At grip, we are committed to protecting your Personal Data and to providing clear and transparent disclosures about the types of information we collect and how we use it.
For your further visits to our website, we would like to inform you about data collection, processing and use when visiting and using our website. As well as objection, revocation, and other rights to which you are entitled as a person affected by data collection and use.
We would like to ask you to read this policy along with our Cookie Policy and if you are a user of our services, please refer to our Service Privacy Policy and our Data Processing Agreement.
In principle, we will only use your Personal Data in accordance with the applicable data protection laws, in particular the General Data Protection Regulation (“GDPR”), and only as described in this Privacy Policy.
General Information
a) What is Personal Data?
Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not Personal Data. This includes, for example, the number of users of a website.
b) What is Special Category Data?
Special category data is Personal Data that needs more protection because it is sensitive. This includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data. As well as, data concerning health, a person’s sex life; and a person’s sexual orientation. In order to lawfully process Special Category Data, it is necessary to consent to the processing.
c) What is processing?
"Processing" means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
d) Responsible for data processing
Responsible for data processing is Adepti of Zeeburgerdijk 486. Amsterdam, The Netherlands. We act as the data controller and ask you to direct all questions about your Personal Data directly to us using info@adepti.co or write us to the above address.
e) The Legal Bases for processing Personal Data
In accordance with the above-mentioned laws, we have to have at least one of the following legal bases to process your Personal Data:
- you have given your consent,
- the data is necessary for the fulfillment of a contract / pre-contractual measures,
- the data is necessary for the fulfillment of a legal obligation or
- the data is necessary to protect our legitimate interests, provided that your interests are not overridden.
General Principles
a) Security
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us.
You can recognise an encrypted connection if the address line of your browser contains a "https://" instead of a "http://" and also has a lock symbol. If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
We have also implemented numerous security measures (“technical and organizational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.
Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion.
Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.
b) Minors
We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.
c) Automated decision-making
Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.
d) Do Not Sell
We do not sell your Personal Data.
e) Special Category Data
Unless specifically required when using our services and consent is obtained for that particular service, we do not process special category data.
f) Social Media
We are present on social media on the basis of our legitimate interest. If you contact us (or login/connect with us) via social media platforms, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contractual service, if any.
g) International Transfer
We may transfer your Personal Data to other companies and/or business partners as necessary for the purposes described in this Privacy Policy. In doing so, your Personal Data may be transferred to so called third countries. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Data we transfer.
f) Where is your data stored?
In the course of our business and website operations, we process data in our Amsterdam based headquarters. All data collect is generally transferred to our Amazon Web Services (AWS) Server. The legal basis for the data processing is our legitimate interest in providing our website.
g) How long is your data stored?
We process and store your Personal Data only to achieve the respective processing purpose or for as long as a legal retention period exists (in particular Dutch’s commercial and tax law). Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.
h) Sharing and Disclosure
We will not disclose or otherwise distribute your Personal Data to third parties unless this is a) necessary for the performance of our services for example with our web host or with our logistic partners to deliver your order, b) you have consented to the disclosure, c) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; as required by law or regulation; if grip (or a part of grip) is sold to or merged with another company; or proceedings at home or abroad or to fulfill our legitimate interests.
Data we collect automatically
a) Collection of access data and log files
We also collect data on every access to our platform. The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Log file information is stored for security reasons (e.g., for the clarification of abuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is necessary for evidentiary purposes is exempt from deletion until the respective incident is finally clarified. The legal basis for the data processing is our legitimate interest in providing an appealing platform.
b) Use of cookies
We use so-called cookies on our web site. Cookies are small text files that are stored on your respective device (PC, smartphone, tablet, etc.) and saved by your browser. For further information please refer to our Cookie Policy. The legal basis for the use of cookies is your consent as well as our legitimate interest.
Data from third party sources
We may obtain data about you from third-party sources, such as our marketing partners, social networks, and other third parties. We may use this data to better analyze your user behavior to improve our ability to provide you with relevant marketing information and services, and to prevent and combat fraud.
Insofar as you have also given us your consent to process your Personal Data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.
Data we collect directly
a) General
We may ask you for Personal Data when you:
- use our website,
- request services, support or information,
- participate online or otherwise in marketing activities,
- subscribe to grip marketing and promotional emails or other materials,
- interact with us on third-party social networking sites (subject to the terms of use and privacy policies of said third parties), or
- contact us.
Categories of Personal Data we collect may include your name, email address, and IP addresses. We may also collect demographic data such your interests, and preferences.
