Last updated: May 2018
G Concepts BV trading as TheBugCo® values the privacy of its customers and observes due care in processing and protecting personal data.
Privacy-sensitive and personal data are processed through our website, and during processing we comply with the requirements of the applicable data protection legislation. This means we:
- Clearly specify our purposes before we process personal data, by using this Privacy Statement.
- Limit our collection of personal data to only the personal data needed for legitimate purposes.
- First ask for explicit permission to process your personal data in cases where your permission is required.
- Take appropriate security measures to protect your personal data and demand the same from parties who process personal data on our behalf.
- Respect your right to inspect, correct or delete your personal data held by us.
TheBugCo® is the controller for all data processing. In this privacy statement, we will explain which personal data we collect and for which purposes. We recommend that you read it carefully.
Use of personal data
We take your trust and right to privacy seriously and work continuously to keep your digital footprint small and in your control. Nevertheless, to enable you in your flow and to improve and secure our service, we need to process some personal data.
By using our website, you are providing certain data to us. This could be personal data. We only retain and use personal data that has either been provided directly by you or that has clearly been supplied to us to be processed.
We may collect and process the following personal data:
- Personal data that you provide by filling in forms on our website. This includes registering to use the website, subscribing to services, newsletters and alerts, registering for a conference or requesting a white paper or further information. Pages that collect this type of personal data may provide further information as to why your personal data are needed and how it will be used. It is completely up to you whether you want to provide it.
- If you contact us, we may keep a record of that correspondence.
- Our website collects personal data about your computer, including (where available) your IP address, operating system and browser type, for system administration, to filter traffic, to look up user domains and to report on statistics.
- Details of your visits to our website, the pages you view and resources you access or download, including but not limited to, traffic data, location data, weblogs and other communication data. Please see the Cookies section below for more information.
The processing reasons
TheBugCo® may process your personal data for the following purposes:
- Operating the service and/or the website
- Providing (technical) support when you reach out to us
These two processing activities are necessary for the performance of the contract/website.
- Following up on legal requests for abuse reports, NTD Reports and fraud investigations
These processing activities are to comply with our legal obligation. In case of a violation or when we need to uphold our Terms, for example, we need to be able to search or share (some of) your personal data.
- Evaluating the use of our Website and Service as well as for statistical purposes. We only use the data in a pseudonymized form when we use your data for this purpose. This means that we cannot trace the data directly back to you. For example, instead of using your email address we use a random string of symbols.
Analysis of user behaviour is based on legitimate interest. This means we need this activity to protect and grow our business. Without being able to look at user behaviour we would most likely not learn enough about our users to offer you a valuable and relevant service.
- When you indicated so: enabling you to engage in actions, promotions or events we offer. After seeking your consent, we will engage with you to keep you posted about news, features, actions or promotions we think you may like. You’ll always have the option to stop receiving these messages from us.
- To fulfill your requests for white papers, articles, newsletters or other content.
We will only reach out to you once you have consented to that engagement. The legal base for sending you any email that isn’t a service-related one is consent.
Other than advertisements on our website, we can inform you about new products or services through our Facebook and Linkedin pages.
On our website we offer the option to ask questions via a form that requires you to fill in a number of details. The information you send us will be saved as long it is needed in order for us to fully respond to and process to the form or the contents of your email.
Providing data to third parties
Your data will not be provided to third parties unless it is necessary in order to process your request.
Our website features social media buttons that are used by the providers of these services to collect your personal data.
Our website can place these cookies for the following purposes:
- Functional cookies are used to provide functionalities when using our website
- Analytical cookies are used to optimise our service to you. For example to optimise the usability of our website by AB-testing a new feature, to make the website more user-friendly and to analyse how you use our website. We also use analytical cookies to stop bots and malicious behaviour like spam.
- Advertisement cookies are used for commercial, editorial and promotional purposes. With these cookies your internet- and surf behaviour can be followed over various domains and websites. Advertisement cookies are often placed by third parties. TheBugCo® does not have access to or control over (personal) data collected via) these cookies or other features that advertisers and third parties may use. Our Privacy Statement is therefore not applicable to these cookies, and we refer you to their Privacy Statements to read how they handle (personal) data.
What are my rights are a user?
You can send your request to access, correction or deletion of your personal data to TheBugCo® by using the email address firstname.lastname@example.org. Please state clear in the subject that your request concerns a privacy matter, and more specific whether it is a request to access, correction or deletion. Bear in mind that under circumstances TheBugCo® requests for additional information to determine your identity.
- The right to request a copy of your personal data that TheBugCo® holds about you.
- The right to request that TheBugCo® corrects your personal data if inaccurate or out of date.
- The right to request that your personal data is deleted when it is no longer necessary for TheBugCo® to retain such data.
- The right to withdraw any consent to personal data processing at any time. For example, your consent to receive e-marketing communications:
- If you want to withdraw your consent to e-marketing, please let us know by using email@example.com.
- The right to request that TheBugCo® provides you with your personal data and, if possible, to pass on this information directly (in a portable format) to another data controller when the processing is based on consent or contract.
- The right to request a restriction on further data processing, in case there is a dispute in relation to the accuracy or processing of your personal data.
- The right to object to the processing of personal data, in case data processing has been based on legitimate interest and/or direct marketing.
We take security measures to minimize misuse of and unauthorized access to personal data.
If, despite our commitment and efforts to protect your personal data, you believe that your data privacy rights have been violated, we encourage and welcome individuals to come to TheBugCo® first to seek resolution of any complaint. You have the right at all times to register a complaint directly with the relevant supervisory authority or to make a claim against TheBugCo® with a competent court (either in the country where you live, the country where you work or the country where you deem that data privacy law has been infringed).
We will retain your personal data only for as long as is necessary. We maintain specific records management and retention policies and procedures, so that personal data are deleted after a reasonable time according to the following retention criteria:
- We retain your data as long as we have an ongoing relationship with you (in particular, if you have an account with us).
- We will only keep the data while your account is active or for as long as needed to provide services to you.
- We retain your data for as long as needed in order to comply with our global legal and contractual obligations.
Third party websites
This statement is not applicable to third-party websites connected to our website through links. We cannot guarantee that these third parties will handle your personal data in a secure and careful manner. We recommend you read these websites’ privacy statements before making use of their websites.
Changes to this privacy statement
We reserve the right to modify this statement. We recommend that you review this statement regularly, so that you remain informed of any changes.
Inspection and modification of your data
Please do not hesitate to contact us using the detail below should you have any questions about our privacy statement or changes to (or deletion of) your personal details.
You may send us a request to view, change or delete these details. Furthermore, you may send us a request a data export containing the details that we use with your permission; you may indicate that you wish us to limit the use of your personal details.
In order to avoid fraud, we may ask you to identify yourself. Where personal details linked to a cookie are concerned, you may request a copy of the cookie. You can access this in your browser settings. Should the details be inaccurate, you may request that we change or delete them.
We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to firstname.lastname@example.org. We will look into and respond to any complaints we receive.
You also have the right to lodge a complaint with the (insert legal authority in Netherlands).
For further information on your rights and how to complain to the CBPL/CPVP, please refer to the Netherlands privacy commission website.
If you have any questions about this privacy statement or how and why we process personal data, please contact us at: