Last updated: 30 May 2025
This “Privacy Policy” addresses any processing of personal data by Saga International B.V.("Saga", “us” or “we”) when you access Saga’s platforms, products, services, technologies,and websites (“Platform Services”), or social media, and portals.Saga processes personal data both as a data controller and as a data processor. ThisPrivacy Policy applies when we are the data controller and determine the purpose of theprocessing. When we act as the data processor, the relevant Service Agreement and DataProcessing Agreement apply between Saga and its customers.
Saga processes personal data related to the following data subjects:
i. Contact persons with our customers
ii. Contact persons with our suppliers and partners
iii. Users of Platform Servicesiv. Participants in seminars, courses, and other eventsv. Job candidates
vi. Individuals sending us requests or who are otherwise in contact with us
We have listed the typical purposes for our processing of personal data, the categories ofpersonal data we typically process, and the legal bases for the processing below.
When contacting a potential customer or onboarding a customer, we will register thecontact person’s details in our systems. We primarily gather the name, telephone number,and email address. The basis for this processing is outlined in GDPR Article 6 (1)(f),balancing of interests, where our interest lies in entering into an agreement with thecustomer, following up on this agreement, invoicing, and communicating with ourcustomer.
We process personal data about our contacts at suppliers and partners to manage thecontracts and relationships with these entities. We mainly process the names, phonenumbers, and email addresses of contact persons at each party. The basis for thisprocessing is outlined in GDPR Article 6 (1) (f), where our legitimate interest is in fulfillingour agreements and managing our relationships with suppliers and partners.
When you use our platform, we collect certain personal data to provide and improve ourservices. To access our services, you'll need an account. When you or your employercreates your user account, we collect personal data such as your name, email address,mobile phone number, role, language preferences, and account credentials.As you visit, use, and interact with our services, we automatically collect certain technicalinformation about your activities, which helps us understand how our platform is usedand improve your experience. Each time you visit our online services, for example, yourbrowser automatically sends us information like your IP address, browser type andsettings, the date and time of your request, and details about how you interacted with theservices. We also automatically collect information about the device you're using toaccess our online services. This includes the operating system, browser, referring pages,exit pages, and time stamps.
The specific information collected can vary depending on your device type and itssettings. Furthermore, we automatically collect information about how you use ourservices, including the features you use, actions you take, your time zone, location, datesand times of access, the amount of time spent within the services, and the types andvolumes of queries you submit.
We use various types of cookies to ensure our Platform Services functions effectively andto enhance the user experience. Essential cookies are strictly necessary for the operationof our website, enabling core functionalities such as page navigation and access tosecure areas. Without these cookies, the website cannot function properly. We also utilizeanalytics cookies to collect information about how visitors use our Platform Services, suchas which pages are most frequently visited and if they encounter any error messages.This data helps us understand website performance, identify areas for improvement, andoptimize your experience. Functional cookies allow us to remember your preferences andchoices (like your user identity and language preference) to provide a more personalizedand convenient experience on repeat visits. You can manage your cookie preferencesthrough your browser settings, though disabling certain types of cookies may impact thefunctionality and features available to you on our website. For more information about theuse of cookies see our Cookie Policy (EU).
We never collect or store any data you upload, download, or otherwise process in thePlatform Services
We organize a variety of seminars, courses, and other events for our clients, partners,students, and other interested individuals. In connection with these events, we collectand process personal data about participants, typically including their name, emailaddress, telephone number, any disclosed food allergies or other preferences, anddetails such as the company they work for.
This personal data is processed primarily to manage event registrations effectively and toaccommodate any specific dietary requirements or other preferences participants mayhave, ensuring a smooth and tailored experience. Should you choose not to provide therequested personal data, we may unfortunately be unable to process your eventregistration.
Our processing of this data is necessary for the performance of a contract with theparticipant, in accordance with Article 6(1)(b) of the GDPR. When we process sensitiveinformation, such as health data pertaining to food allergies, we will explicitly obtain your consent for this specific purpose, aligning with the requirements of Article 9(2)(a) of theGDPR.
