FORA Handelsgesellschaft mbH feels that protection of personal data is essential. We therefore process your data with the utmost care.
With this privacy statement we inform you about how we handle personal data.
- Who is responsible for the processing of your data?
In this privacy statement FORA Handelsgesellschaft mbH (hereinafter: “FORA” or “we”) describes how it handles your personal data as a controller.
- What is personal data?
Information about an identified or identifiable natural person is personal data. Qualifying certain information as personal data partly depends on whether FORA has the legal means which may reasonably be expected to be deployed by FORA to identify a person involved.
- Personal data that we process
We process personal data about you because you yourself provide this data to us when entering into an agreement with us, but also when you use our services and therefore provide us with data, or enable us to record data about your interests and preferences.
Data provided to us
When you enter into an agreement with FORA, we need the following personal data from you:
- (company) name and address;
- Contact data (phone numbers, e-mail addresses);
- Customer number (s);
- Financial data (bank account information, quotes and invoices).
As part of the implementation of an agreement with you or providing a service to you, FORA also processes the following data that can be qualified as personal data:
- User name and passwords
- Other data relevant for the agreement in question.
Data about your use of our services and/or products
When you use FORA services or have any other contact with us, we process – depending on your exact use – the following data that may be seen/is seen as personal data as part of our service provision:
- data relating to your peripheral equipment, such as a MAC-address, an IP-address or any other number;
- your communication preferences and settings;
- data we connect to certain patterns, such as a status in the profile that we create about you based on your consumption behaviour (for example: your product or service purchase frequency);
- surfing behaviour, established on the basis of our own observations or cookies (see also article 9 of this privacy statement);
- customer satisfaction data;
- data about your use of our support department.
- No processing of data from persons under 16 years of age
We do not have the intention to collect data from website visitors younger than 16. We advise parents to be involved with their children’s online activities in order to prevent FORA from processing their personal data.
- Processing: principles and legitimate interests
The processing of personal data takes place based on the following principles in article 6 of the General Data Protection Regulation:
- Implementation of an agreement with you
- Legal obligation
- Task carried out in the public interest
- Legitimate interest of FORA or a third party
Legitimate interests are, among others: marketing, advertising, security, (crime) prevention, IT management, research into and analysis of products or services, business economy, legal matters, internal management.
- Purposes for the processing of personal data
FORA processes your personal data for purposes mentioned below. The number behind each purpose matches the principles mentioned in article 5 of this privacy statement.
- Building and maintaining the customer relationship including maintaining a direct relationship between the responsible and associated financial service providers – among others for commercial purposes [principle: 2, 5].
- Handling orders (including invoicing), the process in financial administrations and logistic handling [principle: 2, 5].
- Offering customer service including service surrounding the purchase of services and products, fulfilling warranty obligations and product withdrawals for our own service provision, handling complaints and requests [principle: 2, 3, 4 or 5].
- Maintaining communication in certain cases to proactively contact users as part of vehicle defects or malfunctions or to plan service agreements, including enabling mobility services [principle: 2 or 5].
- Carrying out a market survey to improve our business operation, brands, services and products [principle: 5].
- Communicating with parties involved and offering a loyalty programme [principle: 1 or 5].
- Approaching you with offers or other commercial information. You always have the possibility to unsubscribe by making an objection. It is indicated for all communication how you can do this [principle: 1 or 5].
- Improving the content of our communication by aligning these to your personal preference [principle: 5].
- (Further) developing and improving new and existing products and services [principle: 5].
- Measuring of customer satisfaction, offering management information and determining company strategy [principle: 1 or 5].
- Organising events for data analysis purposes to be able to improve or develop products or services, where participants in these events work with personal data in a (pseudo) anonymous shape – not directly traceable to you as a natural person, insofar as allowed under applicable law [principle: 5].
- Complying with legal obligations, settlement and enforcement of our rights and agreements [principle: 3, 4 or 5].
- Improving data quality with the help of address-validation techniques [principle: 5].
- Analysing cookies on our website and linking them to customer data known to us. We do this to align the content of our communication to your personal preference as effectively as possible [principle: 1 or 5].
- Sharing with third parties
FORA shares your personal data with third parties in, among others, the following cases and with matching reasons. The number behind each purpose matches the principles mentioned in article 5 of this privacy statement:
- with affiliated financial service providers with the purpose to offer connecting financial services [principle: 2];
- when we are legally obligated or authorised to provide personal data to third parties [principle: 3];
- when we suspect an infringement of third party rights, criminal offences or misuse we may provide personal data to third parties who have a legitimate interest thereto or to authorities that serve the public interest. This may also be enforcement authorities such as the Public Prosecution Department or supervisory authorities [principle: 3, 4 or 5];
- with parties who assist FORA in its service provision and are not a processor (for instance accountants and (legal) advisors) [principle: 5];
- for commercial purposes (such as the sales of company activities or shares or a reorganisation [principle: 5].
FORA also uses services of third parties that function as ‘processors’ (for example hosting-service providers, mobility service providers and research companies, with the purpose to carry out a market survey or customer satisfaction research). These service providers will only process personal data in accordance with the instructions of and under the control of FORA.
- How long do we store data
We store personal data in accordance with our internal data retention policy and/or as long as (i) you are a customer at FORA or keep showing interest in the services of FORA , (ii) we are legally obligated to store data, or (iii) we have substantial grounds to believe we may store the data, where deemed necessary. For analytical purposes, personal data that you provide to us via the contact or complaint form are stored for a maximum of 2 years. After this period the personal data will be made anonymous.
- Mapping website visits
- Your rights, including the right to object
You have the right to know which of your personal data we have recorded and to whom we have provided your personal data. To this end, you can contact us via the customer service. FORA will make every effort to respond within the statutory time-limits. Excessive requests will not be considered.
Next to the right of inspection, you have the following rights with regard to our processing of your personal data:
- the right to withdraw your consent, in as far as our processing of your personal data is based on that consent;
- the right to file a complaint with the Dutch Data Protection Authority;
- the right to rectify/correct (have) your personal data (rectified/corrected);
- the right of removal of your personal data;
- the right op limitation of the processing relevant to you;
- the right op data portability;
- the absolute right to object to direct marketing;
- the right to object to processing that takes place due to FORA’s or a third party’s legitimate interests (depending on your personal circumstances).
You can only exercise your rights insofar as the law grants you such rights. To ensure that the request for inspection was done by you we will ask you to include a copy of your ID. We request that you render the passport photo, MRZ (machine readable zone – the strip with numbers at the bottom of the passport), passport number and Citizen Service Number (BSN) unrecognisable on this copy.
- Security and protection of data
FORA applies fitting security measures to avoid, as much as possible, misuse, loss, unauthorized access and change and undesirable disclosure. FORA has taken both technical and organisational measures to secure your personal data. These security measures are regularly reviewed based on threats.
For questions and/or comments related to this privacy statement please contact:
FORA Handelsgesellschaft mbH
+49 77 32 94 94 – 0
How we process personal data, and the combination or amount of data we process, may change. That is why we reserve the right to adapt this privacy statement. You will be informed about a change, if necessary. The most recent date of a change is always indicated in this Privacy Statement.
This statement was last revised on 23 June 2020.