Last Modified: Jun 18, 2020
1. Who we are
- Personal data means any information relating to an identified or identifiable natural person;
- An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
- Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means.
The GDPR does not apply to anonymous information. Anonymous information is information which does not relate to an identified or identifiable natural person or to personal data rendered anonymous in such a manner that the data subject is not or no longer identifiable. This includes processing anonymous data for statistical or research purposes.
We process your personal data in a secure manner, which includes protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organizational measures.
3. Basis for processing personal data
Processing of your personal data shall only take place on one of the following lawful bases:
- You have given consent to the processing of your personal data for one or more specific purposes (see §4);
- Processing of your personal data is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
- Processing is necessary for compliance with a legal obligation to which the we are subject;
- Processing is necessary in order to protect your or another person’s vital interests;
- Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party (such as preventing fraud or direct marketing), except where such interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data.
4. Purpose(s) of processing your personal data
We cannot process your personal data without a purpose. We collect and process personal data for the following purposes:
- For the realization and performance of a contract between you and us;
- To offer you the requested services and information, tailored to your preference;
- To enable you to interact with our website features;
- To process your request, feedback or report;
- To analyze and optimize our site and services;
- To analyze the incoming and outgoing traffic (clicks) on our site;
- To conduct market research and gather information for product and service development;
- To comply with applicable laws and regulations;
- To prevent fraud or misuse of our services; and
- To cooperate with law enforcement and government agencies.
We only retain this personal data for as long as necessary for the purposes mentioned above, or to comply with statutory (storage) obligations.
5. Personal data we process
Passively provided personal data obtained through cookies and other technical information provided by you, your browser or your device.
A cookie is a small file that is being delivered to you through the pages of this site and that is being stored on your computer. The information stored on this cookie is being used by us each time you visit our site. Cookies help us to analyze the traffic to and from our site and deliver our visitors a better experience during their visit.
Please note that your consent for the placement of analytical and functional cookies is not mandatory by law, so these cookies can be placed automatically.
Withdrawing cookie consent
Types of cookies we use
- Persistent cookies – By using a persistent cookie we can recognize you when you visit our site. We use this for analytical purposes and tailoring the site to your preferences. This way you do not have to set your preferences every time you visit our site, thus saving time and making your use of our site more pleasant. These cookies can be removed through the settings of your browser.
- Session based cookies – By using a session based cookie, we can see which parts of the site you have viewed during your visit. With that information, we can optimize and adapt the site as much as possible to the surfing behavior of our visitors. These cookies are automatically deleted when you close your browser.
Cookies we use
Analytical cookies - Analytical cookies - This website uses third party analytical cookies to collect information about your visit to this site.
- Third Party Analytics by Google Analytics - A third party analytical cookie is placed by Google as part of our use of the service Google Analytics. Google may transfer this information to third parties only when required by law or in cases where third parties process the information on Google's behalf. We have no influence on this. We have not allowed Google to use the information acquired through the analytical cookies for other Google services or advertisements. The information Google collects is anonymized as much as possible. We have asked them to anonymize any IP-addresses by changing the last octet of each IP. The information is transmitted to Google and stored on its servers in the United States. Google is part of the Privacy Shield Framework, to comply with the rules of the GDPR for companies that process personal data from residents of European Union member countries and Switzerland. We have also executed a Data Processing Agreement (or Data Processing Amendment) with Google regarding their Google Analytics service. Please note that Google offers a browser Add-on which enables you opt-out of Google Analytics' use of your (personal) data. You can find the add-on here: https://tools.google.com/dlpage/gaoptout.
For an overview of cookies that are placed through our site see the table below:
|_gid||Persistent cookie||Third party analytics by Google|
|_ga||Session based cookie||Third party analytics by Google|
|_gat||Persistent cookie||Third party analytics by Google|
|_utma||Persistent cookie||Third party analytics by Google|
B. Other technical information provided by you, your browser or your device.
When you visit and interact with our site, your browser or device automatically transmits certain technical information to our website. Such information enables us to know e.g. which browser type you use, what your browser settings are, what country you are in, what your referrer is, etc. With this information we can optimize your user experience. We mainly use this information for analytical, statistical and research purposes, such as tracking referrals and incoming and outgoing traffic. We consider this data anonymous, since this information does not relate to an identified or identifiable natural person.
Actively provided personal data obtained through your interactions with us, such as using specific website features or sending (e-mail) messages.
