Privacy statement - The Elephant Path
The Elephant Path
Karel Doormanstraat 390S
Contact person: Suzan Doornwaard
The Elephant Path is the responsible party within the meaning of the GDPR. The Elephant Path believes it is essential that the personal data of its customers and website visitors are handled and protected with the utmost care.
How The Elephant Path collects personal data
The Elephant Path collects personal data in different ways:
- When you visit our website
- When you email us or contact us via the contact form on our website
- When you provide us with these data in order to make use of our services
- Via third parties with whom we cooperate in the context of our research services.
For what purposes The Elephant Path processes personal data
The Elephant Path uses the personal data collected from you for operational management and for the proper performance of its services. The primary purposes for which The Elephant Path processes personal data are:
- To enter in or execute an agreement with you
- To perform our services
- To call or email you if this is necessary to perform the services you use
- To deliver the services you have taken
- To respond to your request
- For administrative purposes
- To process your payment
- To send newsletters or mailings for which you have signed up
- To analyze the use of our website
- The Elephant Path also processes personal data if we are legally obliged to do so, such as information that we need for our tax return
Which personal data The Elephant Path processes
The Elephant Path processes the following personal data, depending on how you use our website (e.g., contact form) and how you make use of our services:
- Name, address
- Email address
- Telephone number
- Name organization, function
- Billing address
- Chamber of Commerce (KvK) number
- VAT (btw) number
- Bank account number (IBAN)
- Cookies (see Cookie Statement)
- Surf and click behavior
Special and/or sensitive personal data
Special personal data are data of a sensitive nature. For instance, data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, data concerning health or mental condition of participants and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning a natural person’s sex life or sexual orientation, and data of a criminal nature. Due to the nature of our services, we may process special categories of personal data in the context of research we conduct for our customers. We process the data you provide us in that context based on your explicit consent and for that purpose only. You can withdraw your consent at any time. Under the heading ‘Your rights’ you can read how you can do so.
When you participate in research, we may process personal data that are needed for answering the research question or questions, such as name, address, postal code, city, gender, date of birth, function, country of birth, special categories of personal data, user data of websites and apps that are being used in the context of the research. Which data are being processed in a specific research study is stated in an information letter or privacy statement pertaining to that research. Research data may be used:
- To evaluate whether you qualify for the research based on your consent
- For the research purposes as further detailed in the information letter or the appropriate privacy statement you receive or are able to check before you decide to participate in the research based on your consent
Data about persons younger than 16 years old
Within the context of our research services, it is possible that we collect personal data of persons who are younger than 16 years old. In those cases, we only collect or process data with prior consent of the legal representative(s). Other than that, our website and/or services do not intend to collect data about persons who are younger than 16 years, unless they have permission from parents or guardians. However, we cannot check if a website visitor is older than 16. We encourage parents/guardians to be involved in the online activities of their children, to prevent data about children being collected without parental consent. If you are convinced that we have collected personal information about a minor without this consent, please contact us via firstname.lastname@example.org, and we will delete this information.
The Elephant Path does not make decisions based on automated processing (algorithms) on matters that can have (significant) consequences for you. These are decisions that are taken by computer programs or systems, without involving a person.
The Elephant Path uses Google Analytics, a web analytics tool offered by Google Inc. (Google). We have configured Google Analytics services in accordance with the manual for privacy-friendly configuration (“Handleiding privacyvriendelijk instellen van Google Analytics”) as enacted by the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) dated 15 August 2018. This means we entered into a data processing agreement with Google. The data we collect in Google Analytics is anonymized and encrypted. We agreed that:
- The last octet of the IP address will be deleted before saving it
- The setting “share data” is disabled
- We do not make use of any other Google services in combination with the Google Analytics-cookies
Google Web Fonts
To ensure that fonts used on this website are uniform, this website uses so-called Web Fonts provided by Google. When you access a page on our website, your browser will load the required web fonts into your browser cache to correctly display text and fonts. To do this, the browser you use will have to establish a connection with Google’s servers. As a result, Google will learn that your IP address was used to access our website. The use of Google Web Fonts is based on our interest in presenting our online content in a uniform and appealing way. According to Art. 6 Sect. 1 lit. e GDPR, this is a legitimate interest. If your browser should not support Web Fonts, a standard font installed on your computer will be used. For more information on Google Web Fonts, please follow this link: https://developers.google.com/fonts/faq and consult Google’s Data Privacy Declaration here.
See our Cookie Statement.
How long The Elephant Path stores personal data
The Elephant Path does not store personal data longer than the legal retention periods or, if this is not applicable, no longer than is necessary for performing the agreement or processing the question. For administrative data, the legal retention period of seven years applies.
Sharing of personal data by The Elephant Path with third parties
The Elephant Path will only share your personal data with business partners and third parties if this is necessary for the performance of the services and to comply with any legal obligation. Examples are IT service providers for web hosting, bank or other payment service providers for processing payments, administration software or our accountant for doing administration. With companies that process your data on our behalf, we signed a processor agreement to guarantee the same level of security and to safeguard the confidentiality of your data. We remain responsible for these processing operations.
How The Elephant Path protects personal data
We take the protection of your data very seriously and take appropriate measures to fight misuse, loss, unauthorized access, unwanted disclosure, and unauthorized change. If you feel that your data is not secured properly or there are indications of abuse, please contact us at email@example.com.
You have the right to view, correct or delete your personal data. Furthermore, you have the right to withdraw your consent for the data processing or to object to the processing of your personal data by The Elephant Path. In addition, you have the right to data portability. This means that you can submit a request to move the personal data that we have from you via a digital file to you or another organization appointed by you. In case you participate in research, direct your request to the contact person mentioned in the informative letter. In any other cases, you can send all requests to view, correct, delete and transfer your personal data, or request for withdrawal of your consent or objection to the processing of your personal data to firstname.lastname@example.org. To ensure that the request for access has been made by you, we will ask you to send a copy of your ID. To protect your privacy, make sure that your passport photo, MRZ (machine readable zone, the strip with numbers at the bottom of the passport), passport number and Citizen Service Number (BSN) is made black. We will respond as quickly as possible at your request, but no later than four weeks. We would like to point out that you have the opportunity to file a complaint with the Dutch national supervisory authority: the ‘Autoriteit Persoonsgegevens’.
Do you have any specific questions or comments about our Privacy Statement based on this information? If so, do not hesitate to get in touch with us. You may either use the contact form on the website or send an email to email@example.com.
The Elephant Path reserves the right to modify this Privacy Statement. We recommend that you regularly check this page to see if changes have been made. In case of changes to the Privacy Statement that we consider being of a large scale, we will announce this for a period of time on this website.
This Privacy Statement was last modified on October 10, 2018.