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PRIVACY STATEMENT EASYDUS B.V.

Version 2.0.1

To be clear regarding the privacy of the visitors to its website as well as its clients using the services Easydus provides, Easydus issued this privacy statement to ensure a correct understanding of its privacy policy. These privacy terms are subject to the use of the website and services as performed and/or delivered by Easydus and describes in which cases and in which way data is collected, used, published, transferred, secured, modified, deleted or destroyed. De Wet Bescherming Persoonsgegevens (hereafter: WBP): Easydus privacy policy is based on the Dutch legislation regarding privacy which is called: ‘Wet Bescherming Persoonsgegevens’ (‘WBP’). This is the Dutch equivalent of the American ‘Data Protection Act’, but then relevant to its own legal jurisdiction. The terms of this Privacy policy is assumed to be part of the Easydus general terms and conditions and serves, for certain points, as a further clarification of article 7 of these general terms and conditions.

1. General

1.1 General

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Easydus is a trade name used by the legal entity Easydus B.V. which has its registered office at: Stratumsedijk 25-2, 5611 NA Eindhoven, The Netherlands. Easydus BV is registered by the Dutch Chamber of Commerce with the number: 56131372
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Easydus B.V. develops and markets a software application to gather, register and communicate information. Services are offered about the use of the application.
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You can contact Easydus by: - Sending a contact form on www.easydus.com - Send an email to privacy@easydus.com - Send a mail to the address as above

1.2 Data Protection Act

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In line with article 1 sub A of the WBP (Wet Bescherming Persoonsgegevens, the Dutch equivalent of the Data Protection Act) Easydus defines ‘personal data’ as being: any information relating to an identified or identifiable natural person.

In line with article 1 sub B of the WBP Easydus defines ‘processing of personal data’ as: any operation or any set of operations concerning personal data, including in any case the collection, recording, organization, storage, updating or modification, retrieval, consultation, use, dissemination by means of transmission, distribution or making available in any other form, merging, linking, as well as blocking, erasure or destruction of data.

Examples of personal data can be amongst others someone’s name, gender, age, city of residence, e-mail address and/or IP address. Confidential personal data is data which contains sensitive personal information e.g. religion, philosophy of life, race, health, political preferences, sexual nature, etc..
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Easydus will carefully and in line with the WBP and other relevant legal regulations act concerning personal data.
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Easydus will maintain and implement reasonable and appropriate organizational, technical and physical measures to protect personal data against theft, loss, misuse and any other way of improper use.

2. Easydus as Controller

2.1 Purpose gathering and processing personal data

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Anybody requesting information via a contact form on the website, or requesting services by filling in a registration form is being asked to fill in personal data.
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Easydus will process these data automatically or semi automatically in a file for its own use and possible use of affiliated companies.
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The personal data as provided by the user will be used by Easydus in order to perform the services that user already uses or to offer services to (potential) users. The personal data will primarily be used for acceptance of an application and/or processing of that application. This personal data can also be used in sending promotional information on products or services offered by Easydus to this user. Personal data can also be used to inform the user regarding important information such as changes in the general terms and conditions and/or company (privacy) policies. Personal data can also be used for security reasons as well as for statistical analysis.
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Providing the data is done by choice and by doing so the user gives their unconditional agreement to the processing of his or her personal data as described in this policy.
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Besides personal data Easydus also collects and uses non-personal data. Non-personal data is defined as being data that cannot lead to the identification of a specific individual person. Non-personal data can be used, shared and collected for an unlimited number of purposes.
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Easydus reserves the right to use services of third parties in performing the tasks as described in this policy. Easydus will ensure that these third parties sign a confidentiality agreement committing them to the content of this policy. Third parties will only have access to the information needed to perform their job in a normal way. Employees of third parties will be granted access to this information on a ‘need to know’ basis and will be bound to the same confidentiality agreement as is applicable for the company by whom they are employed.

2.2 Users' right of inspection and correction

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In order to ensure that the personal data obtained remains correct, up-to-date and complete, the user is entitled to enforce their right of inspection and correction. The user may also request Easydus to improve, add, delete or block access to (parts of) the personal data if and when this (parts of) personal data turn out to be wrong, incomplete or non-relevant to the purpose of issuing and/of if and when in case of processing personal data against the law and/or in contrary to applicable regulations in users’ view.
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Easydus will inform the user within four weeks after receiving such a request if, and to which extent Easydus will grant the request. Easydus will always motivate a rejection of a request.

2.3 Publication of users' personal data

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Personal data of users will not be published to any third party (besides those appointed by Easydus) unless:- publication is needed to fulfill legal obligations; - in order to perform an agreement between Easydus and user, to safeguard a vital interest of the person involved or client, or in case a client provides unconditional and explicit permission for publication.

2.4 Storage of users' personal data

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Easydus will keep personal data no longer than needed for the purpose for which they are collected unless a longer term for storage is allowed and/or legally obliged.
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If personal data are being stored and processed outside the EEA this will openly be done according to the regulations of the WBP.

