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PRIVACY POLICY

Privacy Statement

Transparency, trust and respect for your personal data and privacy are paramount at Vipper. Through the Vipper Privacy Policy below, which entered into force on 30 April 2019, we wish to inform you of our activities and how we may use your personal information during these activities (‘Privacy Statement’).
May we ask you to thoroughly and carefully read our Privacy Statement, allowing you to have a good idea of how we collect, use, share and process your personal information (‘Personal Data’), hereinafter also referred to as ‘Processing’ and what rights you have regarding the Processing of your Personal Data by Vipper.
Vipper always refers to Vipper BV, a limited company by Dutch law, having its office at Herengracht 184 B, 1016BS Amsterdam, Netherlands, registered at the Dutch Chamber of Commerce with number 72396814.


CONTROLLER – PROCESSOR
1.1. Within the context of this Privacy Statement and the Processing of Personal Data by Vipper, Vipper will be considered as the controller regarding the Processing of Personal Data.
1.2. The present Privacy Statement only applies to those situations where Vipper Processes Personal Data through one of its channels, such as the Vipper Website(s), Application(s) and/or the Carrier Portal. This Privacy Statement therefore does not apply to those situations where Vipper acts as a processor (and not controller) of Personal Data on behalf and for the benefit of a third party.


PROCESSING ACTIVITIES
2.1. This Privacy Statement applies to the Processing of Personal Data by Vipper, collected and processed in the following situations:
2.1.1. Visiting the website(s), including the website(s) on which the present Privacy Statement is displayed, as well as the website(s) where the present Privacy Statement is referred to (hereinafter the ‘Website(s)’).
2.1.2. Visiting the ‘social media’ channels of Vipper.
2.1.3. Forwarding and receiving messages, emails, text messages, telephone calls and any other form of direct communication between yourself and Vipper.
2.1.4. Registering yourself on the aforementioned Website(s), Application(s) and/or the Carrier Portal, in order to use our Services.
2.1.5. Using the Vipper Application(s) and/or the Carrier Portal.
2.2. The Website(s), Application(s) and/or the Carrier Portal may contain links to other organizations, websites, applications, services and any other content that isn’t under control of Vipper and are maintained by third parties. For more information regarding your privacy and the Processing of your Personal Data by these third parties, you should consult the privacy statements of these third parties.


PERSONAL DATA
3.1. Vipper Processes the following Personal Data, which it obtained directly from you:
3.1.1. Your contact information (email, phone number, address, etc.), obtained by Vipper because you register this Personal Data within the systems of Vipper such as the Website(s), Application(s) and/or the Carrier Portal, or because you transfer this Personal Data directly to Vipper in any other way.
3.1.2. Your identity information (name, function, date of birth, etc.), obtained by Vipper because you register this Personal Data within the systems of Vipper such as the Website(s), Application(s) and/or the Carrier Portal, or because you transfer this Personal Data directly to Vipper in any other way.
3.1.3. Your financial and/or billing information, when using Vipper’s Services, whereby this information is obtained because you transfer it directly to Vipper.
3.1.4. Your company data, when using Vipper’s Services, whereby this information is obtained because you transfer it directly to Vipper.
3.1.5. Your technical data, when using the Website(s), Application(s) and/or the Carrier Portal, which Vipper automatically collects through the use of cookies, web beacons and/or similar technologies.
3.1.6. Your voluntarily provided information, including information obtained through voluntary communication from you to Vipper.
3.2. Vipper also obtains Personal Data (or may obtain it) from other sources, combining these Personal Data with the Personal Data you provide. This allows Vipper to update, expand and analyze the Personal Data in Vipper’s possession, as to identify new customers and to create better tailored advertisements by offering Services that you may find interesting. We collect Personal Data in particular from the following source(s):
3.2.1. External providers of company data, including identity information, contact information, company information, use of our Services, technical data and social media profiles for the purpose of target group advertising, sending relevant content and promoting events.
3.3. If you provide Personal Data of third parties to Vipper, you will be considered responsible for the Processing of this Personal Data. Vipper can never be held responsible for the improper use of Personal Data from third parties, whilst Vipper could reasonably expect to be allowed to use this Personal Data.


