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Privacy Statement SafeWord

1. Who is responsible for the processing of your data?

This privacy statement describes how Safeword ("Safeword" or "we") as the data controller processes your personal data that is processed through the Safeword App ("App"). Safeword is the provider of the App.

2. What is personal data?

Information about an identified or identifiable natural person is personal data. Whether certain information qualifies as personal data depends, in part, on whether Safeword has legitimate means that can reasonably be assumed to be used to identify a data subject.

3. Personal data we process

We process personal data about you because you provide or make it available to us when entering into an agreement for the App, as well as when you use the App and provide us with data or enable us to record data about your interests and preferences.

Data provided to us or made available

  • Name
  • Email address
  • Other data relevant to the specific agreement
  • Data about your use of the App

If you use the App or otherwise interact with SafeWord, we process the following data, which may be considered personal data, as part of our service provision, depending on the precise use you make of it:

  • Social login data (Google/Apple)
  • Other relevant (unstructured) data provided by you

4. Processing: legal bases and legitimate interests

The processing of personal data is based on the following legal bases from Article 6 of the General Data Protection Regulation:

  • Consent
  • Performance of a contract with you
  • Legal obligation
  • Legitimate interest of SafeWord or a third party
  • Legitimate interests include: Marketing, advertising, security, (crime) prevention, IT management, (market) research and analysis of our own products or services, business administration, legal matters, internal management

5. Purposes for processing personal data

  • To be able to offer the App and provide the services from the App [legal basis: 1, 2];
  • To communicate with you and send promotional messages, such as offers/announcements, and keep you informed of promotions, newsletters, events, surveys, and other products or services that may be sent by SafeWord. We use your name and contact details to send offers, news, or other commercial messages. We try to align this communication as much as possible with your preferences: what is content-wise relevant to you and in the way you prefer. You can adjust these preferences yourself in the App or by following instructions (unsubscribe) in the respective message. We may also receive data about this from public sources or our group companies and combine it with the data mentioned above. Your Social login data (Google/Apple) is only used to activate your Safeword account during the registration process. [legal basis: 1, 4];
  • To analyze the use of the App (types of users, click behavior, etc.) and functionalities in order to discover trends and develop new products based on them (product development) [legal basis: 4];

6. Analytical, Statistical, and Scientific Processing

We may process your data for market research, historical analysis purposes to discover trends and correlations in data, or to contribute to research for societal and/or scientific purposes or the improvement of traffic safety.

For this purpose, we may provide your data to parties affiliated with Safeword, and possibly to third parties as well. These data may include your personal data, for which we take appropriate measures (such as hashing, aggregation, and encryption) to protect your privacy, so that personal data will no longer be directly traceable to you as a natural person (pseudo-anonymous) for us, Safeword, and possibly involved third parties.

We process your data based on the legal basis of legitimate interest. You can terminate the processing of personal data for the purposes described in this article by notifying us through customer service (see contact details below).

7. Sharing with Third Parties

We share your personal data with third parties in the following cases and for the associated reasons. The number behind each purpose corresponds to the legal basis mentioned in article 4 of this privacy statement:

  • If an event is organized by SafeWord in collaboration with a third party, your personal data will be shared with this third party for the purpose of organizing this event, for example, for registration/participation purposes. [legal basis: 2 or 4];
  • If you make a purchase through our App, we provide your data to the party(ies) that handle payment processing on our behalf. [legal basis: 2];
  • If you have a problem or a question about the App, qualified employees of SafeWord and/or service providers engaged by SafeWord may have access to your personal data to assist you [legal basis: 4];

SafeWord will not grant third parties access to the above-mentioned personal data or provide these personal data to third parties unless it is necessary:

  • For providing a service, for the purposes mentioned above, for example, service providers in the field of hosting and research (these are "processors" of SafeWord);
  • For maintenance and support activities;
  • In connection with a transaction, for example, when SafeWord decides to sell or transfer all or part of its business. SafeWord may transfer information that is collected and stored, including personal information, to the party or parties involved in the transaction as part of that transaction; and/or
  • In accordance with a legal requirement or an order of a competent authority.

If these third parties are considered processors under applicable data protection laws, SafeWord will enter into written agreements with these third parties. Processors engaged by SafeWord act on instruction and under the responsibility of SafeWord.

