PRIVACY POLICY
Marketing as a Service B.V.
Email address for privacy-related inquiries customersucces@hellomaas.com
- This is the Privacy Policy of Marketing as a Service B.V. (‘‘HelloMaaS’’ or ‘‘We’’) registered with Chamber of Commerce under 70663297.
This Privacy Policy is written in the English language. We do not guarantee the accuracy of any translated versions of this Privacy Policy. To the extent that any translated versions of this Privacy Policy conflict with the English language version, the English language version of this Privacy Policy shall be decisive.
As an organization, HelloMaaS processes data regarding marketing possibilities for its clients, and therefore possibly about individuals (‘‘personal data’’). Personal data is data that tells something about you as a person. In this Privacy Policy, you can read what happens to this data. HelloMaaS acts as a data controller within the meaning of the General Data Protection Regulation (‘’GDPR’’). This concerns data related to individuals who come into contact with HelloMaaS in various ways (‘‘Data subjects’’), these categories are:
- Individuals, or representatives of an potential HelloMaaS client, or a representative of an established HelloMaaS client interested in (further) products and services of HelloMaaS (‘‘Interested Parties’’);
- Individuals which are considered freelancers and use our services (‘’Freelancers’’);
- Individuals who are representatives of an HelloMaaS client, using our services on behalf of the client (‘‘Users’’);
- Individuals whom the client collects data from and who are not users themselves (“Third-Party Users”);
- Visitors to our website (‘‘Website Visitors’’);
- Individuals who are in a relationship with us or work for our partners (“Partners”);
In this Privacy Policy, we clarify, among other things:
- Which personal data we process from the different categories of individuals;
- For which purposes we process this data and on what legal basis;
- What rights these individuals have regarding the data we process about them;
- Who you can contact about this Privacy Policy and how HelloMaaS processes personal data about you.
- Data Collection: What data do we collect and for what purpose?
What does HelloMaaS do?HelloMaaS, under its marketing services, has developed HelloMaaS and Hellomarketing.ai, whereby HelloMaaS offers its business clients the opportunity to facilitate, enhance and revolutionize their marketing possibilities and techniques through subscription services and standalone solutions within Hellomarketing.ai utilizing artificial intelligence, or via the HelloMaaS platform for on-demand freelancer marketeers. To this end, it provides advice regarding marketing, marketing teams, freelancers and offers generative AI applications and adaptations that can automate and enhance the marketing process of its clients, together with AI playbooks and adaptable AI-marketing strategies. To be able to fully offer the Underlying Service, HelloMaaS engages the Supplier to develop, tailor and/or host software applications and generative AI-functionalities as requested and scheduled by HelloMaaS’ clients.
The specific tailored marketing applications and AI-generative marketing functionalities are developed by HelloMaaS in collaboration with the third parties, in such way that the third party receives a specific assignment from HelloMaaS to improve a marketing process or other essential marketing aspect based on indirectly supplied parameters and data from HelloMaaS’ clients and parameters and data directly from HelloMaas itself, and creates a sufficient AI application to those marketing processes, or provides a hosting platforms on which such AI applications can be operated.
This is what we do and, and we take pride in it. The data we collect depends on the context of the interaction with HelloMaaS, the choices you make, the choices made by our client, and the products and features utilized. For each data processing activity, we require a legal basis. The legal bases upon which HelloMaaS relies for its processing activities are outlined further in this Privacy Policy, and are contractually underlined in a data processing agreement with our client, if the situation of GDPR requires us to do so.
What information does HelloMaaS collect automatically from the data subjects?
The Services capture some information about you automatically utilizing background local storage and session storage technologies (“Cookies”). Cookies are small files or other pieces of data which are downloaded or stored on your computer or other device, that can be tied to information about your use of the Services. Examples of information of this type are your IP address, the browser you are using, the operating system you are using, the pages on the website that you visit and details of your transaction activity. When we use Cookies, we may use “session” Cookies that last until you close your browser or “persistent” Cookies that last until you or your browser delete them. You may change your browser setting to decline the use of Cookies.
