Privacy Statement SmartTrackers

Version: 17 januari 2022

SmartTrackers B.V., Van Marnixlaan 51, 3818 VB Amersfoort, The Netherlands, registered with the Dutch Chamber of Commerce under Number 61117536, is responsible for the processing of personal data as shown in this privacy statement.

Contact details

SmartTrackers B.V.
Gorterplaats 11A
6531 HZ Nijmegen
+31 (0)24 2022680

Website domains

smarttrackers.nl
Co2m-chart-exporting.herokuapp.com
clubvan49.nl

Personal Data we process
SmartTrackers B.V. processes your personal data by using our services and/or because you provide it to us.

Below you will find an overview of the personal data we process:

Name and surname
Phone number
E-mail address
IP Address
Other personal data that you actively provide for example by creating a profile on this website, in correspondence and by telephone
Information about your activities on our website
Internet browser and device type

Special and/or sensitive personal data that we process

Our website and/or service does not intend to collect information about website visitors under 16 years of age. Unless they have permission from parents or guardian. However, We cannot verify that a visitor is over 16 years old. We therefore recommend that parents be involved in the online activities of their children in order to prevent the collection of information about children without parental consent. If you are convinced that without this permission we have collected personal data about a minor, please contact us via info@smarttrackers.nl, we will remove this information.

For what purpose and based on what basis we process personal data

SmartTrackers B.V. processes your personal data for the following purposes:

Handling your payment
Sending our newsletter
To be able to call or e-mail you if this is necessary to perform our services
Inform you about changes to our services and products
Allow you to create an account
To deliver goods and services to you
SmartTrackers analyses your behaviour on the website to improve the website and to tailor the offer of products and services to your preferences.

Automated decision-making

SmartTrackers B.V. does not take decisions on the basis of automated processing on matters that may have (significant) consequences for individuals. These are decisions taken by computer programs or systems, without a human being (e.g. an employee of SmartTrackers B.V.).

How long we keep personal information

SmartTrackers B.V. does not keep your personal data any longer than is strictly necessary to achieve the goals for which your data is collected. We apply a maximum retention period of 1 year in connection with our backup procedures.

Sharing of personal data with third parties

SmartTrackers B.V. does not sell your data to third parties and will only provide it if necessary for the execution of our agreement with you or to comply with any legal obligation. With companies that process your data in our mission, we conclude an processors agreement to ensure the same level of security and confidentiality of your data. SmartTrackers B.V. remains responsible for these processing.

The following is a list of third parties with whom we share data for the SmartTrackers application (app.smarttrackers.nl):

Service Shared personal Data Retention period Purpose

Amazon S3 (Amazon.com Inc.) Uploaded files 1 year (after user deletion) Recover files in case of loss.

Amazon S3 (Amazon.com Inc.) All the above mentioned personal data 1 year Storing database backups (second off-site location).

Authy (Twilio Inc.) E-mail address and phone number – Provides two-pronged authentication methods for the application. These personal data are only shared when functionality is used by the user.

Trans IP (Trans IP B.V.) All the above mentioned personal data 1 year Trans IP provides us with a VPS environment with which we can make off-site database backups and is also the first off-site backup location.

Heroku (Heroku Inc.) All the above mentioned personal data Number of hours Heroku provides the hosting and server management of our (virtual) Web environment.

MemCached Cloud (Redis Labs Inc.) All the above mentioned personal data Number of hours Caching of HTML documents from the website in fast memory to improve performance.

Zendesk (Zendesk Inc.) IP address. In the case of Use Help function: name, e-mail address and content question. 1 year Handling and organizing questions that users can make via the Web application to our helpdesk.

Postmark (WildBit LLC.) IP address, e-mail address and possibly content of the mail. 45 days Sending notifications and system mails to users.

HireFire IP address, e-mail address, and possible form infills (in log files of request). Number of hours Performance measurements on the basis of which we run more or less processes.

The following is a list of third parties with whom we share data for the SmartTrackers websites (smarttrackers.nl, clubvan49.nl):

Service Shared personal Data Retention period Purpose

Trans IP (Trans IP B.V.) IP address. Number of weeks Handle requests while navigating the website.

Trans IP (Trans IP B.V.) In Case of filling In contact form:

Name, e-mail address, content of the question.
Number of weeks Contact the website visitor to answer the submitted question.

Google Analytics (Google Inc.) IP address. 14 months Analysis of the activity of visitors on the website.

Vimeo (Vimeo Inc.) IP address. – Retrieving video player to view the videos on our website.

The following is a list of third parties with whom we share data for our organization:

Service Shared personal Data Retention period Purpose

MoneyBird (MoneyBird B.V.) Billing information such as: Applicant name, e-mail address, telephone number. 7 years (mandatory storage period Administration Tax Office) Preparing invoices, tracking payments and keeping the financial records.

Scheffer Administraties Billing information such as: Applicant name, e-mail address, telephone number 7 years (mandatory storage period Administration Tax Office) Accounting.

