Privacy Policy

Versie: November 2023

‍

Table of contents

1. General information
2. When do we collect personal data?
3. What personal data do we collect?  
4. For what purposes and on what legal basis do we use your personal data? 
5. Use of cookies
6. Social media buttons
7. Recipients of personal data
8. Data transfer third countries
9. Retention periods of personal data
10. Security of personal data
11. Rights of data subjects
12. Changes
13. Contact, questions and complaints

‍

1. General information 

1.1 This Privacy Statement describes the use by Toogethr B.V., located in (3521 AZ) Utrecht at Stadsplateau 11, registered in the Commercial Register of the Chamber of Commerce under number 66724821 (hereinafter "Toogethr"), of your personal data. We at Toogethr are committed to respect your (online) privacy and acknowledge your need for appropriate protection and management of all personal data collected by or submitted to us (or to carefully selected third parties acting on our behalf).

1.2 It is important to us that the personal data of the users of our products and services, the visitors of our websites, our (potential) customers and our (future) partners are treated with care and that you are well informed about how we process your personal data. We have prepared this privacy statement to inform you on what data we process, how, why and for how long, and what your rights are.

1.3 In deze privacy statement, "personal data" means any information relating to a natural person who can thereby be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, psychological, economic, cultural or social identity.

1.4 This privacy statement applies to all personal data collected and used by us when you visit our websites and/or when you purchase or download and use the products and services offered by us and/or when you interact with us through social media or otherwise.

‍

2. When do we collect personal data?

We collect personal data when you:

• purchase, download or use products or services;
• visit our website(s);  
• request support for our products; 
• request software downloads;
• create a user account;
• request information or materials (e.g. white papers or newsletters); 
• participate in surveys or evaluations;
• participate in promotions, contests or giveaways; 
• contact us;
• apply for a job and/or submit your resume.

‍

3. What personal data do we collect? 

3.1 The types of personal data collected include: 

• First and last name;
• Title and name of your company; 
• Home, billing or other physical address (including street name, city or town name, state/province, zip code);
• (Business) E-mail address; 
• (Mobile) Telephone number (MSISDN);  
• For job applicants: education, work experience and interest in a job; 
• Any other identification that allows Toogethr to contact you physically or online; 
• Any information we collect and retain from you online in connection with your account, such as your username and password; 
• Any information we collect and retain from you online relating to the use of our products, such as IP address, date and time of the request, time zone difference from Greenwich Mean Time (GMT), content of the request, access status/HTTP status code, amount of data transferred, website from which the request originated, browser, operating system and interface, language and version of browser software, location information, identification number of your device, device name, unique device number (IMEI = International Mobile Equipment Identity), unique network subscriber number (IMSI = International Mobile Subscriber Identity) and MAC address for WLAN use;
• Marketing preferences, including consents you have given us; 
• Any other information you provide to us when you communicate with us.

3.2 We also collect information about the use of our website through cookies. For more information, please see the "Cookies" section below.

3.2 When we collect personal data directly from you, we indicate whether the provision of personal data is mandatory. This is the case when we need personal data to comply with legal or contractual obligations: if such data is not provided, we will not be able to manage our contractual relationship or fulfill our obligations. In all other cases, actively providing requested personal data is optional.

‍

4. For what purposes and on what legal basis do we use your personal data? 

4.1 We use your personal data for the following purposes:

• To establish and perform a contract with you or our customers' contact person(s), such as when you or our customers' contact person(s) make a purchase from us or download an application. This may include verifying your identity, taking payments, validating rides and accumulated points, sending reports on rides taken, communicating with you, providing customer service, or arranging other delivery of products or services;

• To enable our operations and pursue our legitimate interests. Specifically:

1. We use your personal data to provide services you have requested, given your consent to, and to respond to comments or complaints you send us; 
2. We monitor the use of our products and services and use your personal data to help us monitor, improve and protect our products, content, services and websites to ensure the stability and security of our products;
3. We may use your personal data to personalize our products or services for you;
4. We may use your personal data to ensure network and information security, including preventing unauthorized access to electronic communication networks and stopping damage to computer and electronic communication systems;
5. We may monitor any customer account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable laws and regulations; 
6. We may use your personal data for market research and marketing purposes; 
7. We may process data for administrative transfers within a group of companies.

