Privacy Policy

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PRIVACY STATEMENT FOR USERS
Version: 29 February 2024

0. EXECUTIVE SUMMARY
0.1 Why, what, where, when, who and how (long)
Why: Your personal data is needed to use our service, create/access a group and communicate with fellow group members or third party suppliers.

What (personal data): DLIT collects and process various types of personal data from you, partly by asking, partly automatically. The personal data we ask from you includes your (full) name, (email) address, (mobile) telephone number, employer. The information we collect automatically includes preferences, special requests, geolocation.

What (about aggregated personal data): when rendering its service, DLIT may ask its users (including yourself) and partners to provide certain data points that may include personal data (including sensitive data). These data points will be converted into [highly] aggregated data and may include averages, totals, or statistical analysis derived from a large dataset and shall not contain personally identifiable information (the "Aggregated Data"). The Aggregated Data cannot be re-converted or de-anonymized or used for re-identification. The Aggregated Data does not fall under the scope of this privacy statement since it does not include personally identifiable information, nor can be used to (re-)identify individuals.

What else – cookies: we use cookies to recognize visitors and remember their preferences (personalisation) and deliver better user experience (see our cookie statement [link] for more information).

What else – rights: you will obviously enjoy all rights as granted by applicable law (e.g. right to know what information we hold, right to be forgotten, right to amend, correct, delete, block your personal information).

What else – security: we have implemented a range of procedures, controls and measures to prevent unauthorised access to, and the misuse of, your personal data that we process (including encryption, prevailing access control tools and technologies and network security controls).

Where: we collect and process information through our website and app. On these platforms, you can manage and maintain your personal information, including the cookie settings. 

When: upon registration with DLIT (or at any time thereafter), DLIT may ask you to provide, update and complete relevant required personal information in its system through the platform on which our service is available to you.

Who: DLIT is responsible for the data it collects and acts as data controller; see paragraph 1.1 below for more information about DLIT. DLIT may share certain Aggregated Data with its partners who use this data for benchmarking purposes.
Furthermore, DLIT may share certain personal information with its affiliated group companies (e.g. for customer service) and trusted subcontractors. DLIT is responsible for these parties (which act as data processor subject to a data processor agreement with DLIT).

How (long): we will collect and process your personal information in accordance with this privacy statement (including cookie statement) and retain personal data for as long as it is deemed necessary to manage the business relationship with you, to provide our services to you and to comply with applicable laws (including those relating to the retention of documents), to resolve disputes or claims with any third parties, and – if otherwise necessary – to enable us to conduct our business. The above is a general overview. Depending on the law that applies to you, we might be required to provide some additional information on your rights and our obligations. Please find below more
detailed information about the use and process of your personal information. 

Important notice: DLIT may from time to time request you to provide (on voluntarily basis) certain sensitive information (e.g. personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, health data (e.g. disability, medical/physical) limitations and illnesses) and a person’s sexual identity or sexual orientation) (the "Sensitive Data"). DLIT shall require the prior explicit active consent (e.g. checkbox) from the User and stipulate the purpose for usage and process when such data is requested. Gender is not a sensitive personal data point.

1. INTRODUCTION AND DEFINITIONS
1.1 About us
1.1.1 We are Diverse Leaders in Tech Coöperatief U.A., a DLIT, incorporated under the laws of the Netherlands and having its registered office at Saenredamstraat 74, 2021 ZV Haarlem (“DLIT”;’we’; ‘us’;’our’).
1.1.2 We collect personal data via our platform (website/app) and cookies (see our cookie statement for more information).
1.1.3 The personal data that DLIT collects in relation to its Users depends on the context of the business relationship and their interaction with DLIT, the choices the User makes and the products, services and functions they use.

1.2 Privacy statement
1.2.1 This privacy statement explains how DLIT processes your personal data. “You”; “your”; or “User”; means you, the user of our service as made available on our website/app (including any other natural person of whom the personal data is provided to DLIT)
1.2.2 This privacy statement applies to every group company of DLIT that is responsible for or involved in the processing of a User's personal data. Depending on the nature of the business relationship, various group companies of DLIT may be responsible for the processing of that personal data. 

