Last update: May 03, 2020

This Privacy Policy clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as “Data”) within our online offering and the related websites, features and content, as well as external online presence, e.g. our Social Media Profile (collectively referred to as the “Online Offering”). With regard to the terminology used, e.g. “Processing” or “Controller”, we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Controller

The data controller is 3D Neuro B.V. (also called 3Dneuro in this privacy policy) with the address:
Toernooiveld 100
6525EC Nijmegen
The Netherlands
E-mail: privacy@3dneuro.com          

Chamber of Commerce number: 70236917
VAT identification number: NL 858206869B01

Here you can find our general terms and conditions: https://www.3dneuro.com/terms-and-conditions/
Data security contact email: privacy @ 3dneuro.com

Types of processed data:

  • Inventory data (e.g., names, addresses).
  • Contact information (e.g., e-mail, phone numbers).
  • Content data (e.g., text input, photos, videos).
  • Usage data (e.g., websites visited, interest in content, access times).
  • Meta/Communication data (e.g., device information, IP addresses).

Categories of affected persons

Visitors of our website and customers.

Purpose of processing

  • Provision of the website and other online services, their functions and contents
  • Answering contact requests and communicating with users
  • Fulfilment of orders, production of ordered goods and services
  • Safety measures
  • Market Research/Marketing

Used terms

“Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “affected person”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by assignment to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more special features that express the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.

“Processing” means any process performed with or without the aid of automated procedures or any such process associated with personal data. The term is broadly defined and includes virtually every handling of data.

“Pseudonymisation” means the processing of personal data in such a way that the personal data can no longer be assigned to a specific affected person without additional information being provided, provided that such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data not assigned to an identified or identifiable natural person.

“Profiling” means any kind of automated processing of personal data which involves the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular aspects relating to job performance, economic situation, health, personal preferences, interests, reliability, behavior, whereabouts or relocation in order to analyze or predict these aspects of that natural person.

“Controller” means the natural or legal person, public authority, body or body that decides, alone or in concert with others, on the purposes and means of processing personal data.

“Processor” means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.

Legal basis

In accordance with Art. 13 GDPR, we inform you of the legal basis of our data processing. If the legal basis is not mentioned in the data protection declaration, the following applies: The legal basis for obtaining consents is Art. 6 para. 1 lit. a and Art. 7 GDPR, the legal basis for processing for the performance of our services and performance of contractual measures as well as for answering inquiries is Art. 6 para. 1 lit. b GDPR, the legal basis for processing to fulfil our legal obligations is Art. 6 para. 1 lit. c GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f GDPR. In the event that the vital interests of the data subject or another natural person require the processing of personal data, Article 6(1)(d) GDPR serves as the legal basis.

Security

We take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, implementation costs and the nature, scope, circumstances and purposes of processing as well as the different probability of occurrence and severity of the risk to the rights and freedoms of natural persons, in accordance with Art. 32 GDPR.

Such measures shall in particular include ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, transmission, security of availability and its separation. Furthermore, we have established procedures to ensure the exercise of rights of data subjects, deletion of data and reaction to endangerment of data. Furthermore, we already consider the protection of personal data during the development or selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and data protection-friendly pre-settings (Art. 25 GDPR).

Cooperation with contract processors and third parties

If, in the context of our processing, we disclose data to other persons and companies (contract processors or third parties), transmit them to them or otherwise grant access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, as required by payment service providers, pursuant to Art. 6 (1) (b) GDPR to fulfil the contract), you have consented to a legal obligation or based on our legitimate interests (e.g. the use of agents, web hosters, etc.).

If we commission third parties to process data on the basis of a so-called “data processing contract”, this is done on the basis of Art. 28 GDPR.

Transfer to third-party countries

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or disclosure or transfer of data to third parties, this only takes place if it occurs for the fulfilment of our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or leave the data in a third country only if the special requirements of Art. 44 ff. Process GDPR. This means, for example, processing is carried out on the basis of special guarantees, such as the officially recognized determination of a data protection level corresponding to the EU (e.g. for the USA by the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).