For components for which you have given your consent, you may withdraw that consent at any time (in the app or operating system settings or by emailing privacy@toogethr.com). More information about how we have balanced our legitimate interests against your privacy interests can be obtained upon request at privacy@toogethr.com.

• For compliance with applicable laws and regulations and protection of our legitimate business interests and legal rights, including, but not limited to, use in connection with legal claims, compliance, regulatory and investigative purposes (including disclosure of such information in connection with legal proceedings or litigation).
• In addition, based on your consent (if required), we will send you direct marketing communications regarding our relevant products and services or other products and services provided by us, our affiliates and carefully selected partners. You may withdraw your consent at any time, see the section "Data subjects' rights" below. In the case of electronic direct marketing, you may opt out by following the instructions in the communication.
• Furthermore, you can use your name and email address to sign up for our newsletter or receive event invitations via the sign-up form on our website. You can unsubscribe from receiving emails at any time by following the instructions in the newsletters. If you are already a customer, we may contact you regarding relevant products or services in our legitimate interest to develop our business. We may do this via email or, if your email is registered on LinkedIn, connect with you on LinkedIn and/or send you messages on LinkedIn. If you are not already a customer of ours, we will only contact you, for example via email or LinkedIn, with offers or about our products or services if you have given us permission to do so. When we contact you via email in this context, you always have the option to unsubscribe at any time by contacting privacy@toogethr.com. 
• You can also download content, for example white papers and research reports, from our website using the forms provided. We collect the data you enter on the form, including your name, company and e-mail address. We process the data you enter on this form for our legitimate interest in tracking who downloads our content.

‍

5. Use of cookies

5.1 In addition to the personal data mentioned above, the use of our web page(s) and the use of our products for various functions uses technical devices, in particular cookies, which may be stored on your device (e.g. computer or smartphone). Cookies and similar techniques are small text files or information in a database, which are stored in the device memory of your device and assigned to the product you are using. Cookies allow certain information to flow to the entity that sets the cookie. Cookies cannot run programs or transfer viruses to your device, but are mainly used to make the Internet offerings faster and more user-friendly.

5.2 We use technically necessary cookies to achieve, facilitate and enhance the proper functioning of our website and products and improve the user experience. In addition, we use cookies to measure which web pages are visited, which features are used the most, to personalize content and advertisements, to provide social media features, and to analyze our traffic. This allows us to continuously improve these web pages to meet the needs of the visitors on our website. Furthermore, we share information about your use of our web page(s) with our partners, for example in the areas of social media, advertising and/or analytics. For more information, please see the Cookie Statement on our website.

‍

6. Social media buttons

6.1 We may use plugins from social media networks, such as Facebook, LinkedIn and Twitter, on our web page(s) and in our products. You can recognize these plugins by their logos. We also use plugins for the embedded video players found on our web page(s). Our plugins do not collect any personal data from you unless you click on these logos or videos. When you click on them, these plugins are activated and automatically transmit data to the plugin provider.

6.2 This means that when you surf our website, no personal data is initially collected by the providers of these social media plugins. It is only when you click on one of the plug-ins that your personal data is transmitted: by activating the plugin, data is automatically transmitted to the respective plugin provider and stored by them. We have no control over these parties, their sites or their privacy policies, and we have no influence over what data these providers collect from you or the extent of their data process.

6.3 This privacy statement does not apply to external parties or external web spaces and any processing of personal data by parties outside Toogethr or its group companies is not covered by this privacy statement. If you want more information about their data processing, we recommend that you read the respective privacy policies on the websites of these providers, especially before providing (personal) data.

‍

7. Recipients of personal data

7.1 We work with third parties to provide you with our website(s) and our products and services. Where necessary, we share your data with our service providers and professional consultants (e.g. in the areas of IT, CRM providers, logistics, telecommunications, sales and marketing). These third parties act exclusively on our behalf and are contractually obligated to comply with the provisions regarding the GDPR. When we share your data with these parties, we ensure that appropriate safeguards are in place to protect your information. For an overview of these third parties, please see the Cookie Statement on our website.

7.2 With respect to our app(s), when you download the app(s), the required information is transferred to the AppStore (Apple) and PlayStore (Android). Think in particular of username, email address and customer number of your account, time of download and the individual device identification number. In addition, the App Store still independently collects various data and provides you with analysis results. We have no control over this party or their privacy policies, and we have no control over what data they collect from you or the extent of their data processing. If you want more information about their data processing, we recommend that you read the respective privacy policy on their website, especially before providing (personal) data.

