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Privacy Statement

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1. Who is responsible for processing your data?

This privacy statement describes how VirtuaKey ("VirtuaKey" or "we") as the data controller handles your personal data processed through the VirtuaKey App ("App"). VirtuaKey is the provider of the App.
 

2. What is personal data?

Information about an identified or identifiable natural person is considered personal data. Whether certain information qualifies as personal data depends on whether VirtuaKey has legal means that can reasonably be expected to be used to identify an individual.

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3. Personal data we process

We process personal data about you because you provide or make data available to us when entering into an agreement for the App, but also when you use the App and thereby provide us with data or enable us to record data about your interests and preferences.

Data provided or made available to us If you enter into an agreement with VirtuaKey for using the App, we need the following personal data from you, which you provide or make available to us:

  • Name

  • Email address

  • Other data relevant to the specific agreement

Data about your use of the App When you use the App or otherwise interact with VirtuaKey, we may process the following data, depending on your specific use of the App:

  • SSO login details

  • Other relevant (unstructured) data provided by you
     

4. Processing: legal bases and legitimate interests

The processing of personal data is based on the following legal bases under Article 6 of the General Data Protection Regulation:

  • Consent

  • Performance of a contract with you

  • Legal obligation

  • Legitimate interest of VirtuaKey or a third party

Legitimate interests include: marketing, advertising, security, (crime) prevention, IT management, (market) research and analysis of our products or services, business operations, legal matters, and internal management.
 

5. Purposes for processing personal data

VirtuaKey processes your personal data for the purposes listed below. The number behind each purpose corresponds to the legal basis mentioned in Article 4 of this privacy statement:

  • To offer the App and provide services from the App [legal basis: 1, 2].

  • To communicate with you and send promotional messages, such as offers, announcements, and updates about actions, newsletters, events, surveys, and other products or services. [legal basis: 1, 4].

  • To analyze the use of the App (types of users, click behavior, etc.) and functionalities to identify trends and develop new products (product development) [legal basis: 4].

 

6. Analytical, statistical, and scientific processing

We may process your data for market research, historical analysis to discover trends and correlations in data, or to contribute to research for social and/or scientific purposes or traffic safety improvement.

We may share your data with parties affiliated with VirtuaKey and, if necessary, third parties. These data may include your personal data, and we take appropriate measures (such as hashing, aggregation, and encryption) to protect your privacy so that personal data can no longer be directly traced back to you as a natural person (pseudonymized).

We process your data based on the legal basis of legitimate interest. You can stop the processing of personal data for the purposes described in this article by notifying our customer service (see contact details below).

 

7. Sharing with third parties

We share your personal data with third parties in the following cases and for the associated reasons:

  • If an event is organized by VirtuaKey in collaboration with a third party, your personal data will be shared for registration/participation purposes [legal basis: 2 or 4].

  • If you make a purchase via our App, we will share your data with the party responsible for processing payments [legal basis: 2].

  • If you encounter an issue or have a question about the App, authorized VirtuaKey staff or hired suppliers may access your personal data to assist you [legal basis: 4].

VirtuaKey will only provide access to personal data to third parties when necessary for:

  • Providing a service

  • Maintenance and support activities

  • Transactions involving the sale or transfer of VirtuaKey assets

  • Compliance with legal requirements or orders from competent authorities

If third parties qualify as processors under applicable data protection laws, VirtuaKey will establish written agreements with these parties. Data collected via the App is stored on servers within the European Economic Area (EEA).

 

8. Data Retention

We store personal data in accordance with our internal retention policy and/or for as long as:

  • You are a customer of VirtuaKey or continue to show interest in VirtuaKey services.

  • We are legally required to retain data.

  • We have valid grounds for retaining data, as long as necessary.

VirtuaKey will not store data longer than required for the purposes outlined in this statement. At the end of each calendar year, data collected in the preceding year will remain available for a maximum of 12 months after the start of the new calendar year. This retention period applies to users who have unsubscribed from all VirtuaKey-related services.

 

9. Your rights, including the right to object

You have the right to:

  • Withdraw your consent.

  • Access your personal data.

  • Rectify incorrect data.

  • Request data deletion.

  • Restrict processing.

  • Object to direct marketing.

  • Object to processing based on legitimate interest.

  • Data portability.

You can exercise these rights by contacting our customer service at info@virtuakey.nl. To verify your identity, we may ask for a copy of your identification document, with sensitive information (e.g., photo, document number, BSN) obscured.

 

10. Stop processing personal data and withdraw consent

You can stop the collection and processing of your data by contacting customer service at info@virtuakey.nl. You must also uninstall the App. Your data will be retained according to the retention periods specified in Article 8.
 

11. Analytics

The App uses analytics services, such as Google Analytics, to understand usage and improve functionality. Data may be transferred to servers in the USA.

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12. Security

VirtuaKey has implemented technical (e.g., secure servers, encryption) and organizational measures (e.g., access controls, regular audits) to ensure your data is protected against unauthorized processing, loss, or misuse.
 

13. Contact

For questions or comments about this privacy statement: VirtuaKey
Email: info@virtuakey.nl

We have a Data Protection Officer (DPO) registered with the Dutch Data Protection Authority, who oversees privacy compliance. You can contact the DPO via info@virtuakey.nl.
 

14. Changes to this privacy statement

This privacy statement may be updated. Significant changes will be communicated through the App or via email.

 

Last updated: November 30, 2024.

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