1. Introduction

This Privacy Policy declaration informs you about how DIPA Global B.V. (hereinafter also referred to as “we”) handles your personal data (hereinafter also as “your data”). We attach great importance to protecting the personal rights of users (hereinafter “users” or “you”) of our products, adhere to the applicable data protection regulations and take the necessary measures to protect your data.

Websites of other providers that can be accessed via our websites are not subject to the data protection regulations stated here. We assume no responsibility or liability for the observance of data protection by third party websites.

2. Data Processing and Purposes of Use

2.1 General Information

“Personal data” means any information relating to an identified or identifiable person. This includes, for example, contact data such as name, telephone number, address or email address; as well as other information that you provide to us for example, during registration, as part of an inquiry or when participating in competitions or surveys and the like.

Any handling of personal data, including in particular, the collection, storage, administration, use, transmission, disclosure or deletion of your data, is considered “processing”. Your data will only be used for the respective purposes which are communicated to you in this data protection Privacy Policy declaration. We take the necessary precautions to protect your personal data from loss, theft and misuse.

In this statement we will inform you in which cases we collect data about you, what data we process from you, for what purposes we use it and to whom it may be passed on. We will also explain to you what rights you have with regard to your data and how you can assert them.

2.2 Non-anonymous users

In the course of the registration process, request forms or the downloading of files, registration for a newsletter, we collect personal data from you such as first and last name, address, email address; and other data such as telephone numbers or date of birth, as well as all data voluntarily entered by the registered user in his user profile.

We use this data to process the inquiries received, to enable and check your access. As a basis for access to online products, data on individual usage behaviour is also collected and evaluated in order to improve our products. Your data will also be used for customer care, and for personalised marketing purposes (e.g. pop-ups).

The online transmission of personal data between the user’s browser and DIPA Global B.V.’s servers is encrypted using the HTTPS protocol. In order to enable the functionality of this encryption technology, the user is obligated to use the current browser versions.

2.3 Anonymous users of our website

When you visit our website, we and third parties collect, store and use data from registered and non-registered users by using “cookies” and similar technologies. Cookies are text files that are stored on the user’s device and which allow an analysis of the use of the products.

This technology makes it possible to recognise individual users as (returning) visitors and to offer them individualised services and products. In general, the use of cookies serves to improve our services and make them more effective and secure. Users of our website can prevent cookies from being saved by selecting “do not accept cookies” in their browser settings.

However, this can hinder the functionality of the website and make it more difficult for users to optimise their online services. Furthermore, the use of our digital services is measured and evaluated by means of various technological systems, mainly from third-party providers. The aforementioned technologies are used in particular to analyse the surfing behaviour of users and to measure reach. The reach measurement can be used by advertisers to determine how many targeted individuals were reached by their efforts. The information collected with such technologies can also be used for marketing purposes, to improve products and websites, to evaluate usage behaviour, and to deliver and design personalised advertising formats (e.g. by means of pop-ups).

In addition to the browser cookie setting, we offer the option of accepting two different cookie settings: 1. EU-compatible cookies, 2. all cookies. The differences are explained below as follows:

1. Services with EU-compatible cookies that are always enabled: Google Analytics (with anonymised IP), Google Tag Manager, online ads
2. all cookies (activated services):
i) Third-party embedded content and services
ii) Embedded functions of various social media services
(Facebook, Pinterest, LinkedIn, email, Twitter etc.)

2.3.1 Use of Google Analytics

DIPA Global B.V. uses Google Analytics. This is a web analysis service of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses cookies which are stored on your computer to enable an analysis of the use of the website.
The information determined by these cookies (time, location, pages accessed and anonymised IP address) are sent to Google and stored in the USA.

Google uses this information to evaluate the use of our website https://www.substratebank.com and to generate reports on the use of the website for DIPA Global B.V.. Google offers a tool for use on most common browsers, with which Google Analytics can be deactivated: https://tools.google.com/dlpage/gaoptout?hl=en

3. Disclosure of personal data to third parties

We do not disclose personal data to third parties unless required to do so by law or ordered to do so by a court order.

This does not include the disclosure of personal data to third parties:
a) for the legal protection of users;
b) to meet legal requirements;
c) to defend and protect the rights of the provider;
d) to comply with the terms of use or the data protection regulations;
e) to solve technical problems of the products;
f) to process your enquiries via a form on our website, which requires the transmission of data to process your enquiry or order. In these cases, the transmission of the data is limited to the necessary minimum for their order fulfilment.
In connection with the “Request a quote” service for projects, we also work together with service providers to whom we forward your enquiry and the relevant personal data for processing and responding to your enquiry. The transmission of data is limited to the minimum necessary for the fulfilment of the order.
g) to cooperate with service partners of the provider, who support us especially in the marketing area, for the analysis of certain technical data and for functions of the processing and/or storage of data. We work with a limited number of trusted external service partners who have been carefully selected by us and meet high data protection and security standards. Data is only disclosed to service partners to the extent that it is necessary for the provision of the services offered.

