Privacy Policy

Your privacy matters to us.

Last Updated: June, 2019

Applicability of Privacy Policy

This is the Privacy Policy of Virtual Vaults B.V. which applies to the websites of Virtual Vaults: virtualvaults.com and other websites of Virtual Vaults (hereinafter jointly referred to as: “Websites”). These rules provide you, as a user of the Websites, insight into what data Virtual Vaults processes during your visit to these web pages, the purposes for which we process said data and the way in which the data is processed.

This Privacy Policy does not apply to the processing of your personal data that takes place in the context of the use by or on behalf of customers of the Virtual Vaults services. For information regarding the processing of your personal data by one of our customers using the Virtual Vaults services, please refer to the organization on behalf of which you have gained access to the services of Virtual Vault.

To the extent there are links on our Websites to third-party websites, after clicking the aforementioned links you will be redirected to the website of the respective third-party (hereinafter: “Third-Party Websites”). The use of such Third-Party Websites is subject to the privacy policy of the respective third party. You should read the Privacy Policy of these third parties in order to gain insight into how this party handles your personal data. Virtual Vaults is not responsible for the information that is provided, processed or collected by third parties during the visits of this Third-Party Websites.

Personal data is data that can be traced back to an individual.

What Personal Data we collect, receive and use

Cookies
In order to enable you as a user of the Websites to use the full functionality of the Websites and to analyse the use of and navigation within the Websites, Virtual Vaults installs small amounts of information (cookies or similar technologies) on the peripheral devices used by its users (such as a laptop, tablet, phone) or Virtual Vaults information reads the information as located in the browser settings on the peripheral devices of its users.

Functional cookies
Virtual Vaults makes use of functional cookies. These cookies are necessary to display the requested websites and the associated functionality. Examples of such cookies are “load balancing” cookies to remember the language preference of the user during a browser session.

Analytical cookies
Virtual Vaults uses analytic cookies in order to analyse the use of the Websites. Analytical cookies provide Virtual Vaults with information about the use and navigation within the Websites. This information helps Virtual Vaults to improve the layout of the Websites, to better match them to the needs of its users, to analyse trends and to improve navigation within the Websites. Virtual Vaults uses Google Analytics cookies in order to analyse the use of the Websites. Virtual Vaults has concluded a processing agreement with Google Analytics. In doing so, it decided to only register part of your IP address and data is not shared with other services of Google Inc. Google Analytics cookies provide Virtual Vaults with information about the use and navigation within/between the Websites. The information that is collected with the help from these analytical cookies is provided to Google Analytics to enable it to evaluate the use that is made of the Websites and to create relevant statistical reports that will only be provided to us. More information about the use by Google Analytics of the information that is provided to it can be found in the Privacy Policy of Google Analytics

Read our Cookie Policy for more information about the cookies we use.

Questions and requests

When Virtual Vaults receives email other communications from you with any questions or requests addressed to Virtual Vaults, we will use these messages to and as long as needed to: a. process your questions/respond to your requests (user communications); and b. on the basis of our justified interest to be able to show that and how your request was responded to. Should you have a complaint about how your request was handled, Virtual Vault may ask the Personal Data Authority to show how these requests were handled.

Retention period
Your Personal Data in your message and the response to this (in the previous subparagraph) is stored for up to 5 years and after that the Personal Data will be deleted. If the data has been anonymised, the data may be retained by Virtual Vaults for a longer period of time. Anonymised means that the data has been cleaned of elements that allow the data to be traced back to you.

Newsletters, white papers and other data sheets

If you wish to download something (white paper or other information sheet) from our Web site, we will ask for your name and email address in order to be able to send you the respective information. In order to also inquire about information about relevant products and services of Virtual Vaults by phone or email, we may ask for some additional information, such as your phone number, gender, organisation and job title. If you have given your consent to receive our newsletter, we will use your name and email address to send it. Each newsletter that you receive gives you the opportunity to unsubscribe from the Virtual Vaults newsletter. If you make use of the option to no longer receive the newsletter, Virtual Vaults will register that you have unsubscribed from the newsletter.

Retention period
If you have successfully unsubscribed from our newsletter, we remove your personal data (name and email address) - collected for sending the newsletter. If you do not unsubscribe, the data will be stored up to a period of 5 years. If the data has been anonymised, the data may be retained by Virtual Vaults for a longer period of time. Anonymised means that the data has been cleaned of elements that allow the data to be traced back to you.

Additional source(s) of personal data

Virtual Vaults performs desktop research and, in this context, may gather (additional) information about you that can be found about your business identity and is industry related; for example, information that can be found about your via public online sources. For example, social media channels such as LinkedIn, Unquote and mena.nl (deal information), but also public lists of, for example, fast-growing companies or guest lists of events that Virtual Vaults visits. Virtual Vaults collects all this data on the basis of its legitimate interest to develop direct marketing activities. The data will be updated periodically, and the obsolete data will be removed.

