PPRIVACY STATEMENT FOR USERS
1. INTRODUCTION AND DEFINITIONS
1.1 We collect personal data via our platform (website/app) and cookies (see our cookie statement for more information).
1.2 This privacy statement explains how The Green Box processes personal data of persons, employees, owners, agents or representatives acting on behalf of our (existing, former or potential) Users (including their guests and/or visitors).
1.2 Box Properties B.V. may be referred to in this document as “we”, “us”, “our” or “The Green Box”.
1.3 User is understood as any natural or legal person who maintains a business relationship with The Green Box or an affiliated group company. Individuals, employees, owners or representatives of or acting on behalf of the Users may be collectively or individually referred to as "you", "your" or "Users".
1.4 This privacy statement applies to every group company of The Green Box that is responsible for or involved in the processing of a User's personal data. Depending on the nature of the business relationship, various group companies of The Green Box may be responsible for the processing of that personal data.
1.5 The personal data that The Green Box collects in relation to its Users depends on the context of the business relationship and their interaction with The Green Box, the choices the User makes and the products, services and functions they use. User for the purpose of this privacy statement means the natural or legal person who does business with The Green Box (including its guests or visitors).
1.6 Please note that the data in the paragraphs below is only considered "personal data" if it relates to a natural person (i.e. an individual human being). These data items are not considered "personal data" when they relate to a legal entity (e.g. BV) or (legal) entity. The personal data of natural persons at or within a User who is a legal person or entity (such as the name, email, telephone number of the contact person/employee of the User) are considered personal data and fall under the scope of this privacy statement.
2. DATA COLLECTION
2.1 Personal data that The Green Box collects
2.1.1 Personal data that you – as a User – provide to us, such as:
• Contact details
We collect relevant contact information from Users (or their contacts, relevant employees, guests and/or visitors), such as first and last name, date of birth (if required), business addresses, business email addresses, business telephone and fax numbers.
• Financial data
We collect data necessary for payment and billing purposes (including your bank details, bank account number, credit/debit card and VAT number) and data otherwise required for invoice processing.
• Verification information
The Green Box may ask (representatives of) Users for a copy of company registration documents, their identity card or passport or other relevant information to verify the User's authenticity. This may also include proof of licences or tax information.
• Other data
When a User communicates with The Green Box, we collect and process information about this communication. During calls with our customer service, live listening and calls can be recorded for quality control and training purposes. These recordings can also be used for claims handling and fraud detection.
Recordings are kept for a limited time before they are automatically deleted, unless The Green Box has a legitimate interest in keeping the recording for longer. This only happens in exceptional cases, such as for fraud investigation, compliance and legal purposes.
2.2 Information We Collect Automatically
2.2.1 Depending on the business relationship, The Green Box may also automatically collect information, some of which may be personal data. This data is collected when a User uses online services such as a registration form or a user account.
The data collected may include:
• Language settings
• IP address
• Place
• Device settings
• Device operating system
• Log information
• Time of use
• URL requested
• Status report
• User agent (information about the browser version)
• Browsing history
• The type of data being viewed
2.3 Personal Information You Provide Us About Others
2.3.1 By sharing personal data of other persons for business purposes - such as data of your employees - you confirm that these persons have been informed about the use of their personal data by The Green Box in accordance with this privacy statement. You also confirm that you have obtained all necessary consents as required by applicable laws and regulations.
2.4 Other information we receive from other sources
• Information on insolvencies
In insolvency cases, The Green Box may receive information about Users from trustees, courts or other government bodies.
• Data related to requests from law enforcement and tax authorities
Law enforcement or tax authorities may contact The Green Box with additional information about Users in the event that they are affected by an investigation.
• Fraud detection and prevention, risk management and compliance
In certain cases, and as permitted by applicable law, The Green Box may need to collect data from third party sources for fraud detection and prevention, risk management and compliance purposes.
3. PROCESSING PURPOSES AND SHARING
3.1 Purposes
3.1.1 The Green Box uses the previously described information about Users, some of which may be personal data, where relevant, for the following purposes:
A. Registration and Administration
The Green Box uses account information, contact details and financial information to manage the business relationship with the User. This also applies to registration and verification purposes.
Certain information, including the name and address of a User, may be used for other purposes in accordance with the agreement entered into between the User and The Green Box.
B. Customer Service
The Green Box uses the information provided by Users (which may include personal data) to provide support services, for example to respond to requests, questions or comments from Users or customers.
C. Other activities, including marketing
If a potential User has not yet completed the online registration, The Green Box may send a reminder to complete the registration process. We believe that this extra service is useful for our (future) Users because it allows them to complete the registration without having to re-enter all registration details.
The Green Box may invite Users to attend and organise events that we believe may be relevant or interesting to them. We may also use personal data to provide and host online forums through which Users can find answers to frequently asked questions about the range and use of The Green Box's products and services.
