1. Data Protection Notice
Electro Voice Dynacord B.V. (hereinafter referred to as “Electro Voice Dynacord” or “We” or “Us” or "Our") is delighted about your visit to our System Activation Site (hereinafter together with our connected services referred to as "Online Offers") and about your interest in our company and our products.
2. Electro Voice Dynacord respects your privacy
The protection of your privacy throughout the course of processing personal data as well as the security of all business data is an important concern to us.
We process personal data as defined Art. 4 Nr. 1 GDPR / Personally Identifiable Information (USA & Canada) (hereinafter referred to as "data") confidentially and only in accordance with statutory regulations.
Data protection and information security are included in our corporate policy.
3. Controller
We are the controller in accordance with Art. 24 GDPR responsible for the processing of the data listed below.
Our contact details are as follows:
Electro Voice Dynacord B.V.
Achtseweg Zuid 173, 5651 GW Eindhoven
Netherlands
Telephone: + 31-40-257 7200
E-Mail: data.privacy.bt-co@keenfinity-group.com
4. Collection, processing and usage of personal data
4.1 Processed categories of data
The following categories of data are processed:
- Personal details (e.g. name, email, user name, password, country, company ID)
- Communication data (e.g. IP address)
- Contractual master data (e.g. contractual relationships, contract acceptance, time and date of signature) - only if you are an end customer of our Online Offers.
4.2 Principles
Data consists of all information related to an identified or identifiable natural person (e.g. names, email addresses, contractual master data) which is an expression of a person's identity.
We process your data only when there is either a statutory legal basis to do so or you have given your consent to the processing or use of your data concerning this matter, e.g. by accepting the agreements included in the order confirmation.
4.3 Processing purposes and legal basis
We process personal data for the following processing purposes:
- Log in
- User Management, automatic creation of a user for an end customer to accept and store the Data privacy Agreement.
- Send emails in case a new password request has been initiated
- Send emails to be able to execute the sales contract
- Logging for fault diagnostics Operations for resolving service disruptions as well as for security reasons
- Contract Management
Legal basis: Legitimate interest on our part among other things for the safeguarding and vindication of our rights as well as our obligations of our services under the license agreements in accordance with Art. 6 (1)(f) GDPR.
4.4 Children
Our Online Offers shall not be used by children under 16 years of age.
4.5 Data transfer to other controllers
Principally, your data is forwarded to other controllers only if required for the fulfillment of a contractual obligation, or if we ourselves, or a third party, have a legitimate interest in the data transfer, or if you have given your consent. Particulars on the legal basis and the recipients or categories of recipients can be found above in the Section "Processing purposes and legal basis".
Additionally, data may be transferred to other controllers when we are obliged to do so due to statutory regulations or enforceable administrative or judicial orders.
4.6 Service providers
We have commissioned external service providers with tasks such as provision of server infrastructure and operations.
We have chosen these service providers carefully and review them regularly, especially regarding their diligent handling of and protection of the data that they have saved.
All service providers are obliged to maintain confidentiality and to abide by the statutory provisions. Service providers may also be other Keenfinity Group companies.
5. Transfer to recipients outside the European Economic Area (EEA)
We can also transfer your data to recipients located outside the EEA in so-called third countries. In such cases, we ensure prior to the transfer either that the data recipient provides an appropriate level of data protection (e.g., due to a decision of adequacy by the European Commission for the respective country in accordance with Art. 45 GDPR or due to the agreement based on so-called EU standard contractual clauses with the recipient in accordance with Art. 46 (2)(c) GDPR).
You are entitled to receive an overview of third country recipients and a copy of the specifically agreed-to provisions securing an appropriate level of data protection. For this purpose, please use the statements made in the section "Contact" below.
6. Duration of storage; retention periods
Principally, we store your data for as long as it is necessary to render our Online Offers for as long as we have a legitimate interest in storing the data. In all other cases we delete your data with the exception of data we must store to fulfill legal obligations (e.g. due to retention periods under the tax and commercial codes we are obliged to have documents such as contracts and invoices available for a certain period of time).
