This Policy was last updated on 23 of October 2018.
The data controller for the processing of your personal data is Surance Technology B.V., registered at the Dutch Chamber of Commerce with registration number 62098896. Our address is Keizersgracht 203, 1016 DS Amsterdam, the Netherlands.
If you have any questions about the processing of personal data resulting after reading our Privacy Statement, you can contact us at firstname.lastname@example.org.
Types of personal data we collect
To assess and open Vive Website and Mobile Application accounts, we can collect and use the following personal data:
- First and last name
- Date, country and place of birth
- Residential address
- Telephone number
- Email address
- Social security numbers and/or other tax identification numbers
- Counter IBAN
- Device data (such as type of device, operating system, IP-addresses and advertising IDs)
- Location data via GPS
- Uploaded images/content
- Device data of added devices and API-keys
- Financial and banking data, product subscriptions and transaction history
- Cookies and usage date on how you use our products and services
- Correspondence with Surance Technology and support data (telephone, chat conversations and email)
- Additional information related to opening an account and creating your personalized investment
- Plans such as your knowledge and experience of financial markets, your financial situation, investment situation and preferences and your risk preferences
- Marketing data (statistics related to our marketing campaigns and data to measure this)
Information about our communication
- When you send us an email, or chat with us online or via social media, we save your correspondence with us if you are already a customer or in the process of becoming one or contacting us to find more about our products and/or services.
- Information we collect when you use our Website and/or our mobile application.
- When you visit our Website and mobile application or use our services, we may register your IP address, browser type, operating system, referring website, web-browsing behavior.
- We may receive an automatic notification when you open (or open a link from) newsletters from us.
Information in relation to social media
Depending on your social network settings, we may receive information from your social network provider. For example, when you sign in for our services using a social network account, we may gather publicly available information you give us access to from your social network profile, including your contact details, interests, and social network.
Information you choose to share with us
You may also choose to share information with us. For example, when you leave a comment for us on Facebook, fill out a survey, submit a contact or application form, leave a review or submit an entry for a contest or scholarship, you have opted to share personal information with us.
Purposes of processing your data
Surance Technologyprocesses your personal data in accordance with the laws and regulations based on several legal grounds. Surance Technology processes personal data to provide our services. For example, personal data is processed to:
- Comply with legal obligations
- To preserve our agreement and to provide our services in a secure manner, we process your personal data. For example, we need your contact information to keep you informed about relevant developments, and we store correspondence data to improve our customer services
- To make your user experience easier and more effective, we may assess how you use our services, and combine this data with information collected via your personal account, registration details, cookies, and similar technologies. This combination enables us to, for example, optimize our search algorithms and offer a better customer experience
- To create better and personalized investment strategies
- To process personal information for (direct) marketing purposes. This means we may use your personal information to send you newsletters, emails, promotions, or other marketing communications. We use the results of our analysis to tailor our marketing communications to your specific interests and preferences. For example, if our analysis shows that you may be interested in certain services, we may customize our newsletters and Website with content that is relevant to you. We may use different channels for our marketing communications, such as emails, social media, and your personal online account during different time frames and in recurrent manner
- To initiate and evaluate business relationships. Your personal data will be processed for the entering into agreements and the performance thereof to the point of commercial services and the managing of the business relations which emerge from them, including the performance of activities aimed at the expansion of our client database
Surance Technology is allowed to process personal data for this purpose because you gave consent or because Surance Technology has a legitimate interest. The consent can be withdrawn at any moment, and you can object at any moment to the processing of your personal data for direct marketing purposes. The withdrawal of consent or exercise of your right to object does not affect the lawfulness of the processing prior to the moment of withdrawal or exercise of the right to object.
You may object or revoke your consent for receiving marketing communications at any time, by following the instructions in the relevant marketing communication or by sending an email to email@example.com
Legitimate and legal interests
In many cases, we are legally required to store certain data about you, for example to verify your identity, for research and to create personalized investment plans.
We can also process certain data when we have a legitimate interest to do so. For example, to prevent and combat misuse, to research and analyze the use of our products and services for marketing purposes, for information and system security or to share certain data with governmental institutions.