To the extent relevant to the business relationship, The Green Box uses personal data for communication, including providing information about system or product updates, sending The Green Box newsletter, inviting Users to participate in references, promotions or for other marketing communications. When we use personal information to send direct marketing messages electronically, we provide an opt-in option.
D. Communication with users
The Green Box has (access to) communication with you (telephone, chatbot, email, platform). We also use automated systems to review, scan and analyse communications for the following purposes:
• Safety
• Fraud prevention
• Compliance with legal and regulatory requirements
• Investigation into possible misconduct
• Product development and improvement
• Research
• Customer engagement (including providing information or offers to guests that we think may be of interest to them)
• Customer or technical support
Communications sent or received using The Green Box's means of communication are received and stored by The Green Box. We do not record all calls. If a call is recorded, each recording is kept for a limited time before being automatically deleted. This is the case unless we have determined that it is necessary to keep the recording for fraud investigation or legal purposes.
E. Analysis, Improvement and Research:
The Green Box uses the information provided to us, which may include personal data, for analytical purposes. This is part of our commitment to improve The Green Box's products and services and to improve the user experience.
This data can also be used for testing purposes, troubleshooting and to improve the functionality and quality of The Green Box's online services. We also invite Users to participate in surveys and conduct other market research from time to time.
Certain Users may be invited to join a user forum to communicate with The Green Box and/or to exchange experiences with other Users.
Please refer to the information The Green Box provides when you are invited to participate in a survey, market research or to join an online platform to understand how your personal data may be treated differently than described in this Privacy Statement.
F. Security, Fraud Detection and Prevention
We process the information provided to us, which may include personal data, to investigate, prevent and detect fraud and other illegal acts. This may include personal data that a User has provided to The Green Box, for example for verification purposes as part of the registration process, personal data collected automatically or personal data obtained from external sources (including from guests).
The Green Box may also use personal data to facilitate investigation and enforcement by competent authorities, if necessary. For these purposes, personal data may be shared with law enforcement authorities.
The Green Box may also use personal data for risk assessment and security purposes, including user authentication, and we use external service providers for third party risk management. These providers help us assess the business risk profile of our Users. They may also provide us with due diligence reports from third parties, which, as permitted by applicable law, may contain potential information about criminal convictions of owners or User violations.
G. Legal & Compliance
In certain cases, The Green Box must use the information provided (which may include personal data) to handle and resolve legal disputes or for regulatory investigations, risk management and compliance. We may also use it to enforce our agreement(s) with Users or to resolve any complaint or claim involving a User, and in accordance with internal rules and procedures.
In addition, we may need to share information about Users (including personal data) where required to do so by law or strictly necessary to respond to requests from competent authorities. This includes tax authorities, courts, other government and public authorities or local municipalities (for example, regarding short-term rental laws).
If we use automated means to process personal data that produces legal or significant consequences for you or other natural persons, we will take appropriate measures to safeguard your or the other person's rights and freedoms. This includes the right to human intervention.
2.2 Legal grounds
2.2.1 As applicable for purposes A and B, The Green Box assumes the legal basis that the processing of personal data is necessary for the execution of the agreement between the User and The Green Box. If the required information is not provided, The Green Box will not be able to work with a User, nor will we be able to provide customer service.
2.2.2 For purposes C to G, The Green Box relies on its legitimate interest to provide its services or to obtain services from Users, to prevent fraud and to improve its services. When we use personal data to serve the legitimate interest of The Green Box or a third party, we will always balance the rights and interests of the data subject and the protection of their information against the rights and interests of The Green Box and/or the third party.
2.2.3 For F and G purposes, The Green Box also relies, where applicable, on compliance with legal obligations (such as lawful law enforcement requests). Finally, where necessary under applicable law, The Green Box will obtain your consent before processing personal data, including for marketing purposes or as otherwise required by law.
2.2.4 If you wish to object to the processing as set out under C to G and cannot find a way to opt out directly (for example in your account settings), please contact The Green Box.
3. SHARE WITH OTHERS
3.1 Sharing with affiliates
3.1.1 To support the use of The Green Box services, your information (which may include personal data) may be shared with or within The Green Box affiliates. This is done for the purposes described below, subject to any contractual terms.
The purposes for sharing data within the The Green Box group of companies are:
A. To offer, provide or make available services and products (including supplier management) and to provide support (such as completing reservation/booking, cancelling, changing and/or managing, account management and any customer service, billing and collection);
B. To prevent, detect and investigate fraudulent and other illegal activities;
C. For analytical, quality and product improvement purposes (including monitoring conversations by live listening or recording for quality and training purposes);
D. Marketing activities (including news items for which you can easily unsubscribe or unsubscribe) and to personalise online services (including personalised offers and promotions);
E. Communication purposes (by email, telephone or post) for the above purposes (including survey, market research, reviews or ratings) or as necessary under our agreement with you;
F. Legal purposes, including the handling of complaints, claims, legal actions and for the detection of fraud (in which cases any telephone conversations may be recorded);
G. To ensure compliance with applicable laws or law enforcement.
With a view to purpose A, and to the extent applicable, The Green Box relies on the legal basis that the processing of personal data is necessary for the execution of the agreement with you for the purchase or use of the Product or Service.