Rights of affected persons

You have the right to request confirmation as to whether the data concerned are being processed and to request information about these data as well as further information and a copy of the data in accordance with Art. 15 GDPR.
You have according to Art. 16 GDPR the right to demand the completion of the data concerning you or the correction of the incorrect data concerning you.
In accordance with Art. 17 GDPR, you have the right to demand that the relevant data be deleted immediately or, alternatively, to require a restriction of the processing of data in accordance with Art. 18 GDPR.
You have the right to demand that the data relating to you, which you have provided to us, be obtained in accordance with Art. 20 GDPR and request their transmission to other responsible entities.
In accordance with Art. 77 GDPR, you also have the right to file a complaint with the governing authority.

Right of withdrawal

You have the right to revoke your consent, provided according to Art. 7 para. 3 GDPR, at any time with future effect.

Right of objection

You can object to the future processing of your data in accordance with Art. 21 GDPR at any time. The objection may in particular be made against processing for direct marketing purposes.

Cookies and right of objection in direct advertising

“Cookies” are small files that are stored on the user’s computer. Different data can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his or her visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, for example, the content of a shopping basket in an online shop or a login status can be stored. Cookies are referred to as “permanent” or “persistent” and remain stored even after the browser is closed. For example, the login status can be saved when users visit it after several days. Likewise, the interests of users used for range measurement or marketing purposes may be stored in such a cookie. “Third-party cookies” are cookies that are offered by providers other than the person responsible for operating the online offer (otherwise, if they are only its cookies, they are referred to as “first-party cookies”).

We may use temporary and permanent cookies and clarify this within the framework of our data protection declaration (privacy policy).

If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

A general objection to the use of cookies used for online marketing purposes can be declared for many of the services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that in this case not all functions of this online offer can be used. We use Cookiebot (provided by Cybot A/S, Havnegade 39, 1058 Copenhagen) to manage your choices for cookies on our website. Find their privacy policy at https://www.cookiebot.com/en/privacy-policy/.

Deletion of data

The data processed by us will be deleted or their processing restricted in accordance with Articles 17 and 18 GDPR. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory storage obligations. If the data are not deleted because they are necessary for other and legally permissible purposes, their processing is restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons. In accordance with the Dutch tax law, we are required to keep data to fulfil our tax obligations for 7 years and 10 years regarding our electronic services.

Business related processing

Additionally, we process

  • contract data (e.g., subject matter of the contract, duration, customer category) and
  • payment data (e.g., bank details, payment history) of our customers, prospects and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.

Services

We process our customers’ data as part of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development / consulting or maintenance, implementation of campaigns and processes / handling, server administration, data analysis / consulting services and training services.

We process inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., e-mail, telephone numbers), content data (e.g., text entries, photographs, videos), contract data (e.g., subject matter of the contract, term), payment data (e.g., bank details, payment history), and usage and metadata (e.g. as part of the evaluation and performance measurement of marketing measures). We do not process special categories of personal data unless these are part of commissioned processing. This includes our customers, prospects, their customers, users, website visitors or employees, as well as third parties. The purpose of the processing is to provide contractual services, billing and our customer service. The legal basis for processing results from Art. 6 para. 1 lit. b GDPR (contractual services), Art. 6 para. 1 lit. f GDPR (analysis, statistics, optimization, safety measures). We process data which are necessary to justify and fulfil the contractual services and point out the necessity of their disclosure. Disclosure to external parties only takes place if it is necessary within the framework of an order. When processing the data provided to us within the scope of an order, we act in accordance with the instructions of the client and the legal requirements for order processing pursuant to Art. 28 GDPR and process the data for no other purposes than those stipulated in the order.

We delete the data after the expiry of statutory warranty and comparable obligations. The necessity of storing the data is checked every three years; in the case of statutory archiving obligations, the data is deleted after their expiry. In the case of data disclosed to us within the scope of an order by the customer, we delete the data in accordance with the specifications of the order, generally after the end of the order.