7.3 Otherwise, we do not share your personal data with third parties or affiliated companies, unless we have your consent in accordance with Article 6(1)(a) AVG, when this is necessary in connection with the above purposes, with legal claims or when we are required to do so by law.

‍

8. Data transfer third countries

We do not process data in countries outside the European Economic Area. However, we do cooperate with some sub-processors who (may) be based in a country or otherwise process personal data on a data server outside the European Economic Area. This is done only in accordance with applicable privacy laws and/or with European Commission approval, including the application of appropriate safeguards including - but not limited to - the Standard Contractual Clauses (the "SCCs") and the European Commission's EU-US Data Privacy Framework. In addition, an appropriate level of protection and security is ensured and the conditions of Chapter V of the GDPR are met. Upon request, this can be demonstrated in writing.

‍

9. Retention periods of personal data

9.1 We store your personal data no longer than is strictly necessary to fulfill the purposes, for which your data is collected. Your personal data will not be stored for longer than the duration of the use of our products and services or the contractual relationship related to our products. After that time, your personal data will be deleted.

9.2 In addition, in the event of a legal dispute or impending legal dispute with you or in the event of other legal proceedings, the storage of your data may exceed the specified retention period.

9.3 Legal requirements for the storage and deletion of personal data remain unaffected by this. When the retention period prescribed by legal provisions expires, personal data will be deleted unless further storage by us is necessary and there is a legal basis for this.

‍

10. Security of personal data

We maintain high security standards and take appropriate technical and organizational measures to ensure a risk-appropriate level of security in accordance with applicable laws and regulations. These measures are in line with the current, general state of technology, in particular to prevent the misuse, loss and/or unauthorized destruction, alteration, disclosure or access by third parties of personal data. Personal data can only be accessed by employees involved in the processing of personal data. Nevertheless, we are not liable if, despite the measures taken, third parties manage to gain unauthorized access to personal data. We would appreciate it if you report any security breaches or indications that your personal data is not properly secured or misused to our privacy officer at privacy@toogethr.com.

‍

11. Rights of data subjects

11.1 You have the following rights regarding your personal data to ask us:

• To obtain an overview and/or a copy of your personal data that we hold about you;
• To update or correct your personal data so that it is accurate; 
• To remove your personal data from our files in certain circumstances; 
• To restrict the processing of your personal data in certain circumstances;
• To transfer (some of) this data to other organizations.

To exercise the above rights, please send an e-mail to the Privacy Officer at privacy@toogethr.com. The Privacy Officer will then inform you of the steps to follow in accordance with our procedure. You will receive a confirmation email once your request has been granted.

11.2 In addition, you have the right to object at any time, based on your specific situation, to the processing of your personal data, in particular when we do not need to process the data to fulfill a contractual or other legal obligation or when we use the data for direct marketing or profiling. For more information, see the complaint procedure on our website.

11.3 Furthermore, you have the right to withdraw your consent at any time when we use your personal data with your consent. Please note that this does not affect the processing of your personal data prior to the withdrawal of your consent. To exercise the above rights, please send an e-mail to the Privacy Officer at privacy@toogethr.com. The Privacy Officer will then inform you of the steps to follow in accordance with our procedure. You will receive a confirmation email once your request has been granted.

11.4 However, there are some exceptions to these rights, for example: it is not possible for us to delete your data if we are required by law to keep it or if we keep your data in connection with a contract with you. Access to your data may also be possible. Similarly, access to your data may be denied if making the information available would reveal personal information about another person or if we are prohibited by law from disclosing such information.

‍

12. Changes

We may edit this privacy statement from time to time to keep it up to date, to ensure that it does not contain errors, to keep pace with new developments and opportunities, to ensure that it contains appropriate and accurate information about your rights and our processing activities, and to remain in compliance with applicable laws and regulations. If we make significant changes to this privacy statement, we will notify you by posting a notice on the website along with an updated version of the privacy statement, by email or by asking for your consent again.

‍

13. Contact, questions and complaints

We hope we have answered your questions about the processing of your personal data. If you have any questions, concerns or complaints about how we process your data, please feel free to contact our privacy officer at privacy@toogethr.com. For more information, see the complaint procedure on our website.

‍

This privacy statement was last modified on November 24, 2023.