People Analytics Privacy Policy
This privacy policy aims to inform users of UNLOQ Campus People Analytics how UNLOQ handles the processing of personal data. These privacy regulations are fully compliant with the General Data Protection Regulation (GDPR).
1 Definitions
1.1 UNLOQ Campus People Analytics: a digital platform for the purpose of monitoring and evaluating L&D programmes and conducting Assessments.
1.2 Personal data: any privacy-sensitive information about a natural person, being a client, L&D professional or respondent.
1.3 Provision of personal data: the disclosure or making available of personal data within UNLOQ Campus People Analytics.
1.4. Processing of personal data: any possible operation concerning personal data, such as the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction of personal data.
1.5 Controller: a natural or legal person, a government agency, a service or another body which, alone or jointly with others, determines the purpose and means of processing personal data, being: UNLOQ located at Langestraat 24-01, 5038 ED Tilburg. The contact details of the controller and its data protection officer are set out in Annex A to these Regulations.
1.6 Processor: a natural or legal person, a public authority, an agency or another body that processes personal data on behalf of the Controller, being:
• The private company with limited liability UNLOQ, having its registered office in Tilburg.
• The private company with limited liability True B.V., having its registered office in Amsterdam.
• The private company with limited liability Mobile Tulip B.V., trading as 'MessageBird', based in Amsterdam. The contact details of these processors are set out in Annex B to these regulations.
1.7 L&D professional: the person who deploys the UNLOQ Campus People Analytics within a Learning & Development programme (L&D programme) and whose personal data are processed. This may include, for example, a coach, trainer, teacher, assessor, psychologist, or other behavioural expert.
1.8 Client: the person who is accompanied by an L&D professional and whose personal data is processed.
1.9 Respondent: contact person of the Client whose personal data are processed.
1.10 Assessment: functionality within the UNLOQ Campus People Analytics whereby the Client gives his or her consent to provide personal data to respondents, which respondents provide feedback on the Client to the relevant L&D professional and Client.
1.11 Programme Manager: the L&D professional charged with leading an L&D programme.
2 CLIENT
2.1. Definitions
See chapter 1 for definitions
2.2. Purpose of processing
The main purposes of processing personal data are:
• Evaluation of L&D programmes;
• Conducting Assessments
Personal data will be collected through online questionnaires completed by the Client. No more personal data will be stored or retained than is necessary for the purpose.
2.3. Ground for processing
2.3.1. The ground for processing personal data is the Client's consent.
2.3.2 The Client may withdraw his or her consent at any time.
2.4. Recipients of personal data
2.4.1 Personal data of the Client shall only be provided to L&D programme manager and the L&D professional of the relevant Client.
2.4.2. Only with the explicit consent of the Client will the personal data also be provided to respondents for the purpose of conducting an assessment.
2.5. Rights of the Client
2.5.1 Right of inspection
The Client has the right to acquaint himself or herself with the personal data relating to him or her and to receive a copy thereof. To this end, he or she shall submit a written request to the L&D programme manager professional on whose initiative the data in question were collected. If, in his or her opinion, it is plausible that direct access could result in damage to the Client's health or misinterpretation of the recorded data, he or she may recommend that access take place under his or her supervision. The controller shall communicate its decision in writing to the Client within four weeks of the request.
2.5.2 Right to rectification
The Client may request that personal data relating to him or her be corrected or supplemented to rectify errors or omissions. He or she shall submit a written reasoned request to that effect to the controller. UNLOQ shall communicate its decision to the Client in writing within four weeks of the request.
2.5.3. Right to oblivion
The Client has the right to have personal data deleted without delay if:
• the personal data are no longer necessary for the purposes for which they were provided,
• he or she has withdrawn the consent referred to in Article 2.3.1 and there is no other legal basis for the processing;
• the personal data have been processed unlawfully; or
• personal data must be deleted to comply with a legal obligation of UNLOQ.
