Privacy policy

Proxuma (Proxuma B.V.) is committed to providing quality services to you and this policy
outlines our ongoing obligations to you in respect of how we manage your Personal
We have adopted the GDPR. The GDPR governs the way in which we collect, use, disclose,
store, secure and dispose of your personal information.

Do We Collect It?

We collect your personal information for the primary purpose of providing our services to you.
We may also use your personal information for secondary purposes closely related to the
primary purpose, in circumstances where you would reasonably expect such use or

We may also use your information to conduct marketing activities including targeted and
non-targeted promotions. You may unsubscribe from our mailing/marketing lists at any time
by contacting us in writing.

Website and Cookies

To ensure we are meeting the needs and wants of our website users, and to develop our
online services, we may collect aggregated information by using cookies or similar electronic
tools. Cookies may be placed on your computer or internet-enabled device whenever you
visit us online. This allows the site to remember your computer or device and serves several

You can accept or decline cookies. Most Web browsers automatically accept cookies, but you
can usually modify your browser setting to decline cookies if you prefer. However, please be
aware that if you do not accept cookies, you may not be able to fully experience some of our
website’s features.

Sensitive Information

We do not normally collect, or store ‘sensitive information’ as defined in the Privacy Act 1988
(e.g., information about ethnic origin, religious beliefs, or health). However, where we are
required to and it is practicable to do so, we will seek your consent before collecting your
sensitive information and informing you of the purpose at the time.

Third Parties

Where reasonable and practicable to do so, we will collect your personal information only
from you. However, in some circumstances we may be provided with information by third
parties. In such a case we will take reasonable steps to ensure that you are made aware of
the information provided to us by the third party.

Disclosure of Personal Information

Your personal information may be disclosed in several circumstances including the following:
• Third parties where you consent to the use or disclosure.
• and where required or authorized by law.

Security of Personal Information

Your personal information is stored in a manner that reasonably protects it from misuse and
loss and from unauthorized access, modification, or disclosure. When your personal
information is no longer needed for the purpose for which it was obtained, we will take
reasonable steps to destroy or permanently de-identify your personal information. However,
most of the personal information is or will be stored in client files which will be kept by us for a
minimum of 7 years.

Access to your Personal Information

You may access the personal information we hold about you and update and/or correct it,
subject to certain exceptions. If you wish to access your personal information, please contact
us in writing. Proxuma will not charge any fee for your access request but may charge an
administrative fee for providing a copy of your personal information. In order to protect your
personal information, we may require identification from you before releasing the requested

Maintaining the Quality of your Personal Information

It is important to us that your personal information is up to date. We will take reasonable
steps to make sure that your personal information is accurate, complete, and up to date. If
you find that the information we have is not up to date or is inaccurate, please advise us as
soon as practicable so we can update our records and ensure we can continue to provide
quality services to you.

Policy Updates

This Policy may change from time to time and is available on our website.

Your Consent

As part of your engagement with us, and your use of our web and social sites, you consent to
the collection, storage, use and dissemination of your personal information in accordance
with this privacy policy and as otherwise permitted by applicable privacy law.

GDPR Privacy

Legal Basis for Processing Personal Data Under GDPR

We may process personal data under the following conditions:
• Consent: You have given your consent for processing personal data for one or more
specific purposes.
• Performance of a contract: Provision of personal data is necessary for the performance
of an agreement with you and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing personal data is necessary for compliance with a legal
obligation to which Proxuma is subject.
• Vital interests: Processing personal data is necessary to protect your vital interests or
those of another natural person.
• Public interests: Processing personal data is related to a task that is carried out in the
public interest or in the exercise of official authority vested in Proxuma.
• Legitimate interests: Processing personal data is necessary for the purposes of the
legitimate interests pursued by Proxuma.

Your Rights Under the GDPR

• Request access to your personal data. Whenever made possible, you can access,
update, or delete your personal data by contacting us on the details at the end of this
Privacy Policy.
• Request correction of the personal data that we hold about you. You have the right to
have any incomplete or inaccurate information we hold about you corrected.
• Object to processing of your personal data. This right exists where we are relying on
legitimate interest as the legal basis for our processing and there is something about your
situation which makes you want to object to our processing of your personal data on this
ground. You also have the right to object to where we are processing your personal data
for direct marketing purposes.
• Request erasure of your personal data. You have the right to ask us to delete or remove
personal data when there is no good reason for us to continue processing it.
• Request the transfer of your personal data. We will provide you, or to a third party you
have chosen, with your personal data in a structured, commonly used, machine-readable
format. Please note that this right only applies to automated information which your
consent for us to use or where we used the information to draw up a contract with you.
• Withdraw your consent. You have the right to withdraw your consent on using your
personal data. If you withdraw your consent, we may not be able to provide you with
access to certain specific functionalities of the service.

Exercising of Your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation, and opposition by
contacting us. Please note that we may ask you to verify your identity before responding to
such requests. If you make a request, we will try our best to respond to you as soon as
possible. You also have the right to complain to a Data Protection Authority about our
collection and use of your personal data if required.

Questions, Enquiries and Complaints

If you have any questions, comments, or concerns or if you wish to report a potential security
issue, please contact [email protected]