Our
privacy policy.

We are committed to using your personal data carefully and securely, and we adhere to at least the following principles when processing personal data:

• Lawfulness, fairness, and transparency: Personal data is processed lawfully, fairly, and in a transparent manner in relation to the data subject.
• Purpose limitation: Personal data is processed only for specified, explicit, and legitimate purposes. These purposes are concrete and documented prior to processing. Personal data is not further processed in a manner that is incompatible with the purposes for which the data is collected.
• Data minimization: When processing personal data, the amount and type of data is limited to the personal data necessary for the specific purpose. The data must be adequate, relevant, and not excessive in relation to the purposes for which it was collected.
• Necessity and proportionality: The processing of personal data is carried out in the least intrusive way and is proportionate to the intended purpose.
• Correctness: Measures are taken to ensure, as far as possible, that personal data is correct and up to date.
• Integrity and confidentiality: Personal data is adequately secured in accordance with applicable security standards.
• Storage limitation: Personal data is not processed for longer than is necessary for the purposes of the processing. In any event, Adaptics complies with statutory retention periods.

• GDPR: The General Data Protection Regulation, which came into force on 25 May 2018.
• Privacy Policy: This Privacy Policy, in which we describe who we are, how and for what purposes we process your personal data, how you can exercise your privacy rights, and anything else that may be of interest for you to know.
• Personal data: Any information relating to an identified or identifiable natural person (‘data subject’).
• Data subject: The person to whom the personal data relate.
• Processing: Any operation or set of operations involving personal data, including but not limited to the collection, organization, adaptation or alteration, retrieval, consultation, use, disclosure, alignment or combination, restriction, erasure, or destruction of personal data.
• Controller: The operational management of Adaptics, i.e., the person or entity that determines, alone or jointly with others, the purposes and means of processing personal data.
• Processor: A person or entity which processes personal data on behalf of the controller.
• Special categories of personal data: Personal data which is by its very nature particularly sensitive merits specific protection, as the context of processing this data could create significant risks for the data subject. Examples include data revealing a data subject’s racial or ethnic origin and processing data concerning health. Processing is prohibited unless the GDPR allows an exception.
• Data concerning health: Personal data related to the past, current, or future physical or mental health of a natural person, including any information on, for example, a disease, disability, disease risk, medical history, clinical treatment, patient number, test results, and the physiological or biomedical state of the data subject.

Our aim is to provide our clients’ employees (or data subjects) with an understanding of their own employability and to improve this through targeted interventions. By means of a preventive medical examination, for example, data subjects can gain an insight into their own physical and mental health. We can also support them with targeted interventions such as training and coaching. Some of the services we offer include:

Preventive medical examinations (Preventief Medisch Onderzoek, PMOs)

A preventive medical examination is a tool for gaining an insight into one’s own health, lifestyle, health risks, and employability. It also gives the employer an impression of the health and employability of a group of employees (e.g., a department or a branch). If there are at least 15 participants, the employer receives an anonymized group report, the results of which cannot be traced back to any specific individual. Your personal data is therefore not shared with your employer.

A PMO consists of:

• A digital questionnaire that you can complete in your own time. The questions relate to your lifestyle, ability to work, enthusiasm, work load, mental load, and physical complaints.
• (Optional) A physical screening during which we record your biometric data, perform a visual and hearing test, measure your glucose and cholesterol levels, and perform a spirometry test. This will give you a complete picture of your vitality and health.
• (Optional) A follow-up vitality consultation with an Adaptics vitality expert.
• An individual advisory report with the results of your PMO and personalized advice on how to improve your health, lifestyle, and employability.

If a PMO is offered to you, this does not necessarily mean that there is a specific health complaint or indication of a health risk or problem. On the contrary, one of the aims of the PMO is to identify and/or prevent a risk or problem at an early stage.

Vitality coaching

Adaptics’ vitality coaching is all about awareness, change, and perseverance. Self-management and personal leadership are essential when it comes to maximizing employees’ vitality, healthy lifestyle, and sustainable employability. The coaching process enhances the employee’s general well-being, thereby improving their performance at work. The vitality coach supports, motivates, and inspires employees to develop the knowledge and skills they need to boost their own vitality, remain employable, and continue enjoying their work.

Once employees have signed up, their coaching programme begins by completing a questionnaire on the physical, mental, emotional, and spiritual aspects of their vitality. If necessary, a telephone consultation will also take place. With the help of a vitality coach, the employee defines their own specific personal goals, which are then recorded in a vitality plan. This vitality plan is the backbone of the vitality coaching programme. This is how we work together to affect lasting behavioural change. All information discussed and shared with the coach is confidential.