The Client shall submit a written reasoned request to this effect to UNLOQ. The controller shall communicate its decision in writing to the Client within four weeks.
2.5.4. Right to restrict processing
The data subject has the right to temporary restriction of processing if:
• the accuracy of the personal data is disputed by the Client;
• the processing is unlawful but the Client does not request erasure of the personal data;
• UNLOQ no longer needs to have the data, but the Client needs the data for a legal matter;
• The Client has objected to the processing of the personal data.
The Client shall submit a written reasoned request to this effect to UNLOQ. UNLOQ shall communicate its decision in writing to the Client within four weeks.
2.5.5. Right to data portability
The Client has the right to obtain the personal data provided to UNLOQ in a structured, common and machine-readable form and to transfer that data to a third party without interference by UNLOQ.
2.5.6 Right to file a complaint
If the Client believes that the provisions of these regulations and/or the General Data Protection Regulation are not complied with, the Client has the right to file a complaint about this with the Personal Data Authority.
2.6. Retention periods
Personal data shall not be kept for longer than necessary for the purposes for which they are processed. After a maximum of 100 weeks from activation of a Client account within the UNLOQ Campus People Analytics, being the maximum evaluation period of an L&D programme, an account is automatically deactivated. A Client account can also be manually deactivated by the L&D professional.
2.7. Transfer of personal data
Transfer of personal data to another controller is not allowed unless the Client gives his/her express consent.
2.8. Entry into force
These regulations come into force on 1 December 2022.
2.9. Right to object
The Client shall at all times have the right to object to the processing of personal data on account of reasons relating to his or her specific situation. He or she shall submit a written reasoned request to this effect to UNLOQ. UNLOQ shall communicate its decision in writing to the Client within four weeks after receipt of the request.
3 L&D PROFESSIONAL
3.1. Definitions
See chapter 1 for definitions
3.2. Purpose of processing
The main purposes of processing personal data are:
• Evaluation of L&D programmes;
• Conducting Assessments
Personal data will be collected through questionnaires completed by the L&D professional. No more personal data will be stored or retained than is necessary for the purpose.
3.3. Ground for processing
3.3.1. The ground for processing personal data is the consent of the L&D professional.
3.3.2 The L&D professional may withdraw his or her consent at any time.
3.4. Recipients of personal data
Personal data of the L&D professional will only be provided to L&D programme manager, the L&D professional's Client and the Client's respondents.
3.5. Rights of the L&D professional
3.5.1 Right of inspection
The L&D professional has the right to examine the personal data relating to his or her person and to receive a copy thereof. He or she shall submit a written request to that effect to the officer of UNLOQ. The controller shall communicate its decision in writing to the L&D professional within four weeks of the request.
3.5.2 Right to rectification
The L&D professional may request that personal data relating to him or her be corrected or supplemented to rectify errors or omissions. He or she shall submit a written reasoned request to this effect to UNLOQ. UNLOQ shall communicate its decision in writing to the Client within four weeks of the request.
3.5.3. Right to oblivion
The L&D professional has the right to have the personal data erased without delay if:
• the personal data are no longer necessary for the purposes for which they were provided,
• he or she has withdrawn the consent referred to in Article 3.3.1 and there is no other legal basis for the processing;
• the personal data have been processed unlawfully; or
• personal data must be deleted to comply with a legal obligation of UNLOQ.
The L&D professional shall submit a written reasoned request to this effect to UNLOQ. UNLOQ shall communicate its decision in writing to the L&D professional within four weeks.
3.5.4. Right to restrict processing
The data subject has the right to temporary restriction of processing if:
• the accuracy of the personal data is disputed by the L&D professional;
• the processing is unlawful but the L&D professional does not require erasure of the personal data;
• UNLOQ no longer needs to have the data, but the L&D professional needs the data for a legal matter;
• The L&D professional has objected to the processing of the personal data.
