Promaton B.V. Privacy Notice
Date Issued: 15th of May 2020
Promaton B.V. ("we", "our", "us") respects the privacy of its website visitors, business partners and all data subjects (collectively, "Users", "you", "your") whose information we process on our website and in the context of the products and services (collectively, "Services") we provided. We embrace full transparency regarding the processing of personal information, its purposes and modalities and the possibilities to exercise your data subject rights in the best possible way.
1. WHO WE ARE 2
2. WHAT PERSONAL INFORMATION DO WE COLLECT 2
3. HOW WE COLLECT PERSONAL INFORMATION 2
4. HOW WE USE YOUR PERSONAL INFORMATION 2
5. SHARING YOUR PERSONAL INFORMATION 3
6. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION 4
7. HOW WE PROTECT YOUR PERSONAL INFORMATION 4
8. WHAT ARE YOUR RIGHTS 4
10. LINKS TO OTHER WEBSITES 5
11. HOW YOU CAN CONTACT US 6
12. UPDATES TO THIS NOTICE 6
1. WHO WE ARE
We are Promaton B.V., having its registered office at Overschiestraat 182, 1062XK Amsterdam, with Dutch Chamber of Commerce registration number 68639902.
2. WHAT PERSONAL INFORMATION DO WE COLLECT
The type of personal information we collect depends on your relationship with us and the Services we deliver. To that end, we may collect the following personal information about you:
Personal contact information, for example, names, place/area of residence, e-mail addresses, phone numbers, etc.;
Diagnostic data related to our products;
User names, passwords and other login data;
Metadata or pseudonymized diagnostic data related to our products.
Personal education information, e.g. recruitment information on your professional experience, qualifications, diplomas and certificates
3. HOW WE COLLECT PERSONAL INFORMATION
We may collect personal information directly from you, for example, via our website, or in the context of the Services we deliver, or services you deliver to us.
4. HOW WE USE YOUR PERSONAL INFORMATION
Personal information we collect from you will be used for the purposes for which you have provided it and might be further used for statutory or other legit purposes only. As an example, if you make use of our service contact form on our website, we will use the information you provided in the first place to respond to your service request. We might further use that information to improve the quality of our customer service process.
Information has not been obtained from you directly will be used by us only after a careful assessment of our interests against your privacy rights. This includes a check on whether you could reasonably expect that processing of your personal data may take place in the given context.
Lawfulness of the processing is one of the main principles with regard to processing of your personal information. We rely on the following legal processing grounds for the purposes where we process your personal information:
1. Contract - processing is necessary for the performance of a contract or in order to take steps prior to entering into a contract. For example:
Administering our relationship with our business partners, such as providing and managing your access to and use of our Services.
Administering our relationship with suppliers, such as payments, providing and managing access to and use of our systems.
2. Legitimate interests - processing is necessary for the purposes of our legitimate interests - only after a careful assessment of our interests against your privacy rights has been performed. For example:
Improving our Services, e.g. training of AI algorithm.
Other general business support purposes - required for our legitimate interests - as described below.
3. Legal obligation - processing is necessary for compliance with a legal obligation to which we are subject or that is otherwise lawful under applicable data protection laws. For example:
Other general business support purposes, including but not limited to, recruitment, procurement, financial and fiscal management, risk and compliance management, and external reporting required under applicable laws.
5. SHARING YOUR PERSONAL INFORMATION
To be able to provide you the best possible Services and further our business operations, we may share certain information internally or with selected third parties. There might also be a certain statutory or legal obligation that we believe in good faith requires us to disclose your personal information externally. Categories of recipients that we might share data with include:
· Employees - for examples, for supporting the development, delivery and improvement of our Services and providing the underpinning technology;
· Service providers - for example, for service development, or managing or hosting services and/or underpinning technology for the Services we are providing;
· Business partners - to the extent they have expressed interest in or use one of the Services we provide;
· Other parties - that might be needed for external audit, compliance, risk management, corporate development and/or corporate governance related matters; or
· Governmental authorities and regulators - as required under applicable law.
Whenever we share personal information internally or with selected third parties, we have appropriate data protection and privacy safeguards in place in accordance with applicable laws.
6. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION
Your personal information will be processed to the extent and for the time necessary to achieve the purposes for which the information is collected. We are committed to the principle of storage limitation and hold your data in accordance with our data retention policy and applicable laws.
When we no longer need your personal information, or we are required by law to erase it, we will take all reasonable steps to remove it from our systems and records or take steps to properly anonymize it so that you can no longer be identified from it.
7. HOW WE PROTECT YOUR PERSONAL INFORMATION
We have put in place a robust information security policy that sets the standards across our business to keep your data safe. We take appropriate technical and organizational measures to ensure the confidentiality, integrity and availability of your personal information and the way it is processed.
8. WHAT ARE YOUR RIGHTS
We will grant your data subject rights under applicable laws, including the European data protection regulation ("GDPR"). Subject to the GDPR, these rights may include the following:
Right of access (‘getting an overview of your personal information’) - you have the right to get an overview of your personal information that we process.
Right to rectification (‘correct your personal information’) - in case your personal information is inaccurate or incomplete, you have the right to rectify or complete your personal information.
Right to erasure (‘right to be forgotten’) - under certain circumstances and to the extent permitted by applicable law, you have the right to request deletion of your personal information.
Right to data portability (‘transfer your personal information’) - under certain circumstances, you have the right to ask us to transfer your personal information directly to you. On your request, and where technically feasible, we will transfer your personal information to another party of your choice.
Right to restrict processing ('stop processing') - under certain circumstances you have the right to request restriction or ceasing of processing of the personal information we hold about you.
Right to object ('challenge to the processing') - under certain circumstances you have the right to object to the processing of your personal information. The reasons for objection should relate to your particular situation, and be related to a processing based on the legitimate interest condition. We will then no longer process the personal information, unless we can demonstrate compelling reasons otherwise.
Withdraw Consent ('stopping processing based on the processing ground of 'consent') - you have the right to withdraw your consent to the processing of your personal information based on the processing ground of 'consent' at any time.
To exercise your rights and/or for any other questions about the handling of your personal information, we refer you to the contact details of the 'How you can contact us' section below.
Cookies or similar techniques (collectively, “Cookies”) are small text files or pixels, which might be stored on your computer or mobile device. Cookies may be necessary to facilitate website browsing or making it more user-friendly. Third party Cookies may collect information to analyze personal browsing behavior.
Necessary Cookies - Necessary Cookies are required for the website to function properly, or to enable additional functionality of the website. Consent of the User is not required.
Statistical & Analytical Cookies - Statistical Cookies help website owners to understand how visitors interact with websites by collecting and reporting information at an aggregated level. Analytical Cookies might also support analytic services that help to improve the website’s functionality and user experience. Consent of the User might be required, depending on the Cookie configuration.
We use the following types of Statistical & Analytical Cookies on our website/services:
Name: Google Analytics
Provider: google- analytics.com
Used to send data to Google Analytics about the visitor's device and behaviour. Tracks the visitor across devices and marketing channels.
10. LINKS TO OTHER WEBSITES
Our websites may contain links to other third-party websites, which may have privacy notices that differ from ours. We are not responsible for the collection, processing or disclosure of personal information collected through other websites.
We are also not responsible for any information or content contained on such websites. Links to other websites are provided solely for convenience. Your usage and browsing on any such website is subject to that website’s own policies. Please review the privacy notices posted on other websites that you may access through links on our website.
11. HOW YOU CAN CONTACT US
If you have any questions about how we process your personal information or want to exercise one of your data subject rights, you can contact us by email or postal mail, using the following contact details:
Promaton B.V., att. Legal department, Overschiestraat 182, 1062XK, Amsterdam, The Netherlands, e-mail: .
In response to a request, we might ask you to verify your identity if needed, and to provide additional information that helps us to understand your request better. If we do not grant your request, whether in whole or in part, we will explain why.
If you feel we are unresponsive or you disagree with our data privacy practices, you can also file a complaint with your Dutch Data Protection Authority (Autoriteit Persoonsgegevens).
12. UPDATES TO THIS NOTICE
From time to time we may update this Privacy Notice. When making changes to this Notice, we will add a new date to the new Privacy Notice.
This version was created on 15-05-2020.