Last Updated: June, 2019
Personal data is data that can be traced back to an individual.
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.
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.
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.
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.
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.
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.
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.
Virtual Vaults shares Personal Data with third parties in the following cases:
• 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.
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.
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 is ISO 27001:2013 certified (information security management system). You can find out more about our security here.
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.
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: firstname.lastname@example.org
• 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: email@example.com
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.