In order to provide you with a more consistent and personalized user experience in your interactions with grip, data collected through one source may also be linked to other data collected by grip through other sources. This may include data that helps us identify you when you access our website through several different devices.
b) Contacting us
If you contact us, we process the following data from you for the purpose of processing and handling your request: first name, last name, e-mail address, and, if applicable, other information if you have provided it, and your message. The legal basis for the data processing is our obligation to fulfill the contract and/or to fulfill our pre-contractual obligations and/or our legitimate interest in processing your request.
c) Hubspot
For booking a Meeting in an easy and convenient way, we use Hubspot. Your data from the form will be transferred to our appointment account at Hubspot after you press the"Book appointment" button.
You will then receive a confirmation email with a link to the event. Your data will be kept at Hubspot until the purpose for storing the data no longer applies (appointment made) or you request us to delete it. Hubspot undertakes not to pass on your data to third parties. The legal basis is your consent as well as our legitimate interest.
d) Account Registration
If you register on our website, we will request mandatory and, where applicable, non-mandatory data in accordance with our registration form. The entry of your data is encrypted so that third parties cannot read your data when it is entered. The basis for this storage is our legitimate interest in communicating with registered users and, in the case of contracts, also the storage of contract data.
e) When using our services
We process the data of our registered users in order to be able to provide our contractual services as well as to ensure the security of our services and to be able to develop it further. This includes in particular our support, correspondence with you, invoicing, fulfillment of our accounting and tax obligations. Your data will not be used by us for automated decision making or profiling, nor will it be shared with third parties. Accordingly, the data is processed on the basis of fulfilling our contractual obligations as well as to fulfill our legal obligations.
The legal basis for the data processing is the fulfillment of our contractual obligations and, in individual cases, the fulfillment of our legal obligations as well as your consent.
Some of the data you choose to provide may be considered non-Personal Data and/or “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. By choosing to provide this data, you consent to our processing of that data.
Where any Personal Data relates to a third party, you represent and warrant that the Personal Data is up-to-date, complete, and accurate and that you have obtained the third party’s prior consent for our collection, use and disclosure of their Personal Data for the Purposes. You agree that you shall promptly provide us with written evidence of such consent upon demand by us.
Unless otherwise specified the purposes of processing are contractual performance and service, contact requests and communication, office and organizational procedures, administration, and response to requests, visit action evaluation. The legal basis for the data processing is the fulfillment of our contractual obligations and, in individual cases, the fulfillment of our legal obligations as well as your Consent.
You may withdraw your consent and request us to stop using and/or disclosing your personal and special category data by submitting your request to us in writing to info@adepti.co
Please note when using our services, you become the data controller and we become the data processor in accordance with Chapter 4 of the GDPR. Where we process your Personal Data as a data intermediary on behalf of you, we will process the Personal Data involved in accordance with your instructions and shall use it only for the purposes agreed between you and us, for further information please refer to our Service Privacy Policy and our Data Processing Agreement.
f) Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.
g) Credit/Debit Cards Payments
Payment by credit card and debit card is made via the payment service provider Stripe to which you pass on your payment details during the checkout, for payment processing. The legal basis for the provision of a payment system is the establishment and implementation of the user contract for the use of the service.
Data processing through integration of third-party services and content
We use content or service offers of third-party providers on the basis of our legitimate interests in order to integrate their content and services ("content").
This always requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content.
The following provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and so-called opt-out measures, if any:
- Analytics and Tracking: Google Analytics by Google LLC
- Spam protection: reCAPTCHA by Google LLC
- Tag Management: Google Tag Manager and Google Site Tag by Google LLC
Your Rights and Privileges
a) Privacy rights
Under the GDPR, you can exercise the following rights:
- The right to access – You have the right to request copies of your Personal Data. We may charge you a small fee for this service.
- The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete the information you believe is incomplete.
- The right to erasure – You have the right to request that we erase your Personal Data, under certain conditions.
- The right to restrict processing – You have the right to request that we restrict the processing of your Personal Data, under certain conditions.
- The right to object to processing – You have the right to object to our processing of your Personal Data, under certain conditions.
- The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you have any questions, please contact us.
b) Updating your information
If you believe that the information, we hold about you is inaccurate or request its rectification, deletion, or object to its processing, please do so by contacting us.
c) Withdrawing your consent
You can withdraw consents you have given at any time by contacting us.
d) Access Request
In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.
e) Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection.
Changes
We may update this Privacy Policy from time to time. If we make changes to this Privacy Policy or materially change our use of your Personal Data, we will revise the Privacy Policy accordingly.
Questions?
If you have any questions about the processing of your Personal Data, please contact us using info@adepti.co or write us to the above address.
This Privacy Policy was last updated on Friday, September 15, 2023.