadvertently or unlawfully leads to the destruction, loss, modification or unauthorised provision of or unauthorized access to transmitted, stored or otherwise processed data.


International Organization

An organization and the falling international public-sector bodies or other bodies established by or on the basis of an agreement between two or more countries.



A natural or legal person, whether or not member at Delta Boat Center B.V., a public authority, a service or another body, to whom/which the personal information was provided.


Personal data

All information about an identified or identifiable natural person (data subject) (right); an identifiable is considered a natural person who can be identified, directly or indirectly, in particular by reference to indicators such as a name, an identification number, location information, an online indicator or of one or more elements that characterizing the genetic, physical, physiological, mental, economic, cultural or social identity of that natural person.



Any kind of automated decision-making where certain personal aspects on the basis of personal data of a natural person to be evaluated.



The processing of personal data in such a way that the personal data no longer can be linked to a specific person without that additional data are used, provided that this additional information be kept apart and technical and organisational measures must be taken to ensure that the personal information to an identified or identifiable natural person. Pseudonimisering is reversible if they make use of the correct key.



Register of the processing operations.


The data subject's consent

Any freely given specific and informed indication of his wishes by which the data subject unambiguously, by means of a declaration or an unambiguous active processing of personal data concerning him Act.


Supervisory authority

A set by a Member State pursuant to article 51 AVG independent public authority.



A natural or legal person, public authority, a service or any other body which processes personal data on behalf of the controller.



An operation or a set of operations that are related to personal data or a set of personal data, whether or not conducted through automated processes, such as collection, recording, organisation, structure, storage, update or change , retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction of data.


Processing responsible

A natural or legal person, public authority, a service or any other body which alone or jointly with others determines the purposes and means of the processing of personal data;

When the objectives and means of this processing in the (inter) national law be adopted, it can be determined who is responsible or the processing according to which criteria this is designated.



Annex 2


Declaration of confidentiality in Delta Boat Center B.V. employment contract


On the non-disclosure obligation for employee and employer is the data protection act/data protection General Regulation apply. The employee is obliged to data, data, and all in him or her knowledge comes in the framework of the implementation of the employment contract, confidential and in accordance with this privacy policy.

The employee committed both during the duration of the employment contract if after termination to refrain from doing any communication to third parties, in any form, either directly or indirectly, on any special feature the company of employer or its affiliated companies, or related, which the employee can reasonably understand that this is not intended for inspection by third parties.

All goods, including written documents and photocopies thereof, as well as automated data carriers (including computer floppy disks, USB sticks or otherwise) that the employee or for the benefit of employer during the employment contract among themselves, are and remain the property of employer. The employee will these matters on the first request by employer, but at least at the time when the employment contract ends, again to employer.