Contractual Services

We process the data of our contractual partners and interested parties as well as other clients, customers, clients, clients or contractual partners (uniformly referred to as “contractual partners”) in accordance with Art. 6 para. 1 lit. b. GDPR to provide our contractual or pre-contractual services to them. The data processed here, the type, scope and purpose and the necessity of their processing, are determined by the underlying contractual relationship.The processed data includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g. e-mail addresses and telephone numbers) as well as contract data (e.g., services used, contract contents, contractual communication, names of contact persons) and payment data (e.g., bank details, payment history).
We do not process special categories of personal data, unless these are part of a commissioned or contractual processing.
We process data which are necessary to justify and fulfil the contractual services and point out the necessity of their disclosure, unless this is evident for the contractual partners. Disclosure to external persons or companies is only made if it is required within the framework of a contract. When processing the data provided to us within the scope of an order, we act in accordance with the instructions of the customer and the legal requirements.

When using our online services, we may store the IP address and the time of the respective user action. This data is stored on the basis of our legitimate interests as well as the users’ interests in the protection against misuse and other unauthorized use. As a matter of principle, this data will not be passed on to third parties, unless it is necessary to pursue our claims pursuant to Art. 6 para. 1 lit. f. GDPR is required or there is a legal obligation in accordance with Art. 6 para. 1 lit. c. GDPR.

The data will be deleted if the data is no longer required for the fulfilment of contractual or statutory duties of care or for the handling of any warranty or comparable obligations, whereby the necessity of storing the data is checked every three years; in all other respects, the statutory storage obligations apply.

External payment service providers

We use external payment service providers through whose platforms the users and we can carry out payment transactions (e.g., each with a link to the data protection declaration)

  • Mollie (https://www.mollie.com/en/privacy)
  • Plink (https://plink.com/privacy-policy)
  • Paypal (https://www.paypal.com/us/webapps/mpp/ua/privacy-full),
  • Visa (https://www.visaeurope.com/privacy/),
  • Mastercard (https://www.mastercard.us/en-us/about-mastercard/what-we-do/privacy.html),
  • American Express (https://www.americanexpress.com/us/content/legal-disclosures/online-privacy-statement.html)

As part of the fulfilment of contracts, we suspend the payment service providers on the basis of Art. 6 para. 1 lit. b. GDPR. Furthermore, we employ external payment service providers on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f. GDPR to provide our users with effective and secure payment options.

The data processed by the payment service providers includes inventory data such as name and address, bank data such as account numbers or credit card numbers, passwords, TANs and checksums as well as contract, totals and recipient information. This information is required to execute the transactions. However, the data entered will only be processed and stored by the payment service providers. This means that we do not receive any account or credit card related information, but only information with confirmation or negative information about the payment. The data may be transferred by the payment service providers to credit agencies. The purpose of this transmission is to verify identity and creditworthiness. For this we refer to the terms and conditions and data protection information of the payment service providers.

For payment transactions, the terms and conditions and the data protection information of the respective payment service providers, which can be accessed within the respective websites or transaction applications, apply. We refer to these also for the purpose of further information and assertion of rights of revocation, information and other interested parties.

Administration, accounting, office organization, contact information management

We process data within the framework of administrative tasks as well as the organization of our company, financial accounting and compliance with legal obligations, e.g. archiving. We process the same data that we process in the course of providing our contractual services. The processing bases are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. Customers, prospects, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, thus tasks which serve the maintenance of our business activities, perception of our tasks and provision of our services. The deletion of the data with regard to contractual services and contractual communication corresponds to the information provided in these processing activities.

We disclose or transmit data to the tax authorities, consultants, such as tax consultants or auditors, as well as similar service providers.

Furthermore, we store information on suppliers, event organizers and other business partners on the basis of our business interests, e.g. for the purpose of making contact at a later date. We store this data, which is mainly company-related, permanently.

Business analyses and market research

In order to operate our business economically, to be able to recognize market tendencies, wishes of the contracting parties and users, we analyze the data available to us to business processes, contracts, inquiries, etc. We process inventory data, communication data, contract data, payment data, usage data, and metadata on the basis of Art. 6 para. 1 lit. f. GDPR, whereby the persons concerned include contractual partners, interested parties, customers, visitors and users of our online offer.

The analyses are carried out for the purpose of economic evaluations, marketing and market research. The analyses serve us to increase the user-friendliness, the optimization of our offer and the economic efficiency. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with aggregated values.

If these analyses or profiles are personal, they will be deleted or made anonymous upon termination of the user, otherwise after two years from the conclusion of the contract. For the rest, macroeconomic analyses and general trend determinations are prepared anonymously wherever possible.

Data protection information in the job application process

We process the applicant data only for the purpose and in the context of the application procedure in accordance with the legal requirements. The processing of the applicant data takes place in order to fulfil our (pre)contractual obligations in the context of the application procedure within the meaning of Art. 6 para. 1 lit. b. GDPR Art. 6 para. 1 lit. f. GDPR if data processing becomes necessary for us, e.g. within the framework of legal procedures.

The application procedure requires that applicants provide us with personal data. If we offer an online form, the necessary data for application will be explicitly stated or otherwise result from the job descriptions and generally include personal data, postal and contact addresses and the documents belonging to the application, such as cover letter, curriculum vitae and certificates. In addition, applicants may voluntarily provide us with additional information.

By submitting the application to us, applicants agree to the processing of their data for the purposes of the application procedure in accordance with the type and scope set out in this data protection declaration.

If special categories of personal data within the meaning of Art. 9 para. 1 GDPR are voluntarily communicated within the scope of the application procedure, they are additionally processed in accordance with Art. 9 para. 2 letter b GDPR (e.g. health data, e.g. severely disabled status or ethnic origin). If special categories of personal data within the meaning of Art. 9 para. 1 GDPR are requested from applicants during the application procedure, they are additionally processed in accordance with Art. 9 para. 2 lit. a GDPR (e.g. health data, if these are required for the exercise of the profession).

If made available, applicants can send us their applications via an online form on our website. The data is encrypted and transmitted to us according to the state of the art.

Applicants can also send us their applications by e-mail. Please note, however, that e-mails are generally not sent in encrypted form and that the applicants themselves must ensure that they are encrypted. We cannot therefore accept any responsibility for the transmission of the application between the sender and receipt on our server and therefore recommend that you use an online form or the postal dispatch. Instead of using the online application form and e-mail, applicants can still send us their application by post.

If the application is successful, the data provided by the applicants can be further processed by us for the purpose of employment. Otherwise, if the application for a job offer is not successful, the applicants’ data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which the applicants are entitled to do at any time.

The deletion will take place after a period of six months, subject to a justified revocation by the applicant, so that we can answer any follow-up questions to the application and meet our obligations under the Equal Treatment Act. Invoices for any reimbursement of travel expenses are archived in accordance with tax regulations.

Talent pool

As part of the application, we offer applicants the opportunity to be included in our “talent pool” for a period of two years on the basis of consent within the meaning of Art. 6 (1) (b) and Art. 7 GDPR.

The application documents in the talent pool will only be processed in the context of future job advertisements and the search for employees and will be destroyed at the latest on expiry of the deadline. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the current application procedure and they can revoke this consent at any time for the future and declare their objection within the meaning of Art. 21 GDPR.

Comments

If users leave comments or other contributions, their IP addresses may be used on the basis of our legitimate interests within the meaning of Art. 6 (1) (f). GDPR for 7 days. This takes place for our safety, if someone leaves illegal contents in comments and contributions (insults, forbidden political propaganda, etc.). In this case, we can be prosecuted ourselves for the comment or contribution and are therefore interested in the identity of the author.

Furthermore, we reserve the right, on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f. GDPR to process user information for spam detection.

On the same legal basis, we reserve the right, in the case of surveys, to store the IP addresses of users for their duration and to use cookies to avoid multiple submissions.

The data provided in the context of comments and contributions will be permanently stored by us until the user objects.

Comment subscriptions

Users may subscribe to the follow-up comments with their consent in accordance with Art. 6 para. 1 lit. a GDPR. Users will receive a confirmation email to verify that they are the owner of the email address they entered. Users can unsubscribe from ongoing comment subscriptions at any time. The confirmation email will contain information on the cancellation options. For the purpose of providing proof of user consent, we store the time of registration together with the IP address of the users and delete this information when users unsubscribe from the subscription.

You can cancel the receipt of our subscription at any time, i.e. revoke your consent. We may store the e-mail addresses we have unsubscribed for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove a previously given consent. The processing of these data is limited to the purpose of a possible defence against claims. An individual application for cancellation is possible at any time, provided that at the same time the former existence of a consent is confirmed.

