Privacy and cookie statement

Version April 2024

This privacy and cookie statement was last updated on April 9, 2024.

Dear Website Visitor,

We have prepared this privacy and cookie statement to make it clear to you that we take your privacy seriously. For that reason, personal data collected by us are carefully processed and secured. In doing so, we comply with the General Data Protection Regulation (AVG). This means that we:

  • clearly define our purposes before we process your personal data, through this privacy and cookie statement.

  • Obtain explicit consent to the processing of your personal data, should consent be required.

  • Store as little personal data as possible and only the data necessary for our purposes.

  • take necessary security measures to protect your personal data. We also impose these obligations on parties who process personal data for us.

  • respect your rights, such as the right to access, correct or delete your personal data processed with us.

Purposes of data processing

In this privacy and cookie statement, we explain what we at CODE24 do with information we learn about you. By using our services or visiting our websites(www.code24.nl, jobs.code24.nl, blog.code24.nl or info.code24.nl), we obtain different types of personal data. For each purpose, we indicate below which data we obtain from you, for what purpose we process this data and for how long this data is stored. If you have questions or want to know exactly what we keep track of, please contact us using the details at the bottom of this privacy and cookie statement.  

Delivering our products and services

As organisation , you can use our products and/or services.

For this purpose, we process the following personal data:

  • Contact name

  • (Business) phone number

  • (Business) email address

  • Organisation name (optional)

  • Payment details

  • Invoice data

  • Any content of correspondence

We use this data to execute the agreement, which we enter into with you, and to maintain the resulting relationships. We keep this data for the duration of the agreement. We keep some data longer if we are required to do so (for example, because of the tax retention period of seven years).

Conducting training sessions

CODE24 provides training regarding the use of the products and services.

For this purpose, we process the following personal data:

  • First and last name

  • Organisation name (optional)

  • (Business) phone number

  • (Business) email address

  • Branch address and location

  • (Business) billing information

  • (Business) payment information

  • Job title and background participant

  • Purchase number/reference

  • Training Progress

  • Any content of correspondence

  • Any dietary requirements

We need this information to send training materials and practical information, to issue a certificate of participation, to bill you, and to provide lunch. We keep this information until you have completed the training and payment has been made. We keep some data longer if we are legally required to do so (for example, because of the tax retention period of seven years).

Sending service messages

We may use your e-mail address without your explicit permission to send you strictly necessary information about our products and services, without commercial charge. For example, about malfunctions, work on our products and/or services, changes in legal documents (for example: general conditions). You can unsubscribe from these mails, but then you will miss very important information. For this reason we advise you not to unsubscribe from the service messages you receive from us.

Contact

We offer several ways to contact us. You can contact us by phone, by e-mail, via the contact form or via the Help Center.

For this purpose, we process the following personal data:

  • First and last name

  • (Business) email address

  • (Business) phone number

  • Organisation name (optional)

  • Any information you enter yourself as message content

We use this information to properly handle your request to contact you and to execute the agreement with you to do so. We will retain this information until we believe you are satisfied with our response.

Improving the quality of products and services

Under the motto of "continuous improvement," CODE24 is working every day to improve its products and services. We may be curious about your experiences with our products and services (i.e. as a healthcare provider - we will never actively approach patients for this purpose). We may contact you about this (for quality purposes). We may use your email address or phone number for this purpose. Information you share with us will be treated confidentially and will not be kept longer than necessary. We do this based on our legitimate interest. If you object to being contacted for quality purposes, we will of course respect your wishes. We will not approach you.

Apply for a job with us

Have you responded to one of our positions or submitted an open application? Then we will process your personal data in order to process your application.

For this purpose, we process the following personal data:

  • First and last name

  • Address details

  • Email address

  • Phone number

  • Curriculum Vitae

  • Motivation letter

  • Optional: References

  • Optional: Link to LinkedIn profile

  • Any other information you send with your application

We use this data in preparation for the possible conclusion of an employment contract. Should you not be employed by CODE24 at the end of the application process, we will retain the application data for no longer than four weeks after the completion of the procedure. This allows us to still approach you if, on further consideration, the previous candidate proves unsuitable. If we are unable to offer you a position at this time, we may (with your consent) retain your application data for up to one year after completion of the application process. You can withdraw your consent at any time by sending us an e-mail. If you join us, we will save your application data in your personnel file.

Screening

In order to guarantee the safety of our products, services and our organisation , all new (hired) employees are tested for integrity. Among other things, you must provide valid proof of identity, relevant diplomas and a Certificate of Good Conduct (VOG). We cover the costs for the application of your VOG.

