Privacy Policy

1. Who is this privacy policy intended for?

This privacy policy (hereinafter referred to as "Privacy Policy") is intended to inform you how Boozt24 B.V., Boozt24 Finance B.V., and Boozt24 Applications B.V. (hereinafter collectively referred to as "Boozt24") collect, store, and process personal data.

The processing of your personal data is carried out in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation (de Algemene Verordening Gegevensbescherming (AVG)); hereinafter referred to as "the Regulation"), and other legislation governing the protection of personal data.

The processing of your personal data is based on the following legal grounds: consent (Article 6(1)(a) of the GDPR in conjunction with Article 7 of the GDPR), necessity to fulfill a contract with you (Article 6(1)(b) of the GDPR), processing to comply with legal obligations (Article 6(1)(c) of the GDPR), legitimate interest in data processing (Article 6(1)(f) of the GDPR).

Boozt24 has a legitimate interest in detecting and preventing misuse of its services, as well as a legitimate interest in improving and tailoring its services to your needs.

Respecting your privacy and the protection of your personal data, Boozt24 will do everything in its power to ensure the security and confidentiality of your personal data and other information processed by us.

Furthermore, based on Article 25 of the GDPR, Boozt24 is engaged in the concepts of data protection by design and by default. This means that Boozt24, through its design, protects the rights of its users through data protection principles (such as data minimization), and ensures that the collected data has the necessary purposes by default.

Boozt24 reserves the right to modify the provisions of the Privacy Policy at its own discretion. Changes to the Privacy Policy shall come into effect from the day of publication on the website. If they involve minor or structural changes, they will take effect without prior notice, and the duty to provide information will rest on you. However, if the changes are substantial or significant, Boozt24 will ensure that its users and relations are informed accordingly, and, where necessary, Boozt24 will request consent regarding the new policy.

The website also uses cookies and trackers.

This page was last updated on: June 7, 2023

2. What data do we collect and how do we do it?

According to Article 4 of the GDPR, "personal data" means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

When processing your personal data, Boozt24 adheres to the following principles for the processing of personal data:

  • Your personal data is only processed to the extent necessary to achieve the corresponding clearly defined and legitimate purposes, taking into account the protection of your privacy;
  • Your personal data is processed accurately, fairly, and lawfully, and only processed for purposes consistent with the purposes that were specified before your personal data was collected;
  • Boozt24 processes your personal data strictly in accordance with the clear and transparent requirements for the processing of personal data as specified by law;
  • Your personal data is processed in a form that no longer allows your identity to be determined for the purposes for which the personal data is processed;
  • When processing your personal data, appropriate technical and organizational measures are taken to ensure the protection of personal data, including protection against unlawful data processing and against accidental loss, destruction, and damage.

 

Your data can be collected in various ways:

  • By using or viewing our website through your browser's cookies.
  • By registering on our website.
  • During and after submitting a quotation request.
  • By filling out forms.
  • By submitting general questions.

2.1 Personal data processed by submitting a quote request

Wanneer je besluit om financiering aan te vragen, op basis van artikel 6 (1) (b) van de AVG, kan en mag Boozt24 (afhankelijk van het rechtsgebied) in het kader van de dienstverlening je vragen om jouw persoonlijke gegevens te verstrekken: bedrijfsnaam, jouw volledige naam, geboortedatum, woonadres, kopie identiteitsbewijs, paspoort, rijbewijs, foto, video, bedrijfsnaam, telefoonnummer, e-mailadres, aangevraagd financieringsbedrag en mogelijk andere soorten gegevens (zoals de uiteindelijke begunstigde).

The aforementioned personal data is collected to contact you and make preparations to conclude the agreement.
Furthermore, in relation to Article 6(1)(c), the collected data may be retained for legal obligations and risk assessment, such as compliance with anti-money laundering and fraud-related legislation and Know Your Customer processes.

The collected data may be provided to other parties to the extent necessary for the execution of agreements between those third parties and Boozt24.
Additionally, the financier and its successors will not only process personal data provided by the seller for those purposes but also collect and process personal data from third-party sources, including potentially credit information agencies, financial crime, and terrorism databases, and any other public records.

To determine the retention period for the personal data specified during your reservation, Boozt24 applies criteria in accordance with the obligations specified in the legislation and also takes into account your rights. For example, Boozt24 sets a retention period for personal data in which requirements related to the execution of the agreement can be met for specific cases. For example, the retention period for Anti Money Laundering-related data is 5 years, which is the same as the statute of limitations for criminal activities. 

