Privacy Statement

At Van Es Holding B.V. including our affiliates (jointly and separately referred to as Van Es, our, us, we), we consider it important to process personal data in a careful, secure and transparent manner. In the context of our business activities, we may process your personal data. This applies to our customers, suppliers, employees, visitors of our website, business partners and all other persons and parties whose personal data we process. This Privacy Statement provides you with information about our use of personal data, our purpose for processing your personal data, how we obtain your personal data, how long we retain your personal data, how we protect your personal data and what your rights are as a data subject towards us.

This Privacy Statement may be updated from time to time. When there is an update, we will inform you thereof in this Privacy Statement. We will notify you separately of any significant changes to this Privacy Statement.

What Personal Data do we Process?

We process your personal data when you contact us or have a (potential) relationship with us. Below you find an overview of the personal data that we process from you:

• First and last name
• Address
• E-mail address
• Phone number
• Country
• Other personal data provided by you

For which purposes do we use your Personal Data?

We process your personal data solely for promoting efficient and effective business operations and more in particular, for one or more of the following purposes:

• Recruitment: recruitment & selection of new employees and candidates.
• Internal and external provision of information: this inter alia includes sending newsletters and sending information about various activities that we carry out.
• Conclusion and execution of agreements with employees, customers, consumers, suppliers and business partners: this includes the processing of personal data that is necessary to conclude an agreement and to be able to provide or receive a service.
• Customer involvement, relationship management and marketing: this includes maintaining and promoting contacts with (former) employees, customers, suppliers, business partners, consumers and account management for marketing purposes and market research.
• Health, safety and security: this includes health and safety at work, the protection of company and employee assets and the authentication of the status of employees, investigators, customers, business partners and/or suppliers and access rights.

Our Legal Ground(s) for using your Data

We only process data that is necessary for the purpose for which they were obtained. Van Es only processes personal data from you if we have lawful grounds to do so. The lawful grounds for processing your personal data depend on the type of service used. We rely upon one or more of the following legal grounds for processing your personal data:
• Consent
You have given us your consent to process your personal data for one or more specific purposes. For example, we rely on this ground to send you our newsletter after you have given us your consent to do so. You can withdraw your consent at any time by contacting us or, in case of withdrawing from our newsletter, make use of the option to opt-out in any direct marketing email we send to you. If you withdraw your consent, this will not affect the lawfulness of our use of your personal data prior to your withdrawal.
• Performance of a contract
Processing is necessary for the performance of a contract to which you are a part off or in order to take steps at your request prior to entering into a contract. For example, when you are a sponsored surgeon, we will process your personal data to e.g. complete remuneration.
• Legal obligation
Processing is necessary for compliance with a legal obligation to which we are subject. For example, we may be required to process your personal data based on an order of a competent governmental authority.
• Legitimate interests
Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of you. For example, we may rely on our legitimate interest to perform a screening as part of a due diligence.

How do we Protect your Personal Data

To protect your privacy and the confidentiality of your data, we take appropriate technical and organizational measures. We follow the Code for Information Security (ISO27001 and ISO17799). This Code describes the standards and technical and organizational measures important for realizing an adequate level of information security. It also offers the best practical method to comply with privacy legislation, such as the General Data Protection Regulation.

We take security measures to prevent misuse of and unauthorized access to personal data. Anyone who can access your personal data via Van Es has a duty of confidentiality.

The systems in which customer data are stored are only accessible for a select group of employees who require access to perform their duties.

If there is evidence or we suspect that something has gone wrong with protection your personal data, we will immediately report this to the Data Protection Authority. If the violation of your personal data may have unfavourable or adverse consequences for you, we will inform you as soon as possible.

Retention of Personal Data

We do not retain your data any longer than is necessary for the purposes for which your data are processed and legally permitted. How long certain data is retained depends on the nature of the data and the purposes for which it is processed. The retention period can therefore be different for each purpose.

Providing Personal Data to Third Parties

We explicitly do not provide your personal data to third parties unless this is necessary in the context of the execution of the agreement, in case it is legally required or if you have given us your consent. For example, such third parties include the Tax Authorities, Pension Funds, the Labour Inspectorate, and other supervisory authorities.

We may also be obliged to provide personal data to third parties based on laws or regulations, according to a judgment of a competent court, or in case of fraud or misuse. If that is the case, we will provide our cooperation.

Passing on your Data to Countries outside the European Union.
We will not pass on your personal data to any company or branch in any country outside the European Union unless a (model) agreement has been concluded or you have signed a declaration in which you have given your consent.

What do we do with your Visitor Data?

General visitor data is registered on the Van Es website, such as the most visited pages. With this data, we can further optimize the layout of our website. It can also be used to place more targeted information on the website. This allows us to improve our services further. We also register how visitors navigate through our website. This data is only stored and processed internally.

What are Your Rights?

If we process your personal data, you have certain rights that are explained below.

Right of Access to your Personal Data
Are you a Van Es customer and do you want to see what personal data is known to us? Then you can use your ‘Right of Access’. We will ask you to indicate specifically which personal data you would like to receive.

Right to Rectification
You have the right to rectify data if your data are incorrect or incomplete. You also have the right to rectify the data if the data is not relevant to how we process it or have processed your data in violation of legal regulation.

We will inform the third party/parties who have received your information of any rectification, unless this is impossible or requires disproportionate efforts.

Right to Delete Data
You have the right to request us to delete certain data. For example, if your data is no longer required for the purposes for which we received it, if you object to the processing or your data has been processed unlawfully by us. However, we cannot always erase all requested data, because we are or may be obliged to retain certain data from you.

Right to Restriction of Processing
You also have the right to restrict the processing of your data. The right to restriction means that we (temporarily) cannot process your personal data and cannot change it, for example, you dispute the correctness of the data, if you believe that the personal data are no longer necessary for the purposes, or if you believe that the processing of your personal data by us  is unlawful.

Right to Object
You can object to the processing of your personal data by Van Es if your personal data is used for purposes other than those for which you have given consent, than necessary for the execution of an agreement, than necessary for compliance with a legal obligation or one of the other lawful bases. For example, if you do not want us to use your personal data to send you personalized offers.

Right to Data Portability
If you have provided us with your personal data, you are entitled to data portability in certain cases. This means that we will provide your data to you in a structured, standard and machine-readable manner if requested by you.

How can you Exercise your Rights?

If you wish to exercise your rights, you can contact us at any time via the contact details stated below or by sending us a letter with your name, address and telephone number. No stamp is required. We will respond to your request within one month.

We ask you to identify yourself based on a valid proof of identity to check whether we provide the personal data to the right person.

Supervision of the Processing of Personal Data

If you believe that the provisions of this Privacy Statement or the General Data Protection Regulation are not or not sufficiently complied with by us, you can report this via privacy@vanesholding.com

If you suspect that we process your personal data in a manner contrary to the privacy legislation, you have the right to file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). This can be done by filling in the complaints form on their website.

Who is Responsible for the Processing of your Personal Data?

The party who is responsible for the processing of your personal data is:

Van Es Holding B.V.
Everdenberg 17
4902 TT Oosterhout
The Netherlands
+31 (0) 184 411 066

Our privacy contact person can be reached via privacy@vanesholding.com. More information about our organization can be found on our website.

About this Privacy Statement

We reserve the right to update this Privacy Statement at any time. The last change was in July 2025. The most recent version can always be found on our website.

If you have any questions or comments about our Privacy Statement, please do not hesitate to contact us via privacy@vanesholding.com.