The L&D professional shall submit a written reasoned request to this effect to UNLOQ. UNLOQ shall communicate its decision in writing to the L&D professional within four weeks.
3.5.5. Right to data portability
The L&D professional is entitled to obtain the personal data provided to UNLOQ in a structured, common and machine-readable form and to transfer that data to a third party without being interfered with by UNLOQ.
3.5.6 Right to file a complaint
If the L&D professional believes that the provisions of these regulations and/or the General Data Protection Regulation are not being complied with, they have the right to lodge a complaint about this with the Personal Data Authority.
3.6. Retention periods
Personal data will not be kept longer than necessary to fulfil the purposes for which they are processed. After a maximum of 100 weeks from the last login activity of the L&D professional, being the maximum period of an evaluation process, an L&D professional account is automatically deactivated.
If the L&D professional no longer wishes to use the UNLOQ Campus People Analytics within the current retention period, he or she can also manually deactivate his or her account.
3.7. Transfer of personal data
Transfer of personal data to another controller is not allowed unless the L&D professional gives his/her explicit consent.
3.8. Entry into force
These regulations enter into force on 01 December 2022.
3.9. Right to object
The L&D professional has at all times the right to object to the processing of personal data for reasons relating to his or her specific situation. He or she shall submit a written and reasoned request to this effect to UNLOQ. UNLOQ shall communicate its decision in writing to the L&D professional within four weeks of receiving the request.
4 RESPONDENT
4.1. Definitions
See chapter 1 for definitions
4.2. Purpose of processing
The main purposes of processing personal data are:
• Evaluation of L&D programmes;
• Conducting Assessments
Personal data will be collected through questionnaires completed by the L&D professional. No more personal data will be stored or retained than is necessary for the purpose.
4.3. Ground for processing
4.3.1. The ground for processing personal data is the consent of the respondent.
4.3.2 The respondent may withdraw his or her consent at any time.
4.4. The categories of personal data obtained from third parties
Annex C to these regulations lists the categories of personal data not provided by the respondent but by third parties, as well as the recipients of these data. This includes the source and purpose.
4.5. Recipients of personal data
Personal data of the respondent will be provided only to L&D programme manager and the Client of the L&D professional.
4.6. Respondent's rights
4.6.1 Right of inspection
The respondent has the right to inspect the personal data relating to his or her person and to receive a copy thereof. He or she shall submit a written request to that effect to the officer of UNLOQ. UNLOQ shall communicate its decision in writing to the respondent within four weeks of the request.
4.6.2 Right to rectification
The respondent may request that personal data relating to him or her be corrected or supplemented to rectify errors or omissions. He or she shall submit a written reasoned request to this effect to UNLOQ. UNLOQ shall communicate its decision in writing to the respondent within four weeks of the request.
4.6.3. Right to oblivion
The respondent has the right to have personal data erased without delay if:
• the personal data are no longer necessary for the purposes for which they were provided,
• he or she has withdrawn the consent referred to in Article 4.3.1 and there is no other legal basis for the processing;
• the personal data have been processed unlawfully; or
• personal data must be deleted to comply with a legal obligation of UNLOQ.
The respondent shall submit a written reasoned request to this effect to UNLOQ. UNLOQ shall communicate its decision in writing to the respondent within four weeks.
4.6.4. Right to restriction of processing
The respondent has the right to temporary restriction of processing if:
• the accuracy of the personal data is disputed by the respondent;
• the processing is unlawful but the respondent does not request erasure of the personal data;
• UNLOQ no longer needs to have the data, but the respondent still needs the data;
• The respondent objected to the processing of the personal data.
The respondent shall submit a written reasoned request to this effect to UNLOQ. UNLOQ shall communicate its decision in writing to the respondent within four weeks.
4.6.5. Right to data portability
The respondent has the right to obtain the personal data provided to UNLOQ in a structured, common and machine-readable form and to transfer that data to a third party without interference by UNLOQ.