2.5 Right of objection

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If and when user no longer wishes to receive any (commercial) information from Easydus and/or her products and services, user can inform Easydus by sending a notification to: admin@easydus.com.
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In case of objection Easydus will take necessary arrangements to stop any processing as soon as possible.

3. Users’ right of inspection and correction

3.1 Customer is the Controller

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After coming to an agreement and becoming a customer of Easydus, the customer will have access to its own personal data of its customers in its own projects via the login on the website. These customer data are being imported via online web forms or uploaded, stored on servers and mailed to respondents and third parties. Personal data can also be communicated to payment providers in order to collect payments.
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Contrary to the personal data that Easydus processes for its clients, for the processing of personal data of the clients of Easydus clients, the following terms (in accordance with the Dutch WBP) for processing client data apply: User is to be seen as the ‘responsible party’ according to the WBP. According to article 1 sub d WBP, the ‘responsible party’ is defined as: the natural person, legal person, administrative body or any other entity which, alone or in conjunction with others, determines the purpose of and means for processing personal data. In this matter Easydus is to be seen as ‘processor’ according to the WBP. According to article 1 sub e WBP, the ‘processor’ is defined as: the person or body which processes personal data for the responsible party, without coming under the direct authority of that party. Easydus processes data in favor of the responsible user according to users’ instructions and users’ explicit responsibility. Easydus and responsible user that wishes Easydus to carry out processing by Easydus as a processor will obtain an applicable agreement as mentioned in article 14 paragraph 2 of the WBP.
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To the extent that Easydus has access to personal data, it shall only process these under instructions from the ‘responsible party’, unless legally bound to do otherwise.
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With regard to processing data on its own clients within the Easydus system, the user is at all times responsible and liable for compliance with the WBP and processing by Easydus. In order to be compliant client needs at least to have issued its own privacy policy. It is an explicit choice of the user as ‘responsible party’ to forward data to third parties or to publish data on a website or other communication medium.
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It is solely the judgment of the client to decide whether she is allowed to collect and process (sensitive) personal data.

3.2 Taking care as a Processor

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As a Processor Easydus stands to carefully process the data provided by the Controller and to take technical and organizational measures to safeguard them against loss or any form of misuse.
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Easydus will be sure that both own personnel and third parties contracted by Easydus are aware with the obligations concerning data protection. Contractual confidentiality arrangements will be closed with penalty of fine.
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Data of Easydus are being stored on servers in the cloud. Easydus makes use of a transactional mail provider and is linked to a payment service provider. In the choice of its partners Easydus demands in security, certification and storage and transport of data are being set. With the suppliers data processing agreements are being closed.
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Within Easydus continuously back ups are made of the total system with a standard frequency:
- Every hour a back up that is saved for three days
- Every night a back up that is saved for three months
- Every month a back up that is saved for 18 months
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To protect against customer mistakes projects will, when deleted by the customer, for one month be soft deleted in order to be able to reset the project when necessary. Soft deleted means the project is not shown in the project menu to users of the system. After a month all data will be deleted, except for data remaining in the saved monthly back ups.
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Easydus will in case of a data leak as soon as possible – but by any means within 24 hours – communicate the event in detail to the Controller. In detail means whenever possible to communicate the reason of the leak, the consequences of the leak and the solution of the problem.
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Controller has the right at its own costs to perform an audit regarding the protection of personal data at Easydus.

4. Use of cookies on the Easydus website and application

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On the Easydus website and app only anonymous user statistics are being gathered.
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The Easydus application uses a login token The IP address of the user and browser information are being linked to this token. This information is only used for the correct working of the system and the detection of problems. No personal data are being gathered. Aside from the token only anonymous user statistics are being gathered.
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This privacy- and cookie policy is not applicable to any third parties websites or apps offering a link or otherwise referring to our website or app This is also the case for linking wit hand sharing of data on social media such as Twitter and Facebook. We are not responsible for the data management and the privacy policies of these third parties and refer to the privacy policies of these third parties.

5. Other stipulations

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With the registration becoming a customer of Easydus you agree as a customer and as a Controller conform the WBP to this privacy statement. The agreement starts with the registration and continues to do so as long as Easydus acts as a Processor on behalf of the Controller.

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Easydus has taken an insurance against liability claims. On request the conditions regarding the insurance can be studied.
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The total liability of Easydus for culpable failure in the fulfillment of the contract is limited to compensation of direct damage and the maximum amount of the agreed price excluding VAT. If the agreement is a continuing agreement, the agreed price will the set at the total of the fees agreed for one year.
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If and when (a part of) Easydus will be restructured, merged and/or acquired by another company all personal data will be seen as part of such a transaction and therefore be seen as an asset owned by Easydus.
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Easydus reserves the right to change her privacy policy if and when needed. In order to be aware of any changes user is obliged to consult the at that time current version of the privacy policy to ensure user is aware of any changes.
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Dutch law exclusively governs agreements and any subsequent agreements with Easydus. The competent Dutch court in the district’s-Hertogenbosch will settle all disputes arising from aforementioned offers, advice, agreements and additional work.

Version 2.0.1