This privacy statement of Bouman Bedrijfsadvisering B.V., with statutory seat in Amsterdam and with office address at Nieuwe Steen 34, 1625 HV in Hoorn, the Netherlands (hereinafter referred to as “Bouman Bedrijfsadvisering”), applies when visiting our website, to (potential) clients using our services, suppliers, relations, and employees of Bouman Bedrijfsadvisering, and relates to all processing of personal data for which Bouman Bedrijfsadvisering is responsible. This privacy statement can also be consulted on www.boumanbedrijfsadvisering.nl or will be sent upon request (via email).

We respect everyone's privacy and comply with the applicable laws and regulations, such as the provisions of the General Data Protection Regulation (GDPR) effective from May 25, 2018, including the implementation act of this regulation, as well as the (processor) agreements Bouman Bedrijfsadvisering has concluded with customers, suppliers, and relations.

Website

The information obtained through the website of Bouman Bedrijfsadvisering is of a general informative nature. Although Bouman Bedrijfsadvisering strives to maintain and update the website continuously, it is possible that the content of (parts of) the website is no longer accurate, complete, or up-to-date. Bouman Bedrijfsadvisering accepts no liability for the consequences of actions or omissions by the website visitor based on the information obtained from the website.

Processing of Personal Data

Bouman Bedrijfsadvisering does everything possible to ensure your privacy. We only process personal data if it is strictly necessary for the purpose of processing, so that we can offer good service and/or it is necessary for our business operations.

We distinguish between actively and passively provided data. Passively provided data are those you provide to website administrators without being aware of it. The data you have passively provided to us is, in principle, not used by us. Only if you provide your contact details (name and email address) so that we can contact you, will this information be recorded. It only concerns data that is necessary to get in touch with you.

Bouman Bedrijfsadvisering also collects and processes data that you actively provide to us.

For relationship management and communication, personal data such as:

• last name, first name(s), initials;

• address, zipcode, city;

• email address(es);

• phone number(s);

• gender;

• position;

• bank account number (if applicable).

In addition to the aforementioned personal data, (special) personal data (of a sensitive nature) of individuals may also be processed for the purpose of financial administration, annualaccounts, annual reports, publication balances, various tax returns, (subsidy) applications, and providing tax or legal advice. For clients with employees, we process (special) personal data of their employees when managing payroll administration. If we process special personal data, this will not happen without your consent. This consent can be withdrawn at any time. Withdrawing consent may result in you no longer being able to use certain services of Bouman Bedrijfsadvisering.

The (special) personal data (of a sensitive nature) that is processed for the aforementioned

services includes:

• Social Security Number;

• copy of identification;

• date of birth;

• place of birth;

• bank account number(s);

• information about the children of clients (if applicable);

• data about mental or physical health in connection with payroll calculation (only

  applicable for payroll administration);

• copy of payroll tax statement; login information such as usernames and passwords (if applicable);

• financial and economic data (if applicable).

We handle the aforementioned (special) personal data with utmost care. Technical and organizational security measures are in place to protect this data.

Are you under 16 years old?

If you are under 16 years old, you may only provide personal data to us if you have received permission from one of your parents or a legal representative who has read Bouman Bedrijfsadvisering's privacy statement.

Legal Basis and Purposes of Processing

The legal basis on which Bouman Bedrijfsadvisering processes almost all personal data is the necessity for the proper execution of the agreement (of assignment) or as preparation for entering into an agreement (of assignment). This applies to all services that Bouman Bedrijfsadvisering provides to its customers, agreements with suppliers, employment contracts with employees, as well as to ensure the necessary business operations run as correctly, efficiently, and safely as possible.

In addition, it is possible that we process your personal data based on consent, a legal obligation, or due to legitimate interest. In case of consent, you have the right to withdraw consent at any time. You can refuse consent, but this may in some cases mean that we must terminate our relevant services to you. Whether our services need to be terminated for this reason is solely at our discretion.