Disclosing or sharing data with third parties
We reserve the right to release personal information without your consent or without consulting you, when we deem it necessary to comply with our legal obligations, to enforce our terms and conditions, to protect the security of our Website and application, or to prevent fraud.
To be able to provide our services, we share certain personal data with third parties. We keep the sharing to a minimum and ensure these third parties will handle your personal data with the same care as we do. This means, among other things, we sign Data Processing Agreements. The third parties or categories of third parties with whom we share data are: Onfido Limited, DeGiro, VWD, Auth0, Northern Trust.
- Email, marketing and ad services for managing and executing service emails, direct marketing emails and setting up marketing campaigns;
- SMS providers for sending SMS messages;
- Payment institutions for processing transactions and safeguarding the safety and integrity of the financial sector.
To comply with laws and regulations we can share data with the concerned institutions. For example, the Tax Authorities can request financial data and we can share data with the Dutch Central Bank for participating in the Deposit Guarantee Scheme. Next to this, Surance Technology can have a statutory or legal obligation to share personal data with investigating authorities to prevent and combat misuse, fraud and crimes.
Security and retention
Surance Technology takes the safeguarding of your information very seriously. Surance Technology will take appropriate technical and organizational measures to protect your personal data against loss or unlawful use. These measures include but are not limited to: facilities protected by appropriate security measures, encryption of devices, version tracking and access to our databases is limited to key personnel and IP addresses and use of it is logged. Personal identifiable information and account activity are also protected through the use of user names and passwords. In order to help maintain the security of your information, you should protect the confidentiality of your user name and password.
How long we keep your personal data
We will hold all the data for so long as we have an obligation to the Customer to provide the Services, and thereafter until such time as we delete the Customer's account in accordance with our Customer Terms and Conditions.
Your personal information will be deleted on one of the following occurrences: - deletion of your personal information by you (or by another person engaged by the Customer); or - receipt of a written request by you (or another person engaged by the Customer) to us
For a large amount of data, we are legally obliged to retain this for a minimum of 5 to 7 years after ending the customer relationship. After this period, we don't store your personal data longer than legally allowed and no longer than necessary for the purposes the data was collected for.
We are able to store personal data for longer periods with a valid legal ground, or when the data is sufficiently (for example) pseudonymised or anonymised.
You can request access to or a copy of your personal data collected by us. You may also request the rectification and removal of personal data or the restriction of the processing of your personal data, if there is a reason for doing so. You also have the right to data portability. You also have the right to object to a processing on grounds relating to your particular situation or against the processing of your personal data for direct marketing purposes. More information on your rights is available at: https://autoriteitpersoonsgegevens.nl.
To exercise your right(s), please send us an email at firstname.lastname@example.org or mail us: Surance Technology B.V., Keizersgracht 203, 1016 DS Amsterdam, The Netherlands.
Revoking & limiting consent
When you have provided us with permission to process personal data, or when we process your personal data based on legitimate interests, you are able to revoke this permission in an easy manner or ask us to limit the use of your data. Revoking your permissions does not mean that stored data is deleted.
Direct marketing & usage data
If you do not want your data to be used for direct marketing activities and analysis of the usage of our products and services, you can let us know via the VIVE app anytime. Next to this, our communication via email contains the possibility to unsubscribe from these messages.
GPS and image and content access
While using the VIVE app, you can provide permission to process location data. If you no longer want us to use location data, you can revoke these permissions easily. This permission is also offering the possibility to protect your account, sending, for example, notifications when there is a login from an unknown location. You'll find these settings in the VIVE app. You can revoke provided permissions at any given moment.
Images and content that you use to personalise your VIVE account can be easily changed in the VIVE app.
For more information on how to delete cookies, please see our Cookie Statement.
Modifications to this Policy
This Policy is effective as of 23 of October 2018. We reserve the right to alter or otherwise make changes to this Policy. Notices may be by email to the last email address you provided us, by posting notice of such change on our Site or the Optimizely Service, or by other communication channels. You consent to receiving notices in these ways. We reserve the right to determine the form and means of providing notifications to you, consistent with applicable law. Changes take effect as soon as the Policy is posted.
Questions or complaints
If you have any question or complaints about the processing, please send an email to us at email@example.com . If you feel that your rights have been violated, you may also make a complaint with the Autoriteit Persoonsgegevens, the Dutch Data Protection Authority (www.autoriteitpersoonsgegevens.nl). For more information on the protection of personal data, please consult the website of the Autoriteit Persoonsgegevens.
