4Supplychain Benelux B.V. (hereinafter: “4Supplychain”) respects the privacy of everyone whose personal data is processed by 4Supplychain. 4Supplychain considers the careful handling of personal data to be of great importance and processes personal data in accordance with the General Data Protection Regulation (GDPR) and other applicable laws and regulations.

This privacy statement applies to all processing of personal data by 4Supplychain, with its registered office in Haarlem and its place of business at Maanlander 47, 3824 MN Amersfoort, registered in the Commercial Register under Chamber of Commerce number 81973128, including personal data of potential clients, clients, prospects, business contacts, website visitors, employees, shareholders, independent contractors, job applicants, and other individuals with whom 4Supplychain has contact in the context of its services or business operations. To the extent that 4Supplychain processes personal data in the context of its own business operations or for its own purposes, it acts as a data controller within the meaning of the GDPR. To the extent that 4Supplychain processes personal data on behalf of a client and exclusively in accordance with that client’s instructions, it acts as a processor. For processing operations in which 4Supplychain acts as a processor, the privacy documentation of the relevant client applies first and foremost.

1. Data Controller

4Supplychain is the data controller within the meaning of the GDPR for the processing operations described in this privacy statement, unless expressly stated otherwise.

4Supplychain’s contact information is:

Maanlander 47
3824 MN Amersfoort
+31 (0) 85 200 70 18
info@4supplychain.com

For questions about this privacy statement or the processing of personal data, please contact 4Supplychain using the contact information provided above.

2. What personal data 4Supplychain processes

4Supplychain processes personal data provided directly by the data subject, received from a client, generated through the use of the website or other means of communication, or lawfully obtained from public or business sources.

Depending on the nature of the relationship with 4Supplychain and the specific contact, this may include, among other things, name, business contact information, job title, company name, email address, phone number, communication details, content of correspondence, calendar and appointment details, information entered via the contact form on the website, information provided via the careers or job application form on the website, resumes, information about work experience, education, expertise, motivation, availability, project details, task assignments, roles, responsibilities, deadlines, progress updates, time logs, billing and administrative data, payment details, and bank information.

In the context of assignments, 4Supplychain may also receive and analyze operational datasets and other data files from clients, such as data regarding procurement, sales, inventory, production, transactions, and other supply chain data. These datasets are not always personal data, but they may contain personal data—for example, when they include the names of contacts, employees, customers, suppliers, or other identifiable individuals.

In addition, when recording, transcribing, and summarizing conversations, personal data may be processed, such as voice recordings, names, job titles, substantive contributions to the conversation, transcripts, interview reports, and summaries.

As part of its regular services, 4Supplychain does not intend to process special categories of personal data or personal data of a criminal nature. If such data is nevertheless processed in the context of an assignment or pursuant to a legal obligation, 4Supplychain will comply with the applicable legal requirements.

3. From whom 4Supplychain receives personal data

4Supplychain receives personal data directly from the data subject when the data subject contacts 4Supplychain, fills out a form, applies for a job, registers as an independent contractor, uses the website, or otherwise communicates with 4Supplychain. In addition, 4Supplychain may receive personal data from clients, from clients’ systems and programs used in connection with an assignment, from CRM systems and project management systems, from public business sources such as company websites and business networks, from software and communication platforms used in business operations, and from other business contacts.

To the extent that communication with 4Supplychain takes place via business networks or social media platforms, the platform in question remains primarily responsible for the processing within its own platform. As soon as 4Supplychain itself receives and uses personal data from such communication, it processes that data for its own business purposes.

4. Purposes of Processing

4Supplychain processes personal data for the purpose of entering into and executing agreements, providing consulting, project management, and interim management services in the field of supply chain management, analyzing business processes and supply chain performance, preparing recommendations and reports, guiding change processes, planning, coordinating, and monitoring activities, maintaining contact with clients, potential clients, and other business contacts, following up on prospects, managing client relationships, providing information about relevant changes to services, working methods, or the organization; processing job applications and managing the engagement of independent contractors; maintaining personnel and business records; tracking hours, leave, and availability; managing financial records and invoicing; handling questions or requests, managing and securing the website, systems, and software, improving services and business processes, and complying with legal obligations.

To the extent that 4Supplychain processes personal data in clients’ systems or otherwise on behalf of clients, this is done exclusively on their behalf and in accordance with their instructions.

5. Legal Bases for Processing

4Supplychain processes personal data only if there is a valid legal basis for doing so.

Processing may be necessary for entering into or performing a contract with the data subject or with the organization for which the data subject works. Processing may also be necessary to comply with a legal obligation, such as tax, administrative, or labor law obligations. Furthermore, processing may take place based on the legitimate interests of 4Supplychain or a client, for example, to maintain business contacts, provide services, plan and coordinate projects, secure systems, improving service delivery, conducting efficient business operations, following up on prospects, and promoting services to existing, former, or potential business contacts. To the extent that 4Supplychain relies on legitimate interest, the interests of data subjects are always taken into account. Finally, processing may take place on the basis of consent, to the extent that consent is required. If processing is based on consent, that consent may be withdrawn at any time. Withdrawal of consent has no retroactive effect.

6. Mandatory Provision of Personal Data

The provision of personal data may be necessary to enter into or perform a contract, to contact you, to process an application or request, to evaluate a job application or registration as an independent contractor, or to carry out an assignment. If the necessary personal data is not provided, 4Supplychain may be unable to enter into a contract, perform its services, process a request, or maintain proper communication regarding the performance of its services.

