Version 1.0 – effective 15 October 2026
1. Who we are
This Privacy Policy explains how THNDR B.V., Parklaan 2, 1406 KL Bussum, the Netherlands, Chamber of Commerce number 88527417 ("THNDR" or the "Company", "we", "us"), processes personal data in connection with the BCS platform ("BCS"). For questions about privacy, contact us at mail@thndr.agency.
2. Our role
- Account and usage data. For the personal data we need to provide and secure BCS (such as your account details and log data), the Company is the controller under the General Data Protection Regulation (GDPR).
- Content. Content that your Organisation uploads or enters in BCS may contain personal data, for example of clients, employees or candidates. We process this data on behalf of your Organisation, which is the controller; we act as processor under a data processing agreement. Questions or requests about that data should be directed to your Organisation.
3. What data we process, why, and on what legal basis
| Purpose | Personal data | Legal basis (GDPR) | Retention |
|---|---|---|---|
| Creating and managing your account | Name, business email, Organisation, role, login credentials (hashed) | Performance of the agreement with your Organisation and our legitimate interest in providing BCS (art. 6(1)(b) and (f)) | Duration of the account + 6 months |
| Recording acceptance of the Terms | Date, time and version accepted, account ID | Legitimate interest in demonstrating acceptance (art. 6(1)(f)) | Duration of the account + 5 years |
| Providing BCS functionality | Content you enter or upload | On behalf of your Organisation (processor) | As instructed by your Organisation |
| Security, fraud prevention and troubleshooting | IP address, device and browser data, login and activity logs | Legitimate interest in securing BCS (art. 6(1)(f)) | 6 months |
| Support | Contact details, content of your support request | Legitimate interest in helping you (art. 6(1)(f)) | 12 months after the request is closed |
| Service communication | Name, business email | Legitimate interest in informing users about changes (art. 6(1)(f)) | Duration of the account |
| Complying with legal obligations | Data required by law | Legal obligation (art. 6(1)(c)) | As required by law |
4. Who we share data with
We do not sell personal data. We share personal data only with:
- your Organisation, which manages your access to BCS;
- service providers that process data on our behalf under a data processing agreement, such as hosting and infrastructure providers located within the EEA, email service providers and monitoring providers;
- authorities, where we are legally required to do so.
5. International transfers
We store personal data within the European Economic Area (EEA). If a service provider processes data outside the EEA, we ensure an adequate level of protection, for example through an adequacy decision or the European Commission's Standard Contractual Clauses.
6. Security
We take appropriate technical and organisational measures to protect personal data, including encryption in transit and at rest, access controls based on roles, logging and regular updates. No system is completely secure; please report suspected security incidents to mail@thndr.agency.
7. Cookies
BCS uses only functional cookies that are necessary for logging in and for the security of the Platform.
8. Your rights
Under the GDPR you have the right to access, rectify and erase your personal data, to restrict or object to processing, and to data portability. To exercise these rights, contact mail@thndr.agency. We will respond within one month. For Content processed on behalf of your Organisation, we will forward your request to your Organisation.
If you believe we process your personal data unlawfully, you can lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or the supervisory authority in your country.
9. Changes
We may update this Privacy Policy. We will inform you of material changes in BCS before they take effect. The current version is always available at /privacy.
10. Contact
THNDR B.V. · Parklaan 2, 1406 KL Bussum, the Netherlands · mail@thndr.agency