2. DATA COLLECTION
2.1 Personal data DLIT collects
2.1.1 We may ask you for the following personal data:

• Contact details
  We collect relevant contact information from Users, such as first and last name, date of birth (if required), (email) addresses, (mobile) telephone numbers, credit card details (if required), preferences or special requests etc.
• Financial data
  We collect data necessary for payment and billing purposes (including your bank details, bank account number, credit/ debit card and VAT number) and data otherwise required for invoice processing.
• Sensitive Data
  We may from time to time request you to provide (on voluntarily basis) certain Sensitive Data. There is no obligation to provide any requested Sensitive Data. Any disclosure of your Sensitive Data is at your sole discretion.
• Other data
  When a User communicates with DLIT, we collect and process information about this communication.

2.2 Information We Collect Automatically
2.2.1 Depending on the business relationship and your settings on your laptop or mobile device, DLIT may also automatically collect information, some of which may be personal data. This data is collected when a User uses online services such as a registration form or a user account.
The data collected may include:

• Language settings
• IP address
• Geo location
• Place
• Device settings
• Device operating system
• Log information
• Time of use
• URL requested
• Status report
• User agent (information about the browser version)
• Browsing history
• The type of data being viewed

2.3 Personal Information You Provide Us About Others or without our request
2.3.1 By sharing personal data of other persons (if applicable), you confirm that these persons have been informed about the use of their personal data by DLIT in accordance with this privacy statement. You also confirm that you have obtained all necessary consents as required by applicable laws and regulations.
2.3.2 Unless explicitly requested by us, we discourage you from providing sensitive personal data at your own initiative. If you choose to disclose without our explicit request, we accept and assume through your self-disclosure your explicit and unconditional consent to process and use that information as described in, and subject to this Privacy Policy.
2.4 Other information we receive from other sources
Data related to requests from governmental authorities
Law enforcement or tax authorities may contact DLIT with additional information about Users in the event that they are affected by an investigation.

Fraud Detection & Prevention, Risk Management & Compliance
In certain cases, and as permitted by applicable law, DLIT may need to collect data from third party sources for fraud detection and prevention, risk management and compliance purposes. 

3. PROCESSING PURPOSES AND SHARING
3.1 Purposes
3.1.1 DLIT uses the previously described information about Users, some of which may be personal data,
where relevant, for the following purposes:

• A. Registration and administration
  DLIT uses account information, contact details and financial information to manage and maintain the business relationship with the User and to render its service to you. This also applies to registration and verification purposes.
• B. Render its business intelligence, analytics, benchmarking, research and customer services DLIT uses the information provided by Users (which may include personal data (including Sensitive Data)) to provide its services, for example, benchmarking services and business intelligence services and such other products and services as from time to time rendered or made available by DLIT to its partners and users, including analytical and research purposes in respect of diversity, inclusion, wellbeing, belonging, equity, accessibility, (workplace) culture, environmental, social, governance, ethics and sustainability within companies, organizations and industries (collectively the “Services”).
  We only use and disclose Sensitive Data as necessary in connection with the performance of services and the provision of goods, compliance with federal, state, or local laws, and as otherwise permitted by applicable privacy and data security laws.
  All personal data provided for the Services (including the Sensitive Data) will be irreversibly aggregated and non-traceable nor referable to the relevant user. All aggregated and non-identifiable data fall outside the scope of this privacy policy.
• C. Other activities, including marketing
  If a potential User has not yet completed the online registration, DLIT may save and send a reminder to complete the registration process. We believe that this extra service is useful for our (future) Users because it allows them to complete the registration without having to re-enter all registration details. DLIT may invite Users to attend events that we believe may be relevant or interesting to them. We may also use personal data to provide and host online forums that allow Users to find answers to frequently asked questions about the range and use of DLIT’s products and services.
  To the extent relevant to the business relationship and depending on your personal preferences, wishes and requests, DLIT uses personal data for communication, including providing information about our services and product (including updates and upgrades), sending our newsletter, inviting Users to participate in (User or Supplier) surveys, reviews, groups, references, promotions or for other marketing communications. When we use personal information to send direct marketing messages electronically, we offer an opt – in option.
• D. Communication with or among Users
  DLIT has (access to) communication with you and other Users (telephone, chatbot , email, platform). We may also use automated systems to review, scan and analyze communications for the following purposes:
  – Product development and improvement
  – General research
  – Customer engagement (including providing information or offers to guests that we think may be of interest to them)
  – Safety
  – Fraud prevention
  – Compliance with legal and regulatory requirements
  – Research possible misconduct
  – Customer or technical support
  Communications sent or received using DLIT’s means of communication are received and stored by DLIT. We do not record all calls. If a call is recorded, each recording is kept for a limited time before being automatically deleted. This is the case unless we have determined that it is necessary to keep the recording for fraud investigation or legal purposes.
• E. Analysis, improvement and research
  DLIT uses the information provided to us, which may include personal data and Sensitive Data, for statistical, analytical and research purposes. This data can also be used for testing purposes, troubleshooting and to improve the functionality and quality of DLIT’s services and products. We also invite Users to participate in surveys and conduct other market research from time to time.
  Certain Users may be invited to join a user forum to communicate with DLIT and/or to exchange experiences with other Users and stakeholders. Please refer to the information DLIT provides when you are invited to participate in a survey, market research or to join an online platform to understand how your personal data may be treated differently than described in this Privacy Statement.
• F. Security, fraud detection and prevention
  We process the information provided to us, which may include personal data, to investigate, prevent and detect fraud and other illegal acts. This may include personal data that a User has provided to DLIT, for example for verification purposes as part of the registration process, personal data collected automatically or personal data obtained from external sources (including from guests).
  DLIT may also use personal data to facilitate investigation and enforcement by competent authorities, if necessary. For these purposes, personal data may be shared with law enforcement authorities.
  DLIT may also use personal data for risk assessment and security purposes, including user authentication, and we use external service providers for third party risk management. These providers help us assess the business risk profile of our Users. They may also provide us with due diligence reports from third parties, which, as permitted by applicable law, may contain potential information about criminal convictions and owner or User violations.
• G. Legal, regulatory and compliance
  In certain cases, DLIT must use the information provided (which may include personal data) to handle and resolve legal disputes or for regulatory investigations, risk management and compliance. We may also use it to enforce our agreement(s) with Users or to resolve any complaint or claim involving a User, and in accordance with internal rules and procedures.
  In addition, we may need to share information about Users (including personal data) where required to do so by law or strictly necessary to respond to requests from competent authorities. This includes tax authorities, courts, other government and public authorities or local municipalities. Finally, DLIT may use personal data for anti-money laundering verification and KYC (know your client) related purposes and obligations.
  If we use automated means to process personal data that produces legal effects or significantly affects you or other natural persons, we will take appropriate measures to safeguard your or the other person’s rights and freedoms. This includes the right to human intervention.

