Privacy Policy dgeGroothandel

Last updated: May 20, 2020
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.
We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

TABLE OF CONTENTS

  1. Interpretation and Definitions
  2. Collecting and Using Your Personal Data
  3. Detailed Information on the Processing of Your Personal Data
  4. Data protection provisions about Our Application dgeGroothandel and use of Google user data
  5. Data protection provisions about Our Application dgeGroothandel and use of Micrsoft user data
  6. Subscription to our newsletters
  7. GDPR Privacy
  8. Our Facebook Fan Page
  9. Children’s Privacy
  10. Other Websites and Services
  11. How “Do Not Track” requests are handled
  12. Changes to this Privacy Policy
  13. Contact Us

1. Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions.
The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.
  • Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to data group europe bv, De Weel 12, 4306 NW NIEUWERKERK (NL). For the purpose of the GDPR, the Company is the Data Controller.
  • Application means the software program provided by the Company downloaded by You on any electronic device, named “dgeGroothandel”
  • Website refers to Our web pages accessible from dgebv.nl, dgebv.io, dgedetailhandel.nl, dgegroothandel.nl and dgedataretail.nl
  • Service refers to the Applications and Websites and other digital properties provided by the Company.
  • Account means a unique account created for You to access our Service or parts of our Service.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
  • Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
  • Facebook Fan Page is a public profile named dgebv specifically created by the Company on the Facebook social network, accessible from https://www.facebook.com/dgebv/
  • Personal Data is any information that relates to an identified or identifiable individual. For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

2. Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phonenumber
  • Visiting and delivery address
  • GLN (Global Location Number)
  • KVK number (Chamber of Commerce)
  • IP Address
  • Cookies and Usage Data

We may collect information that Your device or browser sends us whenever You visit or access Our Services, or when You interact with a Services (“Usage Data”).
This data may include, but is not limited to, information such as your computer’s Internet Protocol address (e.g. IP address), operating system version, browser type, browser version, the Property You interact with, the pages that You visit, the time and date of Your visit to those pages or Properties, the time spent on those pages or Properties, unique device identifiers, and

Cookies and Similar Tracking Technology Data

We use Cookies and similar tracking technologies, including statistical or other identification methods, to track the activity and to provide Our Service to You. Cookies may be set by the Service that you are visiting (known as “first party cookies”), or by third-parties, such as those who serve content or provide advertising or analytics services on Our Services (“third party cookies”). Other tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve, analyze and deliver Our Service.
You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Services.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
  • To contact You: To contact You by email, phone or other equivalent forms of electronic communication, such as application’s notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.

We may share your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to show advertisements to You to help support and maintain Our Service, to contact You.
  • For Business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
  • With Business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
  • With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

3. Detailed Information on the Processing of Your Personal Data

Service Providers have access to Your Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network. You may opt-out of certain Google Analytics features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy?hl=en For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Windev Telemetry

Windev Telemetry tracks how many users are using a particular version of our Application. It helps us to put the number of crash reports in relation to the usage of a particular version. Furthermore, we use Windev Telemetry to anonymously track the usage of our apps and its features. Windev Telemetry does not collect any Personal Identifiable Information (PII). Our Telemetry server is located in The Netherlands and operate under https://www.transip.eu/legal-and-security/terms-and-conditions/ .

Loggly

With Loggly we collect key figures of EDI services used with our Application. It gives us insight into the use of the EDI services. With Loggly we do not collect any Personal Identifiable Information (PII). The Loggly servers operate under https://www.loggly.com/about/privacy-policy/.

EDI services

We may share Your Personal Data with suppliers using the electronic catalogue dgeDataretail. We will only share Personal Data that is necessary for electronic messaging. This data will be shared on https://dr3.dgebv.nl/addresses.html

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us. Further information about Our newsletter subscription process and which data we collect for this purpose can be found in paragraph 5.

We may use Email Marketing Service Providers to manage and send emails to You. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message

Mailchimp

Mailchimp is an email address management and newsletter service platform provided by The Rocket Science Group. The information gathered by Mailchimp is held in accordance with it’s Privacy Policy: https://mailchimp.com/legal/

Usage, Performance and Miscellaneous

We may use third-party Service Providers to provide better improvement of our Service.