The coaching programme can combine different forms of coaching, such as e-coaching, telephone coaching, and face-to-face coaching. On average, a coaching programme lasts six to twelve months, during which the coaching sessions can take place at the employer’s premises or, if preferred, at an external location. By having regular contact moments between the coach and the employee, the employee is continuously motivated to (continue to) work on achieving their goals. By working closely with their coach, the employee learns to take control of their own vitality; the idea is that they will eventually be able to continue their new behaviour on their own.

Vital Scan

Vital Scan is a standardized preventive medical examination. How does it work? You fill in a validated questionnaire online. This provides an instant snapshot of your current vitality level. Based on the results, you will then receive personalized advice on how to improve your vitality – even if you do not currently fit a pre-defined risk profile. This way, we really focus on prevention. To make lasting changes to your vitality, we also offer follow-up or personalized interventions.

Would you like more information about our Vital Scan? Then check out our brochure.

Vital Cycle

We believe we can go the extra mile with your employer to really focus on prevention. We achieve this through our Vital Cycle: a short-cycle research method that enables your organization to turn insights into impact faster, easier, and at a lower cost.

A preventive medical examination, or vitality examination, is typically carried out once every three years. This allows you, as an organization, to take targeted action that is actually needed at that point in time. But what happens in the years after that? How do you monitor whether things are getting better or worse in the intervening period? And how do you get insights, tips, and advice when things start to go downhill? That’s where the Vital Cycle comes in

Would you like more information about our Vital Cycle? Then check out our brochure.

Training courses

Our training courses are designed to raise awareness and encourage personal leadership and behavioural change. When it comes to increasing vitality, there are several dials you can turn and each one acts as a catalyst for the rest. Ultimately, the more dials you turn, the greater the momentum you create. With this in mind, we offer training courses on sleep, exercise, nutrition, emotional intelligence, mental focus, personal fulfilment, stress management, personal vitality, and vital leadership.
All training courses are interactive, even transformational, and should result in practical actions and insights into how to manage your own vitality.

Consultancy

Adaptics’ employability consultants are experienced professionals who provide both tactical and strategic advice on the development and implementation of employability issues. Adaptics has many years of experience in deploying employability specialists at various organizations and in various sectors.
Adaptics, together with its sister companies, is part of the Prevermo Groep B.V. group. The Prevermo Groep B.V. is located at Kerkenbos 1075H, Nijmegen 6464 BB and is registered in the Trade Register of the Dutch Chamber of Commerce under number 57617783.

This Privacy Policy concerns Adaptics only. Within the meaning of the GDPR, we are the ‘controller’ for the personal data processing operations described in this Privacy Policy.

We receive the abovementioned categories of personal data both directly from you and, to the extent permitted by law, from third parties.

Personal data that you disclose to us directly

This includes:

• Personal data you disclose on a registration form when participating in one of our services.
• Personal data you disclose when creating an account on one of our online applications and/or other information you enter and provide when completing a questionnaire.
• Personal data you disclose when participating in a physical health test.
• Personal data you disclose when participating in any of the interventions offered by Adaptics, such as vitality coaching or training.
• Personal data you disclose in the context of, among other things, correspondence, feedback, assistance (Q&A), dispute resolution, satisfaction surveys, etc.

Personal data relating to others that you disclose to us directly

You may also disclose to us personal information about other people, for example, their address or contact details. Please note that it is your responsibility to verify that these individuals consent to the disclosure of their personal data to Adaptics.

Personal data we receive from third parties

We may receive contact details (name, e-mail address, telephone number, department and, in very exceptional cases, address details) from your employer so that we can invite you to participate in a preventive medical examination (PMO), a Vital Scan, a Vital Cycle, vitality coaching, a training programme, or an inspection.

The various purposes described above are described in more detail below. We do not further process your personal data in a manner that is incompatible with the purposes for which they were collected.

To assess and improve your sustainable employability: We process the data we receive from you or your employer for the purpose of assessing and improving your vitality, health, and lifestyle (in other words, your sustainable employability).

Administration: To perform and verify the administration of Adaptics in the broadest sense.

Communication, marketing, and personalization purposes: To make (possibly personalized) promotional offers and/or to provide and exchange information about Adaptics’ activities (e.g., newsletters) – if you have actively consented to this by subscribing to our newsletter or by leaving your details on our website to download content.

Quality and management purposes: To investigate and improve the quality of services, processes, and systems, to inform the management team, and to perform internal audits or to arrange external audits.

Research purposes: In order to improve the quality of our services, personal data is processed for research purposes. Our research purposes are always compatible with the purposes for which your personal data was collected by Adaptics.

