Privacy Policy

Last Updated: October 14, 2024

1. Introduction 

1.1. This Privacy Policy (“Privacy Policy”) governs the processing of personal data by DataSnipper B.V. & DataSnipper Inc (“DataSnipper”, “we”, “our”), collected from or by individuals including our customers, users of our website (https://datasnipper.com (“Website”)) and its subdomains, users of the DataSnipper Software, and individuals we interact with offline. Hereinafter we refer to such individuals as “you”. This Privacy Policy tells you what personal data we process from you and what we do with your personal data.

1.2. When we use the term “Personal Data” we refer to personal data as defined in article 4 of the General Data Protection Regulation (Regulation 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC) (“GDPR”).

1.3. When we use the term “DataSnipper Software” we mean the DataSnipper proprietary software licensed to you under the terms and conditions as described in your Order Form and applicable Documentation. If any capitalizedterms used in this Privacy Policy are not defined herein, they shall have the meanings ascribed to them in the termsand conditions applicable to your Order Form.

1.4. Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Data and how we will manage and protect it.

1.5. DataSnipper may amend this Privacy Policy at any time. In case the Privacy Policy is amended, we will make the amended Privacy Policy available on our Website. At the top of this Privacy Policy, you can see when this Privacy Policy was last updated. Please consult this privacy policy regularly for the most up-to-date information.

2. Processing of Personal Data

2.1. To provide you with good service and fulfill our agreement, we collect data from you. Some of this data you provide directly, such as when you submit web forms, interact with our Website, or use the DataSnipper Software. Other data is collected indirectly, for example, through automatic data technologies or tools. We also collect data from third parties, such as advertising networks, service providers, data analytics providers, and social media platforms.

Information you provide to us

When you visit our Website

• We collect Personal Data when you submit web forms or interact with our Website such as your first and last name, job title, email address, date of birth, telephone number, IP address and other similar business information.

When you use the DataSnipper Software

• When using our User Management System (“UMS”) or the our Automatic Advanced Reporting Feature (“AARF”), we collect User Data, such as, email address, organization & IP address.
  
• When using our Optical Character Recognition (“OCR”) feature, we process Customer Documents, meaning the documents of Customer that have been imported with DataSnipperSoftware and have been selected for Optical Character Recognition. However, if you opt to use OCR with your own private endpoint, we do not process any data when using OCR.
  
• When using UpLink, we process Customer Documents and Customer Data, meaning documents uploaded and reviewed using the system's features.
• We collect payment and billing information, for example, we may ask you to provide a billing address, or a billing contact for your DataSnipper account. You may also provide payment information, such as a credit card number or bank account numbers, when purchasing products or services.

Information we obtain from you

• Online identification data. We process data through automatic data technologies or tools (e.g., Cookies (as defined below) and other tracking technologies, including but not limited to Google Analytics), which collect certain information about your IP address, Website usage, and browser setting. For more information about the automatic tools (Cookies and scripts) we use, please see below Section about “Cookies” under Section 4.
• Video Calls. We conduct sales calls via video calls during which we use a service provider called Gong. If you consent beforehand, Gong creates and provides a written transcript of the calls (video and audio) and collects biometric data via facial recognition technology. Gong uses artificial intelligence to process Personal Data (which may include biometric data) to enable us to analyze such Personal Data, e.g., speaking time of salesperson vs. customer. DataSnipper uses the Personal Data Gong provides exclusively for internal purposes, e.g., for the training of our sales representatives. DataSnipper does not share with any third-party the biometric data Gong collects or generates on our behalf unless required by applicable law. Gong collects and processes this Personal Data solely for the purposes specified by DataSnipper and in accordance with the terms of a specific data processing agreement. If you are planning to participate in a video sales call with us, please review Gong’s privacy policy, found here: https://www.gong.io/privacy-policy/ prior to joining the call.
  
  Before each video call, DataSnipper will inform you again that biometric data is collected and will give you an opportunity to consent or opt out of the recording.

From third parties and/or public sources

For example, through advertising networks, from service providers, data analytics providers and social media.

2.2. We store your Personal Data in accordance with SOC 2 audit criteria or such other audit standards we deem relevant and adequate. We store such Personal Data for as long as necessary to process such Personal Data for the purposes set forth in Section 0 of this Privacy Policy.

2.3. With respect to aggregated and de-identified information we collect, we will not attempt to reidentify the information, except to determine whether our deidentification processes satisfy the requirements pursuant to applicable law.

3. Purposes and legal grounds of Personal Data collection and processing

3.1. Personal Data is collected and processed by DataSnipper for the following purposes and based on the following legal grounds:

4. Disclosure/Sale/Sharing of your Personal Data

4.1. DataSnipper will only share your data with third parties to the extent permitted by current legislation. We may provide your personal data to third parties when:

• We have engaged them to process certain data;
• We have engaged them to process certain data;
• We are legally obligated to do so (e.g., if the police demand this in case of a suspicion of a crime).