When you submit a job application to us, we process personal data to evaluate yoursuitability for a potential position or traineeship. The personal data processed for thispurpose typically includes your CV, diplomas, application texts, certificates, and anyreferences you provide, along with any other information you choose to submit withinyour application. The inability to provide such personal data would prevent us fromassessing your application. This processing is based on Article 6(1)(b) of the GDPR, as it isnecessary to take steps at your request with a view to entering into an employmentcontract. The personal data is primarily obtained directly from you, the applicant, andfrom any references you have provided..
We also receive requests from students, representatives of businesses, public authorities,or private individuals through various channels such as email or telephone. In handlingthese requests, we may process personal data including your name, telephone number,email address, the subject matter of your request, and any other information you providein connection with it. Typically, the consequence of not providing such personal data isthat we will be unable to process and respond to your request effectively. This processingis based on a balancing of interests, in accordance with Article 6(1)(f) of the GDPR, whereour legitimate interest lies in being able to respond to and follow up on these inquiries.Should a request lead to the establishment of a client relationship or a recruitmentprocess, the personal data will then be processed in accordance with the relevantsections of this policy as outlined above.
We distribute newsletters, event invitations, and other relevant information via email tocontact persons registered in our client database and to others who have explicitlyconsented to receive such communications. Recipients of our newsletters or othercommunications can easily unsubscribe from these services at any time by using thededicated link provided within our emails. The legal basis for sending these emails tocontact persons at our existing clients is our legitimate interest in maintaining anddeveloping client relationships by providing legal news and relevant information aboutour services, as outlined in Article 6(1)(f) of the GDPR and consistent with Section 15(3) ofthe Norwegian Marketing Control Act. In other contexts not involving existing clientrelationships, our marketing communications are based on the explicit consent of theindividual concerned, in accordance with Section 15(1) of the Norwegian Marketing Actand Article 6(1)(a) of the GDPR.
We maintain pages on various social media platforms. In connection with these pages, weprocess personal data such as your name, any comments you post, your likes, or anyother information you choose to make available to us through these platforms. Thisprocessing is conducted based on a balance of interests, as per Article 6(1)(f) of the GDPR, where our legitimate interest is to effectively manage and utilize social mediapages to readily connect with customers, students, and other interested parties.When you "like" or become a member of Saga's social media profiles, your personal datawill be shared with the relevant platform. The same applies to other activities on Saga'ssocial media pages, such as content you post and posts you like. The relevant platformwill also be responsible for the personal data it collects and processes. More informationabout this processing and your rights follows from the individual platform's privacy policy.
Our suppliers, particularly platform service providers, may process personal data if suchdata is stored with them or otherwise made accessible to them. These suppliers operatestrictly under a data processing agreement and our direct instructions, ensuring they canonly use personal data for the purposes we have defined and which are detailed withinthis privacy policy.
We do not disclose personal data in any other instances or through any other meansbeyond what is described in this privacy policy, unless the client explicitly encourages orconsents to such disclosure, or if disclosure is legally mandated.
Your personal data, where we are the data controller, may also be subject to processingor storage outside the EU/EEA. In such circumstances, we guarantee that your personaldata benefits from sufficient security safeguards in line with GDPR Chapter V, typicallyachieved through the EU's standard contractual clauses for data transfers or bytransferring data to countries that have received an adequacy decision from theEuropean Commission.
We retain personal data only for as long as necessary to fulfill the purposes for which itwas collected, including for the purposes of satisfying any legal, accounting, or reportingrequirements. Upon expiry of the retention period, personal data shall be securelydeleted or anonymized. This essentially means the following:
I. Contact persons with our customers: Is retained for the duration of the activecustomer relationship, and then for 7-10 years after the relationship ends forfinancial and contractual records, or 1-3 years for general communication data notsubject to specific legal retention periods, unless consent for marketing ismaintained.
II. Contact persons with our suppliers and partners: Is retained for the duration of theactive relationship, and then for 5 years after the relationship ends for financial andcontractual records, or 1-3 years for general communication data not subject tospecific legal retention periods.