7. Recipients of Personal Data

4Supplychain does not sell personal data to third parties. However, personal data may be shared with clients, independent contractors engaged by 4Supplychain or other auxiliary persons, and providers of office automation, cloud storage, AI and analytics tools, meeting and transcription tools, CRM systems, project management systems, administrative, time-tracking, and leave management systems, 4Supplychain’s accounting firm, the bank, IT service providers, and authorized government agencies if there is a legal obligation to do so.

To the extent that parties process personal data on behalf of 4Supplychain, 4Supplychain will enter into a data processing agreement with them if and to the extent required by law.

8. Transfer Outside the European Economic Area

4Supplychain uses cloud software and other third-party digital tools. This software may be modified or supplemented from time to time if, in 4Supplychain’s judgment, this is appropriate for the proper conduct of its business or the performance of its services.

Because this software is often used in a cloud-based environment, personal data may be stored in the digital environment of the relevant supplier or its engaged service providers. As a result, personal data may be processed or stored outside the Netherlands and possibly outside the European Economic Area, for example in connection with email, cloud storage, AI tools, transcription software, project management software, and other SaaS solutions. If this is the case, it is done exclusively in accordance with the GDPR and with appropriate safeguards, such as an adequacy decision by the European Commission or the use of approved standard contractual clauses. If you would like more information about the safeguards in place, please contact 4Supplychain.

9. Automated Decision-Making

4Supplychain does not use automated decision-making in which decisions are made solely on the basis of automated processing, including profiling, and which produce legal effects or otherwise significantly affect the data subject. However, 4Supplychain may use software, AI tools, and meeting assistants to record, organize, transcribe, summarize, or analyze personal data, or to support communication and business operations. These systems are intended solely to support human assessment and decision-making.

10. Cookies and Similar Technologies

The 4Supplychain website may use cookies and similar technologies. To the extent that 4Supplychain uses only technical and functional cookies, these are used to ensure the website functions properly and to enhance the user experience. If consent is required for the use of certain cookies or similar technologies, a cookie notice or another appropriate consent mechanism will be used for this purpose.

11. Retention Periods

4Supplychain does not retain personal data longer than is necessary for the purposes for which it was collected, unless a longer retention period is required by law or is necessary to support a legal claim or defense. Tax and administrative data are, in principle, retained for as long as required by applicable laws and regulations. Data from clients, prospects, and other business contacts are not retained longer than necessary for the provision of services, relationship management, the pursuit of commercial interests, or a legitimate interest. Job application data, data from independent contractors, and other personal data are not retained longer than necessary for the purpose for which they were processed.

If personal data is stored in external software, AI environments, or other third-party systems, 4Supplychain strives to delete the data from those systems as well as soon as it is no longer needed, to the extent reasonably possible.

12. Security

4Supplychain implements appropriate technical and organizational measures to protect personal data against loss and unlawful processing. These measures may include, among other things, access restrictions, secure accounts, strong passwords, security software, security features on laptops and systems, backups, and careful management of access rights.

When using external software, attention is paid to security, settings, and the manner in which data is processed. Where reasonably possible, 4Supplychain uses business or paid accounts and settings that promote confidentiality and privacy protection. With cloud-based software, 4Supplychain is partly dependent on the technical infrastructure and security measures of the relevant suppliers. In addition, 4Supplychain takes appropriate measures itself to secure its equipment, accounts, and work environment. However, despite the measures taken by 4Supplychain and its suppliers, the possibility of security incidents cannot be completely ruled out.

Individuals who process personal data on behalf of 4Supplychain are bound by a duty of confidentiality.

If a data subject has reason to believe that personal data is not properly secured or that misuse has occurred, this can be reported using the contact information provided in this privacy statement.

13. Rights of Data Subjects

The data subject has the right to request that 4Supplychain provide access to their personal data and to request the rectification, erasure, or restriction of the processing thereof. In addition, the data subject has the right to object to the processing of personal data, in particular to processing for direct marketing purposes; the right to data portability to the extent that the GDPR applies; and the right to withdraw previously given consent to the extent that the processing is based on consent.

To the extent that 4Supplychain processes personal data exclusively on behalf of a client, a request regarding privacy rights may need to be directed to that client in the first instance. If 4Supplychain receives such a request while it is not acting as the data controller in that context, 4Supplychain will, to the extent appropriate, forward the request or provide the data subject with further information on the matter.

4Supplychain assesses each request in accordance with the GDPR. A request may be submitted using the contact information provided in this privacy statement. In principle, 4Supplychain will respond no later than one month after receiving the request. If the complexity of the request or the number of requests warrants it, this period may be extended in accordance with the GDPR.

14. Complaints

If a data subject has a complaint regarding the processing of personal data by 4Supplychain, they may contact 4Supplychain using the contact information provided in this privacy statement. In addition, the data subject has the right to file a complaint with the Dutch Data Protection Authority.

15. Data Protection Officer

4Supplychain has not appointed a Data Protection Officer, as there is no legal obligation to do so.

16. Changes

4Supplychain reserves the right to amend this privacy statement. The most current version is always available on its website. In the event of material changes, 4Supplychain will, to the extent appropriate, provide further information regarding such changes.