We may temporarily process your personal data if you decide to provide this to us when using one of our website features. For example, you may voluntarily provide us with your personal data by sending us a (e-mail) message.
E-mails and other messages/mediums
The data processed by sending us an e-mail is limited to your e-mail-address, the contents of the message and the standard technical information included in e-mails. We will process whatever personal data you included in the message. However, we will only process this data to handle your request or feedback. The period for which we store any personal data in your e-mail depends on the extent of your request and our legal obligation to retain such data to comply with laws and regulations, if any. The same goes for any other messages your send to us directly via other mediums, such as Skype or social media.
Below you will find an overview of the information (including personal data) that we process, if you chose to actively provide this information to us.
|E-mails (or other messages)||Purpose of storage||Storage period|
|E-mail address and/or username/account-name||To process your request||Deleted after 5 years *|
|Personal data included in your message (if you chose to provide this to us)||To process your request||Deleted after 5 years *|
|* The extent of your request might result in a longer (or shorter) storage period. This will be communicated to you if applicable.|
6. What we do with your personal data
The passively collected, aggregated information collected through cookies is being used for market research, marketing purposes, to optimize our services and to optimize your experience on our Site.
Other personal data
Personal data you actively provided to us through your use of the site is handled to process your request, feedback or report. We do not provide third parties with your personal data, or information regarding your use of the services or site(s) accessible through our services, unless this is strictly necessary in our sole discretion, and we believe that it is reasonable to do so, including but not limited to, the following reasons:
- To satisfy any laws, regulations or legal requests for such information;
- To operate our services properly;
- To process your request;
- To protect our site’s visitors, the general public, and ourselves. We specifically reserve the right to disclose any and all information to law enforcement in the event that a crime is committed, is suspected, or if we are compelled to do so by lawful criminal, civil, or administrative process, discovery requests, subpoenas, court orders, writs, or reasonable request of authorities or persons with the reasonable power to obtain such process;
- To cooperate with law enforcement authorities, government agencies and/or private-party litigants seeking information about our users, to the extent required by applicable law and/or if we are legally advised to do so. Examples of such cooperation include but are not limited to, lawful criminal, civil, or administrative process, discovery requests, subpoenas, court orders, writs, or reasonable request of authorities or persons with the reasonable power to obtain such process.
7. What are your rights regarding our processing of your personal data?
Access, rectification, restriction and erasure
You can always send us a message to ask what personal data is stored of you or ask us to rectify, restrict or remove your personal data. Since our storage of personal data is minimal, and almost all our data is anonymized and aggregated, we cannot guarantee that we have your data on file. As explained before, when data is anonymized, it is not considered personal data.
If you sent us an e-mail, we can retrieve that e-mail if we still have it on our mailservers. If so, we cannot rectify any data in that e-mail, since e-mails cannot be changed. We can delete any e-mail on request. The same goes for messages you send us through other mediums.
Please note that we might have legitimate interests to continue processing your personal data, which override your interest, rights and freedoms regarding our processing of such data. For example, we might be obligated to continue processing your personal data for the establishment, exercise or defense of legal claims or we need to retain such data for other legal purposes. We will always inform you of this decision when you contact us with a request to exercise one of your rights stated in this section.
The data we process is minimal, and mostly aggregated and anonymized. You have the right to receive the personal data concerning you in an interoperable format, so you can transmit that data to another service provider. We cannot guarantee that we have your personal data on file and/or in an interoperable format, but we will do our best to assist you in enforcing your right regarding data portability.
As explained in our paragraph on cookies, you can withdraw consent by deleting your cookies. You can contact us with your request to withdraw consent for any personal data you provided to us via certain interactions with our site, such as using a specific website feature or sending (e-mail) messages. Please note that we may have a legal obligation to retain your personal data to comply with applicable laws and regulations.
You also have the right to lodge a complaint with a supervisory authority. We suggest that you contact the competent supervisory authority in the country of your habitual residence, place of work or place of the alleged infringement.
8. Data Security
We take your privacy seriously and therefore we have taken appropriate technical and organizational measures to prevent and minimize the risk of unauthorized or unlawful processing, inappropriate use, inaccuracy, accidental loss, destruction and/or damage of (personal) data stored on our network and systems, insofar as this is reasonably possible and expected of us.
9. Third party websites
11. Any Questions