VETUS B.V. (the “Company”), in connection with the provision of the service (information request, contact request, warranty claim etc.) (the “Service”) to users (the “Users”) residing in the European Economic Area (the “EEA”, and the countries that are members of the EEA are individually or collectively referred to as “EEA member countries”), for the purpose of complying with the EU General Data Protection Regulation (the “GDPR”), the GDPR guidelines, the applicable national laws, regulations, guidelines, etc. (“applicable laws”) and to appropriately process the personal data of the Users residing in the EEA, hereby establishes this “Privacy Policy” (this “Privacy Policy”).

1. Processing Personal Data

1.1 Definitions

“Personal data” means any data relating to an identified or identifiable natural person, including, without limitation, name, address, date of birth, telephone number, e-mail address and user IDs of User residing in the EEA.

“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Controller” means a legal person, etc. which, alone or jointly with others, determines the purposes and means of the processing of personal data.

“Processor” means a legal person, etc. which processes personal data on behalf of the Controller.

1.2 Types of personal data to be collected

The Company will collect the following types of personal data concerning Users in connection with the Service:

(a) Name, address details

(b) Phone number

(c) E-mail address

1.3 Purposes of use of personal data

The Company will process the Users’ personal data for the following purposes:

(a) To respond to, accept or decline warranty claims

(b) To respond to inquiries and requests from a (potential) customer/end-user

(c) To send newsletters, when requested by customer/end-user

If the Company is to process the Users’ personal data for purposes other than the above, the Company will notify Users in advance such new purposes of use and other matters as required by applicable laws.

By manifesting their intention to consent to this Privacy Policy, Users will be deemed to have consented to the processing of their personal data by the Company within the scope of the above purposes of use, and the Company will process the Users’ personal data based on such Users’ consent; provided, however, that Users may withdraw such consent at any time, which such withdrawal shall not affect any legitimate processing performed pursuant to the consent prior to the withdrawal.

The Company may require Users to provide their personal data in connection with the provision of the Services. In such case, if certain Users do not provide its personal data, the Company may be unable to provide the Services.

1.4 Retention Period

The Company will retain the Users’ personal data to the extent the Company requires such data for achieving the purposes of use specified in 1.(2) above, and will promptly delete the same when such data is no longer necessary.

1.5 Third Party Transfer

The Company may provide the Users’ personal data to third parties such as the subsidiaries and affiliates of the Company, dealers, retailers, cloud vendors of the Company, etc., to implement the purposes of use specified above. Such third parties which the Company may provide User’s personal data include those located in countries outside the EEA), and the Users are deemed to have consented to the following matters by consenting to this Privacy Policy:

(a) Certain countries outside the EEA may not be furnished with the same level of data protection laws as the EEA, thus part of the rights granted to Users within the EEA may not be available;

(b) Users’ personal data may be provided and processed for the purposes specified in 1.(2) above; and

(c) Users’ personal data may be provided to third parties located in a country outside the EEA.

In addition to the above, if the Company is to transfer the Users’ personal data to a third party located in a country outside the EEA, the Company will ensure that adequate measures are taken concerning the protection of the Users’ personal data such as by executing standard contract clauses based on the GDPR.

1.6 Disclosure, Correction, and other Procedures concerning the Personal Data

The Users are entitled with the rights to access to, request for correction, request for deletion, request to limit the processing, object to the processing, and request for data portability, with regards to the personal data retained by the Company pursuant to the provisions of relevant laws and regulations. Such requests shall be attended to the contact point set forth in “5. Contact” as per below.

The Company may refuse the Users’ request if the Company deems that there is no basis for such request or if the request is deemed excessive.

The Users may file objections to the data protection authorities having jurisdiction over the location of the Users’ domicile with regards to the processing of their personal data by the Company.

1.7 Unsubscribing from direct marketing

If Users wish to unsubscribe from the Company’s direct marketing, such Users should contact the contact point set forth in “5. Contact” below.

1.8 Cookies

We collect information from visitors in order to optimize our website and to accommodate your needs. Additionally, records of visitors will be used for statistical studies of the surfing behavior of visitors to our website and to offer other products and/or services.

The collected data will be anonymous as far as possible and will never be given to third parties without your explicit consent. Our employees are obliged to maintain the confidentiality of your data.

This website uses “cookies” to retrieve the aforementioned data. Cookies are small text files stored on your computer. Of course you are not obliged to accept the use of these “cookies”. However, this may result in parts of our website not functioning properly. Most Internet browsers are set to accept “cookies”, but you can reset your browser to refuse any “cookies”, or to indicate when a cookie is being sent. You can delete the stored “cookies” through your internet browser.

1.9 Google Analytics

To analyze and track how visitors use our website, we use Google Analytics. The information collected by Google Analytics (e.g. your IP address) is stored on Google’s servers. Google uses this information to track the use of our website, to create reports on this and to provide information to its advertisers on the effectiveness of this marketing technique.

Google may transfer this information to third parties when Google is legally required to do so, or where such third parties process the information on Google’s behalf. We have no influence on this. For Google’s privacy policies please click here.

1.10 Social media

On our website you are referred to social media such as Twitter, Facebook and YouTube. You may use these buttons to promote and/or to share our website on these social media. We are not responsible for the privacy policies of Twitter, Facebook, YouTube etc., since these third parties determine how these social media buttons function. By using a social media button a “cookie” will be placed in your computer.

2. Safety Management Measures

In order to protect the personal data from unauthorized access and loss etc., taking into account the type of personal data, the degree of sensitivity and the degree of affect to the Users including economic influence and mental harm in case the personal data is unlawfully infringed, the Company has comprehensively evaluated and judged the risks of personal data infringement, and has implemented necessary and appropriate personal, organizational and technical safety management measures in accordance with such the risk of personal data infringement, and further, will review such safety management measures as necessary, set up the process for taking corrective actions, and constantly make effort to improve its security.

The Company will make effort to appropriately manage personal data by restricting the entry of outsiders into the offices where the processing of personal data takes place, conducting educational awareness raising activities targeting all officers and employees involved in the protection of personal data, and appointing managers in charge for each division which processes personal data.

If the Company, in its role as a Controller, contracts a Processor, the Company shall select a Processor which is capable of implementing appropriate technical and organizational measures and shall manage such Processor in an appropriate manner.

Pursuant to the GDPR, the Company shall prepare records of the processing of personal data.

3. Continuous Improvement

The Company shall continuously review and revise its efforts regarding the processing of personal data in order to correspond with changes in the GDPR, processing methods and the environment.

4. Amendment to this Privacy Policy

The Company may amend this Privacy Policy at any time. The Company shall determine the effective date of the amendment and inform the Users by 5 working days prior to such effective date by means of a note on the homepage of the website. The Users who continue to use the Service on the effective date or thereafter shall be deemed to have consented to the amended Privacy Policy.

5. Contact

The Company’s contact point regarding this Privacy Policy is as shown below. Any questions or concerns regarding this Privacy Policy or the processing of personal data by the Company, or any requests concerning access, correction, deletion, limitation of processing or data portability of the personal data shall be attended to this contact point:

Fokkerstraat 571

The privacy policies of these social media providers are subject to regular changes. You can review the privacy statements of Facebook and YouTube by clicking on their links. By clicking on these links you can gain insight into how these third parties handle your personal data.

This privacy statement was last updated and/or amended on May 25, 2018

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