Cookie policy

What are cookies and similar techniques

A cookie is a small text file that is stored on your computer, tablet or smartphone when you visit the website and can be read again on a later visit. Besides cookies there are similar techniques, such as local storage, pixels and scripts that read data from your device and send it on. The law treats these techniques the same way as cookies. Where this policy speaks of cookies, it therefore also means these techniques.

Legal framework

Placing and reading cookies is governed by article 11.7a of the Dutch Telecommunications Act. Under that article we may only place or read cookies if we have informed you clearly and fully in advance, at least about the purposes, and you have given your consent. That consent must meet the requirements of the General Data Protection Regulation (GDPR): it must be freely given, specific, informed and unambiguous, and be given by an affirmative act.

No consent is needed for cookies:

• that serve solely to carry out communication over the internet;
• that are strictly necessary to provide the service you yourself ask for;
• that are used to obtain information about the quality or effectiveness of our website, provided this has no or only minor consequences for your privacy.

In so far as we process personal data through cookies, the GDPR also applies.

Which cookies we use, for what and on which legal basis

Functional: your cookie choice

When you make a choice in the cookie notice, we store that choice in your browser’s local storage. That way we do not have to ask for your consent again on every page. Only whether you gave or refused consent for each kind of cookie is stored. This is strictly necessary to respect your choice and therefore requires no consent. In so far as personal data is processed in doing so, we do this on the basis of our legitimate interest in a properly working website (article 6(1)(f) GDPR).

Visitor measurement without cookies (Vercel Web Analytics)

To see which pages are visited and whether the website works properly, we count visits with Vercel Web Analytics from Vercel Inc. This measurement uses no cookies and does not follow you across other websites. Your IP address and browser details are used briefly on arrival to create a temporary code, so that visits can be counted without you being recognised. That code is deleted within 24 hours. Your IP address is not kept with the statistics and we only use aggregated figures. In so far as information is read from your device in the process, this is done solely to obtain information about the quality and effectiveness of our website, with no or only minor consequences for your privacy. This falls under the exception of article 11.7a(3)(b) of the Dutch Telecommunications Act. We base the processing of your data on our legitimate interest in insight into the use of our website (article 6(1)(f) GDPR). You can object to this by sending an email to info@bosecuritygroup.com.

Analytics cookies (Google Analytics)

With your consent we use Google Analytics, a service of Google Ireland Limited, to better understand how visitors use the website. For example, we see which pages are viewed, how visitors arrive at the website and how many requests come in through the website. We have set up Google Analytics to be as privacy-friendly as possible: Google does not store IP addresses, Google signals are off, so that data is not linked to Google accounts, and data is not shared with Google for other purposes. The legal basis is your consent (article 11.7a of the Dutch Telecommunications Act and article 6(1)(a) GDPR).

Marketing cookies (Google Ads)

With your consent we use Google Ads, a service of Google Ireland Limited. With it we measure which advertisements lead someone to request a quote, get in touch or apply for a job. After your visit we can also show you our advertisements on other websites and in apps of Google and its partners (remarketing). The legal basis is your consent (article 11.7a of the Dutch Telecommunications Act and article 6(1)(a) GDPR).

No social network cookies or embedded content

The website contains no embedded videos, maps, share buttons or social network pixels. Fonts and images are loaded from our own website and our own file storage, without anything being placed on or read from your device.

Which data is collected

Through Google Analytics and Google Ads the following data may be collected: your IP address or an approximate location derived from it, a unique cookie identifier, details of your browser, operating system and device, the pages you visit and when, the website or advertisement through which you reach us, and whether you successfully submitted a form. In doing so we only pass on which kind of form was submitted. We never pass the contents of what you fill in on a form to Google.

Profiling

Google Ads makes it possible for Google to build a profile of your interests based on your browsing behaviour, so that you are shown advertisements that match it. This only happens if you have consented to marketing cookies. No automated decision-making takes place that produces legal effects concerning you or similarly significantly affects you.

With whom we share data and in which role

• Google Analytics: Google Ireland Limited processes the data as a processor, solely on our instructions and under a data processing agreement.
• Google Ads: Google Ireland Limited processes the data as an independent controller and also uses it for its own purposes. Google’s privacy policy applies to that (policies.google.com/privacy).
• Vercel Inc.: provides the hosting of the website and the visitor measurement without cookies, as a processor on our instructions and under a data processing agreement.
• Our technical administrator has access to data in so far as necessary for the management and security of the website, under a data processing agreement.

We do not sell data to third parties.

Transfers outside the European Economic Area

Google and Vercel may process data outside the European Economic Area, including in the United States. These parties are certified under the EU-US Data Privacy Framework, for which the European Commission has decided that it provides an adequate level of protection. Should that decision lapse, we will put another appropriate safeguard in place, such as the standard contractual clauses adopted by the European Commission.

Retention periods

The lifetime of each cookie is listed in the cookie overview in the annex. In addition:

• we keep your cookie choice for at most 12 months, after which we ask you for your choice again;
• visitor-level data in Google Analytics is deleted automatically after 14 months;
• the temporary code of the visitor measurement without cookies is deleted within 24 hours;
• the retention periods of Google Ads are set by Google and are described in Google’s privacy policy.

How we ask for consent

On your first visit we ask through a cookie notice whether you consent to analytics cookies and marketing cookies. You can accept both, refuse both or choose per kind. Nothing is ticked in advance and refusing is just as easy as accepting. The website works the same in every case; you never need to consent in order to visit the website. We record your choice so that we can demonstrate that you gave consent.

Changing your choice or withdrawing consent

You can withdraw your consent or change your choice at any time through “Cookie settings” at the bottom of every page. Withdrawing is just as easy as giving consent. From that moment we send nothing more to Google for that kind of cookie and we delete the cookies of that kind that are on our domain. Cookies that Google has placed on its own domains can be deleted through your browser settings or through myadcenter.google.com. Withdrawing your consent does not affect processing that took place before you withdrew it.

Links to third-party websites

The website contains links to third-party websites. As long as you do not click a link, nothing from those parties is loaded. If you click through, that party’s privacy and cookie policy applies. We have no influence over the cookies they place and recommend that you read their statements.

Services we may use in the future

In the future we may use the Meta Pixel of Meta Platforms Ireland Limited, to measure the effect of advertisements on Facebook and Instagram and to show advertisements there, and Google reCAPTCHA of Google Ireland Limited, to protect our forms against spam and abuse. We do not use these services at present. If we start using one of them, we will only do so with your prior consent and will update this cookie policy and the cookie overview beforehand.

Your rights

In so far as we process personal data through cookies, you have the right of access, rectification, erasure, restriction of processing and data portability. Where we process data on the basis of our legitimate interest, you can object to it (article 21 GDPR). You can send a request to info@bosecuritygroup.com. We respond within one month. More about how we handle personal data can be found in our privacy policy at www.bosecuritygroup.com/en/privacy-policy.

Complaints

If you disagree with the way we handle your data, please contact us first. You also always have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) through www.autoriteitpersoonsgegevens.nl

Changes

We update this cookie policy when we start using new cookies or services, or when legislation and regulations give reason to do so. If we start using cookies that require consent, we will ask you for consent again before placing them. At the top you can see the version and the date of the latest change.

Annex: Cookie overview