Privacy Statement Rotate Group B.V.

Rotate respects the privacy of all individuals whose personal data may be processed by Rotate in the performance of our business operations. All personal data will be protected in accordance with the applicable data protection laws, which includes – for the European Economic Area (EEA) – the General Data Protection Regulation (GDPR). This Privacy Statement explains how Rotate collects, holds, uses, and discloses personal data when you visit our website, contact us, do business with us or apply for a job at Rotate, for what purpose and what rights you have with regard to the processing of your personal data.

This website is owned and operated by Rotate Group B.V. (referred to in this Privacy Statement as “Rotate”, “we”, “our”, or “us”). Rotate is an entity incorporated under the laws of the Netherlands.

1. WHO IS ROTATE AND HOW CAN YOU CONTACT US?

Rotate Group B.V. is responsible for the processing of your personal data.

If you have any questions concerning this Privacy Statement or data protection in particular, please contact us at privacy@letsrotate.com or via:
Rotate Group B.V.
Arthur van Schendelstraat 650
3511 MJ Utrecht
The Netherlands

2. HOW DO WE USE YOUR PERSONAL DATA?

Below you will find an overview of the purposes for which Rotate processes personal data about you. It includes which personal data Rotate uses for that specific purpose, what the legal basis is and for how long your personal data is retained.

Users of our platform

If the company you work for/with is our customer or if you use the free Live Capacity dashboards, we process your personal data (e.g. your name and e-mail address) to register your account, so we can give you access to our platform. The legal basis for this data processing can be found in the legitimate business interests of Rotate, to be able to execute our agreement with our customer and facilitate your access to and use of our platform. We will retain your personal data for the duration of the agreement with the customer or shorter, e.g. because we have to terminate your account at the customer’s request.

Contact

You may contact us in various ways, including via a contact form on the website, by e-mail and by telephone. The information we obtain from you for this contact will only be used to answer your question and to provide our services. The legal basis for this data processing can be found in the legitimate business interests of Rotate. We will not retain your data longer than necessary to answer your question.

Newsletters

If you would like to keep informed of our developments and studies, you may subscribe to our newsletter. We process your e-mail addresses in order to send the newsletters. Rotate has a legitimate interest in this processing for such direct marketing purposes. You may unsubscribe at any time via the unsubscribe button in our newsletter. Rotate will retain your e-mail address for this purpose as long as you are subscribed to the newsletter and will delete your data within one month of unsubscribing.

Email analytics

Rotate has incorporated an e-mail tracking functionality into its newsletters by embedding a small, transparent image pixel in the outgoing newsletter. As soon as you open the newsletter, Rotate can access certain information, such as the recipient’s name and surname, the recipient’s e-mail address, confirmation that the recipient has received and opened the e-mail, IP address from which the e-mail was opened, whether a link in the e-mail was clicked on, IP address from which the link was clicked on and browser and operating system used by the person who clicked on the link. The processing of these personal data is necessary for the protection of Rotate’s legitimate interests, i.e. to analyse the scope and effectiveness of newsletters sent by Rotate. Data will not be retained for longer than six months.

Careers at Rotate

When applicants provide us with personal data, we will process such personal data for recruitment and selection purposes. The personal data and documents provided by you may include your contact details, CV and motivation letter. We process this personal data to determine your eligibility for the vacancy for which you have applied or, in case of an open application, to determine your eligibility for a position within Rotate. Rotate has a legitimate interest in the aforementioned data processing activities, which include the recruiting of suitable new staff that meet our high standards of service.
Rotate stores applicants’ personal data during the recruitment and selection procedure. Your application data will be deleted (in the event of rejection) by Rotate no later than four weeks after the end or completion of the application procedure. Only with your consent will Rotate retain your application data for a period of one year in order to be able to inform you if a suitable position becomes available for you at a later date.

