Engage Dialog B.V. (“Engage Dialog”) may process personal data, as defined in the General Data Protection Regulation (GDPR), for example when you make use of its website (www.engagedialog.eu). We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. Engage Dialog values clarity on how we process your personal data. This Privacy Notice describes the Engage Dialog’s policies and practices regarding its collection and use of your personal data, and sets forth your privacy rights with due observance of the GDPR and any related applicable legislation.
1. Contact details
Engage Dialog B.V. is the data controller and with its headquarters at Kosterijland 14 c, 3981AJ Bunnik, the Netherlands (“Engage Dialog”) and registered at the Dutch Chamber of Commerce with number 56142242. If you have questions or comments regarding this Privacy Notice please see under 11. “Questions”.
2. To whom does this Privacy Notice apply?
This Privacy Notice applies to visitors of our website and to other business contacts and job applicants.
3. What personal data do we process?
Engage Dialog processes personal data you have provided to us, personal data generated during your visit to our website and personal data we have obtained from other sources such as the personal data generated by social media platforms linked to our website:
– Interaction Data
If you provide us feedback or contact us via an online form, e-mail, or other means including by phone call or by contracting with us, we will collect your name and e-mail address, as well as any other content included in the form, e-mail or conversation, in order to send you a reply. We will store and process your communications and information as needed. When you participate in one of our surveys, we may collect additional information.
This Interaction Data also includes:
- details of the products and services you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries;
- any additional information relating to you that you provide to us directly through our website or indirectly through use of our website or online presence through our representatives or otherwise;
- information you provide to us through our support centre, customer surveys or visits by our representatives from time to time.
The legal basis for this processing is based on:
- either through your consent through your voluntary submission of the form and agreeing to these terms such as by clicking an “I Agree button”; or by your voluntary submission of data to us in other means;
- the personal data being necessary for the performance of a contract to which you are a party;
- for carrying out pre-contractual measures (this includes stages where you request to learn more about our services).
By submitting the form or making contact with us such personal data is transmitted on a voluntary basis and you consent to its collection.
– Subscription Data
On the website you may have the ability to subscribe to various newsletters or other forms. We may collect the data when you input your details for subscription purposes.
- The personal data is processed for the purpose of informing you of information regularly by means of a newsletter or other offer form. The personal information collected during the subscription will only be used for marketing purposes or for reasons made known on the form.
The legal basis for this processing is based on:
- your consent through your voluntary submission of the form and agreeing to these terms such as by clicking an “I Agree button”.
By submitting the form and voluntarily providing us with your data, you are providing consent to the use of such data by us. For the purpose of revocation of consent, there is a corresponding unsubscribe link found in each subscription email.
– Personal data obtained through or generated on our website
We automatically collect information about your computer hardware and software for analytical purposes. We collect IP addresses and browsing behaviour on the website such as information on your first visit, previous visit and current visit, the visited pages and the manner in which you navigate on the website. We track our customers visit within our site, in order to determine what services are the most popular. This data is used to deliver customized content and advertising within our sites to customers whose behaviour indicates that they are interested in a particular subject area.
– Other personal data
Our services are dynamic and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we use your data, we will modify this Privacy Notice and inform you.
4. Third party websites
5. What do we use your personal data for?
We use your personal data for various purposes:
- Informing you of services and products. We use the data to inform you of [Engage Dialog’s] products and services by arranging for meetings or calls, sending postal mails and e-mails to you, implement various campaigns, to respond to your requests or to handle your job application.
- Deliver services. We use the data to deliver products to buyers.
- Customer support. We use the data (which can include your communications) needed to investigate, respond to and resolve demands, inquiries and complaints and service issues (e.g., bugs).
- Conduct tests and surveys. We use the data to conduct questionnaire surveys and services and products monitoring tests to improve our services and to assist you in a better way.
- Improving and securing our website. We use the data to provide, support and make our services more relevant and useful to you and others.
- Employment. We process personal data in relation to our employees, temporary hires and independent contractors without personnel for the purpose of fulfilling our legal obligations as (legally perceived) employers and tax subject;
- Security and Investigations. We use your data if it’s necessary for security purposes or to investigate possible fraud or other violations of this Privacy Notice and/or attempts to harm our visitors our website, ourselves or others.