4.2. DataSnipper discloses your Personal Data to the following third parties:

Third parties processing personal data on our behalf or yours:

• IT service providers
• Email service providers
• Payment service providers
• Video conferencing providers
• Applicant handling software provider
• CCTV system provider
• Advertising service providers

Other companies in the DataSnipper group: We may disclose your Personal Data to companies within the DataSnipper group to the extent necessary for us to fulfill the purposes mentioned under Section 0;

Counterparties in a corporate transaction: We may disclose your Personal Data to a potential buyer during negotiation of, in connection with, a corporate transaction where your Personal Data is included as an asset (e.g., a merger, acquisition, joint venture, or financing or asset sale). Your Personal Data may also be disclosed in the event of insolvency, bankruptcy, or receivership;

Profiling; Advertising based on Lookalike Audiences. From time to time, we provide third-party companies (e.g., Meta) with your Personal Data and certain aggregated and de-identified data to request from such companies the creation of lookalike audiences (i.e., customers likely to be interested in our offerings because they share characteristics similar to our existing customers). This enables us to target our advertising efforts to the members of the lookalike audience.

5. Cookies

5.1. We use cookies and other technologies (e.g., pixels, tags) (collectively, the “Cookies”) on our Website. Cookies are text or image data files that are placed or saved on the internet browser of the user’s computer system. They enable the browser or mobile device to be uniquely identified when the user visits the Website again. In Annex I you will find a list of the Cookies we currently use on the Website.

Functional Cookies. We use certain Cookies that are necessary to run the Website. Deactivating these Cookies will compromise the functionality of the Website. Such essential Cookies therefore cannot be deactivated. If you do not agree with our use of such essential Cookies, your only choice is not to visit the Website.

Analytical, Tracking, and Advertising Cookies. We also use Cookies to track and analyze the behavior of the visitors to our Website. You are given the option not to consent to the use of these Cookies when you are prompted via the cookie banner prior to entering the Website. However, if you do so, you will not be able to enjoy the full functionality of the Website. If you do consent to the use of these cookies, the following activities take place:

Cross-context Behavioral/Targeted/Interest-based Advertising. Cross-context behavioral advertising means sending you targeted advertising based on information (which may include Personal Data) obtained from your activity across businesses, websites, applications, or services with which you intentionally interacted. We may use third party advertising companies to serve you targeted advertising based on your Personal Data as well as aggregated and de-identified data collected when you visited our Website (e.g., browsing history). We may disclose to, or permit, such third-party advertising companies to collect information about your use of our Website to enable them to display advertising on our behalf.

Profiling; Advertising based on Lookalike Audiences: From time to time, we provide third-party companies (e.g., Meta) with your Personal Data and certain aggregated and de-identified data to request from such companies the creation of lookalike audiences (i.e., customers likely to be interested in our offerings because they share characteristics similar to our existing customers). This enables us to target our advertising efforts to the members of the lookalike audience.

Google Analytics and Google Ads: We use a tool called “Google Analytics” - a web analytics service provided by Google to monitor the performance of our Website and collect information on your use of our Website. You can learn more about how Google Analytics collects and processes information here: https://policies.google.com/privacy?hl=en-US; and how to opt out of being tracked by Google Analytics by following the instructions found here https://tools.google.com/dlpage/gaoptout.

We also use Google Ads, a service that allows us to reach people who previously visited our Website. Google Ads may use Cookies and/or device identifiers to serve you ads on various sites on the internet based on your past visits to our Website. You may opt out of the use of this Cookie by visiting Google’s Advertising and Privacy through this link: https://policies.google.com/technologies/ads or by visiting Google Ads Settings accessible through this link: https://adssettings.google.com/anonymous?hl=en or declining the use of analytical, tracking and analytical Cookies when prompted as you enter our Website.  We note that Google only has access to aggregated and de-identified information being collected through these tools.

Do Not Track
Some internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track”, please visit here.

The cookies may collect the following data from you, among others:

• Name
• Login information
• IP address
• Cookie ID
• Website and click behaviour
• Referrer URL

Enabling and disabling cookies: You can set your web browser to only accept cookies with your consent. Consult your browser guide for more information. Please note that many websites will not function optimally when cookies are disabled.

Deleting cookies: Most cookies have an expiry date. When an expiry date is set, the cookie is automatically deleted once that date passes. You can also choose to delete the cookies manually before the expiry date. Please consult your browser guide for more information. Below, you will find a link to the provider’s website for each browser, which provides step-by-step instructions on how to block or delete cookies.