Investors, suppliers, partners

We process personal data that we obtain in the context of our interactions with you as (a staff member of) a (prospective) supplier, investor or business partner because it is necessary to enter into a contract and for the performance of that contract. We may also need your personal data in order to comply with our legal obligations (for example, tax and accounting regulations) and in order to pursue our legitimate interests (for example, in case of a dispute). For these purposes, we may collect and process identification data (such as, name, email address, phone number, postal address), employment data (such as, employer, function) financial data (such as, bank account), and other information provided (for instance in correspondence with us).
Rotate will retain your information for as long as we hold a business relationship. Data required for our bookkeeping is retained for seven years.

Website visitors

We automatically collect generated data about your use of the website. This information consists of your IP address (a unique number, which makes it possible to recognize your device), data displayed or clicked on (including UI elements, links); and other log information (including browser type, IP address, date and time of access, cookie ID, and referrer URL). We need this information in order for the website to work as optimally as possible (for example, to display content correctly and to keep the website secure). The processing of these personal data is based on our legitimate interests. For more information on how we use your information when you visit our website, please be referred to our Cookie Policy [link].

Visitors to our office

We meet visitors at our office, including external training providers, job applicants, suppliers, investors and stakeholders. If your visit is planned, we will send your name and visit information to reception before your visit. If you arrive without an appointment, your name will be noted by the reception upon arrival. The purpose for processing this information is for security and safety reasons and the processing is based on our legitimate interests and the legitimate interests of the building operator (from which we rent our office).

Complaints, disputes and legal claims

We may process personal data to exercise our rights by establishing, exercising or defending a legal claim or in order to defend ourselves or our staff against a legal claim from third parties (including disputes, complaints, questions and/or investigations). It is in our legitimate interest to process personal data be able to exercise our rights and to defend ourselves and our staff against legal claims. Your personal data will be retained for as long as necessary to achieve these purposes.

 

3. WHO DO WE SHARE DATA WITH?

We only share a your data with third parties if:

  • This is necessary for the provision of a service or the involvement of the third party. Sub-contractors, for example, will in principle only get access to the personal data that they require for their part of the service provision and will not be allowed to process the data for their own purposes.
  • The persons within the third party that have access to the personal data are under an obligation to treat this data confidentially. Where necessary this is also contractually agreed on.
  • The third party is obliged to comply with the applicable regulations for the protection of personal data, for instance because we have concluded an agreement with this party or because our Terms of Use apply. This includes that the party is obliged to ensure appropriate technical and organizational security measures, and that any transfer of personal data to countries outside the EEA is adequately legitimized.

We could share your data on a need-to-know basis with the parties mentioned below. In this context, “need-to-know” means that a party only gets access to your personal data if and insofar as this is required for the professional services provided by this party.

  • Authorized persons, employed by Rotate, who are involved with the processing activity concerned. Such as, the members of the support team you are in contact with.
  • Authorized persons, employed by service providers / sub-contractors engaged by Rotate, who are involved with the processing activity concerned.
  • Authorized government institutions. Such as, courts, police, and law enforcement agencies. We may release information about you when legally required to do so, at the request of governmental institutions conducting an investigation or to verify or enforce compliance with applicable laws and regulations. We may also disclose such information whenever we believe disclosure is necessary to protect the rights, property or safety of Rotate or others.

 

4. TO WHICH COUNTRIES WILL WE TRANSFER DATA?

Parties involved with the processing of personal data originating from the EU, may be located in a different country, such as the United State. In order to comply with EU data protection legislation for international transfers, we carefully consider whether an adequate level of protection can be safeguarded. Where necessary, we lay down arrangements in a data transfer agreement based on standard contractual clauses adopted by the European Commission (Article 46(2)(c) GDPR).

In specific situations we can also rely on the derogations from article 49 GDPR to legitimize the data transfer. This means that we may transfer personal data: (i) with your explicit consent, (ii) if this is necessary for the performance of a contract that has been concluded with you or has been concluded in your interest, or (iii) if this is necessary for the establishment, exercise or defence of legal claims. Lastly, in exceptional cases we may also transfer personal data if the data transfer is necessary for our compelling legitimate interests and is not overridden by your interests or rights and freedoms.
For more information about the safeguards for international data transfers, please contact us using the contact details included in this Privacy Statement.

 

5. WHAT ARE YOUR PRIVACY RIGHTS?

Based on the General Data Protection Regulation (“GDPR”; (EU) 2016/679) you have various privacy rights. To what extent these rights can be exercised, may depend on the circumstances of the processing, such as the manner in which Rotate processes the personal data and the legal basis for the processing. Below we included a summary of the relevant privacy rights under the GDPR.

  • Right to withdraw consent. If the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time. After you have withdrawn your consent, Rotate will no longer process your personal data for the related purposes. Please note that the withdrawal of consent does not affect the lawfulness of the processing before it has been withdrawn.
  • Right of access. This concerns the right to request access to your personal data. This enables you to receive a copy of the data we hold about you (but not necessarily the files themselves). We will then also provide further specifics of our processing of the personal data. For example, the purposes for which we process the data, where we got it from, and with whom we share it.
  • Right of rectification. You have the right to obtain rectification of incorrect or incomplete personal data. If needed, you may provide additional personal data in order to complete the collection of personal data.
  • Right to erasure. This concerns the right to request erasure of the data. This enables you to ask us to delete or remove personal data where: (i) the data is no longer necessary, (ii) the processing activities have been objected to, (ii) the data has been unlawfully processed, (iv) the data has to be erased on the basis of a legal requirement, or (v) where the data has been collected in relation to the offering of information society services. However, we do not have to honor such request in all cases.
  • Right of restriction. The right to restriction of processing means that Rotate will continue to store personal data at your request but may in principle not do anything further with it. In short, this right can be exercised when Rotate does not have (or no longer has) any legal grounds for the processing of the data or if this is under discussion.
  • Right to data portability. You have the right to receive your personal data that you have provided to Rotate in a structured, commonly used and machine-readable form and you have the right to transmit those data to another data controller, where the processing is based on your consent or on the performance of a contract.
  • Right to object. Under certain circumstances, you have the right to object to processing of your personal data where we are relying on legitimate interests as processing ground. Insofar as the processing of your personal data takes place for direct marketing purposes, we will always honour your request. If it concerns processing for other purposes, we will make a new balance of interests and determine whether Rotate has compelling legitimate grounds that override your interests.
  • Automated decision-making. This concerns the right not to be subject to a decision based solely on automated processing, which significantly impacts you. In this respect, please be informed that when processing your personal data as described in this Privacy Statement, we do not make use of automated decision-making.
  • Right to complaint. Rotate is committed to resolving complaints about your privacy and our collection or use of your personal data. If you are not satisfied with the way Rotate handles your personal data, you may file a complaint to the appropriate supervisory authority, in particular in the EU Member State of your habitual residence, place of work or where an alleged infringement took place. Please be referred to the website of the European Data Protection Board (EDPB) for an overview of the supervisory authorities and their contact details. However, we would appreciate the chance to deal with any concerns before the supervisory authority is approached, so please contact us beforehand.

How we handle request

You can submit your request to Rotate via privacy@letsrotate.com . We will respond to your request as soon as possible, but in any case within one month of receipt of the request. This period may be extended by two months if necessary, depending on the complexity of the requests and their number. We will inform you within one month of receipt of the request if such an extension is to be made, stating the reason for the delay. If we does not act upon your request, we will inform you of the reasons for not acting.

6. CHANGES TO THIS PRIVACY STATEMENT

We may change this Privacy Statement from time to time to accommodate new technologies, industry practices, regulatory requirements or for other purposes. The latest version can always be consulted via this website. Important changes will also be communicated proactively. This Privacy Statement was last amended in December 2023.