The Green Box further relies on its legitimate interest and that of its group companies to receive, process and share personal data as described under B to G. This is to provide services or obtain services from Users, including to improve them and to prevent fraud. When personal data is used to serve the legitimate interest of The Green Box or a third party, The Green Box will always balance the rights and interests of the person concerned in protecting their personal data and the rights and interests of The Green Box or the third party.
For purpose G, The Green Box also relies on compliance with legal obligations, where applicable (such as in cases of lawful law enforcement requests).
If you wish to object to the processing as set out under B to G, and cannot find a way to opt out directly (e.g. in your account settings), please contact The Green Box.
3.2 Sharing with third parties
3.2.1 We share Users' information (which may include personal data) with third parties, as permitted by law and as described below (which are based on contract performance, legitimate use or legal obligation):
O Service providers (including suppliers, auxiliaries and subcontractors). We share personal information with selected third-party service providers to provide our products and services, billing/collection, prevent and detect fraud, store data and otherwise support our business processes, or so that they can conduct business on our behalf.
O Payment providers and other financial institutions. In order to process payments between a User and The Green Box, relevant personal data may be shared with payment providers and other financial institutions.
O Screening of sanctions lists or risk management as required by applicable law.
O Forced disclosure. When required by law, strictly necessary for the performance of our services, in legal proceedings, or to protect our rights or the rights of users, we disclose personal data to law enforcement agencies, research organisations, users or group companies.
3.4 Sharing and Disclosure of Aggregated Data
3.3.1 We may share information with third parties in an aggregated form and/or other form in which the recipient cannot identify you, for example for industry analysis or demographic profiling.
4. SECURITY AND PROTECTION
4.1 You have access to your personal data via your Account.
4.2 We have procedures in place to prevent unauthorised access to and misuse of personal data.
4.3 We use appropriate business systems and procedures to protect and secure information, including personal data. We also use security procedures and technical and physical restrictions to access and use the personal information on our servers. Only authorised personnel have access to personal data in the context of their work.
5. DATA RETENTION
5.1 We retain personal data for as long as it is deemed necessary to manage the business relationship with a User, to provide The Green Box services to a User and to comply with applicable laws (including those relating to the retention of documents ), disputes or claims with any parties, and if otherwise necessary to enable us to conduct our business.
5.2 Any personal data we hold about you as a User is subject to this privacy statement and our internal retention guidelines. If you have any questions about the specific retention periods for the different types of personal data we process, please contact The Green Box.
6. YOUR CHOICES AND RIGHTS
6.1 Depending on where you are located or the entity of The Green Box that processes your personal data, different rights may apply to the processing of that data, as set out in this privacy statement. As applicable:
• You can ask us for a copy of the personal data we hold about you,
• You can notify us of any changes to your personal information, or you can ask us to correct the personal information we hold about you,
• In certain situations, you can ask us to delete, block, amend or restrict the personal data we hold about you, or object to certain ways in which we use your personal data,
• In certain situations, you can also ask us to send the personal data you provide to us to a third party.
6.2 Where we use your personal information based on your consent, you have the right to withdraw that consent at any time, subject to applicable law. Where we process your personal data on the basis of legitimate interest or public interest, you also have the right to object at any time, subject to applicable law.
6.3 Regardless of your location or the The Green Box entity you have a contract with, we rely on our Users to ensure that the personal information we hold is complete, accurate and current. Always inform us in good time of any changes or inaccuracies in your personal data.
6.4 If your company has agreements with an entity other than The Green Box B.V. and you want more information about the relationship between that entity and The Green Box B.V., you can contact us at any time. You must also do this if you wish to exercise your rights in relation to the personal data processed about you as part of that business relationship.
7. CONTACT US
7.1 If you have any questions, wishes or comments about how we process your personal data, or if you would like to exercise any of the rights you have under this Privacy Statement, please contact us. You can also contact your local data protection authority.
7.2 We handle privacy specific questions, requests and concerns reported to us using internal policies and procedures based on applicable privacy laws, regulations and guidelines. We regularly review and improve this policy and procedures, also taking into account User feedback.
8. CHANGES TO THIS PRIVACY STATEMENT
This privacy statement may be amended or supplemented from time to time. If we intend to make material changes or changes that affect you, we will always contact you in advance. An example of this type of change would be if we started processing your personal data for purposes not described above.
Version: July 7, 2022.