3.2 Legal grounds
3.2.1 As applicable for purposes A and B, DLIT assumes the legal basis that the processing of personal data is necessary for the execution of the agreement between the User and DLIT. If the required information is not provided, DLIT will not be able to work with a User and provide its service, nor will we be able to provide customer service.
3.2.2 For purposes C to G, DLIT relies on its legitimate interest to provide its services to, or obtain services from Users, to prevent fraud and to improve its services. When we use personal data to serve the legitimate interest of DLIT or a third party, we will always balance the rights and interests of the data subject and the protection of their information against the rights and interests of DLIT and/or the third party.
3.2.3 For F and G purposes, DLIT also relies, where applicable, on compliance with legal obligations (such as lawful law enforcement requests).
3.2.4 Finally, if necessary under applicable law, DLIT will obtain your consent before processing personal data, including for its services, marketing purposes or as otherwise required by law.
3.2.5 The collection and process of any Sensitive Data will be strictly under the condition of your prior explicit (active) consent (including at the time of requesting the consent, disclosure of the purpose and use).
3.2.6 If you wish to object to the processing as set out under C to G and cannot find a way to opt out directly (for example in your account settings), please contact DLIT.

4. SHARE WITH OTHERS
4.1 Sharing with affiliated group companies
4.1.1 To support the use of DLIT services, your information (which may include personal data) may be shared with or within DLIT affiliates. This is done for the purposes described below, subject to any contractual terms.
The purposes for sharing data within the DLIT group of companies are:

• A. to offer, provide or make available services and products and to provide support (such as account management and any customer service, billing and collection);
• B. to prevent, detect and investigate fraudulent and other illegal activities;
• C. for analytical, quality and product improvement purposes (including monitoring conversations by live listening or recording for quality and training purposes);
• D. marketing activities (including news items) from which you can easily unsubscribe or unsubscribe) and to personalize online services (including personalized offers andpromotions);
• E. communication purposes (by email, telephone or post) for the above purposes (including survey, market research, reviews or ratings) or as necessary under our agreement with you;
• F. legal purposes, including the handling of complaints, claims, legal claims and for the detection of fraud (in which cases any telephone conversations may be recorded);
• G. to ensure compliance with applicable laws or law enforcement.