Another part of the process may include social media and internet screening. We may use found information during the application process for further assessment. Conducting the screening is necessary to ensure that our image is maintained when hiring new staff. We therefore do this on the basis of our legitimate interest. We may search for your name on Google and any profiles on various social media. This of course insofar as these profiles are public; we will not ask you to grant us access to a protected social media page or make a connection with us. Of course, findings will always be discussed with you. We do not reject people solely on the results of screening. Should you object to the screening, you can indicate this by e-mail at the time of application.

We use the service Homerun to store your application data. We have entered into a processor agreement with Homerun. Homerun is a Dutch IT service provider that complies with CODE24's information security and privacy requirements.

Marketing purposes

Matomo: traffic analysis

We use Matomo for analyzing website visits. Matomo is an open source web analytics platform that allows us to measure, collect, analyze and report website visits.

Purposes of data processing by Matomo

Matomo is used to analyze the behavior of website visitors to identify potential pitfalls; pages not found, search engine indexing issues, which content is most appreciated, et cetera. Once the data is processed (number of visitors reaching a page not found or viewing only one page, etc.), Matomo generates reports for us as website owners to take action. For example, we could change the layout of the pages or publish new content.

Matomo processes the following personal data:

  • Cookies (after consent)

  • IP address (anonymized at 2 bytes)

  • Custom Dimensions

  • User location

Also:

  • Date and time

  • Title of the page viewed

  • URL of the page viewed

  • URL of the page viewed before the current page

  • Screen Resolution

  • Time in local time zone

  • Files that have been clicked and downloaded

  • Link clicks to an external domain

  • Generation time of pages

  • Country, region, city

  • Main browser language

  • User Agent of the browser

The processing of personal data at Matomo is based on explicit consent. Your privacy is our primary concern. Therefore, we do not process personal data at Matomo unless you give us explicit consent.

Recipient of personal data from Matomo
Personal data collected by Matomo is made available to:

  • Our company.

  • Our service provider (Matomo Analytics Cloud by Innocraft): Innocraft, 7 Waterloo Quay PO625, 6140 Wellington, New Zealand.

Hosting Location
Matomo Analytics Cloud is hosted in Germany.

Data retention
We retain personal data captured within Matomo for a period of 365 days.

Withdrawing consent and opting out of tracking
You can withdraw your consent at any time by clicking here. You can also opt out of any tracking by Matomo at any time:

Filing complaints with a supervisory authority
If you believe that the way we process your personal data with Matomo analytics violates the law, you have the right to lodge a complaint with a supervisory authority.

Profiling for automated decision-making
Matomo does not engage in profiling.

HubSpot: marketing tools

Purposes of data processing by HubSpot

We use HubSpot to collect your Personal Information when you submit web forms or interact with our websites, such as by subscribing to our blog or mailing list, signing up for a webinar or demo or requesting information. We may ask for your e-mail address, first and last name, job title and other similar company information. You are free to explore our websites without providing any personal information about yourself.

Cookies and advertising
HubSpot also places cookies and tracking pixels to analyze website visitor behavior and identify potential pitfalls.

We also work with third-party ad networks to display ads on our Web site or to manage our advertising on other sites. Our ad network partner uses cookies to serve you targeted ads based on your interests.

Through our cookie banner, we always ask explicit permission to place non-essential cookies. You can also revoke this consent at any time if you wish.

Mailing lists
You can use various HubSpot forms to sign up to receive mailings from us or download a white paper. We always ask explicit permission to mail you. We record this permission and you can withdraw it at any time if you wish. Every mailing from us contains an unsubscribe link at the bottom of the mail.

Hosting location
HubSpot CRM is hosted for the EU domain in Germany.

Social media buttons

On our websites we use social media buttons, which direct you to the social media platforms. The buttons work because of pieces of code that come from the social media networks. If you want to know what the social media platforms do with your personal data, please read the relevant privacy statement:  

When may we share your personal data with third parties?

CODE24 shares your data with third parties only when permitted by current legislation. We may provide your personal data to third parties because:

  • we have engaged them to process certain data.

  • necessary to perform the agreement with you.

  • you have consented to this.

  • we have a legitimate interest in doing so.

  • we are required to do so by law (for example, if the police demand it in the case of suspected crime).

The parties that process personal data on our or your behalf are:

  • Cookie vendors (please see the cookie table further down in the statement).

  • IT vendors and service providers.

  • Payment service providers (and collection agency).

  • Consultants (e.g., hired sales and marketing staff).

In order to provide our services, CODE24 may provide your personal data to parties based outside the European Economic Area (EEA). CODE24 will only do so if there is an adequate level of protection for the processing of personal data. This means, for example, that we use a model agreement from the European Commission or make agreements on the handling of personal data (e.g. enter into a processor agreement).