Adaptics ensures that as little personal data as possible is processed and that it is always processed in a secure manner. Adaptics may provide data to third parties for (applied) scientific research, but this data is always anonymized. This means that this data can never be traced back to an individual. The anonymization of personal data is carried out by Adaptics itself.

Benchmark: In order to improve the quality of our services, we conduct a benchmark study. This study is compatible with the purpose for which we collected your personal data.

Only anonymized data is used to compile and maintain the comparison group (benchmark). The anonymization of personal data is carried out by Adaptics itself. The benchmark helps Adaptics to determine whether the results differ from the Dutch average, so that we can provide you (on an individual level) and your employer (at company level) with better and more targeted advice.

Laws and regulations: For the purposes of identification, fraud prevention, internal controls and corporate security, and compliance with laws and regulations.

Performance of the contract: We use your personal data to the extent necessary to perform the contract you have entered into with us. Take the contract with your employer, for example. In some cases, it may be necessary to process your personal data in order to invite you to use our services.

Legal obligation: We also use your personal data to the extent necessary to comply with legal obligations imposed on us. Examples include the Arbeidsomstandighedenwet (Working Conditions Act), the Wet op de Geneeskundige Behandelovereenkomst (Medical Treatment Contracts Act (WGBO)), legally required medical examinations or tax laws, and our administrative obligations arising therefrom.

Legitimate interest: We also use your personal data to the extent necessary to pursue our legitimate interests. You can read more about our legitimate interests in the section below.

Consent: With your consent, we may use your personal data to perform a preventive medical examination (PMO), a Vital Scan, a Vital Cycle, vitality coaching, or a training programme. Of course, you can withdraw your consent at any time. In all cases, the data subject’s consent must be given freely, specifically, in an informed manner, and unambiguously. You can read how to do this under ‘Can you withdraw your consent later on?’

Wherever possible, we will apply and incorporate opt-out mechanisms in our communications. This makes it easy for you to let us know if you no longer wish to receive communications from us. Alternatively, you can always contact us for this purpose at kwaliteit@adaptics.nl.

Your personal data may be received by the following categories of recipients:

Companies in our corporate group: We may share personal data with other companies in our group in order to jointly provide content and products and/or services (such as registration and customer support) for a compatible purpose, to assist in the development of products, websites, applications, services, tools, and communications, and to prevent, detect, and investigate potentially illegal activities, violations of our policies, fraud, and/or data security breaches.

Authorities: For example, regulators, tax authorities, police, and other legal authorities. We may disclose your personal data:

• to comply with legal obligations or a court order;
• where this is necessary for the prevention, detection, or investigation of criminal offences (such as fraud, deception, or prosecution); or
• if it is necessary to enforce our policies or protect the rights and freedoms of others.

Business service providers: For example, a mail-order company we use to deliver confidential information to you, or an organization we use to provide customer services.

Suppliers and processors: We share personal data with suppliers who process personal data on behalf of Adaptics. This means that these suppliers process data for us under our responsibility. We ensure that clear agreements are in place with such suppliers and/or processors as required by the GDPR.

Other: Any third party for whom we have obtained your consent to share your personal data (e.g., as part of a partnership) and/or of which Adaptics is now or may become a part as a result of a reorganization, merger, or acquisition.

Only those employees whose roles and responsibilities are directly or indirectly related to the performance of Adaptics’ contractually agreed services have access to your data. Employees only have access to those parts of the data that they need in order to perform their duties properly.

Adaptics’ professionals and employees supervised by them who are directly involved in the provision of treatment or guidance have access to medical records; employers, supervisors, and case managers do not have access to medical records. Individual results will never be shared with your employer.

At the end of a retention period, your personal data will be erased or its identifying characteristics removed. We have defined the maximum retention period for each type of personal data in our Retention Period Policy. If there is a legal retention obligation that exceeds the maximum retention period specified by us, the legal retention obligation will take precedence.

Below, we briefly explain the most relevant retention periods.

• We retain personal data that we collect and which forms part of the medical records for at least 20 years or for as long as is reasonable in the context of good medical practice. In the case of an occupational disease, the retention period may extend to (or more than) 40 years.
• Personal data that we collect from our employees in the context of an employment contract will, in principle, not be kept for longer than two years after the employment relationship with the employee concerned has ended.
  This does not apply if the personal data is relevant for tax purposes* or if, at the end of this period, there is an ongoing dispute/claim or ongoing limitation periods for claims arising from obligations. The relevant data is then kept for longer, until the moment of settlement or expiry of the dispute/claim/existing limitation period.
• Personal data that we collect from self-employed persons in the context of an agreement to perform professional services will, in principle, not be kept for longer than two years after this agreement with the self-employed person concerned has ended.
  This does not apply if the personal data is relevant for tax purposes* or if, at the end of this period, there is an ongoing dispute/claim or ongoing limitation periods for claims arising from obligations. The relevant data is then kept for longer, until the moment of settlement or expiry of the dispute/claim/existing limitation period.
• *We retain personal data stated on, for example, invoices, pay slips, employment contracts, and other documents from our records that are relevant for tax purposes for at least seven years from the first financial year following the end of the financial year in which the invoice was paid.