2.2 Personal data processed for direct marketing purposes and market research

When you decide to apply for financing, based on Article 6(1)(b) of the GDPR, Boozt24 may, depending on the jurisdiction, ask you to provide your personal data for the purpose of service provision. This may include: company name, full name, date of birth, residential address, copy of identification document, passport, driver's license, photo, video, company name, phone number, email address, requested financing amount, and possibly other types of data (such as the ultimate beneficiary).

If you wish to receive direct marketing offers from Boozt24, you can provide your email address on the website.
If you have agreed to subscribe to our newsletter, we may use your email address and phone number to provide information about goods, services, discounts, offers, contests, events, news, or opinion polls, as well as to send other news via email, mail, phone, or SMS, and contact you for these purposes. You have the right to opt-out at any time by following the instructions in the original message or by sending us an email at info@boozt24.com.

Your personal data processed for direct marketing and market research purposes will be retained by Boozt24 for five years, but no longer than the validity of your consent. Please note that you always have the right to withdraw your consent for the processing of your personal data for direct marketing and market research purposes at any time. You can unsubscribe from direct marketing offers by contacting Boozt24 via email at info@boozt24.com or by clicking on the link in the email that allows you to unsubscribe from receiving direct marketing offers.

Boozt24 uses Microsoft Clarity and Microsoft Advertising on its website to track how you use our website through behavioral statistics, heatmaps, and session replays to improve and market our products/services. Usage data from the website is collected using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activities. Additionally, Boozt24 uses this information for website optimization, fraud/security purposes, and marketing. For more information on how Microsoft collects and uses your data, please refer to Microsoft's Privacy Statement .

2.3 Personal data processed to provide you with information

If you want to contact us and receive additional information, you can do so by submitting a request on Boozt24's website and providing your name, company name, phone number, and email address so that Boozt24 knows where to provide the requested information. Your personal data processed for this purpose will be kept by Boozt24 for as long as necessary to properly analyze the information you provided and answer your questions.

3. Who do we share your personal data with?

Based on Article 6(1)(b) of the GDPR, to ensure uninterrupted business operations and proper service provision, Boozt24 may disclose your personal data to its financier, customer service, accounting, and marketing, and to third parties providing services to Boozt24, including marketing companies, information technology service providers, entities screening for Know Your Customer/Anti Money Laundering checks, audit, accounting, legal, and debt collection services, and other parties as required for the purposes stated in this privacy policy. In this case, Boozt24 will take appropriate measures to ensure that the supporting data processors only process the personal data entrusted to them for the purposes specified by Boozt24, carry out the actions instructed by Boozt24 to be completed, and provide appropriate organizational and technical measures to protect personal data.

Personal data provided by Boozt24 to or obtained from external sources may be transferred to or stored in a geographic region that imposes different privacy obligations than your country of origin.

Boozt24 currently does not share your data with third parties for marketing-related services. If Boozt24 starts transferring data to third parties, this will be a substantial change to the privacy policy, and you will be duly informed.

Boozt24 has the right to transfer your processed personal data to government institutions and bodies to properly implement legal requirements. Additionally, your personal data may be transferred to persons providing legal services when these personal data need to be disclosed to establish, implement, or defend the rights and legitimate interests of Boozt24. 

4. Your rights and opt-out

As a data subject, you have the right to:

  • Be informed about the processing of your personal data.
  • Receive information about the personal data collected and from which sources, the purpose of processing, and to whom the data is or has been disclosed.
  • Request correction of your personal data if the data is incorrect and/or incomplete.
  • Request the erasure of your personal data or the suspension of the processing of your personal data.
  • Request restriction of the processing of your personal data and/or object to the processing.
  • Receive the personal data you provided to Boozt24 in a structured, commonly used, and machine-readable format, and to have this data transferred to another data controller, or to request that Boozt24 transfer this personal data directly to another data controller where technically feasible (right to data portability).
 

Boozt24 does not perform profiling of your personal data that may have legal consequences for you or significantly affect you. However, by providing personalized marketing offers and market research, you may be categorized into a relevant customer category. In this regard, you have the right to demand human intervention, express your point of view, and challenge the decision.

If you have agreed to receive marketing, you can opt-out at a later time. You have the right to prevent Boozt24 from contacting you for marketing or research purposes at any time.

