This privacy statement concerns the way in which personal data are collected and how they are handled by the Tilburg Orientation Program (TOP) Foundation, as well as the rights of providers of personal data. This privacy statement has been drawn up in accordance with the General Data Protection Regulation. 

1. Personal data 

The TOP Foundation processes personal data based on contracts, permission, and legitimate interest. The TOP Foundation needs personal data to be able to provide its services to participants, TOP Mentors, and TOP Crew in and before TOP Winter Week. The personal data provided by participants and TOP Mentors creating a TOP account, or by TOP Crew completing a digital registration form is used for various purposes. 

1.1 Providing information 
The TOP Foundation sends participants, TOP Mentors, and TOP Crew information regarding TOP Winter Week by using the personal data provided in the TOP account. 

1.2 Creating a WhatsApp group 
In the weekend before the start of TOP Winter Week, the TOP Foundation sends names and phone numbers of  participants to TOP Mentors so mentors can create a WhatsApp group. Participants are informed of this when they create a TOP account. 

1.3 Registration for events 
The TOP Foundation uses personal data for the registration of participants, mentors, and TOP Crew to provide access to the events during TOP Winter Week. Creating groups of participants and mentors by means of personal data is also part of the registration process. 

1.4 Payment system for events 
Personal data are linked to a personal RFID chip that can be used during TOP Week to make payments. The RFID chip is part of a digital, cashless payment system that is used by the TOP Foundation. The cashless payment system isn’t used during TOP Winter Week, so no personal data is linked to a RFID chip during TOP Winter Week.  

1.5 The TOP Foundation makes audiovisual recordings during TOP activities for reporting and promotional purposes. 

2. Receivers of data 

2.1 Tactile B.V. 
Tactile B.V. is a company that facilitates the Introcloud application for the TOP Foundation. The TOP Foundation commissions Tactile B.V. to process the personal data of participants, TOP Mentors, and TOP Crew based on a data processing agreement. Every participant, TOP Mentor, and TOP Crew member gets a personal account in the Introcloud web application. Tactile destroys all data when the contract expires. 

2.2 3WA Registration system 
The personal data provided when creating a TOP account is automatically stored in the 3WA registration system. The TOP Foundation and the administrator of the TOP registration system have access to the personal data stored on the 3WA server. 

2.3 SendinBlue 
The SendinBlue platform is used to provide participants and TOP Mentors with information via e-mail. SendinBlue has access to the first names and e-mail addresses of participants and TOP Mentors as soon as they are used for sending e-mails. Agreements have been set out on the use of the data in a data processing agreement with SendinBlue. 

2.4 Tilburg University 
The TOP Foundation and the Marketing and Communication department of Tilburg University send e-mails to new students to promote TOP Winter Week and to recruit participants. To prevent that students who already registered for TOP Winter Week receive these e-mails, the TOP Foundation sends a list of all registrations to the Marketing and Communication department of Tilburg University. 

2.5 Study and student associations 
The 3WA registration system included an option to get more information about study associations and student associations via the TOP Foundation. If TOP participants explicitly indicate in the 3WA registration system the wish to get more information, their personal data will be shared with the relevant parties. Furthermore, ESN Tilburg, Magister JFT, the MAK Mentorship System and IDEA will have access to the data of the mentors and participants relevant to them. These parties are responsible for the follow-up program after TOP Winter Week. 

3. Storage period 
Personal data will be stored in the 3WA registration system for a maximum period of five years after the TOP account is created. In this five-year-period, there is the possibility that the TOP account is used by the participant or mentor to reregister. 

4. Security 
The TOP Foundation does not make any physical copies of personal data. The data are only managed in above-mentioned systems. The personal data and the applications managed by the TOP Foundation are adequately secured. 

5. Rights of the data subjects 

5.1 Right to access 
Participants, TOP Mentors, and TOP Crew have the right to access their data stored by the TOP Foundation at all times, either by e-mail or through telephone contact. An overview of the stored data will be shared with the participant, TOP Mentor, or TOP Crew member. 

5.2 Right to rectification 
If data are incorrect or have changed, the data subject has the right to have them rectified by the TOP Foundation. 

5.3 Right to transfer 
If the data subject switches to a different party or service, the data subject has the right to have his/her data stored by the TOP Foundation transferred. The TOP Foundation must transfer all data to the other party. 

5.4 Right to have data removed 
The data subject has the right, at all times, to have personal data removed. 

5.5 Right to lodge a complaint 
Data subjects have the right to lodge a complaint with the Dutch Data Protection Authority if he/she is of the opinion that the TOP Foundation has infringed his/her rights under the Regulation. 

5.6 Right to stop the data processing (objection) 
Data subject have the right to ask the TOP Foundation to stop using their personal data. 

6. Duties 
The TOP Foundation will never share personal data with third parties other than for the purposes referred to in this privacy statement. The required data are the minimum data required for the provision of services by the TOP Foundation. If these required data are not provided, the TOP Foundation cannot offer its services. 
The TOP Foundation reserves the right to share data if it is legally bound to do so or if the TOP Foundation considers it justified to do so to meet a legal request or to protect the rights, property, or security of the TOP Foundation. In doing so, the TOP Foundation will always try to respect the right to privacy of TOP participants, TOP Mentors, and TOP Crew as much as possible. 

Adopted by the Board of the Tilburg Orientation Program Foundation on October 25, 2022