Effective Date: February 09, 2021
Thank you for visiting this site provided by ACN Europe B.V. (Company No. 34110202) which is incorporated under the laws of The Netherlands and whose registered address is Thomas R. Malthusstraat 1-3, 1066 JR Amsterdam, The Netherlands (referred to herein as “Company”, “we”, “us, or “our”). We are serious about the privacy of our customers and users of our websites and applications (individually and collectively, “you”).
Who Collects Your Personal Data
What Personal Data Do We Collect?
How Do We Collect Personal Data?
Why we Use Personal Data
Legal grounds for processing Personal Data
How We Transfer Personal Data to Third Parties
How Long We Keep Your Personal Data
Where We Store Your Personal Data
Third-Party Sites and Content
Provision of Cardholder Data
Your Right of Access, to Rectification and Erasure of Your Personal Data
Your Right to withdraw your consent
Your Right to restriction of processing
Your Right to data portability
Your Right to object
Opting Out of Promotional Offers from Company
ACN Europe B.V.
Thomas R. Malthusstraat 1-3
1066 JR Amsterdam
2. Additional Terms
In some cases, when you have requested a particular product or service, we may need to collect additional information, or use your information in different ways to provide that product or service. In such cases, additional information about our collection, use and disclosure of your Personal Data with respect to specific Company services and products may be found in the relevant terms and conditions, notices, and statements for those services and products (“Additional Terms”).
4. Who Collects Your Personal Data
5. What Personal Data Do We Collect?
The Personal Data and other information that we collect varies depending on your relationship with the Company.
When providing IDSealSM products and services, we may process the following Personal Data:
Residential and business address;
Date of birth;
Product information on the service/product you licensed, such as type, start date and status;
Recordings of telephone calls where you have been provided with notice of the recording at the start of the call as well as the possibility that you can refuse to such recording;
Electronic and written communications;
Your IDSeal account login information;
When visiting our websites, we may process the following Personal Data:
IP addresses and general geolocation information;
MAC addresses, operating system, and browser information.
6. How Do We Collect Personal Data?
We collect your Personal Data in a variety of ways, including:
the submission of Personal Data by you to Company through the websites or services;
the submission of an online order for IDSeal services or products from Company;
when you communicate with us by email, telephone, fax, chat line, the websites, or otherwise;
provision of your Personal Data to Company by Company’s business partners, such as our engaged payment processing providers, in order for you to use the IDSeal services or products (also see section 8); and
Although Company collects Personal Data primarily from you, it may also collect Personal Data from other sources including service providers, or other third parties who represent that they have a right to disclose that information.
Company will not contact you by telephone or email to request sensitive information such as credit card numbers, account numbers, passwords, and PIN codes. We recommend that you do not respond to telephone calls or emails requesting this type of information and that you contact us if you receive such a request that purports to be from Company.
7. Why we Use Personal Data
Company collects and processes Personal Data and other information for a variety of purposes, including:
to present our websites and their respective contents to you;
to verify, process, and administer your orders for IDSeal services and products;
to collect payment from you for IDSeal services and products;
to provide IDSeal services and products to you;
to maintain our commercial relationship with you, including billing and customer service;
to carry out our obligations and enforce our rights in connection with any contracts that you may enter into with us, including the provision of notices pursuant to those agreements;
to provide you with information about your Company account, your purchases, and our policies;
to understand and respond to your service needs, including problems with your IDSeal services and products;
to meet our legal and regulatory obligations, protect Company’s legal and financial interests (including fraud detection and prevention), and to conduct compliance investigations;
to comply with Company’s statutory reporting obligations to government agencies (e.g. collecting and remitting taxes, responding to regulatory authority inquiries in the field of consumer protection or data protection);
for the provision and receipt of services and fees;
to prepare internal (aggregated) reporting on customer matters and general business needs;
to provide to our business partners and their representatives that market and promote IDSeal services and make referrals to Company, for commission purposes, such as tracking, compensation, supervision, and training purposes;
to facilitate Company’s financial, accounting and administrative functions;
to allow us to identify and inform you about related services and products offered by Company that may be of interest to you, including sending commercial and marketing communications;
for any other purpose disclosed by us when you provide the Personal Data, including in any privacy polies associated to Additional Terms; and
for any other compatible purpose with your informed consent.
8. Legal grounds for processing Personal Data
• The processing is necessary to perform an agreement between you and Company
Processing purposes: a., b., c., d., e., f., g., h., l., n., p.