Akismet Anti-Spam

Our online offer may use the service “Akismet” offered by Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA. The use is based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f) GDPR. With the help of this service, comments of real people are distinguished from spam comments. All comment information is sent to a server in the USA, where it is analyzed and stored for four days for comparison purposes. If a comment has been classified as spam, the data will be stored after this time. This information includes the name entered, the e-mail address, the IP address, the comment content, the referrer, information on the browser used, the computer system and the time of entry.

Further information on Akismet’s collection and use of the data can be found in Automattic’s privacy policy: https://automattic.com/privacy/.

Users are welcome to use pseudonyms or refrain from entering their name or email address. You can completely prevent the transfer of data by not using our comment system. That would be a pity, but unfortunately, we see no other alternatives that work just as effectively.

Access of profile pictures at Gravatar

We use the service Gravatar of Automattic Inc. 60 29th Street #343, San Francisco, CA 94110, USA, within our online offer and especially in our blog.

Gravatar is a service where users can log in and store profile pictures and their e-mail addresses. If users leave contributions or comments with the respective e-mail address on other online presences (above all in blogs), their profile pictures can be displayed next to the contributions or comments. For this purpose, the e-mail address provided by the users is transmitted to Gravatar in encrypted form for the purpose of checking whether a profile has been saved for it. This is the sole purpose of the transmission of the e-mail address and it will not be used for other purposes, but will be deleted thereafter.

The use of Gravatar is based on our legitimate interests within the meaning of Art. 6 Para. 1 letter f) GDPR, as we offer the possibility of personalising their contributions with a profile picture with the help of Gravatar.

By displaying the images, Gravatar obtains the IP address of the users, as this is necessary for communication between a browser and an online service. Further information on the collection and use of data by Gravatar can be found in Automattic’s data protection information: https://automattic.com/privacy/.

If users do not want an image associated with their email address to appear in Gravatar’s comments, you should use a non-Gravatar email address for commenting. We would also like to point out that it is also possible to use an anonymous or no e-mail address if users do not wish their own e-mail address to be sent to Gravatar. Users can completely prevent the transfer of data by not using our comment system.

Access of Emojis and Smilies

Within our WordPress blog, graphical emojis (or smilies), i.e. small graphical files that express feelings, are used that are obtained from external servers. The providers of the servers collect the IP addresses of the users. This is necessary so that the emoji files can be transmitted to the users’ browsers. The Emoji service is offered by Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA. Privacy policy of Automattic: https://automattic.com/privacy/. The server domains used are s.w.org and twemoji.maxcdn.com, whereby to our knowledge these are so-called content-delivery networks, i.e. servers which serve only a fast and secure transmission of the files and the personal data of the users are deleted after the transmission.

Emojis are used on the basis of our legitimate interests, i.e. interest in an attractive design of our online offer in accordance with Art. 6 para. 1 lit. f. GDPR.

Contact

When contacting us (e.g. via contact form, e-mail, telephone or social media), the user’s details for processing the contact enquiry and its processing pursuant to Art. 6 para. 1 letter b. (in the context of contractual/pre-contractual relationships), Art. 6 para. 1 lit. f. (other requests) GDPR. User information can be stored in a customer relationship management system (“CRM system”) or comparable request organization.

We delete the requests if they are no longer necessary. We review this requirement every two years; the statutory archiving obligations also apply.

Newsletter

With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to the receipt and the described procedures.

Content of the newsletter: We send newsletters, e-mails and other electronic notifications containing advertising information (hereinafter “newsletters”) only with the consent of the recipients or a legal permission. If the contents of a newsletter are specifically described within the scope of a registration, they are decisive for the consent of the users. In addition, our newsletters contain information about our services and us.

Double opt-in and logging: Subscription to our newsletter takes place in a so-called double opt-in procedure. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no one can log in with other e-mail addresses. Subscriptions to the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes the storage of the login and confirmation time, as well as the IP address. The changes to your data stored with the shipping service provider are also logged.

Credentials: To subscribe to the newsletter, simply enter your name and e-mail address. We ask you to enter your name in the newsletter in order to address you personally.