4.6.6 Right to file a complaint
If the respondent believes that the provisions of these regulations and/or the General Data Protection Regulation are not complied with, they have the right to lodge a complaint about this with the Personal Data Authority.
4.7. Retention periods
Personal data will not be kept for longer than necessary to fulfil the purposes for which they are processed. Maximum 100 weeks after activation of a respondent account within the UNLOQ Campus People Analytics, being the maximum evaluation period of an L&D programme, the respective account is automatically deactivated. A respondent account can also be manually deactivated by the L&D professional.
4.8. Transfer of personal data
Transfer of personal data to another controller is not allowed unless the respondent gives his/her explicit consent.
4.9. Entry into force
These regulations enter into force on 01 December 2022.
4.10 Right to object
The respondent has the right at all times to object to the processing of personal data due to reasons related to his or her specific situation. He or she shall submit a written reasoned request to that effect to UNLOQ. UNLOQ shall communicate its decision in writing to the respondent within four weeks of receiving the request.
ANNEX A
Controller contact details:
UNLOQ - Stationsstraat 24-01, 5038 ED Tilburg, The Netherlands.
Data protection officer: Head of Technology
Phone: 033-247 34 28
E-mail: privacy@unloq. org
ANNEX B
Processors' contact details:
• The private company with limited liability: UNLOQ. based in Tilburg. Address: Stationsstraat 24-01, 5038 ED Tilburg, , The Netherlands.
• The private company with limited liability: True B.V., having its registered office in Amsterdam. Address: Keienbergweg 100, 1101 GH Amsterdam, , The Netherlands.
• The private company with limited liability: Mobile Tulip B.V., trading as 'MessageBird'. based in Amsterdam. Address: Baarsjesweg 285, 1058 AE Amsterdam, , The Netherlands.
ANNEX C
Personal data obtained from third parties
Goals:
A) Evaluation of L&D programmes
B) Conducting Assessments
Category Target Source Recipient
Name of respondent A + B Client Programme Manager and L&D professional
Mail address respondent A + B Client Programme Manager and L&D professional
1 Definitions
1.1 UNLOQ Campus People Analytics: a digital platform for the purpose of monitoring and evaluating L&D programmes and conducting Assessments.
1.2 Personal data: any privacy-sensitive information about a natural person, being a client, L&D professional or respondent.
1.3 Provision of personal data: the disclosure or making available of personal data within UNLOQ Campus People Analytics.
1.4. Processing of personal data: any possible operation concerning personal data, such as the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction of personal data.
1.5 Controller: a natural or legal person, a government agency, a service or another body which, alone or jointly with others, determines the purpose and means of processing personal data, being: UNLOQ located at Langestraat 24-01, 5038 ED Tilburg. The contact details of the controller and its data protection officer are set out in Annex A to these Regulations.
1.6 Processor: a natural or legal person, a public authority, an agency or another body that processes personal data on behalf of the Controller, being:
• The private company with limited liability UNLOQ, having its registered office in Tilburg.
• The private company with limited liability True B.V., having its registered office in Amsterdam.
• The private company with limited liability Mobile Tulip B.V., trading as 'MessageBird', based in Amsterdam. The contact details of these processors are set out in Annex B to these regulations.
1.7 L&D professional: the person who deploys the UNLOQ Campus People Analytics within a Learning & Development programme (L&D programme) and whose personal data are processed. This may include, for example, a coach, trainer, teacher, assessor, psychologist, or other behavioural expert.
1.8 Client: the person who is accompanied by an L&D professional and whose personal data is processed.
1.9 Respondent: contact person of the Client whose personal data are processed.
1.10 Assessment: functionality within the UNLOQ Campus People Analytics whereby the Client gives his or her consent to provide personal data to respondents, which respondents provide feedback on the Client to the relevant L&D professional and Client.
