Switch Language: Dutch
Date: April 2021, Version 1.0
Attic® is a portal that gives you access to up-to-date security information, allows you to solve any problems in your own digital facilities and to call in the help of experts. As the need for these kinds of functionalitiescan arise at any time and place, Attic® is built as an application for mobile devices. The app can be connected to your IT facilities in the cloud. If you do this, we will automatically monitor for security issues. Settings of applications are tested on security and alerts on potential abuse are presented to you through the app.
Attic® processes your personal data carefully, safely and securely. We find it important that you have confidence in our organisation around all of our services and products. That is why we do everything we can to protect your privacy. The rules on protecting your privacy are laid down in the General Data Protection Regulation (GDPR), with the Dutch Data Protection Authority (de Autoriteit Persoonsgegevens) supervising compliance with the law.
2. Who is the controller of the processing of personal data?
Zolder B.V. is the controller of the processing of personal data.
3. Who is the Data Protection Officer or Privacy Officer?
Zolder B.V. does not have a Data Protection Officer and/or Privacy Officer. If you have any questions and/or remarks about the processing of your personal data, please send an e-mail to firstname.lastname@example.org. We will make sure your question is answered as soon as possible.
4. What personal data do we use for Attic®?
- E-mail address
- First and last name
- Job Title
- Company name
- Billing address
- IP Address
- Payment details
- Communication details
5. For what purposes do we use your personal data?
We use the aforementioned personal data for various purposes:
Managing our customer database
Zolder B.V. processes contact information (first and last name of the contact person, company name, e-mail address) of (potential) customers to keep records of and analyse the use of Attic®.
Regular business operations
Zolder B.V. processes contact, payment and communication details of customers for its own regular business operations. We send invoices, keep accounts and store correspondence with customers on our server and in online work files.
Zolder B.V. sends newsletters to the users of Attic® in the form of notifications for new updates and release notes of the application.
The services related to the use of Attic®
To use the application, customers create an account in advance. Attic® is designed to notify the users in time of any incidents that may occur. After this, Zolder B.V. will deal with the incident and/or perform additional investigation.
Zolder B.V. analyses the data of customers to spot new trends in information security or incidents.
6. On what legal basis do we use your data?
6.1 Performance of a contract
Zolder B.V. uses the personal data to perform a contract; the user agreement. Before this agreement is made, a customer is registered in the system by creating a user account, this is considered the pre-contractual phase.
6.2 Legitimate interest
Zolder B.V. has its own legitimate interest in analysing the personal data of customers in order to spot new trends. The customer always has the right to object to the use of his or her personal data for this purpose.
7. Automated individual decision making
Attic® does not use automated individual decision making, because this is not necessary for our services.
8. Do we share data with other parties?
Zolder B.V. ensures that the exchange of data with third parties takes place within the legal framework. For example, this means that we make agreements with third parties to ensure that they take appropriate organisational and technical measures to assure our customers’ privacy.
9. Will your data be transferred outside the EU?
Zolder B.V. has the principle of only processing personal data within the EU. For the storage of data, we use data centres in Finland and Germany. These data centres are fully controlled by Zolder B.V. External parties do not have access to our own data centres.
10. How do we protect your data?
Because we take personal data protection very seriously, Zolder B.V. has a strict policy regarding this. We take the following measures:
– Authorization policies
– Retention periods
– Monitoring for suspicious behaviour
11. How long do we retain your data?
We do not retain personal data any longer than needed for the purpose for which it was obtained. We base this consideration on the type of personal data, the product or service for which we have obtained the data, and what you as a data subject can reasonably expect as a retention period.
For example, the data you provide to us to make use of Attic® is removed 3 months after the end of the service.
12. What rights do you have based on the processing of personal data?
Zolder B.V. finds it essential that customers can properly exercise their rights based on the law. Via email@example.com you can exercise the following rights:
- Right of access: you have the right to access to the personal data being processed by us;
- Right to rectification: if the personal data that we process about you is incorrect, you have the right to have it corrected;
- Right to erasure: if we no longer need your personal data for the purpose for which we received it, you have the right to ask us to erase it. A number of exceptions to this may apply, such as our obligation to retain certain data for, among other things, the tax authorities;
- The right to restriction: During the period that we are in the process of determining whether your data should be rectified, determining the unlawfulness of data processing, determining whether data should be erased or you have objected to the processing, you have the right to request the restriction of the processing;
- The right to data portability: upon your request, we must transfer all personal data we hold on you to you or another organisation of your choice. You can only exercise this right if the data is processed on the basis of consent or an agreement;
- The right to object: if we process data on the basis of legitimate interest or general interest, it is possible to object, after which a balancing of interests will follow. In the case of direct marketing, you always have the right to object.
If you have any questions or if you would like additional information about exercising your rights, please send an e-mail to firstname.lastname@example.org.
13. Lodging a complaint with the competent authority: the Dutch Data Protection Authority
Zolder B.V. believes it is important to have satisfied customers. Even though we do everything we can to achieve this, it can happen that you as a customer are not satisfied. It is possible to submit a complaint to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). you can do this via: https://autoriteitpersoonsgegevens.nl/nl/contact-met-de-autoriteit-persoonsgegevens/tip-ons