11 August 2022
1. About us
This privacy notice covers Future Connections Holding B.V. (“We” “Us” “Our”) group of companies (Future Connections B.V., Future Connections España Soluciones de Conectividad S.L., Future Connections UK Solutions Ltd and Future Connections Technologies B.V.). Future Connections is a B2B independent solutions integrator and provider that helps network operators and service providers to bridge the gap between legacy and innovative technologies with convergence, integration, migration, automation and consultancy services. We develop and deliver customised services and products that enhance, strengthen and automate business processes and provide new levels of efficiency.
The owner of the website www.sandbox.futureconnections.com is Future Connections Holding B.V.
Future Connections is a data controller for our activities which relate to our internal functions such as HR, Finance, Marketing and our IT, but where we provide services to our customers, we act as a data processor and process data under their documented, written instructions.
Future Connections is committed to safeguarding privacy, including your personal data in line with requirements under data protection legislation. Data protection legislation can include (but is not limited to) the EU GDPR 2016, the UK GDPR, e-Privacy Directive and any other applicable legislation mandating data protection. This also includes any replacement legislation that may come into effect from time to time.
Please read the following privacy notice carefully to understand how we collect and use your personal data. This privacy notice also explains your rights in respect of your personal data.
2. Contact us
Future Connections Holding B.V address is Bredaseweg 85, 4872 Etten-Leur, The Netherlands, VAT number NL858275776B01. You can find contact and address details to our other offices here.
If you have any questions about this privacy notice, you can get in contact with our group Data Protection Officer (DPO) by writing to The DPO, Future Connections Holding B.V., Bredaseweg 85, 4872 LA Etten-Leur, the Netherlands, emailing email@example.com or calling +31 850 666 000.
3. What personal data we collect, how we collect it and why
3.1 Data that you provide voluntarily to us
When you use our website, products or services, have meetings with us or you otherwise communicate with us, we may ask you to provide certain personal data voluntarily, including your name, company position, postal address, telephone number, mobile number, email address and account usernames. For example, we may ask you to provide some or all of this personal data when you register an account, place an enquiry with us, apply for a job vacancy, subscribe to our marketing communications or for marketing events organised by ourselves where you have provided permission. We use this information to create and administer your account, send you marketing communications, provide you with the products and services or information you request and respond to your enquiries. In general, the personal data that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal data.
3.2 Data collected automatically
When you use our website, products or services, we may collect certain data automatically from your computers or devices, including mobile devices. The data we collect automatically may include your IP address (explained below), device type, operating system details, unique device identification numbers (including any mobile advertising identifiers), browser-type, browser language, operating system, geographic location and other technical information.
3.3 Data that we obtain from third party sources
From time to time, we may receive personal data about you from third party sources including and without limitation from:
- recruitment agencies
- credit check agencies
- lead generation providers
- resellers and other partners who sell our products and services to you, but only where such third parties have confirmed that they have your consent or are otherwise legally permitted or required to disclose your personal data to us.
The types of personal data we may receive from third parties may include contact details, CVs, credit history and order information. We use the information we receive from these third parties for various purposes, such as to assess your suitability for a job position and maintain and improve the accuracy of the records we hold about you in our contact databases. You can contact us using our details above should you like to discuss this further with us.
3.4 Data collected through our products and services
We use data that we collect from our products and services for the purposes for which you provided it.
3.5 Cookies and tracking
3.6 Location information
We may collect different types of information about your location, including general information (for example IP address or postal / ZIP code) and more specific information (for example GPS-based functionality on mobile devices when used to access our website). This information may be used to customise the services provided to you, such as location-based information and features. If you access the website through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.
4. Other specific ways we collect and use your personal data
4.1 Job applications and enquiries
If you are making a job application or enquiry, you may provide us with a copy of your CV or other relevant information. We may use this information for the purpose of assessing your application. We may also keep this information on file to contact you about future opportunities unless you ask us not to do so. For further information on how we process your CV, CV retention and other information, please refer to our separate recruitment privacy notice.
4.2 Account management
If you obtain products or services from us, we may use your contact details and (where applicable) payment information for the purposes of (i) providing employee training, customer support and account management, (ii) order processing and billing, (iii) verifying your usage of the products and services in accordance with the terms and conditions of your agreement with us, (iv) contacting you (including by email communication) regarding license expiry, renewal and other related notices, and (vi) maintaining our company accounts and records.