• The processing is necessary for us to comply with our legal obligations
Processing purposes: i., j., n., p.
• The processing is necessary for the legitimate interests of Company, except where such interests are overridden by your interests or fundamental rights and freedoms
Processing purposes: a., e., f., g., h., i., k., l, m., n., o., p.
• Where appropriate and required, we will ask for your consent.
Processing purposes: o., p., q.
9. How We Transfer Personal Data to Third Parties
Agents that are licensed to promote the IDSeal services and products in the EU on our behalf and the company that pays those agents: such as our Independent Business Owners and our parent company, ACN, Inc.
Payment processing providers: such as Elavon Financial Services DAC and/or GoCardless LLC
Hosting and back-up providers: such as Amazon Web Services and Rackspace
IT providers of the IDSeal services and products: such as IDSeal, LLC
Customer service providers: such as our affiliate Telecommunications Operations & Service Centre (ACN) sp zoo
We also may provide Your Personal Data to governmental authorities as part of regulatory, statistical, or analytical reports, as required or allowed by applicable laws and regulations, to investigate and help prevent potentially unlawful activity, or in response to a specific request from government, regulatory, or law enforcement authorities, such as a subpoena, search warrant, or other legal process. We also may disclose your Personal Data to the extent we determine doing so is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others, which includes exchanging information with other companies and organizations.
We reserve the right to transfer any Personal Data we have about you in the event that we merge with or are acquired by a third party, undergo another business transaction such as a reorganization, or should any such transaction be proposed.
10. How Long We Keep Your Personal Data
The Company keeps your Personal Data as long as it is required for the purposes for which it was initially collected in accordance with our records retention policy, subject to applicable law. Such period varies depending on the type of Personal Data involved. For example, we keep customer service records for five years, while customer contracts are kept for the term of the agreement plus ten years. In some cases, we need to keep your Personal Data for a minimum period of time in order to comply with legal or regulatory obligations. Please contact us using the contact details above if you have questions about specific retention periods.
11. Where We Store Your Personal Data
The Personal Data processed by Company for the purposes indicated in section 7 is directly collected from you. For international transfers of personal data pursuant to Article 44 et seq. GDPR that take place for the purposes described herein and for all other purposes Company will take all measures required to comply with GDPR in order to ensure the protection of your Personal Data. For instance, by storing your Personal Data on secured computer servers and entering into data processing agreements with its processors.
13. Third-Party Sites and Content
14. Provision of Cardholder Data
Company may require you to provide our payment providers with credit or debit card information (“Cardholder Data”) in connection with the purchase of IDSeal products and services. Cardholder Data may be used for current payments and stored for future or recurring payments. Payments are issued through our payment providers. Company requires its providers to maintain controls consistent with the Payment Card Industry Data Security Standard and other industry standards to protect Cardholder Data; however, these safeguards may not prevent every unauthorized attempt to access, obtain, or use Cardholder Data.
Nonetheless, you should also take measures you deem appropriate to safeguard your Personal Data, such as by maintaining the confidentiality of your access credentials, logging out of websites, closing your web browsers when you have concluded your online activities, changing your passwords regularly, and not providing your Personal Data to persons who are unfamiliar to you.
Company may communicate with you by email or chat and these communications may at times contain Personal Data. These communications may not be secure. Please do not send government-issued identification numbers, financial information, Cardholder Data or other sensitive information to us by email or chat, and we will not ask you to provide such information in this manner.
16. Your Right of Access, to Rectification and Erasure of Your Personal Data
You have the right to access the Personal Data that we hold about you, and to have us correct your Personal Data if the information that we have is inaccurate or incomplete, and, in some cases, to request deletion your Personal Data. You may obtain a copy or correct or request deletion of your Personal Data by contacting our Privacy Officer in writing at :
ACN Europe B.V.
Thomas R. Malthusstraat 1-3
1066 JR Amsterdam
Please note, however, that in some cases we may not be able to allow you to access certain Personal Data in certain circumstances, for example if it contains Personal Data of other persons, or for legal reasons, to protect our interest in legal proceedings. We may require you to verify your identity before we allow you to access, correct or delete your Personal Data.
17. Your Right to withdraw your consent
You have the right to withdraw consent for our use of your Personal Data however please be aware that doing so may impact our ability to provide services and products to you where such information is necessary for the provision of such services and products. Please also note that we are permitted to keep certain of your Personal Data in order to meet our legal, financial, audit, and business needs, even if you withdraw your consent.
