Privacy Policy
Hrybov & Gritz Holding B.V., located at Bruggebouw, Bos en Lommerplein 280, 1055 RW, Amsterdam, Netherlands, is responsible for the processing of personal data as described in this privacy statement.
Contact Information
Natalia Komarovskaia is the Data Protection Officer at Hrybov & Gritz Holding B.V. She can be reached by email at: info@hgholding.eu
Personal Data We Process
Hrybov & Gritz Holding B.V. processes your personal data because you use our services and/or because you provide this data to us yourself. Below is an overview of the personal data we process:
• First and last name
• Date of birth
• Address details
• Phone number
• Email address
• Bank account number
Purposes and legal basis for processing
Hrybov & Gritz Holding B.V. processes your personal data for the following purposes and on the following legal bases (Article 6 of the GDPR):
Performance of the contract (Art. 6(1)(b) of the GDPR):
- For the performance of the contract for the provision of services
- For billing purposes
Legal obligation (Art. 6(1)(c) GDPR):
- To maintain proper (financial) records, to the extent required by law
- To properly archive and retain your data in accordance with statutory retention periods
Legitimate interest (Art. 6(1)(f) GDPR):
- For the effective management and governance of our organization, to the extent that your interests or fundamental rights do not override this interest
No processing takes place for other purposes, unless it concerns a compatible purpose within the meaning of the GDPR, or you have given your prior consent for this.
What are the obligations of Hrybov & Gritz Holding B.V.?
Under the GDPR, we are the Data Controller for the processing of personal data contained in your file. In our work, we are required to take the following into account:
- If Hrybov & Gritz Holding B.V. engages one or more employees to perform services, they will each treat your personal data confidentially. This is set forth in writing in those employees’ employment contracts.
Your personal data is properly secured against unauthorized access. We have taken the necessary technical and organizational measures to prevent a security incident.
Your personal data will not be retained longer than necessary to provide proper service. After that, it will be destroyed or anonymized.
How long we retain personal data
Hrybov & Gritz Holding B.V. does not retain your personal data for longer than is strictly necessary to achieve the purposes for which your data is collected. We apply the following retention periods:
- General customer data (name, address, contact details, file information): 12 months after the termination of services, after which it is destroyed or anonymized.
- Financial and tax data (such as invoices and payment details): 7 years after the end of the fiscal year, in accordance with the statutory retention obligation under the Dutch Tax Laws.
Upon expiration of the retention period, your data will be securely destroyed or irrevocably anonymized.
The retention periods mentioned above apply unless you contact us to exercise your right of access and/or the right to be forgotten under the GDPR; in that case, your data will be deleted upon your request.
Automated decision-making
Hrybov & Gritz Holding B.V. does not use automated decision-making or profiling as referred to in Article 22 of the GDPR. This means that no decisions are made based solely on the automated processing of personal data that produce legal effects concerning you or similarly significantly affect you. All processing and decision-making is carried out by employees of Hrybov & Gritz Holding B.V. who manually work with your customer profile.
Special and/or sensitive personal data that we process
Our website and/or service does not intend to collect data from website visitors under the age of 16, unless they have permission from a parent or guardian. However, we cannot verify whether a visitor is over 16. We therefore advise parents to be involved in their children’s online activities to prevent data about children from being collected without parental consent. If you believe we have collected personal data about a minor without such consent, please contact us at info@hgholding.eu, and we will delete this information.
Sharing Personal Data with Third Parties
Hrybov & Gritz Holding B.V. does not sell your data to third parties and only discloses it if necessary to fulfill our agreement with you or to comply with a legal obligation. We enter into a data processing agreement with companies that process your data on our behalf to ensure the same level of security and confidentiality for your data. Hrybov & Gritz Holding B.V. remains responsible for these processing activities.
Transfer of personal data outside the EU
Hrybov & Gritz Holding B.V. does not transfer your personal data to countries outside the European Union (EU) or the European Economic Area (EEA). All data processing takes place exclusively within the EU/EEA.