Timeframes

We aim to respond to your request to exercise your right(s) within one calendar month. If we are unable to do so within one calendar month, we will notify you of the reason for the delay within the same month. Please note that Adaptics may ask for additional information to verify your identity. We may extend our response period by two calendar months, provided that we can justify this based on the complexity of your request(s) and/or the number of requests you have submitted.

Costs

In principle, we will provide the requested information and respond to requests to exercise your right(s) free of charge. In some cases, follow-up requests may involve administrative costs. For example, if you request several copies of the same information.

Refusal to cooperate with your request

We will only refuse a request in very exceptional circumstances: if the request is manifestly unfounded or excessive.

A request is manifestly unfounded if the conditions for a request are not met, or if you request information outside the scope of the GDPR (for example, if you request access to another person’s personal data). A request is considered excessive if it places a very disproportionate burden on us, for example, if you request your records on a weekly basis. We bear the burden of proof to show that the request is manifestly unfounded or excessive.

Your right to access, rectify, and/or erase your personal data

If you have your own account with us through an Adaptics online application, you have access to your registered personal data. You can rectify or erase some data yourself at any time; for example, you can edit your account details and personal information.

If you wish to access the personal data that we hold about you and/or to rectify or erase data (where permitted) that you cannot amend yourself, please contact us at kwaliteit@adaptics.nl.

We will rectify or erase your personal data if it is factually inaccurate, incomplete for or irrelevant to the processing purpose, or otherwise in violation of a legal requirement. The right to erase your personal data or have your personal data erased is not absolute. We will assess requests for erasure against other (fundamental) rights and interests on a case-by-case basis.

We will inform third parties to whom this data has been disclosed of a rectification, the erasure of personal data, or a restriction of processing. We are not required to inform these parties if this proves impossible or would require a disproportionate effort (in terms of cost and time). You may request from us a statement of the party or parties to whom we have issued this notice.

Your right to restriction of processing and your right to data portability

To exercise your right to restrict the processing of your personal data and your right to transfer your personal data (data portability), you may also send your request to kwaliteit@adaptics.nl.

The right to restrict the processing of your personal data means marking stored personal data with the aim of restricting its processing in the future. In short, the processing of personal data will be temporarily frozen pending resolution of an objection or dispute.

During this period, we will only process such personal data:

• with your consent;
• for the establishment, exercise, or defence of legal claims;
• to protect the rights of others or for important reasons of public interest for the European Union or a Member State.

The right to data portability gives you the right to obtain your personal data that you have provided to us and then to transfer that data to another controller (other than Adaptics). This right only applies where the processing is based on your consent (whether explicit or not) or is necessary for the performance of a contract.

Your right to object

To exercise your right to object, you can also contact kwaliteit@adaptics.nl.

You can exercise your right to object in three situations:

• Firstly, you can object to us processing your personal data in relation to your personal circumstances. The processing must then be based on the pursuit of our legitimate interest or that of a third party to whom the data is disclosed. We will cease processing unless there are compelling, legitimate grounds which render our processing interest greater than your interest in the ceasing of the processing.
• Secondly, you may object to the processing of your personal data for direct marketing purposes. We will always comply with such a request.
• Thirdly, you may object to the processing of your data for scientific or historical research or for statistical purposes on grounds specific to your situation. We will always comply with such an objection.

You can notify us of the withdrawal of your consent by e-mail [kwaliteit@adaptics.nl] or by post.

If Adaptics refuses to comply with a request from a data subject, Adaptics will inform them of the reasons. If the data subject is unable to accept these reasons, they are free to lodge a complaint. In this case, the following procedure applies:

• The data subject can contact Adaptics again.
• Adaptics will then register a complaint.
• The complaint will be dealt with as soon as possible, but within one month at the latest.
• In the event of a privacy-related complaint, Adaptics is obliged to seek the advice of the DPO.
• If Adaptics is unable to resolve the complaint to the satisfaction of the data subject, the data subject may lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).
• The data subject also has the option of enforcing their request in court.

Where it is necessary for us to collect your personal data, we will inform you accordingly. If you choose not to provide the personal data requested, we will not be able to enter into the relevant contract or to provide the relevant service.