You share all kinds of personal data with powerUp without noticing it. We naturally handle
this data carefully. This statement provides information on how powerUp approaches processing your personal
data. This is clarified through examples that make it easier to understand. If you have any questions about
this Privacy Statement, please contact us: firstname.lastname@example.org In this privacy statement we will use
terms. Below is an explanation of those terms.
Information that says something directly or indirectly about you is referred to as personal data. Examples
include your name and email address, or telephone number. Information relating to a legal entity is not
personal data, but information relating to a legal entity’s contact person or representative does count as
Processing means anything that can be done with personal data. This includes the collection, storage, use,
transfer and removal of data.
1. Whose personal data does powerUp process?
We process personal data if we have, want to have, or have had a business relationship with you, or if we have
had contact with you.
The people whose personal data we process include:
People who show an interest in powerUp or our products and services
People who are connected in another way with a business or organisation with which we have, want to have, or
have had a business relationship, such as third-party participants, potential clients.
2. Who is responsible for the processing of your personal data?
This privacy statement considers the processing of personal data by powerUp. Data may be shared within oneUp to
the extent that this is permitted by law. When sharing data within oneUp, we comply with the rules that we have
agreed within oneUp, the oneUp Privacy Codes. These rules describe how the divisions of oneUp deal with personal
3. Which personal data does powerUp process?
powerUp processes names, email addresses and phone numbers.
4. How does powerUp come by your personal data?
We receive your personal data because you provide it to us yourself. Example: data you send to us in order that
we can contact you or register an account.
5. For which purposes, and on what basis, does powerUp process personal data?
The purposes for which we process personal data are described below. In addition, we indicate the basis on
which this processing is done. By law, every personal data processing operation must have a legal basis.
a. To enter into a business relationship and agreement with you
We need to have your personal data if you want to apply to our services, become a client, or if you want to use
if you want to login on our website, we have to process your data.
For the most part, we process your personal data because this is necessary to conclude the agreement. We can
also have a legitimate interest in processing your personal data for this purpose.
b. To help develop and improve products and services
In order that we can be of service to you and can innovate, we develop and improve products and services on an
We also process data when analyzing your visit to our website. We do this with the aim of improving our
We process your data because we have a legitimate interest in this. We may also ask you for your consent to
process your data for the purpose of developing and improving our products and services. If you do not give
consent for the purpose of developing and improving our products and services, this will not affect the
we provide to you. You can withdraw your consent at any time by contacting email@example.com.
c. For account management, promotional and marketing purposes
We may process your personal data for account management, promotional and marketing purposes. In doing so, we
use data we have obtained from you.
We may use your data to inform you about a product that might be of interest to you.
If you do not want us to use your data or contact you for the purpose of direct marketing or by post, e-mail
telephone, you can contact firstname.lastname@example.org.
We request your consent to process your data for promotional and marketing purposes.
d. For archiving purposes, scientific or historical research purposes or statistical purposes
We may also process your personal data if this is necessary for archiving purposes in the public interest,
scientific or historical research purposes or statistical purposes. Where possible, we will seek to anonymise
pseudonymise your data first.
When processing personal data for archiving purposes, scientific or historical research purposes or
purposes, we process the date on the basis of the legitimate interest of powerUp, the financial sector or our
clients and employees.
6. How long does powerUp keep your personal data?
We do not keep your data for any longer than necessary to fulfil the purposes for which we collected the data
the purposes for which data are reused. Once we no longer require the data for the purposes described in
sections 5 a to 5 d, we may still keep the data for archiving purposes, in the event of legal proceedings, or
for historic or scientific research purposes or statistical purposes.
7. Does powerUp use automated individual decision making including profiling?
We will only make a decision based solely on automated processing including profiling which produces legal
effects concerning you or significantly affects you, in case it is allowed by law and we have notified you. We
do not envisage that any decisions will be taken about you that produces legal effects or significantly
8. Which people at powerUp have access to your data?
Within powerUp, your personal data can be accessed only by individuals who need to have access owing to their
role and for official business purposes. All of these people are bound by a duty of confidentiality.
