1. Who we are.
This policy explains how ADAPT TWINS handles personal data that we process through our website and in business contacts. The data controller is ADAPT TWINS, registered with the Dutch Chamber of Commerce (KVK) under number 93579446, with its registered address at Marnixstraat 388a, 1017 PL Amsterdam, the Netherlands. Our office is located at Meentweg 37b, 1261 XS Blaricum, the Netherlands. Questions about privacy can be sent to info@adapt-twins.com.
2. Who this policy applies to.
- visitors to adapt-twins.com;
- people who contact us, book a call or sign up for updates;
- talent who approach us about a digital twin;
- business contacts we are in touch with or reach out to.
If you work with us, for example as talent, management, a brand or a partner, you will receive additional information at the start of our collaboration about how we handle data within that collaboration.
3. What data we process.
- Website visitors. Technical data needed to make the site work, such as your IP address, browser and device. Read more in our cookie policy.
- Contact, calls and updates. Your name, email address, organization, job title and what you write to us. If you book a call, also the time and what you fill in when booking.
- Talent who approach us. Your name, contact details and what you send us, such as photos and your social media accounts.
- Business contacts. Name, job title, organization and business contact details. We receive this data from you, from your organization or from public and business sources, such as websites, LinkedIn and business databases.
4. Why we process this data.
| Purpose | Legal basis |
|---|---|
| Running and securing the website | Legitimate interest |
| Answering your question and holding a call | Legitimate interest, or steps prior to entering into a contract |
| Sending you updates | Consent |
| Website statistics | Consent |
| B2B company insights from website visits | Consent |
| Reviewing your message and, if relevant, introducing you to a partner management agency | Consent |
| Establishing and maintaining business contacts | Legitimate interest |
| Administration and invoicing | Legal obligation |
Newsletter email addresses are stored in our CRM, HubSpot (HubSpot, Inc., EU data center), to send the newsletter. The legal basis is your consent. You can unsubscribe at any time. With your analytics consent, HubSpot records page visits and may associate the visiting company based on IP address for B2B sales insights.
5. Who we share data with.
- Service providers working on our behalf, such as providers for hosting, email, appointment scheduling and customer management. We enter into data processing agreements with them.
- Google (Google Analytics), as our processor for website statistics, only if you consent to analytics cookies.
- HubSpot, Inc., with data stored in the EU data center, as our CRM processor for newsletter email addresses and, only with analytics consent, website visits and B2B company insights.
- Partner management agencies, if you approached us about a digital twin and agree that we introduce you.
- Authorities, if the law requires us to.
We do not sell your data.
6. Data outside the EU.
Some service providers, such as our appointment scheduling tool, may process data outside the EU. In that case we ensure appropriate safeguards, such as an adequacy decision or the European Commission's standard contractual clauses. Google may process data in the United States under the EU-US Data Privacy Framework and standard contractual clauses.
7. How long we keep data.
| Data | Retention period |
|---|---|
| Contact, correspondence and business contacts | Up to 2 years after the last contact |
| Updates | Until you unsubscribe |
| Messages from talent without follow-up | 6 months after review |
| Administration and invoicing | 7 years, in line with Dutch tax retention requirements |
8. Security.
We take appropriate technical and organizational measures to protect your data. Only people who need the data for their work have access to it.
9. Your rights.
You have the right to access, correct or delete your data. You can object to processing, including business contact we initiate with you. You can request restriction and data portability. You can withdraw your consent at any time. Send your request to info@adapt-twins.com. We respond within one month. If you disagree with how we handle your data, you can file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at autoriteitpersoonsgegevens.nl.
10. Age.
We work with talent aged 18 and over.
11. Changes.
We may update this policy. The date at the top shows when it was last changed.