The sending of the newsletter and the performance measurement associated with it are carried out on the basis of the recipients’ consent pursuant to Art. 6 para. 1 lit. a, Art. 7 GDPR or, if consent is not required, on the basis of our legitimate interests in direct marketing pursuant to Art. 6 para. 1 lt. f. GDPR.

The registration procedure is recorded on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR. We are interested in the use of a user-friendly and secure newsletter system that serves both our business interests and the expectations of users and also allows us to provide proof of consent.

Cancellation/Revocation – You can cancel the subscription to our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. We may store the e-mail addresses we have unsubscribed for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove a previously given consent. The processing of these data is limited to the purpose of a possible defence against claims. An individual application for cancellation is possible at any time, provided that at the same time the former existence of a consent is confirmed.

Newsletter – Provider

The newsletter is sent through the email marketing service Mailerlite Paupio g. 28, Vilnius 11341, Lithuania. The data protection regulations of the service provider can be viewed here: https://www.mailerlite.com/privacy-policy. The service provider will be used on the basis of our legitimate interests in accordance with Art. 6 para. 1 lit. f. GDPR and an order processing contract pursuant to Art. 28 para. 3 sentence 1 GDPR.

The service provider can use the recipient’s data in pseudonymous form, i.e. without assignment to a user, to optimize or improve its own services, e.g. to technically optimize the dispatch and presentation of the newsletter or for statistical purposes. However, the shipping service does not use the data of our newsletter recipients to write them down itself or to pass the data on to third parties.

Newsletter – Analytics

The newsletters may contain a so-called “web-beacon”, i.e. a pixel-sized file which is downloaded from our server when the newsletter is opened or, if we use a shipping service provider, from whose server. Within the scope of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and time of retrieval are initially collected.

This information is used to technically improve the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or access times. The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our endeavor, nor, if used, that of the shipping service provider, to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our contents to them or to send different contents according to the interests of our users.

A separate revocation of the success measurement is unfortunately not possible, in this case the entire newsletter subscription must be cancelled.

Hosting, E-Mail and cloud services

The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail delivery, security services and technical maintenance services that we use for the purpose of operating this online offer.

We or our hosting provider process inventory data, contact data, content data, contract data, usage data, and meta- and communication data of customers, interested parties, and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer according to Art. 6 Para. 1 lit. f GDPR in conjunction with. Art. 28 GDPR (conclusion of order processing contract). In addition, we are using software services that are run on certain service provers’ servers and are accessible through the internet (“cloud services”, also known as “software as a service” (SaaS) for storage, organization and sharing of documents, presentations and calendars, e-mail storage and distribution, hosting and participation in chats and audio or video conferences.

In this context, we may process personal data on the servers of the service providers. This includes inventory data, contact data, content data, contract data, usage data, and meta- and communication data of customers, interested parties, and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer according to Art. 6 Para. 1 lit. f GDPR in conjunction with. Art. 28 GDPR (conclusion of order processing contract). In addition, service providers may process usage and meta data for service-related purposes (for example securing or optimizing their service) or place certain cookies on the user’s devices. We strive to minimize the amount of meta and tracking data of users in general (for example by avoiding tracking cookies as much as possible) and aim to incorporate third party services in a way that minimizes access to personal data for third party providers. For details of data processing by cloud service providers, we refer to the privacy policies linked below.

Dropbox

Cloud storage service provider, Dropbox, Inc., 333 Brannan Street, San Francisco, California 94107, USA; 
Website: https://www.dropbox.com; 
Privacy policy: https://www.dropbox.com/privacy; 
Privacy Shield : https://www.privacyshield.gov/participant?id=a2zt0000000GnCLAA0&status=Active; 
Terms of service: https://www.dropbox.com/terms/business-agreement-2016.

Google Cloud Services

Cloud storage service provider, Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; 
Website: https://cloud.google.com/; 
Privacy policy: https://www.google.com/policies/privacy, 
Privacy and security notes: https://cloud.google.com/security/privacy; 
Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000000001L5AAI&status=Aktive; 
Standard terms: https://cloud.google.com/terms/data-processing-terms; 
Additional data processing terms: https://cloud.google.com/terms/data-processing-terms.

Microsoft Cloud Services

Cloud storage service provider, Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; Website: http://microsoft.com; Privacy policy: https://privacy.microsoft.com/en-us/privacystatement, Trust center: https://www.microsoft.com/en-us/trust-center; Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAK&status=Active.

