Privacy Policy

  1. Who we are
    1. “We”, “us” or “our” means Xplore Group BV, with registered office at Orteliuslaan 25 3528BA Utrecht and with company number 17215516. We will be considered the data controller in respect of the personal data we collect in connection with your use of our website.
    2. This privacy policy aims only to provide you with information regarding the processing of personal data in the context of our website. For our privacy practices relating to our services, please refer to the agreement you have entered into with us or the contact as indicated below. Our website,, is owned and operated by Xplore Group. The website is hosted by Sidekick NV. For further information, please refer to article 5 of this Privacy Policy.
    3. Your privacy is important to us. Hence, we have developed this privacy policy to provide you with more information regarding the collection, communication, transfer and use (“processing”) of the personal data you share with us, as well as to provide you with more information regarding your rights. We therefore request that you read this privacy policy.
    4. If you have any questions, comments or complaints regarding this Privacy Policy or the processing of your personal data or wish to make a request in accordance with Article 4, please contact us in any of the following ways:
      1. By e-mail:, for the attention of N. Jaspers
      2. By post: Van Deventerlaan 31, 3528AG, Utrecht + N. Jaspers

This Privacy Policy was last updated on 16/08/2022.

  1. How we use and collect your personal data
    1. Personal data is defined as any information about an identified or identifiable natural person. Identifiable refers to identifiers (such as name, identification number, location data, etc.) that can be used to directly or indirectly identify a natural person.
    2. The personal data we collect is collected for the following purposes:
      1. If you use the contact form on our website, we will use your personal data to respond to your request either via e-mail or by telephone. Your e-mail address will also be included in our database for sending our newsletter and providing information regarding events, seminars et al.
      2. If you subscribe to the newsletter, your e-mail address will be used to send you our newsletters. In addition, we may keep you informed of events, seminars, etc. that we organise that may be relevant to you.
      3. We process your personal data for the purpose of supporting the website and improving your user experience. This purpose extends to monitoring the security, availability, (performance), capability, and health of our website.
      4. We process your personal data to enforce or comply with rights granted under applicable law (such as defending against legal claims) if necessary. We may also use your personal data to fulfil our obligations under applicable law.
    3. We collect the following categories of personal data:
      1. Contact details: If you use the contact form, you will be asked to provide the following information: name, e-mail address, telephone number, place of employment. This is information provided directly by you.
      2. Newsletter: If you subscribe to our newsletter, you will be asked to provide your e-mail address. This is information provided directly by you.
      3. Usage information: We process personal data relating to your use of our website: IP address, device ID and type, referral source, language settings, browser type, operating system, geographical location, length of visit, page visited, or information regarding the timing, frequency and pattern of your visit. This information may be aggregated and may help us collect useful information regarding the use of the website. In the event that such usage information is anonymised (and therefore not traceable to you as a natural person), then such information is not covered by this Privacy Policy. This information is collected automatically through your use of the website.
      4. Log In data: We collect personal data relating to your digital marketing strategy: login data (account name, password, e-mail address). This personal data is provided by you. Credit card data is only entered by our customer and impossible to use without permission.
    4. The legal grounds for using your personal data are
      1. Contractual ground: the processing is necessary for the performance of the completed agreements in the employment contract.
      2. Consent. Xplore Group has obtained unambiguous and explicit consent from the individual. We obtained this consent when the employment contract was signed. You have the right to withdraw your consent at any time. This will not affect the lawfulness of the processing that occurred before the withdrawal of your consent.
      3. Legitimate interest: the processing is necessary for the protection of legitimate interests, in particular the promise of the best Xplore Group customer experience.  (e.g. offering new services). Without the processing, the above-mentioned pursuit does not become feasible.
    5. Your personal data will only be used according to the purposes set out in Article 2.2.
  1. Retention of your personal data and deletion
    1. Your personal data will not be kept longer than necessary to fulfil a specific purpose. However, as it is not possible to specify a period in advance, the period will be decided as follows:
      1. The period depends on which services Xplore Group provides. These are agreed and established contractually. When using our Hosting service, an indefinite term agreement is drawn up by default. This agreement can be terminated at any time. Terms regarding digital strategy are also established when the agreement is concluded. The duration of these agreements depends on demand and is contractually agreed.
      2. If you withdraw your consent or object to the processing of personal data, and such objection is withheld, we will delete your personal data. However, we will keep those personal data necessary to respect your preferences in the future.
      3. However, we are entitled to keep your personal data if this is necessary to comply with our legal obligations, to bring a legal claim or defend ourselves against such claim or for evidentiary reasons.
  1. Your rights as an individual
    1. This article summarises your main rights in accordance with the applicable data protection legislation. We have tried to summarise them for you in a clear and readable way.
    2. If you wish to exercise any of your rights, please send us a written request in accordance with Article 1 of this Privacy Policy. We will endeavour to respond to your request without unreasonable delay, but in any event within a period of one month from receipt of your request. If we are unable to respond within the aforementioned one-month period and wish to extend the period, or in case we will not respond to your request, we will notify you accordingly.
    3. Right of inspection
      1. In the event that we process your personal data, you have the right to access your personal data as well as certain additional information as defined in this Privacy Policy.