Trello (Atlassian PTY Ltd) Name, e-mail address, phone number, and contact address information. 1 year Maintain internal administration, reporting and progress consultancy pathways.

Google workspace (Google Mail, Google Calendar, Google Docs, Google Inc.). Name, e-mail address, phone number, and contact address information. – Communication between employees of SmartTrackers and customers (or potential customers) via e-mail. Track contact information and scheduled appointments. Notes and minutes.

Campaign Monitor (Campaign Monitor Pty Ltd). Name, e-mail address, and IP address. – Composing and sending newsletters.

Cookies, or similar techniques, which we use

SmartTrackers B.V. only uses technical and functional cookies. And analytical cookies that do not infringe your privacy. A cookie is a small text file that is stored on your computer, tablet or smartphone on the first visit to this website. The cookies we use are necessary for the technical operation of the website and your ease of use. They make sure that the website works properly and, for example, remember your preference settings. We can also optimize our website. You can opt out of cookies by setting your Internet browser to not store cookies. In addition, you can also delete any information previously saved through your browser’s settings.

View, modify, or delete data

You have the right to view, correct or delete your personal data. You can do this yourself through your account’s personal settings. In addition, you have the right to revoke your consent to the data processing or to object to the processing of your personal data by our company and you have the right to transfer data. This means that you can submit a request to us to send the personal data that we have from you in a computer file to you or another organization you mentioned.

If you wish to use your right to object and/or the right to data transfer or have other questions/comments about the data processing, please send a specified request to info@smarttrackers.nl.

To ensure that the request for inspection has been made by you, please send a copy of your identity document to the request. In this copy, make your passport photo, MRZ (machine readable zone, the strip with numbers at the bottom of the passport), passport number and civic Service (BSN) black. This to protect your privacy. SmartTrackers B.V. will respond to your request as soon as possible, but in any case within 4 weeks.

SmartTrackers B.V. also wishes to point out that you have the possibility to lodge a complaint with the national Supervisor, the authority personal data. This can be through the following link: https://autoriteitpersoonsgegevens.nl/nl/contact-met-de-autoriteit-persoonsgegevens/tip-ons

How we protect personal information

SmartTrackers B.V. takes the protection of your data seriously and takes appropriate measures to prevent misuse, loss, unauthorized access, unsolicited disclosure and unauthorized alteration. If you have the impression that your data is not properly protected or there are indications of abuse, please contact our customer service or via iso@smarttrackers.nl. SmartTrackers B.V. has taken the following measures to protect your personal data:

Security software, such as a virus scanner and firewall.
TLS (formerly SSL) we send your data via a secure Internet connection. You can see this in the Address bar ‘https’ and the padlock in the address bar.
DKIM, SPF and DMARC are three Internet standards that we use to prevent you from receiving e-mails that contain viruses, are spam, or are meant to obtain personal (login) information from our name.
DNSSEC is an extra security measure (additional to DNS) for converting a domain name (smarttrackers.nl) to its associated IP address (server name); It is provided with a digital signature. You can have the signature checked automatically. This way we prevent you from being diverted to a false IP address.
The data on the machines of the employees of SmartTrackers B.V. are encrypted stored (full-disk encryption). In the event of loss or theft, this data cannot be seen by unauthorized persons.
Employees of SmartTrackers B.V. make sure they use two-stage verification methods to log in, if they are available for the third party services they use.
Regularly update our software and Web application framework so that possible (security-) bugs are fixed quickly.

Service	Shared personal Data	Retention period	Purpose
Amazon S3 (Amazon.com Inc.)	Uploaded files	1 year (after user deletion)	Recover files in case of loss.
Amazon S3 (Amazon.com Inc.)	All the above mentioned personal data	1 year	Storing database backups (second off-site location).
Authy (Twilio Inc.)	E-mail address and phone number	–	Provides two-pronged authentication methods for the application. These personal data are only shared when functionality is used by the user.
Trans IP (Trans IP B.V.)	All the above mentioned personal data	1 year	Trans IP provides us with a VPS environment with which we can make off-site database backups and is also the first off-site backup location.
Heroku (Heroku Inc.)	All the above mentioned personal data	Number of hours	Heroku provides the hosting and server management of our (virtual) Web environment.
MemCached Cloud (Redis Labs Inc.)	All the above mentioned personal data	Number of hours	Caching of HTML documents from the website in fast memory to improve performance.
Zendesk (Zendesk Inc.)	IP address. In the case of Use Help function: name, e-mail address and content question.	1 year	Handling and organizing questions that users can make via the Web application to our helpdesk.
Postmark (WildBit LLC.)	IP address, e-mail address and possibly content of the mail.	45 days	Sending notifications and system mails to users.
HireFire	IP address, e-mail address, and possible form infills (in log files of request).	Number of hours	Performance measurements on the basis of which we run more or less processes.