Protonmail

E-mail provider, Proton Technologies AG, Chemin du Pré-Fleuri 3, CH-1228 Plan-les-Ouates, Genève, Switzerland; 
Privacy policy: https://protonmail.com/privacy-policy; 
GDPR compliance explanation: https://protonmail.com/gdpr

Online presence in social media

We maintain online presences within social networks and platforms in order to communicate with active customers, interested parties and users and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and the data processing guidelines of their respective operators apply.

Unless otherwise stated in our privacy policy, we process the data of users who communicate with us within social networks and platforms, e.g. write articles on our websites or send us messages.

Integration of third-party services and content

Within our online offer, we make no representations or warranties of any kind based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) content or service offerings of third parties to incorporate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).

This always presupposes that the third-party providers of this content perceive the IP address of the users, since without the IP address they could not send the content to their browser. The IP address is therefore required for the display of this content. We make every effort to use only those contents whose respective providers use the IP address only for the delivery of the contents. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include technical information about the browser and operating system, referring websites, visiting time and other information about the use of our online offer, as well as be linked to such information from other sources.

Vimeo

We can integrate videos of the platform “Vimeo” of the provider Vimeo Inc, Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA. Privacy Policy: https://vimeo.com/privacy into our online offering. Please note that Vimeo may use Google Analytics and refer to the privacy policy (https://www.google.com/policies/privacy) and opt-out options for Google Analytics (http://tools.google.com/dlpage/gaoptout?hl=de) or Google’s settings for data use for marketing purposes (https://adssettings.google.com/.).

YouTube

We can integrate the videos of the platform “YouTube” of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated into our online offering.

Google Fonts

We may integrate the fonts (“Google Fonts”) of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated into our online offering.

Google Maps

We may integrate the maps of the service “Google Maps” of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, into our online offering. The processed data may include in particular IP addresses and location data of the users, which, however, are not collected without their consent (as a rule within the framework of the settings of their mobile devices). The data can be processed in the USA. 
Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

Twitter

Functions and contents of the Twitter service, offered by Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, can be integrated into our online offering. This may include, for example, content such as images, videos or texts and buttons with which users can share content from this online offer within Twitter.If the users are members of the Twitter platform, Twitter can assign calling up the above content and functions to the users’ profiles there. Twitter is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law. (https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active). Privacy policy: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization.

LinkedIn

Within our online offer, functions and contents of the LinkedIn service, offered by LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland, can be integrated. This may include, for example, content such as images, videos or texts and buttons with which users can share content from this online offer within LinkedIn. If the users are members of the LinkedIn platform, LinkedIn can assign the call of the above contents and functions to the profiles of the users there. Privacy Policy of LinkedIn: https://www.linkedin.com/legal/privacy-policy. LinkedIn is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law. (https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active). Privacy Policy: https://www.linkedin.com/legal/privacy-policy, Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Age of consent

By using our services, you represent that you are at least 18 years of age.

Disclosure

We will not sell your personally identifiable information to any company or organization, but we may transfer your personally identifiable information to a successor entity upon a merger, consolidation or other corporate reorganization in which 3Dneuro participates or to a purchaser or acquirer of all or a portion of 3Dneuro’s assets to which this Site and our Services relates.

Privacy Policy Updates

3Dneuro may need to update this Privacy Policy from time to time. We will post our updated Privacy Policy on our Site located at 3dneuro.com and in the Services, along with a notice that the Privacy Policy has been changed so you are aware of what personally identifiable information we may collect and how we may use this information. 3Dneuro encourages you to review this Privacy Policy regularly for any changes. Your continued use of this Site, Services and/or continued provision of personally identifiable information to us will be subject to the terms of the then-current Privacy Policy.

Get in touch!

If you:

  • would like to request access to information we hold about you (the data will be transferred to you within 30 days of any request for that information) and/or correct, modify, delete or update Personal Data that you have provided to us, or
  • have any questions regarding this Privacy Policy or the practices of this site, wish to withdraw your consent for the continued collection, would like to object to your Personal Data being used, or have any additional questions:

Please contact us via email at privacy @ 3dneuro.com.