INTRODUCTION

Thank you for reading our Privacy Statement. We kindly request that you read it carefully so that you understand how we process your personal data.

Because JANE processes personal data, JANE is responsible for processing this data in accordance with the General Data Protection Regulation, or GDPR for short (European Regulation: 2016/679).

According to the GDPR, the processing of personal data means everything that can be done with personal data, such as: collecting, recording, organizing, storing, updating or modifying, retrieving, consulting, providing to third parties, and so on.

Data is considered personal data if someone is named or if the identity of a person can be easily traced from the data. This ‘person’ is referred to as the ‘data subject’. The GDPR distinguishes between general personal data (such as name, date of birth, and address) and special personal data (such as data relating to health, religious beliefs, sexual orientation, and the like). Special personal data is always sensitive personal data, but not all sensitive personal data is ‘special’, such as social security numbers or test results.

The GDPR stipulates what information about the processing of personal data must be provided to data subjects. This is done in this statement.

COMPANY DETAILS: VanderSchaaf Publications BV

• Address: Koningin Julianastraat 33, 6668
• Website: www.Jane.nl
• Email address: jamila@Jane.nl
• Chamber of Commerce number: 28082543
• Trade names: JANE, Jane Institute, Jane Publishing, VanderSchaaf Publications

PURPOSE STATEMENT AND EXPLANATION

With this statement, JANE provides insight into its use of personal data on www.Jane.nl and www.Jane-data.com. The privacy statement applies to everyone whose personal data is processed by JANE. JANE thereby complies with its duty to provide information under Article 13 of the GDPR and ensures that appropriate technical and organizational measures are taken (or arranged) to protect the data collected and processed.

If you have any questions, please contact us at jamila@Jane.nl.

METHOD OF DATA COLLECTION

JANE collects personal data in the following ways:

• Cookies are used to collect personal data that we use to optimize the website and for analytical purposes. For example, we collect the number of website visitors and the duration of a visit (e.g., through Google Analytics). All these statistics are anonymized.
• When you fill in a contact or registration form on the website or send us an email, the data you send us will be stored for as long as necessary to provide the service you have requested. The data will only be used for the purpose described in the form. For more information, see the rest of this statement.
• Any photos, videos, messages, and/or other expressions of those involved are or will only be posted on a JANE website after explicit permission has been given by the person(s) involved.

HOW SECURE IS MY DATA AT JANE?

We have taken measures to prevent your personal data from being stolen, lost, or otherwise processed unlawfully. For example, we use secure connections and encryption. Those who are involved by virtue of their position (and who are bound by a duty of confidentiality) and those involved can only access their data with a personal secure account.

In addition, we never disclose the personal data you provide to third parties, unless there is a legitimate reason to do so, such as your consent or a legal obligation.

JANE uses a commercial third party (supplier) to assist in processing data for the purposes stated in this privacy statement. This includes the application that enables the use of our (test) methodology and secure storage at this organization (the supplier of the application or the “processor”). This is done on our behalf and under our responsibility on the basis of an agreement.

We do not share personal data with commercial third parties for other purposes. Nor will we ever sell personal data to third parties. We also do not use this data ourselves for advertising purposes.

When international transfers are involved and personal data is transferred outside the EU, appropriate safeguards are always applied (such as SCCs or adequacy decisions).

We do not make decisions about individuals solely on the basis of automated processes such as computer programs (profiling). In all cases, someone, usually a coach, is involved in drawing and discussing conclusions based on a test for further use.

We keep a record (processing register) of the personal data we process. This ensures that we always know what data we use and why.

If we want to process personal data in new ways that could pose (significant) risks to the privacy of the data subject, we first investigate those risks. This is called a data protection impact assessment (DPIA). This allows us to take appropriate measures in advance to protect personal data and comply with the GDPR.

PARTIES INVOLVED IN JANE PROCESSES

When processing data, JANE distinguishes between two categories of persons whose data is processed. The first category consists of candidates who use the JANE testing methodology. The second category consists of coaches who guide the candidates and provide them with personal advice.

CANDIDATES

1.What data does JANE process?

When a candidate wishes to use the JANE methodology, we process:

• your first and last name;
• email address;
• your year of birth;
• your level of education (in broad categories);
• your gender (male/female/other/not specified);
• date of test administration;
• your test answers/test results;
• any email correspondence.

We use your data exclusively for:

• administering and processing the personality test;
• reporting results to the organization/coach who is guiding you through the process.

After a retention period, the data is converted in such a way that it:

• can no longer be traced back to an individual candidate (anonymized);
• but can be used for statistical, scientific, and/or quality purposes.