We use third party analytics services, including Hubspot and Google Analytics, to help analyse how users use the Services. We use the information we get from Analytics Services only to improve our Services. The information generated by the Cookies or other technologies about your use of our Services (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ Terms of Use and Privacy Policy. By using our Service, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above.
For more information regarding how Google collects, uses and shares your information, please visit www.google.com/policies/privacy/partners/. You can deactivate Google Analytics using a browser add-on if you do not wish the analysis to take place. You can download the add-on here: https://tools.google.com/dlpage/gaoptout?hl=en.
We operate social media pages on third party networks and have social media icons on our website. When you visit or link to our social media pages, data is processed both by us and the applicable social media provider. Social media providers are unaffiliated with us, and we are not responsible for the content or privacy practices of social media providers. Social media providers have their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit their websites or interact with their platforms.
What information does HelloMaaS collect voluntarily from the data subjects?
- Concerning Interested Parties, we may process the following data:
- Contact information (name and address details, phone number, and similar data necessary for communication);
- Concerning Freelancers, we may process the following data:
- Contact information (name and address details, phone number, and similar data necessary for communication);
- Registration/Authentication data (email address and password);
- Subscription data;
- Information regarding education, work experience (c.v.) hourly rates, fixed prices packages and other sort of the relevant price-indication information;
- In some cases: a certificate of good conduct and data regarding an identity document;
- Data regarding medical conditions;
- Age and gender.
When Freelancers provide explicit consent as defined in the GDPR for categories of data which are considered to be sensitive under the GDPR, we may also process:
- Concerning Users, we process the following data:
- Contact information (name and address details, phone number, and similar data necessary for communication);
- Concerning Third-Party Users of HelloMaaS, we process the following data:
- Marketing documentation, possibly containing multiple data that is aggregated or anonymized but might indirectly identify a natural person in a specific situation when combined with other data;
- Ideal Costumer Profiles, which do not consist of personal data as defined by the GDPR, but might indirectly identify a natural person in combination with other data;
- Segmentation data, which sees to data in a broader sense but might indirectly identify a natural person when combined with other data.
- Concerning Partners, we process the following data:
- Contact information (name and address details, title, phone numbers, and similar data necessary for communication);
- Data concerning the nature and content of the current employment;
- In some cases: a certificate of good conduct and data regarding an identity document;
- Data related to electronic messages originating from or intended for Partners and data necessary for maintaining contact with these Partners.
- Concerning Website Visitors, we process the following data:
- Data related to visiting out website, such as data for the identification and communication with website visitors or data recorded to track visitor statistics on our website. We use a cookie policy to which you are referred when accessing our website.
- Concerning Interested Parties, we may process the following data:
- For what purposes do we process this data and on what legal basis?
What are the purposes of HelloMaaS’ data processing?
We process personal data for the following purposes:
- To perform and deliver our applications and services, including providing support;
- To complete purchases or transactions;
- To improve, repair, and customize our application and services;
- To understand how people use our application and services;
- To evaluate and enhance our application and services;
- To research, develop, and test new services and features;
- To conduct troubleshooting activities;
- To communicate with data subjects, including to provide status updates, transactional emails and other service communications, to provide notices about a data subject’s account and to contact them through telephone, text, email or chat, as permitted by law, and to send marketing communications;
- To enhance our security measures;
- For recruitment and selection of freelancers;
- To comply with laws and regulations to which HelloMaaS is subject and cooperate with regulators, other appropriate agencies or authorities and law enforcement bodies, both within a data subject’s jurisdiction and internationally;
- To manage and assure the integrity of our platform and services;
- To protect and defend the rights and property of our users, Client and its affiliates, and third parties; and
- For other legitimate business and lawful purposes.