9. Does powerUp use personal data for any other purposes?
If we want to use information for any purpose other than the purpose for which it was obtained, we may do this
as long as the two purposes are closely related. If there is not a sufficiently strong connection between the
purpose for which we obtained the data and the new purpose, we will ask you to give your consent. If you have
given us consent you may withdraw that consent at any time. To do this, please contact
10. Does powerUp transfer your personal data to other parties and to other countries outside the EU?
a. Within powerUp and oneUp
Your personal data may be shared by divisions of oneUp, for example for the development of new products and
services. We share your data with divisions of oneUp, in which oneUp holds a majority interest, only if the
divisions comply with oneUp’s rules, as set out in the oneUp Privacy Code. The oneUp Privacy Code describes
rules that all these divisions of oneUp have to comply with. The oneUp Privacy Code guarantees adequate
protection of personal data.
b. Outside powerUp and oneUp
We may only engage parties if this is in keeping with the purpose for which we processed your personal data,
example for outsourcing and ICT. Moreover, this other party can be engaged by us only if it reaches specific
agreements with us, has demonstrably implemented appropriate security measures and guarantees that your
data will remain confidential. Your personal data may also be shared with other parties that we engage in the
course of our business or for the provision of our services.
If we transfer your data to other parties outside the European Union, we take additional measures to protect
your data. In some countries outside the European Union, the rules for protecting your data are different from
those that apply within Europe. If we make use of a third party located outside the European Union, and if the
European Commission believes that the country in which this third party is located does not offer adequate
protection in the area of personal data processing, we will only transfer your data if other, suitable
guarantees are in place, such as the contractual arrangement approved by the European Commission, or on the
basis of the Privacy Shield (United States).
11. What rights do you have concerning your personal data held by powerUp?
a. right of information
This privacy statement describes what powerUp does with your data. In certain cases, we provide additional or
different information. We will do this if there are other reasons for providing you with information in
to the privacy statement. We may do that by means of a letter, by leaving a message in your inbox or in
way to be determined by us.
b. right of access to and rectification of personal data
You may ask email@example.com whether we process data relating to you, and if so, which data this
that case, we can provide you with access to the data processed by us that relates to you. If you believe your
personal data has been processed incorrectly or incompletely, you may request that we change or supplement the
c. right to erasure (‘right to be forgotten’)
You may request that we erase data concerning yourself that we have recorded, for example if you object to the
processing of your personal data. Your interest must also be greater than powerUp’s interest in processing the
d. right to restriction of processing
You may request that we restrict the personal data relating to you that we process. This means that we will
process less personal data relating to you.
e. right to data portability (only applicable if the GDPR applies to the processing of your personal data)
You have the right to request that we supply you with data that you previously provided to powerUp in the
context of a contract with us or with your consent, in a structured, machine-readable format, or that we
transfer such data to another party. If you ask us to transfer data directly to another party, we can do this
only if this is technically feasible.
f. right to object to processing based on a legitimate interest
If we process your data because we have a legitimate interest in doing so you may object to this. In that
we will reassess whether it is indeed the case that your data can no longer be used for that purpose. We will
stop processing your data if your interest outweighs our interest. We will inform you of our decision, stating
g. right to object to direct marketing
You have the right to request that we stop using your data for direct marketing purposes. It may be the case
that your objection relates to being approached through a specific channel, for example if you no longer wish
be contacted by telephone but still want to receive our newsletters. We will then take steps to ensure you are
no longer contacted through the relevant channel.
If you make a request as described above, we will respond no later than one month after we receive your
You may send your request to your firstname.lastname@example.org. We may ask you to explain your request for access
detail. In very specific cases, we may extend this period in which we must respond to a maximum of three
In that case, we will keep you informed about the progress made with your request. If you make a request, we
ask you to provide proof of your identity. For example, if you submit a request to exercise your right of
or right to data portability, we will want to be certain that we provide your personal data to the right
In that case, we will ask you to come to our office so that you can make your identity known and we can verify
your identity. In some cases, there may be doubts as to whether we can send you the data securely. If so, we
ask you to come to our office to collect your data. In certain cases, we may not be able to comply with your
request, for example because this would violate the rights of others, would be against the law or is not
permitted by the police, or another public authority, or because we have weighed up the relevant interests and
determined that the interests of powerUp or others in processing the data take precedence. In that case, we
inform you. If we adjust your data or erase your data at your request, we will notify you of this and also
inform the recipients of your data wherever possible.
12. Who can you contact if you have a question or complaint concerning personal data held by powerUp?
If you have any questions concerning the processing of personal data by us, please contact
13. Can powerUp change this privacy statement?
Yes, our privacy statement may change from time to time. We will adjust the privacy statement when new data
processing operations are introduced. If these changes are also relevant for you, we will draw your attention
these changes or clearly communicate them to you. The most recent version of the powerUp privacy statement is
always made available online at https://www.powerupinnovation.com/privacy
You can also view
previous versions on our