When anonymizing, general characteristics such as age category, education level, and gender may be used, but these results can no longer be traced back to individual persons.

2. What is the basis and purpose of data processing?

The basis for processing your data is your consent, which we may infer from your voluntary provision of your personal data on the website/web form.The purpose of the processing is to enable the use of the JANE test methodology and to provide you with test data.

3. Who receives the processed data?

At JANE, employees may only process personal data if this is necessary for the performance of their duties. Upon registration, this is the representative of JANE and the coach involved in the test. The data is consulted after the test has been taken and then possibly again only if a candidate (or coach on behalf of the candidate) requests this at a later date.

4. What is the retention period and criterion for data retention?

The GDPR does not specify retention periods, but some laws do. The retention criterion of the GDPR is that data may not be stored for longer than is necessary for the purpose for which you have made it available. Experience shows—based in part on statistical data relating to changes in job and/or employer—that there may be a need to consult test data again within five years (on average). For this reason, test data is retained for five years, unless a candidate:

• Has previously requested deletion, or;
• Has agreed to or requested longer retention.

After deletion of the personal data, only the anonymized data – for statistical, scientific, and/or quality purposes – will remain in our possession, but it will no longer be traceable to a specific person. In that case, there will no longer be any personal data as referred to in the GDPR.

Due to accounting obligations to the tax authorities, JANE retains its invoices with specifications for up to seven years after the end of the year in which this data was compiled. These invoices contain:

• Candidates’ initials and surnames;
• Year of birth (due to price differences);
• The quarter in which the tests were taken;
• Which coach was invoiced for this (and therefore had access to it) and at what price.
• This is not personal data (in terms of content); it is only created for accounting purposes.

COACHES

Coaches are professionals trained by JANE who guide candidates and provide advice on the use of (the test results of) the JANE methodology.

1. What data does JANE process?

We process:

• your initials, first name, and last name;
• your gender (male/female/other/not specified);
• business contact details/email address/telephone number;
• your involvement with candidates (active or inactive).
• What is the basis and purpose of the data processing?
• The basis for the (limited) processing of your data is the license agreement concluded by JANE with the coach.

2. Who receives the processed data?

All data processed by us is only sent to JANE. Only your contact details may be passed on to candidates on the one hand and our website and provider on the other, so that you can use the methodology and guide candidates via a unique login.

What is the retention period or criterion that JANE applies to data retention?

The retention criterion of the GDPR is that data may not be retained for longer than is necessary for the purpose for which you have made this data available. After termination of a license agreement, we will retain your contact details for:

• 7 years after the year in which the (last) invoices were sent to the coach.
• Or for as long as there is a basis for longer retention.

FOUNDATIONS

For the record. The GDPR requires justification for the processing of personal data. The GDPR refers to this as a basis and recognizes several foundations. The GDPR foundations are:

• Consent; this must be freely given and entails the right to withdraw it at any time.
• The performance of a contract;
• Legal obligation.
• A legitimate interest: e.g., storing data for longer than required by law or contrary to a request for erasure (e.g., an ongoing claim); in that case, JANE will provide a reasoned explanation;
• A vital interest: for example, in the event of an emergency, which is not really conceivable here;
• Public interest or exercise of official authority: not applicable to us.

RIGHTS OF THE PARTIES INVOLVED

As a party, you have various rights with regard to your personal data. JANE respects these rights and ensures that you can easily exercise them. These rights can be exercised as long as we process your personal data (an example of which is storage). This means that when your data is only available in anonymized form, it no longer constitutes personal data within the meaning of the GDPR, so that the rights listed below no longer apply.

These rights are:

• Right of access: you have the right to know what personal data we process about you and why.
• Right to rectification: is your data incorrect or incomplete? Then you can ask us to correct or supplement it.
• Right to request the erasure of your data (“right to be forgotten”): in certain cases, you can request us to delete your data, for example if it is no longer necessary for the purpose for which it was collected.
• Right to restriction of processing: you can ask us to temporarily stop processing your data, for example during an objection procedure.
• Right to data portability: you have the right to receive your data in a structured, commonly used, and machine-readable format so that you can transfer it to another organization.
• Right to object: you may object to certain forms of data processing, such as profiling or direct marketing.
• Right to withdraw consent: have you previously given consent for processing? If so, you can withdraw that consent at any time.

To exercise a right, please send an email to: info@Jane.nl

If you have a complaint about the use of your personal data by JANE, please contact us via the contact form on our website.

PLEASE NOTE: In all cases, JANE will first have to verify the identity of the person making the request before responding to a question or request. JANE may ask for identification for this purpose. You will then receive a response from us within one month at the latest.

Randwijk, February 2026