5. On what legal bases do we process personal data?
We only process personal data if there is a valid legal basis for doing so. Depending on the situation, this may be:
a. performance of a contract;
b. steps taken prior to entering into a contract;
c. legal obligation;
d. legitimate interest, for example for business communication, service improvement, security, or internal administration;
e. consent, for example for newsletters, certain cookies, photos, videos, or the processing of special categories of personal data;
f. explicit consent, where legally required for sensitive or special categories of personal data.
Consent can be withdrawn at any time. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.
6. E-learning, AI, and digital applications
In providing our services, Mension may use e-learning, online learning environments, digital modules, AI applications, tools, platforms, or other digital applications.
These digital applications support users in learning, reflection, analysis, development, collaboration, leadership, behavior, and decision-making. They may process information that users enter themselves, including personal or sensitive information, as well as usage data such as login times, interactions, progress, preferences, and technical data.
When AI is used within digital applications, results, suggestions, analyses, or advice may be generated based on the information entered by users. These results are supportive in nature and do not replace professional legal, medical, psychological, financial, or other specialist advice. Users and clients remain responsible for decisions and actions taken based on the use of these applications.
For the operation of e-learning, AI applications, and other digital applications, Mension may use AI suppliers, technology partners, and other technical suppliers, including suppliers for hosting, security, storage, monitoring, application management, and support.
Digital applications may store input, output, account data, progress data, and usage data for the operation of the application, quality assurance, security, support, reporting, and service improvement.
Mension does not share individual input, output, reflections, accounts, or personal usage data by name with clients, unless this has been clearly agreed upon in advance, is legally required, or the user in question has given their consent.
Mension may share general, anonymized, or aggregated insights with clients, for example regarding themes, patterns, learning needs, or development questions within an organization. This is only done insofar as this information is not traceable to individual persons.
Users are requested not to enter information into e-learning, AI applications, or other digital applications that is not necessary for the purpose of use. If users enter sensitive or special categories of personal data, we process this with care and only within the framework of our services, applicable legislation, and agreements with the client.
7. Confidentiality within programs
Mension often works with personal, team, and organizationally sensitive information. We handle this with care and confidentiality.
We do not share personal conversation notes, individual reflections, or personal information of participants with clients, unless this has been clearly agreed upon in advance, is legally required, or the participant in question has given their consent.
We may share general insights regarding group patterns, themes, collaboration, culture, leadership, or development needs. In doing so, we ensure that this information is not unnecessarily traceable to individual persons.
8. Website, cookies, and analytics
Our website uses cookies and similar technologies.
Functional cookies are necessary for the website to function properly. We only use analytical cookies in a manner that complies with legislation. For tracking cookies, marketing cookies, and similar technologies, we request prior consent via the cookie banner.
We may use analytics and the LinkedIn Insight Tag to analyze website usage, measure campaigns, and improve our communication. These technologies are only used if consent has been given, insofar as consent is legally required.
Visitors can set or change their cookie preferences via the cookie banner on our website.
9. Newsletter and communication
If someone subscribes to our newsletter, we use their email address to send the newsletter.
You can unsubscribe at any time via the unsubscribe link in the newsletter or by contacting us at hello@wearemension.com.
We may also approach existing business relationships with information about similar services, provided this complies with applicable rules and the recipient can easily unsubscribe.
10. Who do we share personal data with?
We only share personal data when necessary for our services, business operations, or legal obligations.
We may share personal data with:
a. clients, insofar as this fits within the assignment and does not conflict with confidentiality;
b. participants or involved parties, insofar as necessary within a program;
c. suppliers of digital applications, hosting, email, cloud storage, administration, accounting, CRM, analytics, and security;
d. OpenAI and other AI or technology partners required for AI applications, e-learning, or other digital applications;
e. trainers, coaches, consultants, or other professionals working on behalf of or in collaboration with Mension;
f. legal, financial, or administrative advisors;
g. government authorities or regulators if we are legally required to do so.
We enter into data processing agreements with parties that process personal data on our behalf where necessary.
11. Transfers outside the European Economic Area
Some suppliers may process personal data outside the European Economic Area. If this occurs, we ensure appropriate safeguards are in place, such as standard contractual clauses, additional security measures, or other valid legal mechanisms.
12. How long do we retain personal data?
We do not retain personal data longer than necessary for the purpose for which it was collected, unless we are legally required to retain data for a longer period.
Our standard retention periods are as follows:
a. contact requests and general correspondence: a maximum of 2 years after the last contact;
b. quotes and assignment information: a maximum of 7 years as part of our records;
c. invoice and payment data: 7 years due to tax obligations;
d. program information, intake data, evaluations, and coaching notes: as long as necessary for the program and a maximum of 7 years after completion, unless longer retention is required;
e. account data for digital applications: as long as the account is active and a maximum of 7 years after account termination;
f. input, output, progress data, and usage data of AI applications, e-learning, and other digital applications: a maximum of [insert period], unless longer retention is required for security, complaints, support, legal obligations, or agreed-upon reporting;
g. newsletter data: until the individual unsubscribes;
h. cookie and analytics data: according to the retention periods in the cookie banner and the settings of the respective tools.
13. Security
We implement appropriate technical and organizational measures to protect personal data against loss, misuse, unauthorized access, disclosure, and alteration.
These measures may include access security, passwords, two-factor authentication, encryption, logging, authorization management, supplier agreements, confidentiality, and secure storage.
Only individuals who require access to data for their work are granted access to personal data.
14. Rights of data subjects
Under privacy legislation, data subjects have various rights. They may ask us for:
a. access to their personal data;
b. correction of inaccurate or incomplete data;
c. deletion of data;
d. restriction of processing;
e. data portability;
f. objection to processing;
g. withdrawal of consent;
h. an explanation regarding automated processing, where applicable.
Requests can be sent to hello@wearemension.com.
We may request additional information to verify the identity of the requester. We will respond within the statutory timeframe.
15. Complaints
If you feel that we are not handling your personal data with the necessary care, please let us know. We will work with you to find a solution.
Complaints can be sent to hello@wearemension.com.
Additionally, every data subject has the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).
16. Changes
We may update this privacy policy if our services, website, digital applications, legislation, or working methods change.
The most current version can always be found at www.wearemension.com.
In the event of significant changes, we will inform the parties involved wherever reasonably possible.
