Privacy Policy
PRIVACY STATEMENT RMONI
1 General information
This privacy statement (Privacy Statement) specifies how Rmoni (Rmoni B.V., registered in the Chamber of Commersunder number: 68434871; "we", "us", "our") handles personal data in the context of its software, applications, hardware and several other professional services (“Products and Services”) and its website <www.rmoni.com> (the “Website”). Personal data is data about a living person. The term includes both data that is directly identifiable (e.g. someone's name) and indirectly identifiable (e.g.someone's IP address).
2 Who is responsible for the processing of your personal data?
Rmoni is responsible for the processing of personal data as outlined in this Privacy Statement. Rmoni is therefore the data controller within the meaning of the applicable privacy regulations, among which the General Data Protection Regulation (“GDPR”).
3 Which personal data do we process?
In providing our Products and Services, we may process the following personal data.
You can also check out our Cookie Statement here.
4 What are the purposes and legal grounds of processing?
According to the GDPR, we may only process your personal data if we have a valid legal ground to do so. The GDPR specifically states these legal grounds. In the case of Rmoni, these are usually: your (prior) consent, compliance with a legal obligation we must meet or legitimate interest to conduct our normal business.
Rmoni processes personal data of customers with contracts primarily for the purpose of providing its services on the basis of its legitimate interests to conduct its normal business. This is only the case if these interests outweigh the privacy interests of the person to whom the data relates. In that case, the legitimate interests of Rmoni correspond to the purposes set out below. For further information on the balancing of interests in a specific case, please contact us using the contact details at the bottom of this Privacy Statement. Other data is processed to comply with an applicable legal obligation, for example to meet applicable minimum retention periods.
It may also be necessary in exceptional cases to process personal data to protect someone's vital interests. This may be the case, for example, in the unlikely event that someone falls unconscious at the Rmoni office and health data must be provided to a care provider. If Rmoni cannot rely on one of the afore mentioned bases, consent must be obtained for the processing of personal data.
Rmoni will inform you in a specific situation if providing personal data is a legal or contractual obligation or necessary condition for entering into an agreement. It will also inform you of the possible consequences of not providing the data.
Rmoni processes these personal data for the following purposes and on the basis of the relating legal grounds:
5 How do we obtain your personal data?
Rmoni collects personal data that you have directly provided to us. For example, data about a particular person provided by filling out a contact form on the Website. We may also collect personal data through the use of the Website or our application, such as an IP address or data about the use of our application (log data). Sometimes we process personal data not on our own initiative, but to comply with a legal obligation incumbent on us. This is the case, for example, when we retain personal data for a longer period in order to comply with a legal retention obligation.
We may also receive personal data through public sources, such as information from a public LinkedIn profile or a website.
6 Under which circumstances and with whom do we share your personal data?
Third parties we involve
We may involve third parties, such as service providers or subcontractors, to support us in our business activities. For example, Hubspot (for CRM purposes), Leadinfo (for marketing purposes) and AFAS (for administrative purposes). These third parties may process personal data on our behalf as part of the services they provide to us. To ensure that this personal data is adequately protected and processed in accordance with applicable laws and regulations, we enter into a processor agreement with these parties.
We only share personal data if this is necessary for the purpose of the service provision or involvement of that third party. For example, third parties will only have access to the personal data they truly need for their services. Persons within those third parties who have access to the personal data are required to keep the personal data confidential. Third parties are not allowed to use personal data about you that we share with them for their own purposes, such as marketing or other purposes.
Mergers and acquisitions
We may transfer or provide your personal data to a buyer or potential buyer in the event of a merger or acquisition (potential or prospective) of all or part of our businessor assets. In the event of such a transfer, we will take all steps reasonably expected of us to ensure that the receiving party processes your information in accordance with this Privacy Statement.
Government agencies
We may share your personal data with government agencies, such as police, the IRS or other authorities where we are required to do so by law.
7 To which countries do we transfer your personal data?
If necessary, we may transfer personal data to third parties located outside the European Economic Area (“EEA”).
Transfers outside the EEA. The transfer of personal data to a third party outside the EEA can in the first place be legitimized based on an adequacy decision of the European Commission, in which it is decided that the (part within the) third country inquestion ensures an adequate level of data protection. On the website of the European Commission, you can find an overview of the adequacy decisions that have been taken.
If personal data is transferred to a country outside the EEA for which there is no adequacy decision, we agree on the applicability of the relevant version of the Standard Contractual Clauses with the relevant party. This is a standard contract to safeguard the protection of personal data, which is approved by the European Commission, in which the parties fill out the appendices. Where appropriate, additional safeguards are taken.
8 How do we protect your personal data?
Protecting your privacy and personal data is very important to us. Therefore, Rmoni has implemented appropriate technical and organizational measures to protect and secure the personal data we process,in order to prevent violations of the confidentiality, integrity and availability of data.