Cookie Statement Surance Technology B.V.
This Cookie Statement was last updated on 23 of October 2018
Websites use techniques that increase user-friendliness and make the websites as interesting as possible for each visitor. The best-known examples of such techniques are cookies and scripts. (hereafter "cookies"). Cookies may be used by website owners or by third parties – advertisers, for example – who communicate via the website you visit.
We think it is important that you know which cookies our Website and mobile application use and for which purposes they are used. We want to guarantee your privacy and user-friendliness as much as possible. Below you can read more about the cookies we use and for which purposes.
- To make sure the Website and mobile application function properly
- To measure usage of the Website and mobile application
- To display advertisements on our Website and mobile application
- To measure the relevance of our information and your interest in the offer
Cookies to measure usage of the Website and mobile application
The information we collect in this way is used to compile statistics. These statistics give us insight into how often our web page is visited, where exactly visitors spend most of their time, and so on. This enables us to make the structure, navigation and content of the Website as user-friendly as possible for you. The statistics and other reports are not traced back to persons unless they register on the Website.
See below for a list of the cookies we use to gather statistics, what data they collect and how long they are used.
|Name of the cookie||Placed by||Purpose||Duration|
|_ga||Used to distinguish users||2 years|
|_gid||Used to distinguish users||24 hours|
|_gat||Use to throttle request rate||1 minute|
For the cookies that our third parties place and the possible data that they collect, we refer to the statements that these parties provide on their own websites about this; see the links below. Please note that these statements are subject to change on a regular basis. A third party is Google Analytics: https://www.google.com/policies/privacy/
Cookies for the display of advertisements
These cookies are used by advertising networks who act as intermediaries between Surance Technology and advertisers. They are used to show relevant, personalised advertisements or offers through every type of medium (e.g. e-mail, social media, banner ads) based on your behaviour on our Website. They are also used for remarketing advertisements.
These cookies are used to:
- Show relevant, personalised advertisements or offers through every type of medium (e.g. e-mail, social media, banner ads) based on your behaviour on our Website and mobile application
- Limit the number of times each advertisement is displayed;
- Measure the effectiveness of an advertising campaign;
- Make a link to social media, so that you can be recognised when you wish to use social media through Surance Technology Website and mobile application.
See below for a list of the cookies media agencies, advertising networks, and/or we use in combination with advertisements, what data they collect and how long they are used. This list is subject to change.
|Name of the cookie||Placed by||Purpose||Duration|
|Double Adworks Conversion||Advertising Tracking||90 days|
For the cookies that our third parties place for advertising purposes, we refer to the statements that these third parties provide on their own websites. Please note that these statements are subject to change on a regular basis. Surance Technology has no influence over this.
- Google AdWords Conversion (Google): https://policies.google.com/privacy
Other / Unforseen Cookies
Due to the way the internet and websites work, we may not always have insight into the cookies that are placed by third parties via our Website or mobile application. This is particularly the case if our web pages contain so-called embedded elements; these are texts, documents, images or films that are stored with another party, but which are shown on, in or via our Website and/or mobile application.
If you do not want websites to place cookies on your computer at all, you can change your browser settings so that you receive a warning before cookies are placed. You can also change the settings in such a way that your browser rejects all cookies or only the cookies of third parties. You can also delete cookies that have already been placed. Please note that you will need to change the settings separately for each browser and computer you use.
Please be aware that if you do not want cookies, we will no longer be able to guarantee that our Website is working properly. It is possible that some functions of the Website are lost or even that you can't see certain websites at all. In addition, the refusal of cookies does not mean that you will no longer see any advertisements. The ads will no longer be tailored to your interests and will be repeated more often.
How to adjust your settings varies from browser to browser. If necessary, consult the help function of your browser. If you want to disable cookies from specific parties, you can do so via www.youronlinechoices.com.
We will have to amend these statements from time to time, for example because our Website or the rules surrounding cookies change. We may change the content of the statements and the cookies at any time and without prior warning. You can consult this web page for the latest version.
If you have any questions or remarks, please contact firstname.lastname@example.org.