Your Rights

As a data subject, you have the following rights:

• the right to information about the existence and purpose of the processing before your personal data is processed;

• the right to access the personal data we process;

• the right to rectification or correction if we have processed incorrect information about you, or the right to provide a supplementary statement when processing occurs based on incomplete data;

• the right to erasure (right to be forgotten): in certain cases, we will delete your personal data at your request, unless there is a legal obligation to retain it;

• the right to restrict processing: in certain cases, you have the right for us not to process or modify your personal data;

• the right to data portability: you have the right to obtain the personal data we have about you in a structured, commonly used, and machine-readable format.

If you wish to exercise your rights, we kindly request you to submit your request in writing, by letter, or by email (see below for the contact details of Bouman Bedrijfsadvisering). We will verify your identity before complying with your request.

Services by Third Parties

Bouman Bedrijfsadvisering engages (legal) entities (“Third Parties”) to ensure that its services run as efficiently, correctly, and safely as possible. These Third Parties include software and IT system providers, specialized advisors, and other service providers. The services provided by these parties are performed under the responsibility of Bouman Bedrijfsadvisering. If these parties necessarily need access to personal data, a (processor) agreement will be concluded, if necessary, which includes agreements regarding the correct and safe processing and confidentiality of this personal data.

Disclosure to Third Parties

We never pass on your data to a third party for further processing without your consent. Bouman Bedrijfsadvisering will only disclose your personal data to law enforcement or government agencies when required by applicable law or by order of a government agency, and only to the extent necessary to combat fraud or criminal activities. Information intended for third parties such as the government or banks, other than the aforementioned information, such as tax returns and financial reports, will only be provided by us based on authorization from the data subject. Preferably, these documents will be sent directly by the data subject to these third parties. Under no circumstances does Bouman Bedrijfsadvisering sell entered data to third parties unless the data subject has expressly given permission to do so.

Security and Retention Period

Taking into account the state of the art, implementation costs, as well as the nature, scope, context, and processing purposes, and the varying risks for the rights and freedoms of natural persons in terms of probability and severity, Bouman Bedrijfsadvisering takes appropriate technical and organizational measures to ensure a level of security appropriate to the risk. It is ensured that only the necessary persons have access to the data, that access to the data is protected, and that security measures are regularly reviewed. Employees of Bouman Bedrijfsadvisering are bound by a confidentiality obligation when processing personal data.

If we no longer need personal data, it is checked and deleted when possible. The retention period depends on the purpose of the processing and legal provisions. Bouman Bedrijfsadvisering may retain personal data longer if there are circumstances that warrant it, but will never do so longer than necessary.

Processing Register

In accordance with applicable laws and regulations, Bouman Bedrijfsadvisering maintains a register of processing activities carried out under the responsibility of Bouman Bedrijfsadvisering.

Data Breach Policy

Bouman Bedrijfsadvisering keeps a register of data breaches. Additionally, we have established an internal policy regarding, among other things, reporting data breaches. As required by law, a data breach that could have serious consequences is reported to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). If the data breach is likely to result in a high risk to the rights and freedoms of the data subject, we will also notify the data subject of the data breach.

Changes

Bouman Bedrijfsadvisering reserves the right to make changes to its privacy policy. Bouman Bedrijfsadvisering therefore advises you to consult this Privacy Statement regularly. If Bouman Bedrijfsadvisering implements significant changes that may affect the processing of personal data, it will inform the data subjects in advance.

Contact

For questions and/or complaints about your rights and the way Bouman Bedrijfsadvisering handles your personal data, we kindly request you to first contact us in writing by letter or email.

Bouman Bedrijfsadvisering strives to provide you with an answer within four weeks. Bouman Bedrijfsadvisering handles your data with the utmost care. If you nevertheless wish to file a complaint, Bouman Bedrijfsadvisering refers you to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

Contact details:

Bouman Bedrijfsadvisering B.V.
Attn: Mr. K.J.K. Bouman
Nieuwe Steen 34
1625 HV Hoorn
Email: info@boumanbedrijfsadvisering.nl
T: 0229-23 18 97
Chamber of Commerce number: 86886320

Privacy statement dated July 8, 2022