HelloMaaS may obtain your written consent from time to time in electronic form by using online agreements, subscriptions or other acknowledgements on the Services, including for any other contemplated uses of your personal data not addressed in this Privacy Policy, which shall be communicated at due time. These specific uses will be elaborated upon in the agreements or subscriptions. Please read all online agreements carefully before accepting them.
We process the data mentioned above for the purposes listed above on the basis of the following legal grounds.
On which legal grounds under the GDPR does HelloMaaS base these processing activities?
- Performance of a Contract: HelloMaaS may process data when the processing is necessary for providing our applications and services, such as facilitating interactions between HelloMaaS or Freelancers, Users or Partners;
- Compliance with a Legal Obligation: HelloMaaS processes data to fulfill necessary legal obligations, such as verifying the identity of our partners and employees;
- Legitimate Interests: HelloMaaS may process data when it is necessary for the legitimate interests pursued by HelloMaaS or a third party, provided that these interests outweigh the interests or fundamental rights of the data subject. This includes using contact information for sending unsolicited commercial messages, maintaining business relationships, and improving our applications and services;
- Consent: When a data subject has given consent for the processing of certain data, HelloMaaS may rely on this consent as a legal basis. Data subjects have the right to withdraw their consent at any time, and HelloMaaS will stop processing their personal data from that moment, unless there is another legal basis for processing.
- Explicit Consent: For special categories of personal data as defined in the General Data Protection Regulation (GDPR), such as data related to medical conditions, HelloMaaS only processes them when the data subject has given explicit consent. There is a distinction between “regular” consent and “explicit” consent when the collecting of aforementioned data occurs within the jurisdiction of the GDPR. Because HelloMaaS may need to use special sensitive categories of personal data to operate its service, it may request explicit consent for processing this type of data. When doing so, this will be clearly stated in the request.
These legal bases ensure that HelloMaaS’ data processing activities are carried out in accordance with the principles of data protection and privacy under the General Data Protection Regulations (GDPR).
- With whom can we share personal data?
HelloMaaS is a provider of services headquartered in the Netherlands, and as such may need to share information with internal personnel and third party providers in different geographic locations in order to perform our Services, including without limitation our payment processors, technology providers and professional advisors. We may disclose information (within or outside your country of residence) if we have a good faith belief that disclosure is necessary by law or the legal process, to protect and defend our or others’ interests or property, or to enforce agreements you enter into with us.
The agreements you enter into with us can be, among others, to be included into the HelloMaaS freelancer pool, or, if you are a client willing to use our services, an agreement to obtain marketing strategies and revolutionize your marketing possibilities and techniques through subscription services and standalone solutions within Hellomarketing.ai utilizing artificial intelligence, in which case personal data might be provided and may be shared with our trusted third party partners for technical solutions. For this purpose, our terms & conditions provide an obligation to our clients to provide any personal data in accordance with the GDPR.
In order to transmit mobile text messages, we share information with platform providers, phone companies, and other third-party service providers who assist us in the delivery of mobile messages, when applicable and only if you have given permission for the use of your contact information. As with all information collected by HelloMaaS, we reserve the right at all times, to the extent permitted by law, to disclose any information as necessary to satisfy any law, regulation or governmental request, to avoid liability, or to protect our rights or property.
Your information may be transferred to another company (within or outside your country of residence) in the event of any reorganization, merger, sale, joint venture, assignment, transfer, liquidation or other disposition of all or any portion of our business, assets or stock with such third party. We may share aggregated and de-identified information with third parties (within or outside your country of residence) for analytical, research or other similar purposes.
Below are examples of third parties with whom we may share data.
We may share personal data about Interested Parties with:
- Partners, when it is necessary to communicate any wishes under the services;
- Others, with the consent of the data subject, or when there is a legal obligation.
We may share personal data about Freelancers with:
- Users, when it is necessary for the matching between a Freelancer and a User;
- External parties providing our competency tests, when necessary;
- Others, with the consent of the data subject, or when there is a legal obligation.