You have the right to prevent Boozt24 from contacting you for marketing or research purposes at any time. If you intend to exercise your rights, you can contact our data protection officer at privacy@boozt24.com. Please note that when exercising your rights, you must properly verify your identity.

Therefore, if you plan to send a request to Boozt24, you must confirm your identity, in the procedure established by law, using electronic communication means that allow for identification. Boozt24 will provide you with the requested information free of charge within one month, but if the requests you send are clearly unfounded or excessive, especially due to their repetitive content, Boozt24 has the right to charge a reasonable fee, taking into account the administrative costs of providing the information or the notifications or actions you request, or to refuse to take action based on the request.

If you believe that Boozt24 is processing your personal data incorrectly or not properly implementing your rights, you should first contact Boozt24. Boozt24 is ready to work with you to resolve any issues. If you are not satisfied with Boozt24's response, you also have the right to file a complaint with the national supervisory authority (also see Article 9).  

5. What are your duties and responsibilities?

By using Boozt24's services, you accept full responsibility for the accuracy and correctness of the personal data you provide. By submitting personal data (e.g., by completing an application form), you accept full responsibility for the legality of the submission of your personal data.

If there are changes to the personal data or other related information you have provided, you must inform us accordingly.

If incorrect data is collected, we have the right to restrict/terminate the service relationship.

6. How does Boozt24 protect your personal data?

Boozt24 uses appropriate organizational and technical measures to protect personal data from accidental or unlawful destruction, damage, alteration, and other unlawful actions. When selecting these measures, the risks to your rights and freedoms as the data subject are taken into account.

In this case, Boozt24 ensures strict access control to the processed personal data, granting access solely to Boozt24 employees who need the personal data to perform their work and monitoring how the granted access is used. Boozt24 protects access to personal data with passwords of the appropriate level and enters into confidentiality agreements with individuals who have access to your personal data.

Employees of Boozt24 with access to personal data are familiar with the requirements for the protection of personal data and ensure the confidentiality of the processed personal data.

7. Our activities on social media platforms

The website provides links to Boozt24's social media accounts. The social network website (and the relevant data controller) manages all information you provide to us through social media (including messages, "Likes," and "Follows," and other forms of communication). The website contains links to our social media accounts.

We recommend that you read the privacy policies of these social media platforms and contact these service providers directly if you have questions about how they use your personal data. 

8. Processing personal data of customers and debtors

The text below applies only to customers and debtors.

8.1 How do we use your data?

We use your data:

  • To perform factoring services;
  • For collection and debtor management;
  • To prevent fraud;
  • To comply with laws and regulations;
  • To keep track of our contact with you;
  • To enable you to use the technology we use to arrange your financing if you are a customer of ours or to process your payments if you are a debtor of our customer;
  • For refinancing receivables.

8.2 Who do we receive your data from?

Boozt24 receives personal data from:

  • Customers with whom we have a (factoring) agreement.
  • Debtors.

8.3 With whom do we share your data?

We share your data with:

  • The provider of the financing platform Boozt24 Applications B.V.
  • The representative of our bondholders Stichting Boozt24 Finance
  • Our financier ING Commercial Finance B.V. (information about the processing of your personal data by ING can be found at https://www.ing.nl/de-ing/privacy-statement)
  • Incassobureaus en/of gerechtsdeurwaarders, voor zover noodzakelijk voor inning van vorderingen.

 

We also share your data with third parties if:

  • This is necessary for the purpose of the processing and the task of the persons or third parties involved;
  • It is required by law;
  • We have your permission for this.

9. The right to lodge a complaint

If you believe that your privacy rights have been violated, you can contact Boozt24 via email at privacy@boozt24.comYou can also file a complaint with the Data Protection Authority or the court.

10. Where can you go with questions?

For questions, you can contact Boozt24.

10.1 How to contact us?

If you have questions about Boozt24's privacy policy, the data we hold about you, or if you wish to exercise your data protection rights, feel free to contact us.
Email us at: info@boozt24.com
Call us: 085-0270079
Or you can send an email to our data protection officer: privacy@boozt24.com

10.2 How to contact the relevant authority?

If you want to report a complaint or if you believe that Boozt24 has not properly handled your complaint, you can contact the Data Protection Authority (AP).

Mailing address:
Autoriteit Persoonsgegevens
Postbus 93374
2509 AJ DEN HAAG

Telephone:
Telephone number: (+31) – (0) 70 – 888 85 00
Fax: (+31) – (0) 70 – 888 85 01
Visit address:
(by appointment only)
Bezuidenhoutseweg 30