Sharing with third parties

Virtual Vaults shares Personal Data with third parties in the following cases:
• With our processors, in order to perform (part of) the services they are tasked with. These third parties may only process the data at our behest, and we demand that these parties agree to process such data according to our instructions and in accordance with this Privacy Policy and other measures about confidentiality and security. Our current processors are: (a) an external hosting party (Microsoft) which is located in the Netherlands with a fall-back location in Ireland where your personal data is stored during the retention periods stated in this statement; (b) Google Analytics for analysing the use of/navigate within the Websites (for more information, see the header “Analytical Cookies”); (c) a Party which provides our email services (Mailchimp); (d) a party that enables chat conversations with leads on our website (Drift) and (e) a party that hosts the landing page through which targeted lead campaigns are performed (Unbounce);
• With the competent courts, regulators, or other regulatory agencies if we believe in good faith that the granting of access, processing, use, or provision of the data requested by them is necessary to comply with applicable laws and regulations, is necessary in the context of judicial proceedings or to comply with an enforceable request from the respective regulatory authority.
• To a company with which Virtual Vaults merges, or to which some or all of its assets are sold, or to a company that acquires Virtual Vaults. We believe that we have a justified interest in providing your personal data for these purposes to such company;
• To other third parties, if we have received your prior express consent (“informed consent”).

Transmission of personal data to a recipient from a third country or to an international organisation
Your personal data may be transferred by Virtual Vaults to countries outside of the EU/EEA. Virtual Vaults provides your personal data to two of its processors (Drift and Mailchimp) located in the United States. With regard to the transfer of personal data to the United States, the following security measure has been taken: The processors (Drift and Mailchimp) are a member of the Privacy Shield.

You can receive more information regarding the aforementioned security measure taken by contacting Virtual Vaults. See below in this Privacy Policy for the relevant contact details.

Anonymised data
If the data is anonymised, the data may be retained by Virtual Vaults for a longer period of time. Anonymised means that the data has been cleaned of elements that allow the data to be traced back to you.

Security

We will handle your Personal Data with the utmost care. Virtual Vaults takes appropriate security measures as protection against unauthorised access to or unauthorised modification, disclosure or destruction of data. This includes internal monitoring of our policies and security measures with respect to the collection, storing and processing of data, as well as physical security measures to protect against unauthorised access to systems on which we store Personal Data. Virtual Vaults processes personal data for the purposes for which it is collected and in accordance with this Privacy Policy. We will continue to review our Privacy Policy with respect to the collection, storing and processing of data to make sure that we only collect, store and process personal data that is required to provide or improve our services or which are otherwise permitted in accordance with this policy.

Virtual Vaults is ISO 27001:2013 certified (information security management system). You can find out more about our security here.

Your rights

You have the right to submit a request to us to review, correct and/or remove your personal data that we process. In addition, in certain cases, you have the right to request us to limit the processing of your personal data and to object against to the processing of your personal data. Please find a more detailed explanation below.

Review, correction, and removal of personal data and objection
At your request, Virtual Vaults will undertake a good faith effort to inform you about and grant access to your personal data that is processed by Virtual Vaults; to correct your personal data that is processed by Virtual Vaults, if it is incorrect; to remove/delete/limit your personal data that is processed by Virtual Vaults, in whole or in part, in accordance with the GDPR.

Virtual Vaults does not have to grant every request. Virtual Vaults may refuse your request if:
a. Virtual Vaults has the right to continue the processing; b. you repeat the request in an unreasonable manner; c. the handling of the request requires excessive technical efforts; d. the privacy of others would be at risk; or e. your request is almost impossible in a practical sense (for example, if your request relates to data stored on back-up tapes).

Handling of the request.
If Virtual Vaults receives a request from you, Virtual Vaults may ask you to identify yourself before we answer and process the request. This is to prevent someone pretending to be you from accessing your personal data or having it changed.

You can submit request for access, correction and/or removal, or limitation and objection, in writing by email or by regular mail. Our contact information can be found under the header “Questions and complaints procedure”.

Virtual Vaults will not charge you for answering your requests. Nor for the further processing thereof.

Questions and complaints procedure

Should you have any questions or have a complaint regarding the processing of your personal data by Virtual Vaults, you can report these at no charge and easily to Virtual Vaults, in the following manner:
• By email: security@virtualvaults.com
• By regular mail: Virtual Vaults Nederland B.V., K.P. van der Mandelelaan 60, 3062 MB, Rotterdam, The Netherlands

You can reach our security officer at the email address: security@virtualvaults.com

[Dutch] Data Protection Authority

If you do not agree with our response, then you may submit a complaint to the competent personal data authority of the Member State in which you live. In the Netherlands, this is the Data Protection Authority. You can submit a complaint on the website of the Data Protection Authority. You can reach the Data Protection Authority via phone number: (+31) - (0) 70 - 888 85 00.

New developments and changes to the Privacy Policy

This Privacy Policy may be updated from time to time, for example to bring it in line with the laws and regulations that are applicable at that time. If this Privacy Policy is amended, then this will be communicated to you.