1.11 Programme Manager: the L&D professional charged with leading an L&D programme.
2 CLIENT
2.1. Definitions
See chapter 1 for definitions
2.2. Purpose of processing
The main purposes of processing personal data are:
• Evaluation of L&D programmes;
• Conducting Assessments
Personal data will be collected through online questionnaires completed by the Client. No more personal data will be stored or retained than is necessary for the purpose.
2.3. Ground for processing
2.3.1. The ground for processing personal data is the Client's consent.
2.3.2 The Client may withdraw his or her consent at any time.
2.4. Recipients of personal data
2.4.1 Personal data of the Client shall only be provided to L&D programme manager and the L&D professional of the relevant Client.
2.4.2. Only with the explicit consent of the Client will the personal data also be provided to respondents for the purpose of conducting an assessment.
2.5. Rights of the Client
2.5.1 Right of inspection
The Client has the right to acquaint himself or herself with the personal data relating to him or her and to receive a copy thereof. To this end, he or she shall submit a written request to the L&D programme manager professional on whose initiative the data in question were collected. If, in his or her opinion, it is plausible that direct access could result in damage to the Client's health or misinterpretation of the recorded data, he or she may recommend that access take place under his or her supervision. The controller shall communicate its decision in writing to the Client within four weeks of the request.
2.5.2 Right to rectification
The Client may request that personal data relating to him or her be corrected or supplemented to rectify errors or omissions. He or she shall submit a written reasoned request to that effect to the controller. UNLOQ shall communicate its decision to the Client in writing within four weeks of the request.
2.5.3. Right to oblivion
The Client has the right to have personal data deleted without delay if:
• the personal data are no longer necessary for the purposes for which they were provided,
• he or she has withdrawn the consent referred to in Article 2.3.1 and there is no other legal basis for the processing;
• the personal data have been processed unlawfully; or
• personal data must be deleted to comply with a legal obligation of UNLOQ.
The Client shall submit a written reasoned request to this effect to UNLOQ. The controller shall communicate its decision in writing to the Client within four weeks.
2.5.4. Right to restrict processing
The data subject has the right to temporary restriction of processing if:
• the accuracy of the personal data is disputed by the Client;
• the processing is unlawful but the Client does not request erasure of the personal data;
• UNLOQ no longer needs to have the data, but the Client needs the data for a legal matter;
• The Client has objected to the processing of the personal data.
The Client shall submit a written reasoned request to this effect to UNLOQ. UNLOQ shall communicate its decision in writing to the Client within four weeks.
2.5.5. Right to data portability
The Client has the right to obtain the personal data provided to UNLOQ in a structured, common and machine-readable form and to transfer that data to a third party without interference by UNLOQ.
2.5.6 Right to file a complaint
If the Client believes that the provisions of these regulations and/or the General Data Protection Regulation are not complied with, the Client has the right to file a complaint about this with the Personal Data Authority.
2.6. Retention periods
Personal data shall not be kept for longer than necessary for the purposes for which they are processed. After a maximum of 100 weeks from activation of a Client account within the UNLOQ Campus People Analytics, being the maximum evaluation period of an L&D programme, an account is automatically deactivated. A Client account can also be manually deactivated by the L&D professional.
2.7. Transfer of personal data
Transfer of personal data to another controller is not allowed unless the Client gives his/her express consent.
2.8. Entry into force
These regulations come into force on 1 December 2022.
2.9. Right to object
The Client shall at all times have the right to object to the processing of personal data on account of reasons relating to his or her specific situation. He or she shall submit a written reasoned request to this effect to UNLOQ. UNLOQ shall communicate its decision in writing to the Client within four weeks after receipt of the request.
3 L&D PROFESSIONAL
3.1. Definitions
See chapter 1 for definitions
3.2. Purpose of processing
The main purposes of processing personal data are:
• Evaluation of L&D programmes;
• Conducting Assessments
Personal data will be collected through questionnaires completed by the L&D professional. No more personal data will be stored or retained than is necessary for the purpose.