Zendesk

Zendesk is a customer support software. The service is operated by Zendesk. Zendesk service may collect information from Your Device. The information gathered by Zendesk is held in accordance with its Privacy Policy: https://www.zendesk.com/company/customers-partners/privacy-policy/

4. Data protection provisions about Our Application dgeGroothandel and use of Google user data

Accounts are added to Our application dgeGroothandel using OAuth authentication. OAuth is a secure mechanism which gives dgeGroothandel access to Your Google account data without letting it know Your password. This token is valid during Your use of dgeGroothandel and is encrypted saved on your own database server.

Our application dgeGroothandel allows the user to send mails with Gmail. Therefore, the application dgeGroothandel uses the Gmail API. There is no third party involved. Therefore, the data from the Gmail account will be processed on your local device and stored by the application on your own database server only.

Here, the following applies in particular:

  • The Application will only use access to send email messages (including attachments) in name of the user using the scope https://www.googleapis.com/auth/gmail.send. The Application will not transfer this Gmail data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
  • The Application will not use this Gmail data for serving advertisements.
  • The Application will not allow humans to read this data.

For a few features of the application dgeGroothandel, it is necessary to transfer a very limited data set of Google user data to your own database server. The following paragraphs are describing which data will be used and why:

  • In order to use GMail email aliases, the application does send a request for aliases to the Google People API.

5. Data protection provisions about Our Application dgeGroothandel and use of Microsoft user data

Accounts are added to Our application dgeGroothandel using OAuth authentication. OAuth is a secure mechanism which gives dgeGroothandel access to Your Microsoft account data without letting it know Your password. This token is valid during Your use of dgeGroothandel and is encrypted saved on your own database server.

Our application dgeGroothandel allows the user to send mails with Outlook. Therefore, the application dgeGroothandel uses the Micrsoft Graph API. There is no third party involved. Therefore, the data from the Outlook account will be processed on your local device and stored by the application on your own database server only.

Here, the following applies in particular:

  • The Application will only use access to send email messages (including attachments) in name of the user using the permission Mail.Send. The Application will not transfer this Outlook data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
  • The Application will not use this Outlook data for serving advertisements.
  • The Application will not allow humans to read this data.

For a few features of the application dgeGroothandel, it is necessary to transfer a very limited data set of Outlook user data to your own database server.

6. Subscription to our newsletters

The email addresses with which support requests are made, will be automatically signed up to Our newsletter.

Our newsletters are used by Us to inform about Our Services and may contain information of commercial or promotional nature concerning Our Services.

With the registration for the newsletter, we store personal information of You. This personal information includes Your email address.

The personal data collected as part of a registration for the newsletter will only be used to send Our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly by communicating this to the controller.

We use https://mailchimp.com/ to manage and send our newsletters. For more information about Mailchimp please check section 3.

7. GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

If you are from the European Economic Area (EEA) or the United Kingdom, our legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

We or our Service Providers may process Personal Data under the following conditions:

  • Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
  • Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
  • Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.
You have the right under this Privacy Policy, and by law if You are within the EU, to:

  • Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within the settings section of the Application. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
  • Request correction of the Personal Data that We hold about You. You have the right to to have any incomplete or inaccurate information We hold about You corrected.
  • Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
  • Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
  • Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
  • Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA) or the United Kingdom, please contact Your local data protection authority in the EEA or the United Kingdom.

8. Our Facebook Fan Page

Data Controller for the Facebook Fan Page

The Company is the Data Controller of Your Personal Data collected while using the Service. As operator of the Facebook Fan Page (https://www.facebook.com/dgebv/), the Company and the operator of the social network Facebook are Joint Controllers.

The Company has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms of Service: https://www.facebook.com/terms.php
Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more information about how Facebook manages Personal data or contact Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.

9. Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

10. Other Websites and Services

Our Services may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

11. How “Do Not Track” requests are handled

Our Services do not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

12. Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

13. Contact Us

If you have any questions about this Privacy Policy, You can contact us:
By email:
info@dgebv.nl
By mail:
data group europe bv
De Weel 12
4306 NW NIEUWERKERK
The Netherlands
To comply with our obligations under EU data protection legislation, we have appointed a Data Protection Officer (DPO) who is contactable using the details provided above.