2. Who is responsible for the data processing?
You can always reach out to us in regard to all data privacy related questions:
Le Mirage Building 14th Floor
Vliegend Hertlaan 71
3526 KT Utrecht The Netherlands
3. What information do we collect?
Depending on the respective processing situation, we might collect and process personal data from you. Below you will find a list of the data relating to the respective processing scenario:
3.1 If you visit our website
Generally, visiting our website does not require the disclosure of your identity. However, for technical reasons, we might process the following information:
· Information on the use of our website (e.g. browser used, operating system used, referrer url, time of server request, content retrieved, duration of use);
3.2 IP address; and other technical information comparable with the previous ones.
If you contact us
You can contact us via the contact form on our website, by e-mail, telephone or in writing. When contacting us by e-mail, telephone or mail, we generally only store and process your e- mail address, telephone number, address, company and other information that you have provided to us in the course of contacting us. If you reach out to us via our contact form, we store your name, your company, your address, your telephone number and e-mail address, information relating to your inquiry and other comments you have entered in the contact form.
3.3 If you subscribe to our newsletter
Our website provides the opportunity to subscribe to our newsletter. To receive our newsletter, you are required to enter your e-mail address. It is not possible to send the newsletter without processing your e-mail address. In this context, we use your e-mail address exclusively for sending out our newsletter. In addition, we also process your family name, your first name and your company. Providing this data is voluntary and exclusively serves the purpose of being able to address you personally in the newsletter. In order to check your entitlement in regard to the submitted e-mail address, we carry out the so-called “double opt-in procedure”. After registering for the newsletter, we will first send you a confirmation email. Only after clicking on the link contained in the confirmation email we include your e-mail address in the newsletter distribution list.
4. How do we collect your personal data?
5. Why and on which legal grounds do we collect and use your personal data?
The reasons for using your personal data may differ depending on your interaction with us. Generally, we use your personal data for the following purposes and on the basis of the following legal justifications:
5.1 Performance of a contract
We process your personal data to fulfil contractual or quasi-contractual obligations or to establish a contract, for example for the provision of our services or if you contact us. The legal justification for the processing in this case is Art. 6 Para. 1 lit. b GDPR.
5.2 Legal obligations
We are obligated to retain certain information due to legal requirements, such as for tax and business regulations, for example, tax or commercial laws. The legal justification of such data processing activities is our need to comply with applicable legal obligations. The legal justification for the processing in this case is Art. 6 Para. 1 lit. c GDPR.
5.3 Legitimate interests
We also process your personal data to protect our legitimate interests, unless your interests or fundamental rights and freedoms, which require the protection of your personal data, prevail.
Subject to a balance of interests test to be made in individual cases, we regularly assume that our legitimate interests will prevail in the following processing situations, which are not exhaustively listed:
· If you visit our website;
· Optimization of our offers and services;
· Analysis of the use of our website;
· Ensuring the confidentiality and integrity of our IT systems; and
· cooperation with state authorities.
The legal justification for the processing in this case is Art. 6 Para. 1 lit. f GDPR.
If you have given us explicit consent to process your personal data, we will process your personal data within the scope and based on your consent. Your consent might refer to, for example, sending out our newsletter.
Consent is always voluntary and can be revoked at any time and without giving reasons with effect for the future. The refusal of consent or a revocation of consent will have no negative consequences for you. The legal justification for the processing in this case is Art. 6 para. 1 lit. a GDPR.
6. With whom and on which legal grounds do we share your personal data?
As required in accordance with how we use it, we will share your personal data with the
following third parties in the scenarios outlined below:
6.1 Transfer regarding the performance of a contract
We will share your personal data with third parties based on Art. 6 Para. 1 lit. b GDPR if the data transfer is necessary for the performance of a contract or a legal relationship similar to a contract. This is the case, for example, with shipping and transport service providers or payment service providers.
6.2 Transfer to data processors
We may also transfer your personal data to data processors. If we transfer your personal data to a data processor, we will always contractually ensure that the data processor will process the data only on our behalf. For this purpose, we will conclude data processing agreements pursuant to Art. 28 GDPR with our processors. Due to this contact, processors are contractually obliged, for example, to either delete or return the data at the end of the contract.
6.3 Transfer in regard to our legitimate interests
In case we are obliged to do so by law, by court order or due to an enforceable official order, we will transfer your personal data to the official bodies entitled to receive such information. The legal basis for the data transfer in this case is either Art. 6 Para. 1 lit. c or Art. 6 Para. 1 lit. f GDPR.
7. International transfer of data
In certain scenarios, we might transfer your personal data in countries located outside the European Union. This may mean that your personal information will be stored in a jurisdiction that offers a level of protection that may, in certain instances, be less protective of your personal information than the jurisdiction you are typically a resident in.
For this reason, we have entered into guarantees to ensure appropriate safeguards. If we transfer information from the European Union to third parties outside the European Union and in countries or not subject to schemes which are considered as providing for an adequate data protection standard, we will enter into contracts which are based on the EU Standard Contractual Clauses with these parties.
8. How long do we store your personal data?
We will store your personal data for as long as necessary to fulfill the purposes for which we collect the personal data in accordance with our legal obligations and legitimate business interests. The following describes the fundamental principles in regard to data retention and outlines essential retention periods that we comply with.
Generally, we keep personal data necessary for the performance of a contract for six up to ten years depending on the nature and scope of the contract in order to clarify any inquiries or claims after the expiry of the contract for compliance with statutory retention requirements, for example, tax laws.
We may retain any personal data that we deem necessary to investigate or defend claims against us, or to prosecute or bring claims against you, us, or any third party, for as long as we believe such action may be necessary.