7. Security
Our employees and the companies providing services on our behalf, are obliged to confidentiality and to compliance with the applicable data protection laws.
We take all necessary technical and organizational measures in accordance with Art. 32 GDPR to ensure an appropriate level of security and to protect your data that are administrated by us especially from the risks of unintended or unlawful destruction, manipulation, loss, change or unauthorized disclosure or unauthorized access, and harm to the integrity of the your data. Our security measures are, pursuant to technological progress, constantly being improved.
8. Your rights - EU/EEA
To exercise your rights, please use the details provided in the section "Contact" below. In doing so, please ensure that an unambiguous identification of your person is possible.
Right of access (Art. 15 GDPR)
You have the right to obtain confirmation from us about whether your personal data is being processed, and, if this is the case, access to your data.
Right to rectification (Art. 16 GDPR)
You have the right to obtain the rectification of inaccurate data.
Right to erasure (Art. 17 GDPR)
As far as statutory requirements are fulfilled, you have the right to obtain the completion or deletion of your data. This does not apply to data which is necessary for billing or accounting purposes, or which is subject to a statutory retention period. If access to such data is not required, however, its processing is restricted (see the following).
Right to restriction (Art. 18 GDPR)
As far as statutory requirements are fulfilled you have the right to demand the restriction of the processing of your data.
Right to data portability (Art. 20 GDPR)
Within our processing there is no data portability scenario possible. However as far as statutory requirements are fulfilled you may request to receive personal data that you have provided to us in a structured, commonly used and machine-readable format or - if technically feasible - that we transfer those personal data to a third party.
Right to object (Art. 21 GDPR)
Additionally, you may object to the processing of your data at any time. Please take into account that due to organizational reasons, there might be an overlap between your objection and the usage of your data within the scope of a campaign which is already running.
Objection to data processing based on the legal basis of "legitimate interest" (Art. 6 (1)(f) GDPR)
In addition, you have the right to object to the processing of your data at any time, insofar as this is based on ‘legitimate interest’. We will then terminate the processing of your data, unless we demonstrate compelling legitimate grounds according to legal requirements which override your rights.
Right to lodge complaint with supervisory authority (Art. 77 (1) GDPR)
You have the right to lodge a complaint with a supervisory authority. You can appeal to the supervisory authority which is responsible for your place of residence or your state of residency or to the supervisory authority responsible for us:
Autoriteit Persoonsgegevens (AP)
Bezuidenhoutseweg 30
PO box 93374
NL 2509 AJ Den Haag/The Hague
Telephone: + 31-70-88 88 500
Telefax: + 31-70-88 88 501
E-Mail: info@autoriteitpersoonsgegevens.nl
Homepage: https://autoriteitpersoonsgegevens.nl/nl
9. Your rights - USA & Canada
State specific privacy laws within the United States provide data subjects certain rights regarding the data that businesses collect and how the collected data is used. If you would like to exercise data subject right available to you, find the “How to exercise your rights” section below. Our privacy team will examine your request and respond to you as quickly as possible.
We may still use any aggregated and de-identified Data that does not identify any individual and may also retain and use your data as necessary to comply with our legal obligations, resolve disputes, and enforce our Agreements. We maintain and use all de-identified information in de-identified form. We do not attempt to reidentify it except to ensure our de-identification processes are in compliance with applicable law.
Dependent on the state of your residence, you may be provided the following rights:
- Right to know or confirm what data is collected
- Right to access your data
- Right to correct inaccurate data
- Right to delete data
- Right to know what data is sold or shared and to whom.
- Right to data portability
- Right of no retaliation following opt-out or exercise of other rights
- Right to appeal
- Right to non-discrimination
Individuals located in Canada have certain rights pursuant to Canadian Privacy Laws. Subject to certain exceptions and limitations, and depending upon the jurisdiction where you reside, such rights may include:
- The right to withdraw your consent to the collection, use or disclosure of your data.
- The right to be informed of the existence, use, and disclosure of your data, and to be provided with an account of the use that has been made or is being made of this information as well as the third parties to which it has been disclosed (including a list of organizations to which your information may have disclosed).