3.3. Ground for processing
3.3.1. The ground for processing personal data is the consent of the L&D professional.
3.3.2 The L&D professional may withdraw his or her consent at any time.
3.4. Recipients of personal data
Personal data of the L&D professional will only be provided to L&D programme manager, the L&D professional's Client and the Client's respondents.
3.5. Rights of the L&D professional
3.5.1 Right of inspection
The L&D professional has the right to examine the personal data relating to his or her person and to receive a copy thereof. He or she shall submit a written request to that effect to the officer of UNLOQ. The controller shall communicate its decision in writing to the L&D professional within four weeks of the request.
3.5.2 Right to rectification
The L&D professional may request that personal data relating to him or her be corrected or supplemented to rectify errors or omissions. He or she shall submit a written reasoned request to this effect to UNLOQ. UNLOQ shall communicate its decision in writing to the Client within four weeks of the request.
3.5.3. Right to oblivion
The L&D professional has the right to have the personal data erased without delay if:
• the personal data are no longer necessary for the purposes for which they were provided,
• he or she has withdrawn the consent referred to in Article 3.3.1 and there is no other legal basis for the processing;
• the personal data have been processed unlawfully; or
• personal data must be deleted to comply with a legal obligation of UNLOQ.
The L&D professional shall submit a written reasoned request to this effect to UNLOQ. UNLOQ shall communicate its decision in writing to the L&D professional within four weeks.
3.5.4. Right to restrict processing
The data subject has the right to temporary restriction of processing if:
• the accuracy of the personal data is disputed by the L&D professional;
• the processing is unlawful but the L&D professional does not require erasure of the personal data;
• UNLOQ no longer needs to have the data, but the L&D professional needs the data for a legal matter;
• The L&D professional has objected to the processing of the personal data.
The L&D professional shall submit a written reasoned request to this effect to UNLOQ. UNLOQ shall communicate its decision in writing to the L&D professional within four weeks.
3.5.5. Right to data portability
The L&D professional is entitled to obtain the personal data provided to UNLOQ in a structured, common and machine-readable form and to transfer that data to a third party without being interfered with by UNLOQ.
3.5.6 Right to file a complaint
If the L&D professional believes that the provisions of these regulations and/or the General Data Protection Regulation are not being complied with, they have the right to lodge a complaint about this with the Personal Data Authority.
3.6. Retention periods
Personal data will not be kept longer than necessary to fulfil the purposes for which they are processed. After a maximum of 100 weeks from the last login activity of the L&D professional, being the maximum period of an evaluation process, an L&D professional account is automatically deactivated.
If the L&D professional no longer wishes to use the UNLOQ Campus People Analytics within the current retention period, he or she can also manually deactivate his or her account.
3.7. Transfer of personal data
Transfer of personal data to another controller is not allowed unless the L&D professional gives his/her explicit consent.
3.8. Entry into force
These regulations enter into force on 01 December 2022.
3.9. Right to object
The L&D professional has at all times the right to object to the processing of personal data for reasons relating to his or her specific situation. He or she shall submit a written and reasoned request to this effect to UNLOQ. UNLOQ shall communicate its decision in writing to the L&D professional within four weeks of receiving the request.
4 RESPONDENT
4.1. Definitions
See chapter 1 for definitions
4.2. Purpose of processing
The main purposes of processing personal data are:
• Evaluation of L&D programmes;
• Conducting Assessments
Personal data will be collected through questionnaires completed by the L&D professional. No more personal data will be stored or retained than is necessary for the purpose.
4.3. Ground for processing
4.3.1. The ground for processing personal data is the consent of the respondent.
4.3.2 The respondent may withdraw his or her consent at any time.
4.4. The categories of personal data obtained from third parties
Annex C to these regulations lists the categories of personal data not provided by the respondent but by third parties, as well as the recipients of these data. This includes the source and purpose.