A summary of key provisions is set out below:
4.3. 1 Marketing communications
From time to time we would like to send you marketing news and updates regarding our activities, products and services. You can always change your preferences or opt-out by clicking on the relevant unsubscribe link that you can find at the bottom of each of our emails.
4.3. 2 Market research and surveys
We conduct marketing research across all our countries. Our surveys are anonymous unless you choose to share your personal data with us. Your feedback is stored in our Zoho platform. If at any time you want to be removed from our surveys, please email our DPO to request it. We will use the survey results in order to improve our understanding of our users’ demographics, interests and behaviour, for training purposes, to measure and increase customer satisfaction and to improve the products and services we offer during the following year.
4.3. 3 Website requests
If you request information or contact us via our website, such as completing a form or sending an email or downloading a document, we will ask you to provide data and tell you at the time how the information will be used. We may also use your personal data to add to our marketing database for marketing purposes such as sending emails to keep you informed about our activities, products and services. As mentioned before, you can request not to be included on our mailing lists by opting out using the unsubscribe link in the emails or by contacting our DPO.
4.3. 4 Network monitoring
We may collect logs and other data about access to and traffic passing through our network and equipment for the purposes of availability and performance monitoring, maintenance, security monitoring and investigations, new product and service development, the enhancement of existing products and services, generating statistics, reporting and trend analysis.
4.4 Lawful basis for processing personal data
We rely on the following lawful basis to process personal data:
- Consent (e.g. marketing communications as mentioned above)
- Contractual obligation (e.g. to enter into employment contracts)
- Legal obligation (e.g. for anti-bribery, corruption etc)
- Legitimate interests (e.g. to answer any questions or enquiries received)
5. With whom we might share your personal data
5.1 Category of recipients
We may transfer or disclose your personal data to the following categories of recipients:
At times we may need to share your data with other entities to support the delivery of, provide functionality on, or help to enhance our products or services, or to process data on our behalf. Examples of such entities are:
- Companies belonging to the Future Connections Holding B.V. group
- third parties who provide data processing services to us (i.e. recruitment agencies, employee administration, data hosting, legal services, marketing services, analytics services, customer support)
- third parties to whom we may choose to sell, transfer or merge parts of our business or assets, as well as third parties we may seek to acquire or merge with. If a change happens to our business, then the new owners may use your personal data in the same way as we currently do, which can also extend to consent for marketing communication
We may also need to share your data with any competent law enforcement body, regulatory government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation or (ii) to exercise, establish or defend our legal rights.
5.2 International transfers of data
As we operate globally, there may be instances where we may need to transfer your data outside the EU/UK. We may need to share your data with other entities or companies who are in the European Economic Area (the EU member states, Norway, Iceland and Liechtenstein), in an adequate listed country or in other third countries who may not have similar data protection laws to the EU/UK. If we need to transfer your information outside the EU/UK, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this notice.
6. Data retention
We regularly review our data retention practices to ensure we only retain personal data for as long as necessary in line with our data processing activities. We have created data retention policies and accompanying data retention schedules to help document relevant retention periods.
7. Your data protection rights
Under data protection legislation individuals have the following data protection rights:
- Right to be informed
- Right to access data
- Right to rectification
- Right to erasure
- Right to restrict processing
- Right to objection
- Right to portability
- Right not to subject to automated decision making and profiling
You can exercise a right by contacting our DPO using the details mentioned above. Please note that if you email firstname.lastname@example.org, you may need to attach to your email a copy of your identity card or another accepted document for identification. Your document will be used just to verify your identity, will be seen by our DPO and will be disposed of once your request has been processed.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
8. Concerns and complaints
We understand you may have concerns and complaints to this notice and any aspects to how we process personal data. If you would like to contact us directly to talk to us about a concern or to raise a complaint, you can do so by using our contact details above.
Our lead supervisory authority is the Dutch DPA (https://autoriteitpersoonsgegevens.nl/en) and you can contact them to submit a complaint if you prefer to do so. You can also submit a complaint directly to the ICO if you are based in the UK via this link https://ico.org.uk/make-a-complaint/. If you are based elsewhere within the European Economic Area, a list of supervisory authorities can be found here.
9. Review and updates
We will review this notice and make changes to it from time to time. We recommend that you check this notice to see where changes have been made and to ensure you are able to review the updated information at all times.