18. Your Right to restriction of processing
You are entitled to ask us to (temporarily) stop using your Personal Data, for example where you think that the Personal Data we hold about you may be inaccurate or where you think that we no longer need to use your Personal Data.
19. Your Right to data portability
You may have the right to ask that we transfer Personal Data that you have provided to us to a third party of your choice. This right can only be exercised when you have provided the Personal Data to us, and when we are processing that data by automated means based on your consent or in order to perform our obligations under a contract with you.
20. Right to object
You have the right to object to the processing of your Personal Data which is based on our legitimate interests. You may also ask us to stop using your Personal Data for marketing purposes at any time, and if you so, we will immediately cease use of your Personal Data for this purpose. For other purposes based on our legitimate interests, we will no longer process the Personal Data on that basis when you file an objection, unless we have a compelling legitimate ground for the processing. Note, however, that we may not be able to provide certain services or benefits if we are unable to process the necessary Personal Data for that purpose.
21. Opting Out of Promotional Offers from Company
If you consent to having your email address or contact information used by us to promote our own or third-parties’ products or services and later change your mind, you can withdraw your consent (opt-out) by sending us an email stating your request to firstname.lastname@example.org. In addition, you may later opt-out of promotional emails by clicking the unsubscribe or opt-out or unsubscribe link contained in such emails.
The Company does not promote products and services to children or knowingly accept orders from individuals below the age of majority.
24. Contact Us
You also have the right to lodge a complaint with the competent data protection authority in your country of residence or domicile. You can find the names and contact details of the data protection authorities in the EU under https://edpb.europa.eu/about-edpb/board/members_en.
Issue Date: 1 April 2021
2.0 What Are Cookies?
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but Personal Data that we store about you may be linked to the information stored in and obtained from cookies. Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website.
If you do not know what cookies are, or how to control or delete them, then we recommend you visit http://www.aboutcookies.org for detailed guidance.
Please be advised that the cookie related information that may be collected is not used to identify you personally. These cookies are not used for any purpose other than those described herein.
The cookies we use can be classified into the following categories:
Essential Cookies. We have identified these cookies as being strictly necessary for proper functioning of our websites and to allow users to access secure areas of the Sites.
Non-Essential Cookies. These cookies are not essential for the Sites to function but are used to provide, maintain and improve our services to meet your needs. We do not set any of these cookies without your consent. We may process your Personal Data by means of these cookies. For more information on how we use your Personal Data, please review the Policies.
3.1. Technical Cookies
We use a session cookie to remember your log-in for you if you are a registered user, and what you have put in the shopping basket, when you are on a page where a shopping basket may be available. These we deem strictly necessary to the function of the Sites. If these cookies are disabled then various functionality on the Sites will be broken. The Sites runs the popular WordPress CMS and cookies are used to store basic data on your interactions with WordPress, and whether you have logged into WordPress. More information on session cookies generally and how they are used is available at https://www.allaboutcookies.org.
3.2 Analytics Cookies
3.3 Third Party Cookies
These are cookies set on your machine by external websites whose services are used on the Sites. Cookies that may be set across the Sites, depending upon the availability of the sharing third party website, include LinkedIn, Twitter and Facebook used in connection with the “share” buttons across the site for the purpose of permitting visitors to share content onto social networks. Certain videos on the Sites are hosted by Vimeo and cookies are used to enable you to watch the embedded video. In order to implement these features and connect them to the relevant social networks and external websites, there are scripts from domains outside of the Sites. You should be aware that these third party websites are likely to be collecting information about what you are doing all around the internet, including on the Sites.
You should check the respective policies of each of these third party websites to see how exactly they use your information and to find out how to opt out, or delete, such information.
4.0 How to Control Cookies
You can control and/or delete cookies at your discretion by adjusting your browser’s settings (for instance, under the “Internet Options,” “Settings” or “Preferences” feature of your browser). Please note, however, that refusing to accept cookies from us may affect your experience using the Sites. Please visit https://www.allaboutcookies.org/ for further details about how you may control cookies. You can delete all cookies that are already on your system and you can set most browsers to prevent them from being placed. If you do this, however, you may need to manually adjust some preferences every time you visit a site (including the Sites) and some services and functionalities may not work as intended.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt -out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website, located here: http://optout.networkadvertising.org/?c=1.
Issue Date: April 2, 2021