PURPOSES AND LEGAL BASIS
4.1. Vipper Processes your Personal Data for the following purposes and based on the following legal grounds:
4.1.1. Personal Data obtained through the Website(s), Application(s) and/or the Carrier Portal: Vipper Processes your Personal Data in the context of the agreement between yourself and Vipper regarding the use of the Website(s), Application(s) and/or the Carrier Portal. If no agreement has been entered into between yourself and Vipper, Vipper relies on its legitimate interest to manage its Website(s), Application(s) and/or the Carrier Portal, including the Personal Data entered therein.
4.1.2. Account management on the Website(s), Application(s) and/or the Carrier Portal: Vipper Processes your Personal Data in your personal account on the basis of the agreement between yourself and Vipper, in accordance with the provisions of the general terms and conditions.
4.1.3. Contacting Vipper: Vipper Processes your Personal Data in order to answer your communication. This can be done in the context of an agreement between yourself and Vipper or in accordance with Vipper’s legitimate interest to Process your Personal Data in this context.
4.1.4. Financial data: Personal Data of a financial nature is only processed by Vipper in order to carry out the financial transactions between yourself and Vipper, ensuing from an agreement between yourself and Vipper.
4.1.5. Offering necessary functionality: Vipper offers its Services through its Website(s), Application(s) and/or the Carrier Portal. To guarantee the necessary functionality of these communication channels, Vipper Processes your Personal Data as to respect the agreement between yourself and Vipper. If there is no agreement between yourself and Vipper, Vipper will process your Personal Data based on its legitimate interest to Process Personal Data as to be able to offer its Services through these communication channels.
4.1.6. Securing the communication channels: Vipper emphasizes the great importance of your privacy and the protection of your Personal Data. To this end, Vipper must continuously improve the security of its Website(s), Application(s) and/or the Carrier Portal. As to improve the security of its Website(s), Application(s) and/or the Carrier Portal, Vipper Processes your Personal Data in accordance with its legitimate interest to use this data as to continuously improve and further secure its Services, its communication channels and its systems in general.
4.1.7. Continuous improvement of its Services: For your comfort and satisfaction when using its Services, Vipper aims to continuously improve its Services as well as improve and further develop its Website(s), Application(s) and/or the Carrier Portal. To this end, Vipper Processes your Personal Data in accordance with its legitimate interest to use this data as to improve and optimize its Services, the communication channels and its systems in general.
4.1.8. Compliance with the terms and conditions: Vipper Processes your Personal Data as to act in compliance with its terms and conditions, arising from the agreement between yourself and Vipper. Furthermore, Vipper relies on its legitimate interest to Process your Personal Data as to ensure correct compliance with its terms and conditions.
4.1.9. Personalized advertisements and content, including direct marketing: Regarding marketing activities, Vipper Processes your Personal Data as to provide you with targeted, personalized advertisements, information and offers. Vipper always does this in accordance with its legitimate interest to Process Personal Data in order to be able to offer its users the best experience possible. Where necessary, Vipper will request your permission prior to the Processing. Vipper may send you marketing information or any other marketing related content, based on its legitimate interest to promote its Services. Where necessary, Vipper will request your permission prior to the Processing.
4.1.10. Legal obligations: Vipper may Process your Personal Data in the context of legal obligations imposed on Vipper, for example by government agencies, courts, regulators or other competent institutions, whether or not under applicable law. Vipper may furthermore Process your Personal Data to protect its own rights, property, information and the like, including through legal proceedings, where Vipper has a legitimate interest to do so.
4.1.11. General: Vipper may be required by law or by agreement to Process your Personal Data and possibly provide it to third parties. When Vipper is not allowed to do this, it is unable to execute the agreement with you.


SHARING PERSONAL DATA
5.1. Vipper may, legally obliged or not, share your Personal Data with third parties. Vipper only shares your Personal Data with the following third parties:
5.1.1. Organizations and companies under direct control of Vipper, that are a part of the total offer of Services by Vipper such as: sister or subsidiary companies that manage specific parts or activities of the Vipper Services.
5.1.2. Service providers with whom Vipper has an agreement, such as: IT providers, financial transaction processors, research and analysis companies, marketeers, customer service companies and professional service providers (e.g. lawyers, bankers, auditors, etc.). Vipper will only share your Personal Data with these third parties in accordance with the purpose and legal grounds mentioned above.
5.1.3. The direct partners of Vipper who are directly part of the Services offered by Vipper and without whom Vipper can’t offer its Services.