We may share personal data about Users with:
- Partners, when it is necessary to communicate specific wishes for the HelloMaaS services conducted under the agreement with a HelloMaaS client.
- Others, with the consent of the data subject, or when there is a legal obligation.
We may share personal data about Third-Party Users with:
- Partners, for the sake of providing the service under the agreement, for which the client has covered the GDPR bases;
- Others, with the consent of the data subject, or when there is a legal obligation.
We may share personal data about all data subjects with the consent of the data subject or when there is a legal obligation. When it comes to special categories of personal data as defined under the GDPR, we only do this with the explicit consent of the data subject.
- How do we protect your personal data
HelloMaaS has integrated various technical and organizational measures to protect your personal data from destruction, loss, alteration, unauthorized disclosure, or unauthorized access. These measures encompass reasonable administrative, physical, and technological safeguards. No Internet or e-mail transmission is ever fully secure or error free, however. We therefore cannot guarantee absolute security of your data, and we are not responsible for processes and networks that we do not control.
- Transfer to countries outside the EEA
It may happen that personal data is transferred to a country outside the European Economic Area (EEA) that provides a lower level of protection for personal data than the regulations within the EEA. For instance, a Supplier of online services that we use might be located outside the EEA (e.g., in the United States of America), and using that service may involve the transfer of personal data to the Supplier.
In such a situation, if personal data is transferred to a country outside the EEA with less legal protection for personal data, we will use commercially reasonable efforts to ensure appropriate safeguards are in place and to ensure that the transfer complies with applicable privacy regulations.
- How long do we retain personal data
We retain the personal data we collect for so long as reasonably necessary to fulfill the purposes for which the data was collected and to perform our contractual and legal obligations. We will retain personal data required to comply with privacy requests, to manage active accounts, as required by law, in order to resolve disputes, or to enforce our agreements. We will retain the personal data we process on behalf of our Users as directed by them. We may also retain copies of your personal data for disaster recovery purposes or for our legitimate business purposes. Notwithstanding the generality of the foregoing, we store email addresses until the user requests to be unsubscribed.
- Your rights regarding your personal data
We are committed to facilitating the exercise of your rights granted by the laws of your jurisdiction, which may include the right to request the correction, modification or deletion of your personal information and the right to opt out of the sale or sharing of your personal information (as applicable). We will do our best to honor your requests subject to any legal and contractual obligations. If you would like to make a request, please contact us at customersucces@hellomaas.com or make changes to any user profile information connected to your account.
If you are located in the European Union, the United Kingdom or another jurisdiction that has adopted laws substantially similar to the European Union’s General Data Protection Regulation (GDPR), your privacy rights include the following:
- The right to request whether personal data concerning them is being processed and, if so, to access it;
- The right to request rectification and erasure of such data;
- The right to object to processing or request restriction of processing;
- The right to withdraw consent for processing when processing is based on your consent;
- The right to receive or transmit your data to an organization of your choice in a structured, commonly used, and machine-readable format;
- Depending on your country of residence, the right to lodge a complaint with a supervisory authority responsible for enforcing data protection rules. In the Netherlands, this authority is the Autoriteit Persoonsgegevens in The Hague (www.autoriteitpersoonsgegevens.nl).HelloMaaS will handle requests related to the exercise of these rights in accordance with the regulations. These rights are not absolute; they do not apply under all circumstances, and applicable regulations provide for necessary exceptions. If we do not fulfill your request, we will explain why. If you have any questions about our use of your personal information or this Privacy Policy, please contact our complaints officer by email at customersucces@hellomaas.com.
- Contact Information
Please contact us if you have any questions about our Privacy Policy, or to exercise the rights described above, by sending an email to customersucces@hellomaas.com.
- Changes
This Privacy Policy was last updated on 30 July 2024.
If we make changes to this Privacy Policy in the future, we will publish the updated Privacy Policy on our website, along with the date the changes take effect.