Privacy Policy - SpacetoGrow

Who we are

Space to Grow helps organisations see how they really function. We do that with the Growth Compass (for the organisation), the Human Compass (for the individual) and the Match Compass (person and role). To do this we work with personal data, and some of it is personal: how someone naturally works and what drives them. We handle that data with care.

This statement covers participants in our Compasses, clients and their contacts, visitors to spacetogrow.nl, and anyone who contacts us or books a conversation.

Controller: SpaceToGrow B.V., Dutch Chamber of Commerce (KvK) 96654511. Your privacy contact is Isabella Becker, at privacy@spacetogrow.nl.

Our starting point

We never sell your data, we don't show ads, and we only use your profile for the purpose you completed it for.

What we process

Human Compass or Match Compass: Name, email, organisation and role (if your employer invited you), your Human Compass choices, your profile and report, and notes from the feedback conversation
Growth Compass: Your answers and image choices, plus an invitation link. Your name never appears in the report
Client or contact person: Name, role, organisation, business contact details, agreements and invoicing details
Contact and booking: Name, email, phone (if given), your message and the appointment
Website visit: Technical data such as IP address, browser, device and pages visited

We don't ask for special categories of data, such as health, religion, ethnicity or political views. Please don't share these in an open answer or a message either.

Why we process it

Running your Human Compass or Match Compass, your report and feedback conversation (when you take part yourself): Contract
The same, commissioned by your employer: Your employer's legitimate interest in development, team composition and role design. Space to Grow then acts on your employer's behalf
Running the Growth Compass and the organisation report: The client's legitimate interest
Preparing, delivering and invoicing client work: Contract
Accounting and tax: Legal obligation
Staying in touch and answering questions: Legitimate interest
Improving and validating our methodology, with anonymised data only: Legitimate interest
Newsletter and insights: Consent, which you can withdraw at any time
Securing and improving the website: Legitimate interest

Who sees what

Human Compass, on your own

Only you and your Space to Grow specialist see your report. We don't share it with anyone without your consent.

Human Compass, through your employer

Your employer receives a copy of your results. The start screen tells you this before you begin. Inside your organisation, only the people guiding the process see your results, and only for the purpose agreed at the start.

Growth Compass

Your answers are reported at group level only. The report never shows who answered what. A group needs at least 5 people before we show its results.

No decisions made by a computer

A profile is the start of a conversation, not a verdict.

Research

To improve and validate the methodology, we only use data stripped of your name and anything else that could identify you. We only publish group-level figures.

Sharing

We share data only when needed: with your employer (if your employer commissioned the work), with suppliers who process data on our instructions under a data processing agreement, with certified Space to Grow specialists bound by confidentiality, when the law requires it, and with a new owner after a merger or acquisition, under the same terms. We tell you about that in advance.

We store data inside the European Economic Area (EEA). If a supplier uses a server outside the EEA, we only do so with the safeguards the GDPR requires, such as an adequacy decision, the EU-US Data Privacy Framework or the European Commission's standard contractual clauses.

Retention

Human Compass, development track: 2 years after the track ends, or sooner if you ask
Human Compass or Match Compass, recruitment: 4 weeks after the procedure ends. 1 year with your consent
Growth Compass, individual answers: 12 months after the report is delivered. After that we keep only anonymised group-level figures
Client and prospect contact details: 2 years after last contact
Invoices and accounting: 7 years (legal obligation)
Newsletter: Until you unsubscribe

Security

Data travels encrypted over the internet. Only people who need the data for their work get access, through a personal account. We make regular backups. Your invitation link is personal, so please don't share it. If a data breach occurs, we report it to the Dutch Data Protection Authority within 72 hours when required. If it puts you at high risk, we tell you directly too.

Cookies

The website uses functional cookies, which it needs to work. We also measure visits with an analytics tool, set up to protect privacy: IP addresses are shortened and no data is shared for advertising. We don't use tracking or advertising cookies, and we will ask for your consent first if that changes. Links to other websites are not covered by this statement.

Your rights

You have the right to access your data and get a copy, to correct it, to have it deleted, to restrict its use, to object (for example to processing based on legitimate interest, or to direct marketing), to take your data to another party (data portability), and to withdraw your consent.

Email privacy@spacetogrow.nl. We respond within one month. If we need to check that you are who you say you are, we do that through the email address we have for you. We don't ask for a copy of your ID. Took part through your employer? Then we work with your employer to handle your request properly. Sometimes we have to keep data longer, invoices for example. If so, we explain why.

If you're unhappy with how we handle your data, tell us first. You can also file a complaint with the Autoriteit Persoonsgegevens. Our services are for people aged 16 and over. We update this statement when our services or the law change. We tell you actively about major changes, and the latest version is always at spacetogrow.nl/privacy.