4. Transfer to other countries

If necessary and appropriate for the data processing described in this Privacy Policy declaration, we may also transfer your personal data to third parties abroad. If the level of data protection in the country concerned is not adequate, we contractually ensure that the protection of your personal data is maintained to a high standard. We ensure this by concluding EU standard contractual clauses with the companies concerned, by verifying that the respective companies are certified according to Swiss-US or EU-US Privacy Shield (if the data recipient is located in the USA or stores the data there) and/or by the presence of Binding Corporate Rules (BCR) recognised by a European data protection authority for the companies concerned.

5. Plug-ins and other integration of third party services

Our digital services are networked in many ways with third-party functions and systems, for example by integrating plug-ins into third-party social networks such as Facebook, LinkedIn or Twitter. If you have a user account with these third parties, it may also be possible for these third parties to measure and evaluate your use of our digital services. Other personal data, such as IP address, personal browser settings and other parameters, may be transmitted to and stored by these third parties. We have no control over the use of such personal data collected by third parties and assume no responsibility or liability.

6. Legal basis for data processing

We always process your personal data in accordance with the applicable data protection regulations.

The contractual relationship serves as the legal basis for the processing of personal data for the purpose of processing the contractual relationship. This also applies to processing operations that are necessary to carry out pre-contractual measures.

In the case of data processing required to fulfil a legal obligation, the legal obligation in question serves as the legal basis.

For further processing, we rely on our primary interest. For example, to adapt and continuously improve our services to the needs of our customers; and to carry out marketing activities in order to offer you suitable products or services and display advertisements that are relevant to you. This is an important basis for the financing and further development of our services. In order to achieve these interests, the processing of personal data as described by us is necessary. However, we have taken measures to reduce the impact of data processing on our users. We have compared our interest with the interest of our users and have concluded our data processing does not unduly affect the interests or basic rights of our users and that our interest in this data processing outweigh the others accordingly. Should you disagree with this, you have the right to object to such data processing at any time within the legally permissible framework (see clauses 8 and 9).

In cases where we obtain consent for the processing of data, this is regarded as the legal basis.

7. Data retention

We will only use and keep your data for as long as necessary for the purpose for which it was processed or for as long as there is another legal basis for doing so. We retain data which we hold on the basis of a contractual relationship with you, for at least as long as the contractual relationship exists and limitation periods for possible claims by us are running, or statutory or contractual retention obligations exist.

8. Your rights

Right to information and correction
You have the right to receive information from us, at any time and free of charge, as to whether and which personal data we process from you. You may also ask us to correct or complete inaccurate information about you in our systems.

Right to erasure and restriction
You have the right to ask us to delete or restrict the processing of your personal data.

Please note that even after you have requested to delete your personal data, we may have to retain it due to legal or contractual storage obligations (e.g. for billing purposes) and in this case will only restrict or block your data as necessary. Furthermore, deletion of your data may mean that you can no longer obtain or use the services you have registered for.

Right to object
You have the right to object to the processing of your data, which you can assert with us (see section 9 in detail).

Right to data portability
If applicable, you may also assert your right to data portability.

Withdrawal of consent
You can revoke your consent to data processing at any time, with effect to the future. In the event of revocation, we may no longer be able to provide you with personalised use of free and/or paid products.

Right of complaint
If applicable, you have the right to file a complaint with the competent supervisory authority regarding data processing. You can do this at the supervisory authority in your place of residence, your workplace or the place of the suspected data protection violation.

9. Objection

You have the right to object to the processing of your personal data in accordance with legal requirements at any time.

a) Newsletter
You can unsubscribe from a newsletter at any time via your user account or the relevant link in the newsletter itself.

10. Contact

If you have any questions or comments about our data protection policy, would like information regarding your rights under Sections 8 and 9 or how to assert them, you can contact the data protection officer of DIPA Global B.V. at the following address:

DIPA Global B.V.
Pascallaan 36
8218 NJ LELYSTAD
THE NETHERLANDS
Email: legal@substratebank.com

11. Changes to this Privacy Policy

We expressly reserve the right to change this Privacy Policy declaration at any time. If adjustments are made, we will publish them immediately on our website. It is your responsibility to check the current version of the Privacy Policy on our website, therefore we recommend that you consult this declaration regularly.

Lelystad, 01.12.2020

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