Rmoni has internal processes according to which we safeguard an appropriate level of technical and organisational security. We will make our best efforts to prevent your personal data from being accidentally lost, used or accessed, altered, or disclosed in an unauthorized way. In addition, we limit access to your personal data to those authorized employees and (other) business relations and third parties who have a need to know. Furthermore, Rmoni implemented two-factor-authentication, vulnerability code-scans, secured websites with SSL-certificates, password-rules (passwords are stored by way of encryption). Finally, Rmoni engages in research groups to be informed of state-of-the-art security measures. All Rmoni employees and other persons engaged by Rmoni for the processing of personal data are obliged to ensure the confidentiality of this data.
9 What are your privacy rights?
In relation to the processing of your personal data by Rmoni, you have the following privacy rights:
- Right of access. This concerns the right to request access to your personal data. This enables the you to receive a copy of the data we hold about you (but not necessarily the files themselves). We will then also provide further specifics of our processing of the personal data. For example, the purposes for which we process the data, where we got it from, and with whom we share it.
- Right to rectification. This concerns the right to request rectification of the data that we hold about you. This enables you to have any incomplete or in accurate data corrected.
- Right to erasure. This concerns the right to request erasure of the data. This enables you to ask us to delete or remove personal data where: (i) the data is no longer necessary, (ii) the processing activities have been objected to, (ii) the data has been unlawfully processed, (iv) the data has to be erased on the basis of a legal requirement, or (v) where the data has been collected in relation to the offering of information society services. However, we do not have to honor such request in all cases.
- Right to object. This concerns the right to object to the processing of personal data where we are relying on legitimate interest as processing ground (see above). In sofar as the processing of the data takes place for direct marketing purposes, we will always honor an objection. For processing for other purposes, we will also cease and desist processing, unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms or that are – for example - related to the institution, exercise or substantiation of a legal claim. If such is the case, we will inform on our compelling interests and the balance of interests made.
- Right to restriction. The right to restriction of processing means that Rmoni will continue to store personal data at the request of you but may in principle not do anything further with it. In short, this right can be exercised when Rmoni does not have (or no longer has) any legal grounds for the processing of the data or if this is under discussion.
- Automated decision-making. This concerns the right not to be subject to a decision based solely on automated processing, which significantly impacts you. In this respect, please be informed that when processing your data, we do not make use of automated decision-making.
- Right to withdraw consent. This concerns the right to withdraw consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
- Right to complaint. This concerns the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work or where an alleged infringement took place. Please be referred to the website of the European Data Protection Board (“EDPB”) for an overview of the supervisory authorities and their contact details. However, we would appreciate the chance to deal with any concerns before the supervisory authority is approached, so please contact us beforehand.
10 How to exercise your privacy rights?
You can exercise the privacy rights above free of charge, by phone or by e-mail via the contact details displayed below. If requests are manifestly unfounded or excessive, in particular because of the repetitive character, we have the right to either charge a reasonable fee or refuse to comply with the request. In addition, we may request specific information to help us confirm your identity before we further respond to a privacy request. Finally, we will provide information about the follow-up of the request without undue delay and in principle within one month of receipt of the request. Depending on the complexity of the request and on the number of requests, this period can be extended by another two months.
11 How long do we keep your personal data?
In general, Rmoni does not keep personal data for longer than is necessary in relation to the purposes for which we process the personal data. There could, however, be exceptions applicable to the general retention terms. In view hereof, shorter retention periods could apply :if an individual exercises certain privacy rights, it is possible that we retain it for a shorter period of time. Longer retention periods could also apply. In certain situations, we process personal data of individuals for a longer period of time than what is necessary for the purpose of the processing. This is for instance the case when we have to process personal data for a longer period of time:
· Retention obligation - to comply with a minimum retention period or other legal obligation to which LCE is subject based on EU law or the law of an EU member state;
· Procedure - personal data which is necessary in relation to a legal procedure;
· Freedom of expression - when further processing of personal data is necessary in order to exercise the right to freedom of expression and information.
· Consent - for example: With the job applicant's consent, we retain their data for one year as of finalization of the application procedure instead of 4 weeks.
12 Contact information
If you have any questions regarding this Privacy Statement, or data collection by Rmoni in particular, please contact us at info@rmoni.com or by using the contact information below:
Rmoni B.V.
Twentepoort West 10-8
7609 RD Almelo
The Netherlands
Telephone number: 0031 74 265 7787
13 Changes to this Privacy Statement
Occasionally, we may need to update or change this Privacy Statement. In case of important changes, we will inform you in an appropriate manner and ask you to take note of the changes made. The latest version of the Privacy Statement is always available on our Website.
This Privacy Statement was updated in September 2024.