INTERNATIONAL TRANSFER OF PERSONAL DATA
6.1. Vipper Processes and stores your Personal Data solely within the European Economic Area.
6.2. In the near future, Vipper may Process your Personal Data outside of the European Economic Area as well, including countries that are not subject to an adequacy decision by the European Commission and do not offer the same level of privacy protection. In such cases, Vipper will guarantee that the third parties involved will respect your privacy and Personal Data and offer a minimum level of data protection.


MINORS
7.1. Vipper does not provide its Services directly to minors. Vipper does not knowingly Process Personal Data of minors and, as a rule, only Processes Personal Data of minors that it has obtained through parents, guardians and/or other adults that are responsible for the minors in question. If you, as a parent, guardian or otherwise, believe that Vipper Processes the Personal Data of minors without your permission, you can contact Vipper as to resolve the matter.


RETENTION OF PERSONAL DATA
8.1. The actual retention period, the duration of Vipper storing your Personal Data, depends on the nature, quantity and sensitivity of the Processed Personal Data, the purpose for which it is Processed and the legal basis on which the Personal Data is Processed.
8.2. At the end of the retention period, your Personal Data will be automatically deleted by Vipper from its systems, unless this isn’t possible due to certain circumstances (either technical, organizational, legal, etc.). In the latter case, Vipper will take the necessary steps to prevent further use of your Personal Data.
8.3. It is possible that Vipper anynomises your Personal Data and makes further use of the data for statistical research. This has no impact on your right to privacy.


YOUR RIGHTS AS DATA SUBJECT
Your rights

9.1. Within the scope of the GDPR, applicable within the European Economic Area, everyone whose Personal Data is being Processed has specific rights with regard to his or her Processed Personal Data. These rights are as follows:
9.1.1. You have the right to receive information about your Personal Data as well as access to your Personal Data.
9.1.2. You have the right to see your Personal Data rectified if the Personal Data is incorrect, taking into account the purposes for which the Personal Data was collected.
9.1.3. You have the right to see your Personal Data erased (‘the right to be forgotten’). Note however that this right is not absolute, which means that depending on the circumstances, Vipper may retain certain Personal Data.
9.1.4. You have the right to limit the Processing of your Personal Data, to an extent that only the legally permitted Processing is still allowed.
9.1.5. You have the right to see your Personal Data transferred, to the extent possible, to yourself or to a third party.
9.1.6. You have the right to object to all Processing of your Personal Data, when Vipper processes your Personal Data based on its legitimate interest. You may always object to the processing of your Personal Data with the aim of direct marketing.
9.1.7. You have the right to retract your permission, given to Vipper, to Process your Personal Data when the Processing of that Personal Data is based on the legal ground of ‘Permission’.

Exercising your rights

9.2. If you wish to exercise one or more of your rights, you must contact Vipper directly, using the contact details below. Every question or request is handled within one month after receipt. If more time is required to process your question or request, you will be notified by Vipper, which message will include an estimate of the expected duration to handle the question or request.
9.3. Some rights can be exercised by yourself through your profile on the Website(s), Application(s) and/or the Carrier Portal.


SECURING YOUR PERSONAL DATA
10.1. Vipper takes all reasonable organizational, technical and physical security measures to protect your Personal Data against accidental or unlawful destruction, loss, alteration and/or unauthorized use and access.
10.2. Despite all efforts made by Vipper, Vipper can never guarantee the absolute security of your Personal Data.


CHANGES TO THE PRIVACY STATEMENT
11.1. It is possible that in the near future, the present Privacy Statement will be amended by Vipper. That is why the date of entry into force is mentioned at the top of the Privacy Statement.
11.2. Vipper requests that you read the Privacy Statement from time to time, as to assure your awareness of the most recent version and its provisions.


CONTACT DETAILS
12.1. If you wish to contact Vipper, you can always do so by sending your message to:
12.1.1. By mail to Vipper BV, Herengracht 184 B, 1016BS Amsterdam, The Netherlands.
12.1.2. By email to privacy@vipper.com