Privacy Statement

As a service provider, Headroom Assistance processes large amounts of data from our customers, who are using the services provided by Headroom. Our customers are invaluable to Headroom Assistance. Therefore it is extremely important to ensure careful and secure processing of our customers’ data.

Through this Privacy Statement, Headroom Assistance (“Headroom”, “we”, “our”, “us”) informs you about the way in which Headroom processes personal data of (potential) customers, business partners and website users. At Headroom Assistance, we value your privacy. If you have any questions regarding our use of your personal data, you can reach out to us via the contact details provided at the bottom of this Privacy Statement.

Who is Headroom?
Headroom’s responsibilities
What personal data does Headroom process?
Does Headroom process sensitive personal data?
Where does Headroom collect and use your personal data for?
How long does Headroom keep your personal data?
How does Headroom secure your personal data?
Does Headroom share your personal data with third parties?
Does Headroom use cookies?
What rights do you have?
How can you contact Headroom?
Data Protection Officer

Who is Headroom?

We are Headroom Assistance Inc., the platform that offers Remote Executive Assistance to Entrepreneurs & C-Suites. Headroom makes it easy to focus on what you love and do best. Let us take care of the rest.

More information about Headroom can be found on www.headroomassistance.com.

Headroom’s responsibilities

For all activities and purposes mentioned in this Privacy Statement, Headroom acts as the data controller as referred to in the EU General Data Protection Regulation 2016/679 (GDPR). We have drawn up our own general terms and conditions that are directly applicable to the customer.

What personal data does Headroom process?

Headroom processes your personal data because you use Headroom’s services and/or because you provide personal data to Headroom yourself. An overview of the personal data processed by Headroom, depending on the product or service you use and in what capacity, is provided below.

Customer

Please note that in principle, we process data about your business. Business information is not considered personal data. However, if you act as a sole trader, (some of) your business information may be qualified as personal data. Therefore, the data listed below is personal data we will process from you (especially information about the legal representatives of your company). If you use Headroom’s services as a customer, the following personal data are processed:

Your first and last name;
Your date of birth;
Your address details;
Your telephone number;
Your email address;
Your ID document details (if you are the legal representative);
Other personal data that you actively provide, for example by creating a personal environment on our website, in written correspondence and via telephone.
Your payment details (e.g. bank account number or credit card number);

Other personal data that you actively provide, for example in written correspondence or via telephone when you contact our employees.

Where does Headroom collect and use your personal data for?

If you (apply to) use Headroom’s services as a customer, your personal data are processed for the following purposes:

To assess your application;
To draft and perform the agreement;
To provide our services
To process payments after your / our customer’s approval;
To send information about your product or service and updates and/or changes to it;
To contact you in relation to your experience with our products and services and to inform you of other new or relevant Headroom products or services;
To perform analyses for statistical and scientific purposes;
To train and assess Headroom employees;
To provide support (such as via e-mail and phone);
If you use Headroom’s websites, your personal data may be processed for the following purposes (depending on where you use our websites for):
To enable you to download and use resources and whitepapers;
To analyze your behavior on Headroom’s websites in order to improve the websites and to tailor the range of products and services to your preferences and needs;
To perform analyses for statistical and scientific purposes.

Headroom processes personal data for the purposes listed above based on your consent, for the performance of a contract, to be able to provide our services, based on legal obligations, performance of tasks in the public interest and to pursue legitimate business interests. If Headroom wants to process your personal data for other purposes than described above, Headroom will only do so when we obtain your consent or when we have legitimate interests, if legally required.

If, as our customer, you withdraw your consent for marketing related purposes, we may still contact you regarding product functionality or updates, security updates, responses to customer support requests or other transactional, non-marketing/administrative related purposes.

How long does Headroom keep your personal data?

Headroom will not retain your personal data longer than the mandatory statutory period or, if such a mandatory statutory period does not apply, no longer than is strictly necessary for the realisation of the purposes for which your personal data were obtained. If you want us to delete your personal data earlier, you can send us an email to [email protected].

How does Headroom secure your personal data?

The protection of your personal data is very important to Headroom. Headroom has therefore taken various technical and organisational security measures to protect your data and to comply with applicable laws and regulations. Headroom uses, for example, file integrity monitoring, strong authentication, encrypted transfer of information, monitoring and alerting, and industry best practices for adequate encryption and system configuration.

Furthermore, organisational measures include role separation, least-privilege principles, personnel screening, strict procedures for managing adjustments, incidents, vulnerabilities and suppliers, and continuous training of our staff. The functionality of our security measures is tested periodically.

Cross-border data transfers

When providing our services, your personal data may in some cases be processed by third parties (as processor, as joint or independent controller) outside the European Economic Area (EEA). If your personal data is processed outside the EEA in a third country (a country without an adequate level of protection as indicated by the European Commission), Headroom ensures that i) the correct contract is concluded with regard to data processing (processor agreement, joint controller agreement or controller-controller provisions if desired), and ii) an appropriate transfer mechanism is in place, such as EU Standard Contract Clauses. In this way Headroom ensures that your personal data is always secured at at least the same level and that the confidentiality of your personal data is guaranteed.

Does Headroom use cookies?

Headroom uses functional, analytical and marketing cookies. A cookie is a small text file that is stored in the browser of your device such as a computer, tablet or smartphone when you first visit Headroom’s websites. On the one hand, Headroom uses cookies with a purely technical functionality. These cookies ensure that the website works properly and, for example, remembers your preferred settings, so that Headroom is able to optimize the websites. On the other hand, Headroom uses cookies that keep track of your browsing behavior so that Headroom can offer you tailor-made content and advertisements. Some cookies on Headroom’s websites are placed by third parties, for example advertisers and/or social media companies. More information about Headroom’s use of cookies can be found in our Cookie Statement.

What rights do you have?

You have the right to access, correct, erase, restrict, transfer, or object to the personal data that Headroom processes, unless Headroom cannot execute these rights based on a legal obligation or whenever exceptions apply.

How can you contact Headroom?

If you have any questions regarding our use of your personal data, you can contact us via [email protected].

Data Protection

Headroom works with an external, international operational, certified Data Protection & Compliance company.

If, in spite of the above, you suspect that your data is not properly handled, secured, has been misused or if you believe that Headroom does not adequately process your personal data, please reach out to [email protected].

Amsterdam, 01 January 2022.