6. Legal grounds for processing
The main legal grounds used by Engage Dialog are:
- (Conclusion of) an agreement: we will process your personal data if and to the extent necessary to enter into or for the performance of a contract;
- A legal obligation; such as any legal investigation: to comply with relevant laws, regulations, enforceable governmental requests or to respond to subpoenas or warrants served on us to protect or defend the rights or property of [Engage Dialog] or users of our services; to investigate or assist in preventing any violation or potential violation of the law or any of our policies or procedures to protect the safety of any person or to protect the safety or integrity of our platform including for security reasons detect, prevent or otherwise address fraud, security, technical issues or any other act that poses a risk of being illegal, unethical or legally actionable to respond to an emergency.
- Your vital interests: in order to protect these, should the need arise; and/or
- A legitimate interest: we may also process your personal data, if we have a legitimate interest and do not disproportionately infringe on your privacy.
- Consent: you will always have the right to withdraw any consent given to process personal data. Withdrawal of consent will not affect the lawfulness of processing before the withdrawal.
7. Data retention
Your personal data will not be kept longer than necessary and will be deleted as soon as reasonably possible in view of the purposes for processing your personal data (see par. 5) or where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal data has been stored in backup archives), we will securely store your personal data and isolate it from any further processing until archiving is possible.
If you have questions about, or need further information concerning, our data retention periods, please contact us, see under 11. “Questions”.
8. Sharing personal data with third parties
We sometimes need to share your personal data with third parties:
- Service providers. We may use service providers (processors) to help us provide our services (e.g., storage, maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to personal information as reasonably necessary to perform these tasks on our behalf and are obligated to not to disclose or use it for other purposes. The processors may solely process your personal data based on our instructions. For example, we work with service providers offering SaaS solutions (Software as a Service) and other hosting services. We also hire IT service providers that provide support to the safe and stable operation of our systems. If we engage a third party to handle personal information, we shall perform appropriate thorough background checks on such third party and exercise proper supervision over such third party for the safe management of personal information. We will conclude a data processor agreement with our data processors, which meets the requirements laid down in the GDPR.
- Legal disclosures. We may need to share your data when it’s required by law or to protect your and our rights and security.
- Commercial use. Your personal data will not be shared with third parties for commercial purposes other than conducting our business.
9. Transfer outside the European Economic Area
We may need to transfer your personal data to parties located outside of the European Economic Area (EEA). We shall only transfer personal data to parties outside the EEA if an adequate level of protection of the personal data is ensured or if specific safeguards are in place (for example by making use of EU standard contractual (data protection) clauses) or if a legal derogation or exemption applies.
10. What are your rights with regard to your personal data?
In accordance with the GDPR and applicable legislation and depending on the circumstances, you have rights with respect to:
- Consent: you can withdraw this, see above under 6.1;
- Information, access and rectification of your personal data: you have the right to receive information about the type and contents of the personal data that is stored or processed by Engage Dialog or by third parties and to request the correction of and/or change to any incorrect or incomplete personal data that is held;
- Erasure and restriction of personal data: under certain circumstances, it is possible to request restriction of the processing or erasure of your personal data;
- Objection: you can object to the use of your personal data or request to limit its use;
- Data portability: you can request a copy of your personal data and the transfer thereof to another party.
- Profiling and automated decisions: you have the right to object to decisions made solely on automated processing and profiling;
- Complaints: you have the right to log a complaint with the supervisory authority, see under 12.1;
If you have any complaints about how we handle your personal data or any indications of misuse, please contact us by sending an email to firstname.lastname@example.org or calling +31 30 656 61 44. We would be happy to help you find a solution.
We keep our privacy notice under regular review and therefore our Privacy Notice may change from time to time, so please review this page of our website from time to time. If the changes are significant, we will provide a more prominent notice (including, for certain services, a website or email notification of changes). Your continued use of our website after we publish or send a notice about our changes to this Privacy Notice means that you are consenting to the contents of the updated Privacy Notice.
This Privacy Notice was last updated on 28 September 2018.