The personal data collected through the App are stored on a server of a SafeWord supplier in the European Economic Area (EEA). If personal data are transferred to a recipient in a foreign country, this is usually only done to a recipient in a country that, according to the European Commission, provides an appropriate level of protection for personal data. If personal data are sent to a recipient in a country that does not provide an appropriate level of protection, SafeWord will ensure that the legally required safeguards are in place, such as the conclusion of an EU model contract or the requirement of Privacy Shield certification from the recipient. If you would like more information about the transfer of your personal data to countries outside the EEA, you can contact SafeWord"s Data Protection Officer (see article 13 of this privacy statement).

8. How Long We Retain Data

We retain personal data in accordance with our internal data retention policy and/or as long as (i) you are a customer of SafeWord or continue to show interest in SafeWord"s services (ii) we are legally required to retain data, or (iii) we have good reason to believe that retaining data is necessary. SafeWord does not retain data longer than necessary to provide you with the functionalities in the App and in line with the purposes mentioned for processing this data.

After the end of each calendar year, the data collected in the preceding calendar year will be available for a maximum of 12 months after the start of the new calendar year. This retention period applies to users who have unsubscribed from all services related to Safeword via info@getsafeword.nl.

9. Your Rights, Including the Right to Object

You have the right to know which personal data we have recorded about you and to whom we have provided your personal data. For this purpose, you can contact us through customer service. SafeWord will make every effort to respond within the legal timeframe. Excessive requests may be disregarded.

In addition to the right of access, you have the following legal rights regarding our processing of your personal data:

  • The right to withdraw your consent, to the extent our processing of your personal data is based on it;
  • The right to file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens);
  • The right to have your personal data rectified/corrected;
  • The right to erasure of your personal data;
  • The right to restriction of processing;
  • The right to data portability;
  • The right to object to direct marketing;
  • The right to object to processing carried out due to the legitimate interests of SafeWord or a third party (depending on your personal circumstances).

You can only exercise your rights to the extent permitted by law. To ensure that a request has been made by you, we may ask you to include a copy of your identity document with this request. We only ask for this if we consider it necessary to identify you, and we request that you make the photo, MRZ (machine-readable zone; the strip with numbers at the bottom of the passport), passport number, and Citizen Service Number (BSN) unrecognizable on this copy. We will destroy the copy of your identity document immediately after we have identified you.

10. Ceasing the Processing of Personal Data and Withdrawing Consent

You have the choice to stop the collection and processing of your personal data by SafeWord at any time. For this, please contact our customer service via info@getsafeword.nl. You also need to uninstall the App. Your data will still be retained in accordance with the specified retention periods in Article 8.

As part of using the App, you may receive messages, including commercial communications and service messages, from SafeWord. If you no longer wish to receive these messages, you can adjust your consent/preference for them in the App"s communication settings menu and unsubscribe at the bottom of each email you receive from us.

11. Analytics

The App uses a form of Analytics. This service uses cookies to analyze how the user uses the App and then compiles information reports on the use of the App for SafeWord. The information generated by the cookies about your use of the App is transmitted to and stored by Google on servers in the United States. This service may only provide the information generated by the cookies to third parties if required by law or to the extent that these third parties process the information on behalf of this service. This service will not combine your IP address with other data it has. The use of this service is necessary to analyze the functioning of the App.

12. Security

SafeWord has implemented appropriate technical (including secure servers, firewalls, and electronic data connection security and encryption) and organizational security measures to protect your personal data against unlawful or unauthorized processing, loss, destruction, damage, alteration, or disclosure and to ensure the secure transmission of your personal data from the vehicle and the App to the servers.

13. Contact

For questions and/or comments regarding this privacy statement, you can contact:

SafeWord

Attn: SafeWord Customer Service

Email: info@getsafeword.nl

We have a Data Protection Officer registered with the supervisory authority, the Dutch Data Protection Authority. This is someone within our organization who oversees compliance with privacy legislation such as the General Data Protection Regulation (GDPR). Our Data Protection Officer can be reached by email at info@getsafeword.nl.

14. Changes to this Privacy Statement

The way we process personal data and the composition or quantity of data we process may change. Therefore, we reserve the right to amend this privacy statement. You will be notified of any changes if necessary.

If changes to the privacy statement result in substantial changes to the services provided by SafeWord under the user agreement for the use of the App, you will first be given the opportunity to terminate the user agreement. For more information, please click here for the terms of use.

This statement was last revised on October 4, 2023