4145-6692-7403, v. 2 (last updated 15-3-2023)
1 WHO IS RESPONSIBLE FOR THE PROCESSING OF (PERSONAL) DATA?
Civinc is an online discussion platform of Civinc B.V. (hereinafter “Civinc”), located at Tweede van der Helststraat 89h, 1073 AN Amsterdam. Civinc is active in the field of digital innovation.
We attach great importance to your privacy and the protection of personal data. The casual, anonymous setting of the conversations is central to our mission and we therefore take it extra seriously.
This privacy statement describes how we handle your privacy when you use the Civinc platform. it also describes, among other things, the rights that you, as the data subject, have.
On the Civinc platform you can have conversations with people who have a different opinion about certain topics. we refer to the application with which we make it possible to conduct these conversations hereinafter “the platform”.
All personal data is collected, processed and secured in accordance with the General Data Protection Regulation (“GDPR”). Civinc is responsible for the processing operations listed below under the GDPR.
2 HOW CAN YOU GET IN TOUCH?
If you have any questions about this privacy statement, you can send an e-mail to email@example.com, or by post to Civinc, attn. privacy contact person, Tweede van der Helststraat 89h, 1073 AN Amsterdam.
3 FROM WHOM DO WE PROCESS (PERSONAL) DATA?
We process the data of persons who use the Civinc platform and persons who contact us via email or social media. We do not save/store personal data but process it to enable the necessary functions of the platform. We only store data that cannot be directly traced back to you and are therefore anonymous, with the exception for when you choose to explicitly share personal details in direct communication or (feedback) forms, such as but not limited to your name and e-mail address.
4 WHAT DATA DO WE PROCESS?
Below is an overview of the categories of data that we process:
|Categories of (personal) data||Examples|
|Data that says something about the use of the platform||– That you use the platform|
– The type of equipment you use
– The operating system you are using
|– The internet browser you use |
– The start time of the conversation and the time of end of the conversation
– The time of starting individual conversations with partners and the time of ending these individual conversations
– Information collected by means of cookies (see also article 5 and the Appendix)
– User ID: This is a number assigned to you as a user of the platform
– Your answers to statements
– The number of messages sent between participants
– The content of the conversation (for 48 hours after session ends, solely to run necessary data analysis)
– The duration of the chats
– Number of likes distributed and received
– Number of conversation partners
– Who proposes to switch position/partner
– Your answers to the questions before and/or after the conversations
– Whether you have reported your conversation partner
|Communication and contact||– (E-mail-)correspondence|
|Public messages about Civinc you leave on the internet||– Messages on social media|
5 HOW DO WE GET YOUR PERSONAL DATA?
We receive part of the data because you provide it to us when you use the platform. We receive another part of your data because you communicate with us.
If you follow Civinc on social media or interact with or about Civinc on social media, we may gain access to some of your public profile information. If you share information about Civinc via social media, your data may become visible via those social media. Civinc itself also follows social media channels and in this way can access data about you on social media.
Some data is collected using cookies and similar techniques. Cookies are small text files that are stored on your computer, smartphone or other device when you visit our website. Cookies help us to operate and analyze the website. Cookies can remember data from your previous visit to our website so that the site works better and shows more relevant information for you.
A complete overview of the cookies we use can be found in the Appendix. We only use the analytical cookies of Google Analytics. We have set these cookies in a privacy-friendly manner, in accordance with the manual of the Dutch Data Protection Authority (AVG).
6 FOR WHAT PURPOSES DO WE COLLECT YOUR DATA AND ON WHAT BASIS?
|Goal & purpose||Examples|
|To enable (desired) use of the platform Basis: Legitimate interest We and the users of the platform have a legitimate interest that the platform functions properly and that the platform is not abused||To match you to a conversation partner To start the chat session. To stop unlawful and unwanted use of the platform. To improve the platform.|
|To ensure the security and stability of IT systems and secure the platform Basis: Legitimate interest We and the users of the platform have a legitimate interest in securing our IT systems and the platform.||Monitoring IT systems. To conduct internal audits and investigations. To adequately secure the platform and user data.|
|To combat unlawful and/or punishable acts via the platform Basis: Complying with legal obligations resting on us and/or Legitimate interest We and third parties have a legitimate interest in being able to combat unlawful or criminal acts.||To investigate unlawful and/or criminal acts To provide data to third parties if we are obliged to do so.|
7 ANONYMIZATION AND FEEDBACK
We delete the content of the chat session after the session has ended, as well as other data that can identify you. The answer to any open questions will be saved. Although we recommend in such cases not to share personal information in your answer, you can choose to do so. You then choose to make your personal data public. The answers to the statements and questions are aggregated and anonymized and cannot be traced back to individual participants. These responses provide insight into the attitude of participants towards the theme and can be fed back to the participating organization in the form of a report.
8 TO WHOM DO WE PROVIDE PERSONAL DATA?
We will share your answer(s) to the statement(s) and any other information you have provided at onboarding (such as group) with your conversation partner before the chat session starts.
In addition, we may use the services of third parties to process your data in accordance with this privacy and cookie statement. We have concluded a processing agreement with third parties that act as processor for us, which includes, among other things, that they will only process data on our behalf.
9 DO WE TRANSFER PERSONAL DATA TO OTHER COUNTRIES?
We may use third party services to process your data in accordance with this privacy and cookie statement. These parties will be located inside the European Economic Area (EEA). Further information and/or a copy of the agreement concluded in this context can be obtained by sending an email to firstname.lastname@example.org.
10 HOW LONG DO WE STORE YOUR DATA?
Your data will not be kept longer than we need it for the purposes for which it is collected or processed. Civinc uses the following retention periods, depending on the purpose and category of data:
– We do store the content of the chat sessions temporarily. The chat in which you are active is temporarily encrypted on the server. This way we can restore your chat if, for example, you (accidentally) refresh the page. All chat content will be deleted after 48 hours after each session. Chat meta-data will be stored as outlined in paragraph 2 and 6.
– We do not store your IP address.
11 WHAT HAPPENS IN THE EVENT OF THE TRANSFER OF THE COMPANY?
In the future, one or more parts or assets of Civinc may be transferred to a third party or Civinc may merge with a third party. In that case, your personal data may be transferred to this third party.
12 WHAT ARE YOUR RIGHTS?
You have a number of rights with regard to the processing of your data (see below). If you want more information about this or if you want to exercise one of these rights, please contact us via the contact details mentioned under article 2. We will respond to your request as soon as possible.
- Right to withdraw your consent;
- Right of access;
- Right to rectification;
- Right to erasure;
- Right to restriction of processing;
- Right to data portability;
- Right to object to processing;
- Right to object to direct marketing;
- Right to object and human intervention in automatic decisions;
- Right to make a complaint. This can be done at Civinc via email@example.com or at the Dutch Data Protection Authority.
We may change our privacy and cookie statement from time to time. This is possible, for example, if there are new data processing operations or in connection with developments in technology or regulations. If necessary, we will inform you of this when you use the platform. If necessary, we will ask for your permission for a changed or new processing.
ATTACHMENT: COOKIES OVERVIEW
The table below shows an overview of the cookies we use, including the purposes for which they are used and the third parties involved:
Statistical cookies help website owners understand how visitors use their website by collecting and reporting data. Where possible, the data is anonymized or pseudonymised.
|Google analytics||Analytics (improving website, analysis)||2 years||Third party|