Cookies, or similar technologies, that we use
Hrybov & Gritz Holding B.V. uses only technical and functional cookies, as well as analytical cookies that do not infringe on your privacy. A cookie is a small text file that is stored on your computer, tablet, or smartphone when you first visit this website. The cookies we use are necessary for the technical operation of the website and your ease of use. They ensure that the website functions properly and, for example, remember your preferences. They also allow us to optimize our website. You can opt out of cookies by configuring your internet browser so that it no longer stores cookies. In addition, you can also delete all information previously stored via your browser settings.
Your rights as a data subject
You have the following rights:
• The right to know whether and which of your personal data are being processed (right of access, Art. 15 GDPR).
• The right to receive a copy of the personal data we process about you (Art. 15(3) GDPR).
• The right to have inaccurate or incomplete data corrected or supplemented (Art. 16 GDPR).
• The right to erasure (“the right to be forgotten”) of your data, provided that retention is not necessary based on a legal obligation or another compelling interest (Art. 17 GDPR).
• The right to restrict the processing of your data in certain cases (Art. 18 GDPR).
• The right to data portability: you may submit a request to us to send the personal data we hold about you in a machine-readable file to you or another organization designated by you (Art. 20 GDPR).
• The right to object to the processing of your personal data (Art. 21 GDPR).
• The right to withdraw your consent to data processing at any time, provided that the processing is based on consent (Art. 7(3) GDPR).
You may send a request to exercise the above rights to info@hgholding.eu. We will respond to your request as soon as possible, and in any case within four weeks.
Hrybov & Gritz Holding B.V. also reminds you that you have the right to file a complaint with the national supervisory authority, the Dutch Data Protection Authority, via: https://autoriteitpersoonsgegevens.nl/nl/contact-met-de-autoriteit-persoonsgegevens/tip-ons
How we protect personal data
Hrybov & Gritz Holding B.V. takes the protection of your data seriously and implements appropriate technical and organizational measures to prevent misuse, loss, unauthorized access, unwanted disclosure, and unauthorized modification. If you feel that your data is not properly secured or there are indications of misuse, please contact us at info@hgholding.eu
Contact Information
Natalia Komarovskaia is the Data Protection Officer at Hrybov & Gritz Holding B.V. She can be reached by email at: info@hgholding.eu
Personal Data We Process
Hrybov & Gritz Holding B.V. processes your personal data because you use our services and/or because you provide this data to us yourself. Below is an overview of the personal data we process:
• First and last name
• Date of birth
• Address details
• Phone number
• Email address
• Bank account number
Purposes and legal basis for processing
Hrybov & Gritz Holding B.V. processes your personal data for the following purposes and on the following legal bases (Article 6 of the GDPR):
Performance of the contract (Art. 6(1)(b) of the GDPR):
- For the performance of the contract for the provision of services
- For billing purposes
Legal obligation (Art. 6(1)(c) GDPR):
- To maintain proper (financial) records, to the extent required by law
- To properly archive and retain your data in accordance with statutory retention periods
Legitimate interest (Art. 6(1)(f) GDPR):
- For the effective management and governance of our organization, to the extent that your interests or fundamental rights do not override this interest
No processing takes place for other purposes, unless it concerns a compatible purpose within the meaning of the GDPR, or you have given your prior consent for this.
What are the obligations of Hrybov & Gritz Holding B.V.?
Under the GDPR, we are the Data Controller for the processing of personal data contained in your file. In our work, we are required to take the following into account:
- If Hrybov & Gritz Holding B.V. engages one or more employees to perform services, they will each treat your personal data confidentially. This is set forth in writing in those employees’ employment contracts.
Your personal data is properly secured against unauthorized access. We have taken the necessary technical and organizational measures to prevent a security incident.
Your personal data will not be retained longer than necessary to provide proper service. After that, it will be destroyed or anonymized.
How long we retain personal data
Hrybov & Gritz Holding B.V. does not retain your personal data for longer than is strictly necessary to achieve the purposes for which your data is collected. We apply the following retention periods:
- General customer data (name, address, contact details, file information): 12 months after the termination of services, after which it is destroyed or anonymized.
