Privacy statement
This privacy statement states how the Tilburg Orientation Program (TOP) Foundation collects personal data, the purposes for which these personal data are processed, and how the data are handled. It also contains all the rights of providers of personal data. This privacy statement has been formulated in conformity with the EU’s General Data Protection Regulation.
1. Personal data
The TOP Foundation processes personal data based on contracts, permission, and legitimate interest. The TOP Foundation needs personal data to be able to provide its services to participants, TOP Mentors, and TOP Crew in and before TOP (Winter) Week. The personal data provided by participants and TOP Mentors creating a TOP account, or by TOP Crew completing a digital registration form is used for various purposes.
1.1 Providing information
The TOP Foundation sends participants, TOP Mentors, and TOP Crew information regarding TOP (Winter) Week by using the personal data provided in the TOP account.
1.2 Creating a WhatsApp group
In the weekend before the start of TOP (Winter) Week, the TOP Foundation sends names and phone numbers of participants to TOP Mentors so mentors can create a WhatsApp group. Participants are informed of this when they create a TOP account.
1.3 Registration for events
The TOP Foundation uses personal data for the registration of participants, TOP mentors, and TOP Crew to provide access to the events during TOP (Winter) Week. Creating groups of participants and TOP mentors by means of personal data is also part of the registration process.
1.4 Payment system for events
Personal data are linked to a personal RFID chip that can be used during TOP Week to make payments. The RFID chip is part of a digital, cashless payment system that is used by the TOP Foundation. The cashless payment system isn’t used during TOP Winter Week, so no personal data is linked to a RFID chip during TOP Winter Week.
1.5 Audivisual recording
The TOP Foundation makes audiovisual recordings during events of TOP (Winter) Week for reporting and promotional purposes.
2. Receivers of data
2.1 Tactile B.V.
Tactile B.V. is a company that facilitates the Introcloud application for the TOP Foundation. The TOP Foundation commissions Tactile B.V. to process the personal data of participants, TOP Mentors, and TOP Crew based on a data processing agreement. Every participant, TOP Mentor, and TOP Crew member gets a personal account in the Introcloud web application. Tactile destroys all data after three months from the end of the event. These three months are in the best interest of the participant or TOP Mentor, for getting back the money put on their account. After the expiration of these three months, it is not possible for participants to get back any money left in the account.
2.2 3WA registration system
The personal data provided when creating a TOP account is automatically stored in the 3WA registration system. The TOP Foundation and the administrator of the 3WA registration system have access to the personal data stored on the 3WA server. The data stored in 3WA is divided into three categories: personal data, addresses and places of residence, and registrations with products are kept for seven years due to the fiscal retention obligation in accordance with Dutch legislation. Account details, email addresses, and educational information are retained for three years. This is to keep participants informed of future events and for better organization of the TOP (Winter) Week. Sensitive data, such as medical information and products without prices (nutrition information, clothing sizes, etc.), are deleted after three months to protect the privacy of participants and mentors.
2.3 Tilburg University
The TOP Foundation and the Marketing and Communication department of Tilburg University send e-mails to new students to promote TOP (Winter) Week and to recruit participants. To prevent that students who already registered for TOP (Winter) Week receive these e-mails, the TOP Foundation sends a list of all registrations to the Marketing and Communication department of Tilburg University.
2.4 Study and student associations
The 3WA registration system includes an option to get more information about study associations and student associations via the TOP Foundation. If participants explicitly indicate in the 3WA registration system the wish to get more information, their personal data will be shared with the relevant parties. Furthermore, ESN Tilburg, Magister JFT, the MAK Mentorship System and IDEA will have access to the data of the mentors and participants relevant to them. These parties are responsible for the follow-up program after TOP (Winter) Week.
3. Storage period
The TOP Foundation will not store any personal data for longer than is necessary for the purposes for which the personal data are processed or for compliance with a legal obligation. Personal data such as dietary requirements and clothing sizes, that are not essential for the organization of future editions of TOP (Winter) Week, will be removed from the system after a period of two months. Other general personal data that are necessary with respect to new editions of TOP (Winter) Week, will be stored for a maximum of three years in the 3WA registration system in which the TOP account is created. The system is necessary to ensure that TOP (Winter) Week can be organized in a way that best accommodates the participants. Storing the data for these three years enables the TOP account to be used for future registration as a participant or TOP mentor. Finally, financial records are kept for seven years in accordance with the legal tax retention obligation.
4. Security
The TOP Foundation does not make any physical copies of personal data. The data are only managed in above-mentioned systems. The personal data and the applications managed by the TOP Foundation are adequately secured.
5. Rights of the data subjects
5.1 Right to access
Participants, TOP Mentors, and TOP Crew have the right to access their data stored by the TOP Foundation at all times, either by e-mail or through telephone contact. An overview of the stored data will be shared with the participant, TOP Mentor, or TOP Crew member.
5.2 Right to rectification
If data are incorrect or have changed, the data subject has the right to have them rectified by the TOP Foundation.
5.3 Right to transfer
If the data subject switches to a different party or service, the data subject has the right to have his/her data stored by the TOP Foundation transferred. The TOP Foundation must transfer all data to the other party.
5.4 Right to have data removed
The data subject has the right, at all times, to have personal data removed.
5.5 Right to lodge a complaint
Data subjects have the right to lodge a complaint with the Dutch Data Protection Authority if he/she is of the opinion that the TOP Foundation has infringed his/her rights under the Regulation.
5.6 Right to stop the data processing (objection)
Data subject have the right to ask the TOP Foundation to stop using their personal data.
6. Duties
6.1 The TOP Foundation will never share personal data with third parties other than for the purposes referred to in this privacy statement. The required data are the minimum data required for the provision of services by the TOP Foundation. If these required data are not provided, the TOP Foundation cannot offer its services.
6.2 The TOP Foundation reserves the right to share data if it is legally bound to do so or if the TOP Foundation considers it justified to do so to meet a legal request or to protect the rights, property, or security of the TOP Foundation. In doing so, the TOP Foundation will always try to respect the right to privacy of TOP participants, TOP Mentors, and TOP Crew as much as possible.
Adopted by the Board of the Tilburg Orientation Program Foundation on November 7, 2024.
