Privacy Policy

1. Introduction – identification of the data controller

Circular In Motion B.V., having its registered seat at 5913AB Venlo (The Netherlands), Kaldenkerkerweg 27, with KvK (company registration) number 78636361 (hereinafter “CIM BV”, “we” or “us”), operates the digital platform “Circular In Motion”, including every web page belonging to the “cirinmo.com” domain (hereinafter “Website”), including any and all desktop, tablet and mobile applications and application program interfaces (hereinafter “Applications”) and any and all services offered through said digital platform, including Website and Applications, by CIM BV. Our digital platform, including Website, Applications and all services offered through our digital platform, including Website and Applications, are hereinafter jointly referred to as “Cirinmo”.

CIM BV undertakes to comply with Regulation (EU) 2016/679 of the European Parliament and of 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 (the “General Data Protection Regulation”, hereinafter referred to as the “GDPR”). The GDPR can be consulted at any given time via: https://eur-lex.europa.eu/eli/reg/2016/679/oj.

Since CIM BV determines the purposes and means of the processing of the personal data, CIM BV is to be considered as the “data controller” of the personal data collected via Cirinmo.

This Privacy Policy explains the reason for the processing of your personal data, the way we collect, handle and ensure protection of all personal data provided, how that information is used and what rights you have in relation to your personal data. It also specifies the contact details of us being the data controller with whom you may exercise your rights, as well as the contact details of the relevant data protection authorities.

2. What personal data do we process?

At present, we only process personal data that you provide us yourself.

We assign personal data to you for – in general – the use of and communication with regard to Cirinmo, including – especially – the purposes as enlisted under article 3 of this Privacy Policy.

3. For what purposes and on what legal ground(s) do we collect and process your personal data?

Via Cirinmo, we collect and process the following personal data, for the following purposes, based on the following legal grounds:

Purpose

Personal data collected and processed

Legal ground

(1) To respond to all sorts of inquiries with regard to Cirinmo

Contact name, E-mail, Company name. (Optional: Phone number.)

GDPR, Art. 6(1)(f): personal data is necessary for the purposes of the legitimate interests pursued by the Organization or by a third party, and there is no prejudice to the data subject arising from the use.

(2) To inform you about the launch of and enable you to sign up as a user for the Beta- version(s), as well as the first fully operational version of Cirinmo

Contact name, Company name.

E-mail,

GDPR, Art. 6(1)(f): personal data is necessary for the purposes of the legitimate interests pursued by the Organization or by a third party, and there is no prejudice to the data subject arising from the use.

(3) To send you updates about Cirinmo and receive the Cirinmo newsletter

Contact name, E-mail, Company name. (Optional: Phone number.)

GDPR, Art. 6(1)(a): you have given consent to the processing of your personal data for one or more specific purposes


4. How long do we keep your personal data?

Without prejudice to the exercise of your rights as referred to under article 7 of the present Privacy Policy, and unless we are required by law to keep your personal data for a longer period of time and/or unless such longer period is necessary for the establishment, execution or substantiation of a legal claim, all personal data collected and processed…:

… for the following purpose:

… will be kept:

(1) To respond to all sorts of inquiries with regard to Cirinmo

until the end of the first calendar year following the calendar year during which the inquiry was resolved

(2) To inform you about the launch of and enable you to sign up as a user for the Beta-version(s), as well as the first fully operational version of Cirinmo

until the end of the first calendar year following the launch of the first fully operational version of Cirinmo

(3) To send you updates about Cirinmo and receive the Cirinmo newsletter

until you unsubscribe from the updates and newsletter list (via the link provided in all related communication).


5. How do we protect and safeguard your personal data?

We have put in place appropriate technical and organisational measures to protect your personal data against loss, misuse and unlawful processing. These measures include (1) secure communication of data using https, (2) storage of e-mail addresses and phone numbers in an encrypted database and (3) servers protected with industry standard anti-malware, virus killers and other protection software.


6. Who has access to your personal data and to whom is it disclosed?

Access to your personal data is provided to CIM BV’s staff on a “need to know” basis.
Your personal data will not be transferred to any third party without your consent, except for:

–  technical service provider(s) of Cirinmo;
–  affiliated legal entities;
–  our general and legal successors in title;
– to the extent and for the purpose we may be required to do so by law.


7. What are your rights and how can you exercise them?

As a data subject, you have specific rights under the GDPR, in particular the right to:

–  access your personal data;
–  amend your personal data;
–  object to the processing of your personal data;
–  limit the processing of your personal data;
–  have your personal data deleted;
–  withdraw your consent.

Where applicable, you also have the right to data portability.

You can exercise your rights by contacting CIM BV in written by email or by ordinary letter using the contact details as adopted below under article 9 of the present Privacy Policy. Please indicate clearly which of the abovementioned rights you want to exercise.


8. Complaints

Should you have any complaints about the processing of your personal data, please don’t hesitate to contact us.

Any complaint may also be filed at any given time with the following Data Protection Authorities:

–  The Dutch “Autoriteit Persoonsgegevens” (to be considered as the “Lead Supervisory Authority” in case of cross-boarder processing of your personal data, given our “main establishment” being in The Netherlands):

Autoriteit Persoonsgegevens Bezuidenhoutseweg 30
P.O. Box 93374
2509 AJ Den Haag/The Hague The Netherlands

Phone number: +31 70 888 8500
Fax number: +31 70 888 8501
Website: https://autoriteitpersoonsgegevens.nl

Contact: https://autoriteitpersoonsgegevens.nl/nl/zelf-doen/gebruik-uw-privacyrechten/klacht-melden-bij-de-ap

–  You own national Data Protection Authority:
Contact details per country: https://edpb.europa.eu/about-edpb/board/members_en

9. General contact information

Circular in Motion B.V.

Kaldenkerkerweg 27 5913 AB, Venlo
The Netherlands

Phone number: +31 (0) 85 48 54 120
E-mail: privacy@cirinmo.com

Version and date of this Privacy Policy: Version n° 1
November 9, 2020