III. Users of Platform Services: Is retained as long as the account is active; upondeactivation or deletion, core account data is typically held for 30-90 days forrecovery, with transaction data related to accounting or reporting for 5 years, andanonymized usage data retained for longer periods for service improvement.
IV. Participants in seminars, courses, and other events: Data for event participants isretained for 1-3 years after the event to handle post-event queries and feedback, with financial transaction data retained for 5 years, and marketing consenthonored until withdrawn.
V. Job candidates: Personal data for unsuccessful job candidates is retained up to 1year after the recruitment process concludes, or up to 2 years with explicit consentfor future opportunities.
VI. Individuals sending us requests or who are otherwise in contact with us: Personaldata from individuals sending us requests or otherwise in contact is retained for 6months to 1 year after the inquiry is resolved, or longer if the inquiry leads to apotential business relationship.
Under prevailing data protection regulations, you possess a range of entitlementsconcerning your personal information. We have outlined these rights below for yourunderstanding. Should you wish to exercise any of these rights, please contact us.
If you have previously permitted us to send you newsletters, invitations to events, orsimilar, you have the option to revoke this consent at any time. We have implementedmechanisms, usually a link in communications, that allow you to opt out easily. Any otherinstances where you have given consent to process your personal data can also berevoked by contacting us directly
You are entitled to request access to the personal data we hold about you, provided thatthis does not conflict with our obligations of confidentiality. To safeguard againstunauthorized disclosure and ensure that personal data is provided to the correctindividual, it may be necessary for access requests to be submitted in writing or for youridentity to be verified through alternative means.
You have the prerogative to request that we rectify any inaccurate personal datapertaining to you or that we erase your personal data. While we endeavor to fulfill allrequests for data deletion whenever feasible, we may be unable to do so if compellinglegitimate grounds exist for retaining the data. An example of such a reason would be ourlegal obligation to store certain personal data for documentary purposes. Please beaware that the deletion of data related to the operation of our Platform Services mayconsequently impair our ability to provide those services to you.
In certain circumstances, you may request that we temporarily suspend the processing ofyour personal data. This may happen if you claim that your personal data is inaccurate, inwhich case you can ask for a restriction on processing while we verify its accuracyAdditionally, if the processing of your personal data is considered unlawful, you have theright to request that its processing be limited instead of having the data deleted entirely.A restriction can also be requested if we no longer need your personal data for its original purpose, or if you formally object to the processing of your personal data as described inthe following section.
You retain the right to object to the processing of your personal data for direct marketingactivities at any time. Additionally, you may object to the processing of your personal datathat is based on Article 6 (1) (e) or (f) of the GDPR, especially when such objections arebased on your specific situation. Unless we can demonstrate compelling legitimatereasons for the processing that outweigh your interests, fundamental rights, andfreedoms, or if the processing is necessary for the establishment, exercise, or defense oflegal claims, we will stop processing the personal data
In certain situations, you may have a general right to request the transfer of your personaldata to another legal entity or controller in a widely used, machine-readable format.When technically feasible, we can assist with the direct transmission of this personal datato the designated organization.
If you have any concerns or would like to file a complaint regarding our handling of yourpersonal data, please reach out. Alternatively, you can submit a formal complaint directlyto the appropriate data protection authority.
We have meticulously implemented a range of technical and organizational securitymeasures to ensure that all personal data is handled in a secure and protected manner.Our commitment involves conducting regular evaluations of the security protocols acrossall systems utilized for personal data management. Furthermore, we have establishedcontractual agreements with the suppliers of these systems, obligating them to upholdan adequate and robust level of data security
This privacy policy will undergo periodic revisions and updates. You will consistently beinformed should any substantial modifications be introduced. Where necessary, we willseek or refresh consents. The most current version of our privacy statement will alwaysbe readily accessible on our official website
Please contact us if you have any questions or wish to exercise your rights. Our contactdetails are as follows:
Saga International B.V.
CoC: 95742506
Tussen de Bogen 17
1013JB Amsterdam
The Netherlands