• Internet Explorer
• Google Chrome
• Firefox
• Edge
• Safari

6. Security

DataSnipper maintains administrative, technical, and physical controls which are designed to protect your Personal Data against loss or theft, and against any unauthorized access, risk of loss, disclosure, copying, misuse, or modification. We implement security measures where appropriate and applicable, such as, but not limited to:

• Pseudonymization and encryption of Personal Data while in transfer;
• Measures to ensure the ongoing confidentiality, integrity, availability, and resilience of processing systems and services;
• Measures to restore the availability of and access to Personal Data in a timely manner in the event of a physical or technical incident; and
• A process for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures to ensure security of processing.

7. Retention Policy (our “Retention Policy”)

Personal Data are retained for various lengths of time depending on what is reasonably necessary for us to fulfill the purpose for which it was collected. Applicable laws, rules, or regulations may require that we retain it for a longer period of time. We determine the retention period based on the following criteria: the nature of the Personal Data; the context in which the Personal Data have been collected; the consequences to you of deleting the Personal Data, and whether appropriate protections, such as pseudonymization, have been applied to the Personal Data.

8. Data Privacy rights

8.1. Below is a list of requests that you can submit to DataSnipper in connection with your Personal Data.

Right to access
‍You may ask us whether we collect or use any of your personal data and, if so, to receive access to that data in the form of a copy.

Right to rectification
You have the right to have your data rectified if it is inaccurate or incomplete. Upon request, we will correct inaccurate personal data about you and, taking into account the purposes of the processing, complete incomplete Personal Data.

Right to erasure
You have the right to have your personal data erased. This means that we will delete your data. Erasure of your personal data only takes place in certain cases, as prescribed by law and listed in Article 17 of the GDPR, for This includes situations where your Personal Data is no longer necessary for the purposes for which it was originally processed and situations where your data was processed unlawfully.

Right to restriction of processing
You have the right to obtain a restriction on the processing of your personal data. This means that we will suspend the processing of your data for a certain period. Circumstances which may give rise to this right include situations where the accuracy of your personal data is contested, and we need some time to verify its (in)accuracy.

Right to data portability
Your right to data portability entails that you may ask us to provide you with your personal data in a structured, commonly used and machine-readable format, and have such data transmitted directly to another controller, if technically feasible.

Right to object
If the legal basis for processing your Personal Data is the 'legitimate interests' ground (including profiling), you have the right to object to the processing of your Personal Data. You can object to direct marketing at any time if your Personal Data is processed for this purposes, which includes profiling to the extent that it is related to direct marketing.

Withdrawal of consent
If the legal basis of processing Personal Data is your consent, then you may withdraw your consent at any time by following the specific instructions concerning the processing for which you provided your consent. You may also contact us using the contact information below.

8.2. There may be situations where we are entitled to deny or restrict your rights. We may, for example, deny your request for access when necessary to protect the rights and freedoms of other individuals, or refuse to delete your Personal Data in case the processing of such data is necessary for the performance of a contract or for us to comply with legal obligations.

8.3. You can make any of the foregoing requests by contacting DataSnipper using the contact information under Section 11 below. To fulfil your requests under this Section 7, we may request specific additional information from you to verify your identity.

To fulfil your 3request, we will need to verify your identity through a number of (personal) questions. We require this information to ensure that the requested personal data belongs to the right person.

We will generally comply with your request within one month. However, this period may be extended by two months depending on the specific privacy rights or the complexity of the request. If we extend this period, we will inform you in good time.

If you wish to exercise any of your rights, you can do so by sending an e-mail to legal@datasnipper.com.

9. Minors

The Website is not meant for users under the age of 18. We do not knowingly collect information from users under the age of 18, and do not target users under the age of 18. If we receive a valid and verifiable notice through legal@datasnipper.com that a user under the age of 18 has provided us with Personal Data, we will take measures to delete it as soon as possible.

10. Links to Other Sites

The Website may, from time to time, contain links to and from the websites, plug-ins, and applications of our partner networks, advertisers, affiliates, or social media sites. This Privacy Policy does not apply to practices of such third-party websites and online services you may access, which may (or may not) have privacy policies. Please note that DataSnipper does not control such “linked” websites (or the content contained on such websites) and takes no responsibility for their content. To learn about the data privacy practices of these third parties, please visit their respective privacy notices, policies, or contact the website owner directly (in the absence of a privacy notice or policy).

11. Contact Information

To ask questions about this Privacy Policy or to exercise your rights under section 7, contact us at:

DataSnipper B.V.
Aambeeldstraat 34
1021 KB Amsterdam, The Netherlands
legal@datasnipper.com

We will address each question internally and communicate this further with you. Should you feel we have not been able to help you properly with any questions about your privacy, you have the right to file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

If you need to access this Privacy Policy in an alternative format due to having a disability, please contact legal@datasnipper.com.
Please click here if want your data to be deleted from our database.

Annex I – Cookies