We may retain personal data collected from you for customer service and marketing purposes, for up to six years after collection, unless you object against the procession of your personal data for this purpose or you wish the data to be deleted and there are no contractual or statutory storage obligations that prevent this request for deletion.
In regard to business correspondence or documents relevant under commercial code or tax law, statutory retention periods range from six up to ten years. This legal data retention period covers, inter alia, invoices, vendor documents, or financial statements.
We may store your device information and other technical information for up to seven days.
9. Your Rights
You have the following rights in regard to personal data that we hold:
Right of access. The right to obtain access to your personal information.
Right to rectification. The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete.
Right to erasure. The right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed.
Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information.
Right to portability. The right to portability allows you to move, copy or transfer personal information easily from one organization to another.
RIGHT TO OBJECT. YOU HAVE A RIGHT TO OBJECT TO ANY PROCESSING BASED ON OUR LEGITIMATE INTERESTS WHERE THERE ARE GROUNDS RELATING TO YOUR PARTICULAR SITUATION. YOU CAN OBJECT TO MARKETING ACTIVITIES FOR ANY REASON WHATSOEVER.
In addition to the afore listed rights, you also have the right to lodge a complaint with your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data- protection/bodies/authorities/index_en.htm.
10. Is there an obligation to provide personal data?
There is neither a contractual nor a legal obligation to provide us with your personal data for the use of our website. However, if you wish to contact us or obtain our services, certain personal information may be required so that we can process your inquiry.
11. Automated decision-making and profiling?
We do not use your personal data for automated individual decision-making or for profiling.
12. What kind of cookies do we use?
We, and our third-party partners, automatically collect certain types of usage information when you visit our website or otherwise engage with us. You can usually change the settings of your browser to modify the permissions you give to us and third parties for the storing of and gaining access to cookies on your device.
12.1 What are Cookies?
Cookies are text files, containing small amounts of information, which are downloaded to your browsing device (such as a computer, tablet, or mobile phone) when you visit a website. Cookies allow websites or ad networks to recognize a user’s internet browser. This helps websites to know if the browsing device has visited them before.
12.2 What are cookies used for?
Cookies do lots of different jobs, like helping us understand how our website is being used, letting you navigate between pages efficiently, remembering your preferences, and generally improving your browsing experience. Cookies can also help ensure marketing you see online is more relevant to you and your interests.
12.3 What types of Cookies are used on which legal grounds?
The types of cookies used on our site can generally be put into one of the following categories: strictly necessary; analytics and functionality Cookies. You can find out more about each of these cookies categories in the description below.
12.3.1 Strictly Necessary Cookies
These cookies are essential to make our website work. They enable you to move around the site and use its features. Without these cookies, services that are necessary for you to fully use our website may not be available, such as accessing certain areas of the website.
We have a legitimate interest in the use and storage of these cookies for the technically flawless and optimized provision of our service and to carry out the electronic communication process in the functions you require. This data is therefore processed on the basis of Art. 6 Para. 1 lit. f GDPR.
12.3.2 Functionality Cookies
These cookies allow us to remember the choices you make and tailor our website to provide enhanced features and content to you. For example, these cookies can be used to remember your user name, language choice, or country selection, they can also be used to remember changes you’ve made. The legal justification of these data processing activities is either performance of a contract or the balancing of interests as there is a legitimate interest in providing a better user experience through an optimized provision of our service. The data is therefore processed on the basis of Art. 6 para. 1 lit. f GDPR.
12.3.3 Analytics Cookies
These cookies collect information about how people are using our website, for example, which pages are visited the most often, how people are moving from one link to another and if a particular user experiences error messages on certain pages. All information these cookies collect is grouped together with information from other people’s use of our website. Overall, these cookies provide us with analytical information about how our site is performing and how we can improve it. With your consent, we may use analytics cookies to personalize or otherwise customize your user experience, including by arranging search results or displaying advertising messages based on your search queries, booking history, and preferences. The legal justification of such data processing is your consent pursuant to Art 6 Para 1 lit. a GDPR.
12.4 How long will cookies stay on your browsing device?
The length of time a cookie will stay on your browsing device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing the website that has set the cookie. Persistent cookies stay on your browsing device after you have finished browsing a particular website until they are deleted or until they expire. The maximum duration for analytics cookies is two years. You can delete the cookies in the security settings of your browser at any time.
12.5 Third-party tracking and analytics cookies
On our website we use the following tracking and analytics cookies:
12.5.1 Google Analytics
Your IP address transmitted by your browser as part of Google Analytics is not combined with other data from Google. We have also added the code “anonymizeIP” to Google Analytics on this website. This masks your IP address so that all data is generally collected anonymously. Only in exceptional cases is the full IP address transmitted to a Google server in the United States and shortened there.
We also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google AdWords. These features enable us to use first-party cookies and third-party cookies together to inform, optimize, and display ads based on your past visits to the Service.
For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On herehttps://tools.google.com/dlpage/gaoptout/. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.
On this website, we have integrated components of LeadBoxer. The LeadBoxer components automatically recognize and qualify companies who visit a website. The LeadBoxer component allows us to generate leads, thus qualifying potential new customers.
The operating company of LeadBoxer is LeadBoxer BV, Singel 542, 1017 AZ, Amsterdam, The Netherlands. Further information and the applicable data protection provisions of LeadBoxer may be retrieved under https://www.leadboxer.com/privacy/
13. How do we protect your information?
We have implemented appropriate technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, unauthorized change, or damage. All personal data we collect will be stored on our secure servers. All electronic transactions entered into via our website will be protected by SSL encryption technology. In addition, we are using the following technologies and services on our website in order to enhance the security of your information.