4.5. Recipients of personal data
Personal data of the respondent will be provided only to L&D programme manager and the Client of the L&D professional.
4.6. Respondent's rights
4.6.1 Right of inspection
The respondent has the right to inspect the personal data relating to his or her person and to receive a copy thereof. He or she shall submit a written request to that effect to the officer of UNLOQ. UNLOQ shall communicate its decision in writing to the respondent within four weeks of the request.
4.6.2 Right to rectification
The respondent may request that personal data relating to him or her be corrected or supplemented to rectify errors or omissions. He or she shall submit a written reasoned request to this effect to UNLOQ. UNLOQ shall communicate its decision in writing to the respondent within four weeks of the request.
4.6.3. Right to oblivion
The respondent has the right to have personal data erased without delay if:
• the personal data are no longer necessary for the purposes for which they were provided,
• he or she has withdrawn the consent referred to in Article 4.3.1 and there is no other legal basis for the processing;
• the personal data have been processed unlawfully; or
• personal data must be deleted to comply with a legal obligation of UNLOQ.
The respondent shall submit a written reasoned request to this effect to UNLOQ. UNLOQ shall communicate its decision in writing to the respondent within four weeks.
4.6.4. Right to restriction of processing
The respondent has the right to temporary restriction of processing if:
• the accuracy of the personal data is disputed by the respondent;
• the processing is unlawful but the respondent does not request erasure of the personal data;
• UNLOQ no longer needs to have the data, but the respondent still needs the data;
• The respondent objected to the processing of the personal data.
The respondent shall submit a written reasoned request to this effect to UNLOQ. UNLOQ shall communicate its decision in writing to the respondent within four weeks.
4.6.5. Right to data portability
The respondent has the right to obtain the personal data provided to UNLOQ in a structured, common and machine-readable form and to transfer that data to a third party without interference by UNLOQ.
4.6.6 Right to file a complaint
If the respondent believes that the provisions of these regulations and/or the General Data Protection Regulation are not complied with, they have the right to lodge a complaint about this with the Personal Data Authority.
4.7. Retention periods
Personal data will not be kept for longer than necessary to fulfil the purposes for which they are processed. Maximum 100 weeks after activation of a respondent account within the UNLOQ Campus People Analytics, being the maximum evaluation period of an L&D programme, the respective account is automatically deactivated. A respondent account can also be manually deactivated by the L&D professional.
4.8. Transfer of personal data
Transfer of personal data to another controller is not allowed unless the respondent gives his/her explicit consent.
4.9. Entry into force
These regulations enter into force on 01 December 2022.
4.10 Right to object
The respondent has the right at all times to object to the processing of personal data due to reasons related to his or her specific situation. He or she shall submit a written reasoned request to that effect to UNLOQ. UNLOQ shall communicate its decision in writing to the respondent within four weeks of receiving the request.
ANNEX A
Controller contact details:
UNLOQ - Stationsstraat 24-01, 5038 ED Tilburg, The Netherlands.
Data protection officer: Head of Technology
Phone: 033-247 34 28
E-mail: privacy@unloq. org
ANNEX B
Processors' contact details:
• The private company with limited liability: UNLOQ. based in Tilburg. Address: Stationsstraat 24-01, 5038 ED Tilburg, , The Netherlands.
• The private company with limited liability: True B.V., having its registered office in Amsterdam. Address: Keienbergweg 100, 1101 GH Amsterdam, , The Netherlands.
• The private company with limited liability: Mobile Tulip B.V., trading as 'MessageBird'. based in Amsterdam. Address: Baarsjesweg 285, 1058 AE Amsterdam, , The Netherlands.
ANNEX C
Personal data obtained from third parties
Goals:
A) Evaluation of L&D programmes
B) Conducting Assessments
Category Target Source Recipient
Name of respondent A + B Client Programme Manager and L&D professional
Mail address respondent A + B Client Programme Manager and L&D professional