- Financial and tax data (such as invoices and payment details): 7 years after the end of the fiscal year, in accordance with the statutory retention obligation under the Dutch Tax Laws.
Upon expiration of the retention period, your data will be securely destroyed or irrevocably anonymized.
The retention periods mentioned above apply unless you contact us to exercise your right of access and/or the right to be forgotten under the GDPR; in that case, your data will be deleted upon your request.
Automated decision-making
Hrybov & Gritz Holding B.V. does not use automated decision-making or profiling as referred to in Article 22 of the GDPR. This means that no decisions are made based solely on the automated processing of personal data that produce legal effects concerning you or similarly significantly affect you. All processing and decision-making is carried out by employees of Hrybov & Gritz Holding B.V. who manually work with your customer profile.
Special and/or sensitive personal data that we process
Our website and/or service does not intend to collect data from website visitors under the age of 16, unless they have permission from a parent or guardian. However, we cannot verify whether a visitor is over 16. We therefore advise parents to be involved in their children’s online activities to prevent data about children from being collected without parental consent. If you believe we have collected personal data about a minor without such consent, please contact us at info@hgholding.eu, and we will delete this information.
Sharing Personal Data with Third Parties
Hrybov & Gritz Holding B.V. does not sell your data to third parties and only discloses it if necessary to fulfill our agreement with you or to comply with a legal obligation. We enter into a data processing agreement with companies that process your data on our behalf to ensure the same level of security and confidentiality for your data. Hrybov & Gritz Holding B.V. remains responsible for these processing activities.
Transfer of personal data outside the EU
Hrybov & Gritz Holding B.V. does not transfer your personal data to countries outside the European Union (EU) or the European Economic Area (EEA). All data processing takes place exclusively within the EU/EEA.
Cookies, or similar technologies, that we use
Hrybov & Gritz Holding B.V. uses only technical and functional cookies, as well as analytical cookies that do not infringe on your privacy. A cookie is a small text file that is stored on your computer, tablet, or smartphone when you first visit this website. The cookies we use are necessary for the technical operation of the website and your ease of use. They ensure that the website functions properly and, for example, remember your preferences. They also allow us to optimize our website. You can opt out of cookies by configuring your internet browser so that it no longer stores cookies. In addition, you can also delete all information previously stored via your browser settings.
Your rights as a data subject
You have the following rights:
• The right to know whether and which of your personal data are being processed (right of access, Art. 15 GDPR).
• The right to receive a copy of the personal data we process about you (Art. 15(3) GDPR).
• The right to have inaccurate or incomplete data corrected or supplemented (Art. 16 GDPR).
• The right to erasure (“the right to be forgotten”) of your data, provided that retention is not necessary based on a legal obligation or another compelling interest (Art. 17 GDPR).
• The right to restrict the processing of your data in certain cases (Art. 18 GDPR).
• The right to data portability: you may submit a request to us to send the personal data we hold about you in a machine-readable file to you or another organization designated by you (Art. 20 GDPR).
• The right to object to the processing of your personal data (Art. 21 GDPR).
• The right to withdraw your consent to data processing at any time, provided that the processing is based on consent (Art. 7(3) GDPR).
You may send a request to exercise the above rights to info@hgholding.eu. We will respond to your request as soon as possible, and in any case within four weeks.
Hrybov & Gritz Holding B.V. also reminds you that you have the right to file a complaint with the national supervisory authority, the Dutch Data Protection Authority, via: https://autoriteitpersoonsgegevens.nl/nl/contact-met-de-autoriteit-persoonsgegevens/tip-ons
How we protect personal data
Hrybov & Gritz Holding B.V. takes the protection of your data seriously and implements appropriate technical and organizational measures to prevent misuse, loss, unauthorized access, unwanted disclosure, and unauthorized modification. If you feel that your data is not properly secured or there are indications of misuse, please contact us at info@hgholding.eu