      2. You have the right to receive from us a copy of your personal data in our possession, provided it does not adversely affect the rights and freedoms of others. The first copy will be provided to you free of charge, but we reserve the right to charge a reasonable fee if you request multiple copies.
    4. Right of improvement
      1. If the personal data we hold about you is inaccurate or incomplete, you have the right to ask us to correct it, or to request us – taking into account the purposes of the processing – to complete it.
    5. Right to data deletion / oblivion
      1. If any of the following applies, you have the right to obtain deletion of your personal data – without unreasonable delay:
        1. Personal data are no longer needed for the purposes for which they were collected or otherwise processed;
        2. You withdraw your consent on which the processing is based, and there is no other legal basis for processing your personal data;
        3. Your personal data has been unlawfully processed;
        4. Deletion of your personal data is necessary to comply with EU or Belgian law;
      2. There are certain exclusions to the right to data erasure. These exclusions include where processing is necessary,
        1. For exercising the right to freedom of expression and information;
        2. For public health reasons;
        3. For the purpose of archiving in the public interest, or statistical purposes;
        4. To fulfil a legal obligation; or,
        5. For the establishment, exercise or substantiation of a legal claim.
    6. Right to restriction of processing
      1. You have the right to obtain the restriction of the processing of your personal data (meaning that the personal data may be stored by us and used only for limited purposes), if any of the following applies:
        1. You dispute the accuracy of the personal data, for a period of time that allows us to verify the accuracy of the personal data;
        2. The processing is unlawful and you oppose the erasure of the personal data and request instead that its use be restricted;
        3. We no longer need your personal data for processing purposes, but you need it for the establishment, exercise or defence of legal claims; or,
        4. You have objected to the processing, pending the answer to whether our legitimate grounds outweigh yours.
      2. In addition to our right to store your personal data, we can still process it, but only:
        1. With your permission;
        2. For bringing, exercising or defending legal action;
        3. To protect the rights of another natural or legal person; or,
        4. For reasons of public interest.
      3. Before we lift the restriction on processing your personal data, you will be informed.
    7. Right to portability of your personal data / data portability.
      1. Where the processing of your personal data is based on your consent, and the processing is carried out through automated processes, you have the right to receive your personal data in a structured, common and machine-readable form. However, this right does not apply insofar as it would prejudice the rights and freedoms of others.
      2. You also have the right, if technically possible, to have us transmit your personal data directly to another company.
    8. Right to object.
      1. You have the right to object to the processing of your personal data at any time – for reasons related to your specific situation – but only to the extent that the legal basis for the processing is that the processing is necessary for:
        1. The performance of a task of public interest or in the exercise of a task in the exercise of public authority vested in us;
        2. The pursuit of our legitimate interests or those of a third party.
      2. If you object to the processing of your personal data, we will no longer process the personal data unless we can demonstrate legitimate interests for processing that outweigh the interests or fundamental rights and freedoms of you.
      3. Where your personal data are processed for the purpose of direct marketing, whether initial or further processing, you have the right to object to such processing at any time and free of charge, including in the case of profiling insofar as it relates to direct marketing. If you raise such an objection, we will stop processing your personal data for this purpose.
    9. Right to complain to a supervisory authority.
      1. If you believe that the processing of your personal data carried out by us violates data protection legislation, you have the right to lodge a complaint with a data protection supervisory authority. You can do so in the EU Member State of your habitual residence, of the place where you work or of the place where the alleged breach took place. In the Netherlands, you can contact the Personal Data Authority for this purpose. You can do so via the following link: In Belgium, you can file a complaint with the Privacy Commission, Drukpersstraat 35, 1000 Brussel (,
  1. Providing your personal data to third parties
    1. To provide our website, we work with service providers to process and succeed your personal data. We use the following service providers:
      1. Hosting provider: Sidekick NV, with registered office at 2550 Kontich, Veldkant 33A, with company number 0669.636.926
      2. If agreed a third party with access to the website dashboard
      3. If contractually agreed under SEA, we work with Facebook business, Google adwords, LinkedIn business.
      4. (…)
    2. Providing access to your data may be necessary for legal purposes. In such a case, we will be obliged to comply. We may also provide your personal data if this is necessary to protect the vital interests of another natural person.
    3. We do not provide personal data to third parties without prior agreement. Our website uses social media plug-ins that allow you to link to our social media channels or enable you to share content on your social media channels. These social media channels are Facebook, Instagram, LinkedIn, Twitter, Google+, Youtube and Pinterest. If you click on such links, the aforementioned social media partners may collect personal data, such as personal data relating to your profile.
    4. We are not responsible for how these social media partners use your personal data. In such case, they will act as data controllers. For your information, we list the relevant links below (however, these may change from time to time):
      1. Facebook:;
      2. Instagram:;
      3. LinkedIn:;
      4. Twitter:;
      5. Google+:;
  1. Transfer of personal data
    1. No transfer of personal data takes place outside the European Economic Area.
    2. We assure that a transfer of personal data to a third country will take place subject to the necessary safeguards.
    3. You consent to the transfer of personal data to a third country.
  1. Cookies
    1. Our website uses cookies. For further information, please refer to our cookie policy.
  1. Amendments to the privacy policy
    1. From time to time, we may make changes to this privacy policy. The most recent version of the privacy policy can always be consulted on the website.