Capital Chains B.V.
Privacy Notice, May 2018
Online Privacy Notice
Your privacy is important to us. This privacy statement explains how we, Capital Chains, will collect, store and process your Personal Data in line with the requirements of relevant privacy laws and regulations.
What Personal Data do we collect?
In the running and maintenance of our website, we collect and process some Personal Data about you. You provide us with this data directly when you fill out an online registration or request form. We also collect some information indirectly from you by recording how you interact with our website by using technologies such as cookies. The data we collect can include one or more of the following:
- Your first name, last name, email address, phone number, title and company name
- Your region of residence or business operation
Use of our site data:
- Traffic data, location data and IP addresses derived from details of your visits, the pages you have viewed and the resources that you access
We do not normally obtain or purchase any data about you from third parties, but if we receive such data, it will be the responsibility of Capital Chains to ensure appropriate data security.
Why do we collect your Personal Data?
We collect and process your Personal Data on the basis of legitimate interest, where both you and Capital Chains benefit from the business relationship. This may take the form of a contractual requirement, or a requirement necessary to enter into a contract. You are not obliged to provide your Personal Data. However, as a possible consequence of not providing the required data, Capital Chains may not be able to support your business appropriately. Capital Chains does not use your Personal Data for automated decision-making processes or profiling.
In providing your Personal Data, you support Capital Chains in improving your business, in ways such as:
- Direct marketing, newsletters, and relevant articles
- Recommending new products and services that will better your business
- Providing you with information you have requested from us
We also use your Personal Data for business, regulatory and legal purposes:
- To meet the requirements of our contract
- To support commercial discussions between us
- Providing you with our services/updates/promotions etc.
- Dealing with your requests
- Getting in touch in case we need to contact you, for reasons such as policy changes, contractual arrangements or service notifications
- Internal administrative purposes
The information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
In any event, we are committed to ensuring that the information we collect and use is appropriate for the purposes above, and does not impact your privacy. We only collect data that is relevant to the purpose of processing and no information is collected without reason.
When Capital Chains contacts you, our aim is not to be intrusive, and we endeavour not to ask irrelevant or unnecessary questions.
If Capital Chains intends to process the Personal Data for a purpose other than those stated in this document, we shall provide you with the appropriate information and request your consent before doing so.
With whom will we share your Personal Data?
We will not share your Personal Data with any third party without first obtaining your consent. Should you provide your consent, we will only pass your data on to third parties with whom Capital Chains has a contractual arrangement in place, who will be obliged to keep your details securely, and to use them only for the contracted purpose. When they no longer need your data to fulfil this service, they will dispose of the details in line with Capital Chains’ procedures.
Where will your Personal Data be stored?
Personal data collected by Capital Chains may be stored and processed in your region or in any other country where Capital Chains or its service providers maintain facilities. Capital Chains’ service providers maintain data centres in the Netherlands and other countries in the European Union and the United States.
Typically, the primary storage location and any backup location is in the European Union. We take steps to ensure that we process the data we collect according to the provisions of this privacy statement and the requirements of laws applicable at the data location.
For how long will we keep your Personal Data?
We govern data retention periods according to specific business-sector requirements and stated practices, as well as the type of data and the context in which we collected the data.
Capital Chains is required to retain some information in accordance with the law, such as information needed for income tax and audit purposes, for a period no longer than that specified by such laws.
For as long as we maintain a non-contractual business relationship, and notwithstanding any legal requirement, as stated above, we will retain your data for a maximum of 5 years from the last date of contact. After this time, we will permanently dispose of your data.
If you become a client of ours under contract, we will retain your data for the duration of our relationship and, notwithstanding any legal requirement as stated above, for a maximum of 5 years after termination of the contract.
We may retain Personal Data for additional periods depending on individual business needs. You will be contacted and kept informed regarding such requirements. Capital Chains will always endeavour to only keep your data for as long as deemed necessary.
If at any time before the end of the stated retention period you would like us to remove your data from our database or your preferences otherwise changed, notwithstanding any legal requirement as stated above, please contact us at email@example.com.
What are your rights regarding your Personal Data?
At any point while Capital Chains is in possession of or processes your Personal Data, as the Data Subject you have the following rights:
- The right of access: you have the right to request a copy of the information that we hold about you.
- The right of rectification: you have the right to correct data that we hold about you that is inaccurate or incomplete.
- The right to be forgotten: in certain circumstances, you can ask for us to erase the data we hold about you from our records.
- The right to the restriction of processing: where certain conditions apply, you have the right to restrict the processing.
- The right of portability: you have the right to have the data we hold about you transferred to another organisation.
- The right to object: you have the right to object to certain types of processing such as direct marketing and automated processing, including profiling. You also have the right to be subject to the legal effects of automated processing or profiling.
- The right to judicial review: if Capital Chains refuses your request under rights of access, we will provide you with a reason why.
We will forward on all of the above requests should there be a third party involved in the processing of your Personal Data.
How can you access and control your Personal Data?
If Capital Chains holds Personal Data about you, you can request the following information about the processing of the data:
- The identity and contact details of the person or organisation that has determined how and why to process your data
- The contact details of the data protection officer, where applicable
- The purpose of the processing as well as the legal basis for processing
- Information about the legitimate interest of Capital Chains, if applicable
- Information about the type of data we collect, store and process
- The recipient(s) to whom we will disclose the data
- Information about the transfer of data outside of the EEA, if applicable
- How long we will retain the data
You can also request the following at any time:·
- To view, update, correct or delete any of your Personal Data that Capital Chains holds about you
- To obtain a copy of your data
- To restrict certain access or block certain restrictions
- To restrict certain processing
- To object to any communications
- To withdraw consent
You can send any request to firstname.lastname@example.org. When making requests regarding your Personal Data, you will be asked to verify your identity.
How can you file a complaint?
If you wish to make a complaint about how Capital Chains, or other third parties contracted by Capital Chains, process your Personal Data, or how we have previously handled your complaint, you have the right to complain directly to the Supervisory Authority and Capital Chains.
The details for each are:
- Dutch Data Protection Authority (Dutch DPA)
- Please use the Data Privacy contact details below
Who can you contact?
As the data controller, Capital Chains is responsible for your Personal Data that it collects. Should you wish to contact someone regarding any of the information above, please contact us at email@example.com