With a view to purpose A, and insofar as applicable, DLIT relies on the legal basis that the processing of personal data is necessary for the performance of the agreement with you for the purchase or use of the Product or Service.
DLIT further relies on its legitimate interest and that of its group companies to receive, process and share personal data as described under A to G. This is to provide services to or obtain services from Users, including to improve the services and to prevent fraud or other illegal acts. When personal data is used to serve the legitimate interest of DLIT or a third party, DLIT will always balance the rights and interests of the person concerned in protecting their personal data and the rights and interests of DLIT or the third party.
For purpose G, DLIT also relies on compliance with legal obligations where applicable (such as lawful law enforcement requests or enforce its terms and conditions for use of the service).  
Finally, where needed under applicable law, DLIT will obtain your consent prior to processing your personal data, including for email marketing purposes or as otherwise required by law. If you wish to object to the processing as set out under B to G, and cannot find a way to unsubscribe directly (for example in your account settings), please contact DLIT [add contact/link].

4.2 Sharing with third parties
4.2.1 We may share and use the Users' information (which may include personal data) with third parties, as permitted by law and as described below:
(a) Service providers (including Suppliers, auxiliaries and subcontractors). We share personal information with selected third-party service providers that support us with our products and services, billing/collection, prevent and detect fraud, store data and otherwise support our
business processes.
(b) Screening of sanctions lists or risk management as required by applicable law (including KYC (know your customer) and anti-money laundering obligations).
(c) Forced disclosure. When required by law, strictly necessary for the performance of our services, in legal proceedings, or to protect our rights or the rights of users, we disclose personal data to law enforcement agencies, research organizations, users or group companies.
As applicable and unless indicated otherwise, for purpose (a) and (b) DLIT relies on the legal basis that the processing of personal data is necessary for the performance of a contract, and for purposes (a) to (c), DLIT relies on its legitimate interests to share and receive personal data, and, where applicable, for (c) on compliance with legal obligations (such as lawful law enforcement requests).

4.3 Sharing and disclosure of Aggregated Data
4.3.1 We may further share and disclose Aggregated Data (where the recipient cannot identify you) for business intelligence, benchmarking, industry analysis and/or demographic profiling.

5. SECURITY AND PROTECTION

5.1 You have access to your personal data via your Account.
5.2 We have procedures in place to prevent unauthorized access to and misuse of personal data.
5.3 We use appropriate business systems and procedures to protect and secure information, including personal data. We also use security procedures and technical and physical restrictions to access and use the personal information on our servers. Only authorized personnel have access to personal data in the context of their work.

6. DATA RETENTION
6.1 We retain personal data for as long as it is deemed necessary to manage the business relationship with a User, to provide DLIT services to a User and to comply with applicable laws (including those relating to the retention of documents ), disputes or claims with any parties, and if otherwise necessary to enable us to conduct our business.
6.2 Any personal data we hold about you as a User is subject to this privacy statement and our internal retention guidelines. If you have any questions about the specific retention periods for the different types of personal data we process, please contact DLIT.

7. YOUR CHOICES AND RIGHTS
7.1 Depending on where you are located or the entity of DLIT that processes your personal data, different
rights may apply to the processing of that data, as set out in this privacy statement. As applicable:
You can ask us for a copy of the personal data we hold about you (see also your account settings with your relevant personal information),
You can notify us of any changes to your personal information, or you can ask us to correct the personal information we hold about you,
In certain situations, you can ask us to delete, block, amend or restrict the personal information we hold about you, or you can object to certain ways in which we use your personal information,
In certain situations, you can also ask us to send the personal data you provide to us to a third party.

7.2 Where we use your personal information based on your consent, you have the right to withdraw that consent at any time, subject to applicable law. Where we process your personal data on the basis of legitimate interest or public interest, you also have the right to object at any time, subject to applicable law.
7.3 Regardless of your location or the DLIT entity you have a contract with, we rely on our Users to ensure that the personal information we hold is complete, accurate and current. Always inform us in good time of any changes or inaccuracies in your personal data.

8. CONTACT US
8.1 If you have any questions, wishes or comments about how we process your personal data, or if you would like to exercise any of the rights you have under this Privacy Statement, please contact us. You can also contact your local data protection authority.
8.2 We handle privacy specific questions, requests and concerns reported to us using internal policies and procedures based on applicable privacy laws, regulations and guidelines. We regularly review and improve this policy and procedures, also taking into account User feedback.

9. CHANGES TO THIS PRIVACY STATEMENT
This privacy statement may be amended or supplemented from time to time. If we intend to make material changes or changes that affect you, we will always contact you in advance. An example of this type of change would be if we started processing your personal data for purposes not described above.

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Location: Amsterdam, NL

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