How and why does ViciousVenom collect personal data?
ViciousVenom necessarily has to collect some personal data for being able to carry out its work. For instance, ViciousVenom has to record the email addresses of its customers to be able to provide those customers with ViciousVenom software and updates. Records will also exist of other types of contacts with customers, and information on licenses and financial transactions is recorded for legal and business-maintaining reasons.
When processing personal data, ViciousVenom works as carefully as possible. An essential part of that care is transparency. ViciousVenom thinks it is important that third parties and those involved have insight into the way in which they use personal data and the underlying reasons. That is why ViciousVenom has drafted this statement. If you have any questions or comments after reading this Statement, please contact ViciousVenom. This also applies if you would like to exercise one of the rights described below or if you have a complaint. You will find the full address and the name of the contact at the bottom of this statement.
Who is ViciousVenom exactly?
ViciousVenom is registered with the Chamber of Commerce under number XXXXXXXX and is accessible by mail at email@example.com
Does ViciousVenom have a Data Protection Officer?
ViciousVenom has not appointed a Data Protection Officer. ViciousVenom did appoint partner Miss K. Chan who is the first point of contact with regard to privacy and personal data.
What kind of personal data does ViciousVenom process and why does it do that?
ViciousVenom processes different types of personal data for different reasons. The data being processed are Identification data (name, e-mail address, contact person, telephone number, Chamber of Commerce number), Location details (postal and / or branch address) and Financial data (bank account number, payment details) of our customers. The first main purpose of this processing is to create an agreement with the customer which can only happen when ViciousVenom and the customer communicate with each other. Consider, for example, the inventory of the wishes of the customer and the preparation for an offer. The second main goal is to be able to execute the agreement. Consider, for example, periodic consultation on progress. The third main objective is to enable invoicing of the work or services, as well as to facilitate payment (and, if necessary, collection). The last main goal is to inform the customer about developments that may be relevant to him or her.
May ViciousVenom process that data?
ViciousVenom processes personal data if that is necessary in order to establish or execute an agreement with a customer and / or a supplier. This is the case, for example, when a quote is requested, when an order is placed or when ViciousVenom places an order itself. Furthermore, ViciousVenom processes personal data as its own interests justify it. This will be the case if it is reasonably impossible for ViciousVenom to carry out its work without processing this data. Finally, in some cases, ViciousVenom requires (even) permission to use the data. The legal bases for processing are therefore
(i) that processing is necessary for the performance of an agreement in which the person is a party, or is made at the request of the person concerned for the conclusion of an agreement.
(ii) That processing is necessary for the representation of the legitimate interests of ViciousVenom (or a third party)
(iii) That the person concerned has given permission for the processing
With regard to category (ii), it applies in all cases to processing that is necessary for ViciousVenom to be able to realize its services. ViciousVenom simply can not do her work or can not communicate etc. without using the personal data of the customer. That is why it has a legitimate interest in those processing operations. ViciousVenom believes that this interest should be given priority when weighed against the interest of the person concerned. Reasonable are two considerations. First of all, the fact that ViciousVenom knows from experience that such processing as a rule does not encounter any objections. ViciousVenom therefore takes that as a starting point. Secondly, the fact that ViciousVenom does not store the data for longer than necessary. In order nevertheless to respect the rights of the data subject as much as possible, ViciousVenom only uses the data that are necessary to achieve the goal.
With regard to category (iii), permission given can be withdrawn at any time without giving any reason.
Do these personal data also end up with others?
ViciousVenom will in some cases share personal data with parties with which it cooperates. These are so-called 'processors'. ViciousVenom has entered into agreements with those processors. These serve to ensure that those processors (just as ViciousVenom itself) handle these data carefully. For example, this processor is obliged under the agreement to ensure proper security, to deal confidentially with those data and to destroy the data.
ViciousVenom does not intend to share personal data with parties other than processors. It provides at most that, in a single case, information will be shared with (another) employee of the customer or with parties that are in direct contact with the customer.
Will the personal data remain in Europe?
This is the context of the European Economic Area (EEA). It consists of the countries of the EU, supplemented by Norway, Liechtenstein and Iceland. All countries that fall outside it are considered to be a 'third country'. ViciousVenom does not transfer personal data to third countries. The personal data therefore remain in principle in Europe. If in an exceptional case there is still a transfer to a 'third country' then this will only happen to a country of which it has been explicitly established at European level that an appropriate level of personal data is guaranteed there.
How long do the data remain?
ViciousVenom will retain the data collected by it for different periods of time, depending on the category of data and how they have been collected. The exact deadlines are included in the register of processing activities that ViciousVenom has drawn up.
When determining the applicable terms, ViciousVenom first of all assumed legal (minimum) terms. Think of the statutory duty to keep accounting information. Furthermore, where possible ViciousVenom has sought connection with the retention periods included in the Wbp Exemption Decree. For example, with regard to the contact details of the customer, a retention period of up to one year after termination of the relationship between the parties applies. Lastly, ViciousVenom has been guided by its interests and those of its customers when setting the retention periods. For example, it can be important for both parties that documents in which (further) agreements have been recorded are retained for more than two years. If such documents (such as mail correspondence, for example) contain personal data, they will then also be retained.
What rights do I have?
According to the law, you are a 'person involved' and those involved have a number of specifically defined legal rights. You can submit a request to ViciousVenom to view, receive, change or delete your personal data. You can also object to the (further) processing of your data. If ViciousVenom processes your personal data on the basis of your consent, you can revoke that consent at any time. For all these matters and for other questions, please contact firstname.lastname@example.org. ViciousVenom will respond to your message within a month.
If you believe that ViciousVenom is acting in violation of applicable laws and regulations on personal data, you can submit a complaint to the Dutch Data Protection Authority (PO Box 93374, 2509 AJ DEN HAAG).
Is there an automated decision-making at ViciousVenom?
There is no automated decision-making at ViciousVenom.
What else do I need to know?
2. To protect your personal data, ViciousVenom has taken appropriate technical and organizational measures. A description of this is also included in the processing register. ViciousVenom periodically assesses whether these measures are still sufficient.
5. From time to time it will be necessary to change this Statement. ViciousVenom has the right to do so. We advise you to occasionally check this Statement for possible changes.
Version 18 May 2018