Security

CODE24 takes appropriate security measures to limit misuse of, and unauthorized access to, your personal data. For example, we ensure that only the necessary persons have access to your data, that access to your personal data is protected and that our security measures are checked regularly. The security measures we take include the following:

  • Physical Access Control. CODE24 uses measures to prevent unauthorized access to data processing systems that process personal data.

  • Access to personal data is protected by a username, password and, where appropriate, a login token.

  • We use secure connections (TLS) that shield all information between you and our websites and apps when you enter your personal information and share messages.

  • Encryption (encryption) of information.

  • Firewalls, intrusion detection systems, intrusion prevention systems and virus scanners ensure that your data is safe at all times.

  • Data backup.

  • Target access restrictions and data storage within the European Union.

reCAPTCHA

We use the reCAPTCHA service provided by Google Inc. (Google) to protect our website from spam and abuse. For Google reCAPTCHA to work, a website visitor's IP address, mouse movements and possibly other data is collected. This information is sent to and processed by Google for this purpose. By analysing this information, Google can determine whether we are dealing with a real website visitor or a robot. For more information we refer you to Google's privacy statement.

Duties of CODE24

CODE24 is responsible by law for the processing of personal data that takes place within CODE24. It fulfills the duties arising therefrom as follows:

  • Your information is collected and used only for the purposes outlined in this document.

  • You are informed that personal data about you is being processed. This is indicated where we ask for personal data by referring to this privacy statement.

  • All employees within CODE24 have signed a confidentiality agreement.

  • Your personal data is properly secured against unauthorised access.

  • Your personal data will not be kept longer than necessary for proper service.

Your rights as a data subject

With respect to your personal data, you have the following rights:

  • the right to know whether personal data about you is being processed.

  • the right to inspect and copy the data being processed (to the extent it does not violate the privacy of another).

  • The right to request correction, addition or deletion of your data.

  • the right to block disclosure of your data to third parties (one or more of the aforementioned healthcare providers involved).

  • The right to request destruction. This can only be accommodated if the retention of the data is not of substantial interest to another person and the data is not required to be retained by law.

  • The right to oppose the processing of your data.

If you wish to exercise your rights, you may contact CODE24's data protection officer who represents your interests. Your interests can also be represented by a representative appointed by you. Please make sure that you always clearly indicate who you are so that we can be sure that we do not modify or delete data belonging to the wrong person.

In principle, we will comply with your request within one month. However, this period may be extended by two months for reasons related to specific privacy rights or the complexity of the request. If we extend this deadline, we will notify you within the first month.

In addition, you may notify us in writing if you do not wish to be contacted with information about our products and services. See the contact details of the data protection officer later in this privacy statement.

Filing a complaint

If you have any questions, or would like to make a complaint about the use of your personal data, please contact us using the contact information at the bottom of this privacy and cookie statement. We address every question and complaint internally and communicate this further with you. However, if you feel we are not helping you in the right way, you can contact the Personal Data Authority to file a complaint.

You can call on the Personal Data Authority, for example, to mediate in the dispute or seek advice. As a final option, you can appeal to the civil courts.

Changes to this privacy and cookie statement

CODE24 has the right to make changes to this privacy and cookie statement. Changes will be published on our website. Therefore, please check this privacy and cookie statement regularly so that you are aware of any changes.

Contact

CODE24 B.V. (KvK: 37159262)

Attn: Data Protection Officer

Comeniusstraat 2d

1817 MS Alkmaar

Phone: +31 (0)72 - 204 03 00

E-mail: functionaris.gegevensbescherming@code24.nl

Website: www.code24.nl

Personal Data Authority

P.O. Box 93374

2509 AJ DEN HAAG

Tel: 0900 - 200 12 01, available on weekdays from 09:30 to 12:30 (€ 0.05 per minute) https://www.autoriteitpersoonsgegevens.nl/

Cookie Statement

On our website, we use cookies. Cookies are small information files that can be automatically stored on or read from the website visitor's device (such as PC, tablet or smartphone) when visiting a website. This is done through the web browser on the device. We use cookies to enable website functionalities (technical and functional cookies).

When you visit our website for the first time, we will display a message explaining cookies. To the extent we are required to do so, we will ask for your consent to the use of cookies. In the table (see below in this cookie statement) you will find an overview of the cookies we use.

By clicking 'Show details', you can read more about our cookies and change your preferences. By clicking 'Allow All', you consent to the use of all cookies as described in this Privacy and Cookie Statement. The consent applies to the website where consent is given.

Turning cookies on and off

In the web browser you can set to accept the storage of cookies only if you agree to this. Please consult your browser manual for more information. Please note that many websites do not work optimally when cookies are disabled.

Deleting cookies

Most cookies have an expiration date. If an expiration date is set, the cookie is automatically deleted when the expiration date expires. You can also choose to delete cookies manually before the expiration date. Please consult the manual of your browser to do so.

Cookie table