We are Move and we design and develop world class digital products for our clients our website is www.moveagency.com
We can be found at Westerlaan 133, Zwolle, The Netherlands.
We are part of the Framna group of companies which includes companies based in Denmark, Switzerland, Sweden, the UK and USA.
This privacy notice (“Privacy Notice”) sets out how we use and protect your personal data when we collect it in any of the following ways:
Throughout this Privacy Notice, where we refer to “Data Protection Legislation”, we mean the EU General Data Protection Regulation (EU GDPR). This includes any replacement or amending legislation coming into effect from time to time.
When we use the term “personal data” and “processor” in this Privacy Notice, these terms have the meanings given to them in Article 4 of the EU GDPR.
We are committed to meeting the requirements of the Data Protection Legislation and we have developed this Privacy Notice to ensure that you are aware of:
We will only use your personal data in accordance with this Privacy Notice. If we need to use your personal data for any other purpose, we will tell you and we will update this Privacy Notice.
We only collect personal data that we genuinely need and only in accordance with the Data Protection Legislation.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
The table shown at the end of this Privacy Notice explains how and why we process each type of personal data.
You can access the table here
We will only ever process your personal data if we have a legal basis to do so. The legal bases we rely on are:
The table shown at the end of this Privacy Notice explains the purpose of our processing and the legal bases that we rely on for each type of personal data which we process.
You can access the table here.
You have a number of rights under Data Protection Legislation. If you would like to exercise any of these rights, you can contact us using the contact details in the “Contact Us” section further below.
Your rights under the Data Protection Legislation are:
(a) Right to be informed about our collection and use of your personal data
You have the right to be informed about the collection and use of your personal data. This Privacy Notice gives you this information.
(b) Right to access your personal data
You have the right to access the personal data that we hold about you. This is sometimes called a ‘Subject Access Request’. If we agree that we are obliged to provide personal data to you (or someone else on your behalf), we will provide it to you or them free of charge and will aim to do so within 1 month from the point that we are able to confirm your identity. We will ask for proof of identity and sufficient information about your interactions with us so that we can locate your personal data.
(c) Right to correction your personal data
If any of the personal data we hold about you is inaccurate, incomplete or out of date, you can ask us to correct it.
(d) Right to restrict processing
You have the right to ask us to restrict the processing of your personal data. For example, this may be because you have issues with the accuracy of the data we hold or the way we have processed your data. This right is not absolute and only applies in certain circumstances.
(e) Right to erasure
You have the right to have personal data erased. This is also known as the ‘right to be forgotten’. This right is not absolute and only applies in certain circumstances.
(f) Right to portability
The right to portability gives you the right to receive personal data you have provided to us in a structured, commonly used and machine-readable format. It also gives you the right to request that we transmit this data directly to a third party.
(g) Right to object
You have the right to object to our processing of some or all of the personal data that we hold about you. This is an absolute right when we use your data for direct marketing but may not apply in other circumstances where we have a compelling reason to do so, e.g., where we have a legal obligation to do so. You can make a complaint to Autoriteit Persoonsgegevens (the Dutch Data Protection Authority) at any time about the way we use your personal data. However, we hope that you would consider raising any issue or complaint you have with us first. Your satisfaction is extremely important to us, and we will always do our very best to solve any problems you may have.
If you have any feedback about this Privacy Notice or would like to complain about our privacy practices please contact our Data Protection Officer at: privacy@moveagency.com
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
The table shown at the end of this Privacy Notice explains how long we retain each type of personal data. You can access the table here.
Our group companies
We are part of a group of companies known as the Framna Group. You can find details of each of our group companies <here>.
We share your personal data between our group companies for the following reasons:
Where we share data between the group companies we have group information sharing agreements and data processing agreements in place.
External parties
In some circumstances we may need to share your personal data with third parties in order to:
We may share your personal data with the following third parties:
In all cases we will:
In some instances your personal data may be processed outside the European Economic Area (EEA), for example where we use an IT provider based outside the EEA.
If and when this is the case we take steps to ensure there is an appropriate level of security so your personal data is protected in the same way as if it was being processed within the EEA.
Where we need to transfer your data outside the EEA we will use one of the following safeguards:
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
When you first visit our website, you will be asked for your permission for us to use some types of cookies.
We have separated our cookies into four categories:
Strictly Necessary Cookies
These cookies will always be placed.
Strictly necessary cookies are necessary for our website to operate as some cannot be switched off. The cookies include those that ensure our site is secure, operates as you would expect and remembers your privacy preferences.
Performance Cookies
With your permission we use performance cookies to measure and improve the performance of our site. These cookies help us analyse data about web page traffic and to tailor it to customer needs. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our website and will not be able to monitor its performance.
Functional Cookies
With your permission we use functional cookies that enable our website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
Targeting and Advertising Cookies
With your permission we utilise third party marketing and advertising cookies – these cookies are placed by third party marketing companies (such as Google) or social media companies (such as Facebook) and are used to understand the pages that you have visited so relevant advertisements can be shown to you on these platforms and on other websites.
These cookies do not directly store your personal data but can uniquely identify your browser and device. If you do not allow these cookies, you will see less targeted adverts from us. You may however see generic advertisements from or about us on social media or around the web.
Cookies help us provide you with a better experience, by enabling us to monitor which pages you find useful and those which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
We keep this Privacy Notice under regular review.
We may change this Privacy Notice from time to time (for example, if the law changes). If the changes are material, we will take steps to inform you.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
If you would like to:
you can contact us by clicking <here> or by emailing our Data Protection Officer at privacy@moveagency.com.
Purpose / Use
Type of Data
Legal Basis
Retention Period
To respond to any question or enquiries that you make to us.
Identity
Contact
Social Media
For prospects and leads - 2 yearsfrom last contact
For clients - 7 years from lastcontact or end of contract (if later)
Legitimate interest (todevelop our businessand respond toenquiries)
To manage our contractual relationship with you / your employer, this includes:
Identity
Contact
Marketing and
Communications
7 years from end of contract
Performance of acontract with you
Collect and recover money owed to us
Identity
Contact
7 years after end of relevant financial year
Legitimate interest (debtrecovery)
Manage and improve our business interactions with you, this includes:
Identity
Contact
Technical Data
Usage
2 years
Legitimate interest (to develop and improve our business, website marketing campaigns and services)
To promote our services, this includes:
Identity
Contact
Marketing & Communications
Social Media
2 years from last contact
Consent
Business development, this includes:
Identity
Contact
Social Media
2 years
Legitimate interest (to expand and develop our business)
To recruit the best talent within our sector
Identity
Contact
Recruitment
4 weeks
1 year with consent
Necessary prior to entering into a contract with you, consent if kept longer than 4 weeks
To administer and protect our business and website (including troubleshooting, testing, system maintenance, support, reporting and hosting of data, investigating and responding to service or security issues)
Identity
Contact
Technical
Usage
For systems monitoring (for example, to detect and prevent failures, vulnerabilities and external threats) - current year plus 1 year.
Where externally developed IT infrastructure, software and systems are used - 7 years from decommissioning of the infrastructure, software or system.
For technical information relating to client user accounts - 1 year from account closure.
Legitimate interests (for running our business, provision of administration and IT services and network security)
To deliver relevant website content and online advertisements to you and to measure or understand the effectiveness of the advertising we serve to you
Identity
Contact
Usage
Marketing and Communications
Technical
2 years
Legitimate interests (to study how you use our products and services, to develop them, to grow our business and to inform our marketing strategy)