- The right to challenge the accuracy and completeness of your data, and have it amended, updated, or rectified as appropriate.
- The right to acquire information about our policies and practices with respect to data, including: a description of the type of data held by us and a general account of its use; a copy of any brochures or other information that explain our policies, standards, or codes; and information about what data is shared with or accessible to our service providers or affiliates, including outside of Canada.
- The right to data portability.
- The right to challenge our compliance with the applicable Canadian Privacy Laws.
9.1 How to exercise your rights
To exercise your rights, submit a verifiable consumer request or access request, as applicable, to us by either calling us at ELECTRO-VOICE DYNACORD B.V (+31-40-257 7200 or sending an email to: dataprotection.keenfinity@keenfinity-group.com
To assist us in processing your request when exercising your rights, supply the following information:
- Full name
- Phone number
- Address
- Any information you can provide about your previous contact with us (e.g. contact point / touchpoint with us, screenshots, reference to a specific product/newsletter)
Only you (or based on your state of residence, an authorized agent authorized by you to act on your behalf (see below for more information) may make a verifiable consumer request or access request, as applicable related to your data. You may also make a verifiable consumer request on behalf of your minor child.
Your verifiable consumer request or access request, as applicable, must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Data or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with data if we cannot verify your identity or authority to make the request and confirm the data relates to you.
We will only use data provided in a verifiable consumer request or access request, as applicable, to verify the requestor’s identity or authority to make the request.
9.2 Response Timing and Format
We endeavor to respond to a verifiable consumer request or access request, as applicable, within forty-five (45) days of its receipt, or sooner where required by applicable law (including Canadian Privacy Laws). If we require more time (up to 90 days in total), where permitted by applicable law, we will inform you of the reason and extension period in writing. Opt-out requests will be honored as soon as feasibly possible, but no later than 15 days from the date we receive the request.
Any disclosures we provide in response to a verifiable consumer request will only cover the 12-month period preceding the verifiable consumer request's receipt, unless otherwise required by applicable law. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
For data portability requests, where applicable, we will select a format to provide your data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request or access request, as applicable, unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
9.3 Authorized Agent.
When you submit your request through an authorized agent, we require that you:
- Provide us a copy of your written permission for the authorized agent to submit the applicable request; and
- Verify your own identity directly with us.
The foregoing does not apply when you have provided your authorized agent with a power of attorney pursuant to California Probate Code sections 4000 to 4465; provided, that we may require a copy of such power of attorney before fulfilling any request.
9.4 Non-Discrimination
We will not discriminate against you for exercising any of your rights. Unless permitted by applicable law, we will not: (a) deny you goods or services; (b) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (c) provide you a different level or quality of goods or services; or (d) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
9.5 Filing a Complaint
Regulatory authorities that oversee the privacy laws and regulations, including the Office of the Privacy Commissioner of Canada, advise individuals to file an objection or challenge with the relevant company before lodging a formal complaint with a regulatory authority. If you are dissatisfied with our response to an objection or challenge filed under Article XVII above, or you if wish to file a complaint with a regulatory authority first, you may do so as follows:
Under PIPEDA: You may file a complaint with the Office of the Privacy Commissioner of Canada5. Depending upon the province where you live, you may also (or instead) have the right to file a complaint with the applicable provincial privacy commissioner/regulator.
Under U.S. State Laws: You may file a complaint with the applicable state Attorneys General Office or regulatory agency.
10. Changes to the Data Protection Notice
We reserve the right to change our security and data protection measures. In such cases, we will amend our Data Protection Notice accordingly. Please, therefore, notice the current version of our Data Protection Notice, as this is subject to changes.
11. Contact
If you wish to contact us, please use the address listed under ‘Controller’.
To exercise your rights or to report data protection incidents, please use the following email address: dataprotection.keenfinity@keenfinity-group.com
For suggestions and complaints regarding the processing of your data, we recommend that you contact our Data Protection Officer:
IT-Security Coach GmbH
Olper Hütte 5b
57462 Olpe
Germany
Telephone: +49 276183363100
Email: dataprotection@itsecuritycoach.com
Effective date: 2020-05-01