How and why does Castor Networks collect personal data?
Castor Networks collects personal data in the course of its business. In most cases, this involves data that it requests from the data subject or that the data subject provides on his or her own initiative. For example, an initial telephone conversation between Castor Networks and a (potential) customer or the situation in which a (potential) customer sends an email to Castor Networks.
Castor Networks treats personal data with the utmost care. Transparency is an essential element of this care. Castor Networks considers it important that third parties and data subjects have insight into how it uses personal data and the underlying reasons. That is why she drafted this statement. If you have any questions or comments after reading this statement, please contact Castor Networks. Obviously, this also applies if you wish to exercise any of the rights described below or if you have a claim. The full address and name of the contact person can be found at the bottom of this declaration.
Who exactly is Castor Networks?
Castor Networks is considered the controller of personal data. It is registered with the Chamber of Commerce 72385073, with its registered office at the following address: Rijnzathe 4, 3454PV, De Meern, Netherland, it can be contacted at +31 (0)88 646 0100 and by e-mail at the following address: firstname.lastname@example.org.
Does Castor Networks have a data protection officer?
Castor Networks has not appointed a Data Protection Officer. However, it has designated an employee who is the first point of contact with regard to privacy and personal data. This is Mr./Mrs. The full address is given at the bottom of this statement.
What personal data does Castor Networks process and why?
Castor Networks processes different types of personal data, for different reasons. The data it processes are identification data (name, e-mail address, contact person, telephone number, number at the Chamber of Commerce), location data (postal and/or professional address), and financial data (bank account number, payment information). The first main purpose of this processing is to conclude an agreement with the customer. To do this, Castor Networks and the customer must be able to communicate with each other. For example, identify the customer's wishes and prepare an offer. The second main objective is to implement the agreement that has been concluded. For example, regular consultations regarding progress or... The third main objective is to facilitate the invoicing of activities and/or the provision of services, as well as payment (and collection if necessary). The last main objective is to inform the client about developments that may be relevant to him/her.
Is Castor Networks authorised to process this data?
Castor Networks processes personal information if it is necessary to enter into or execute an agreement with a customer and/or supplier. This is the case, for example, when a quote is requested, when an order is placed or when Castor Networks places an order. In addition, Castor Networks processes personal data if its own interests justify it. This will be the case if it is reasonably impossible for Castor Networks to carry out its activities without processing this data. Finally, in some cases, Castor Networks (also) requests permission to use the data. Therefore, the legal grounds for the processing are as follows:
- the processing is necessary for the performance of an agreement to which the data subject is a party, or is carried out at the request of the data subject for the conclusion of an agreement.
- The processing is necessary for the representation of the legitimate interests of Castor Networks (or a third party)
- The data subject has given his or her consent to the processing
With regard to category (ii), it concerns in any case the processing necessary for the performance of Castor Networks' services. It simply cannot carry out its activities, it cannot communicate, it cannot... etc. without using the customer's personal data. It therefore has a legitimate interest in these processing operations. Castor Networks considers that this interest should prevail when it is weighed against the interest of the data subject. The reason for this is twofold. First, the fact that Castor Networks knows from experience that such processing does not normally give rise to objections. So Castor Networks takes this as a starting point. Secondly, the fact that Castor Networks does not keep the data longer than necessary. Nevertheless, in order to respect the rights of data subjects as far as possible, Castor Networks uses only the data that is necessary to achieve the purpose.
With regard to category (iii), the consent given may be withdrawn at any time without giving reasons.
Does this personal data also end up with others?
In some cases, Castor Networks will share personal data with the parties with whom it collaborates. These are called "subcontractors". Castor Networks has entered into agreements with these subcontractors. They are used to ensure that these subcontractors (just like Castor Networks) process the data with care. For example, the agreement obliges the processor to ensure adequate security, to treat the data confidentially, and to destroy the data.
Castor Networks does not intend to share personal data with parties other than subcontractors. It provides that the information will, at most, be shared with one (other) employee of the customer or with the parties who have a direct relationship with the customer in some cases.
Will personal data remain in Europe?
In this context, we refer to the European Economic Area (EEA). It includes EU countries, as well as Norway, Liechtenstein and Iceland. All countries that are not included are considered "third countries". Castor Networks does not transfer any personal data to third countries. In principle, personal data therefore remain in Europe. If, in an exceptional case, there is a transfer to a 'third country', it will only be a country for which it has been expressly established at European level that an adequate level of security of personal data is guaranteed there.
How long will the data be kept?
Castor Networks retains the data it collects for different periods of time depending on the category of data and how it was collected. The exact periods are included in the processing register that Castor Networks has established.
Initially, Castor Networks based the applicable periods on the legal (minimum) periods. Take into account the legal obligation to keep accounting information. In addition, Castor Networks has also sought to comply with the retention periods included in the PDPA Exemption Order, to the extent possible. For example, the customer's contact information is subject to a retention period of up to one year after the termination of the relationship between the parties. Finally, to determine the retention periods, Castor Networks was guided by its interests and those of its customers. For example, it may be important for both parties that documents containing (other) provisions are retained for more than two years. If these documents (e.g. e-mail correspondence) contain personal data, these will also be retained.
With regard to the data collected via cookies on the website, the retention periods as defined in the cookie statement (see elsewhere on this website) apply.
What are my rights?
By law, you are a "data subject", and data subjects have a number of specifically defined legal rights. You may submit a request to Castor Networks to access, receive or modify your personal data or have it deleted. You can also object to the (further) processing of your data. If Castor Networks processes your data on the basis of your consent, you can withdraw this consent at any time. For all these questions, please contact:
3454 PV, De Meern
+ 31 (0)88 646 0100
Castor Networks will respond to your message within one month.
If you believe that Castor Networks is acting in violation of applicable laws and regulations regarding personal data, you can lodge a complaint with the Dutch Data Protection Authority (Postbus 93374, 2509 AJ DEN HAAG).
Does Castor Networks have an automated decision-making process?
There is no automated decision-making at Castor Networks.
What else do I need to know?
- To maintain an appropriate privacy statement, Castor Networks has established a registry that includes all the different ways in which it processes personal data. For each processing operation, the purpose, basis and retention period are included, among others. If you believe that you have not been sufficiently informed through this Privacy Statement, you may request access to this register.
- To protect your personal data, Castor Networks has taken appropriate technical and organisational measures. A description of these is also included in the register of treatments. Castor Networks periodically assesses whether these measurements are still adequate.
- Castor Networks' privacy statement also covers matters independent of its relationships with its customers. For example, there is also a retention period for the data of a candidate for a position.
- Castor Networks ensures that all its employees are aware of its privacy statement and that they are also aware of its importance. All employees are required to keep personal data confidential.
- It will be necessary to amend this statement from time to time. Castor Networks is authorized to do so. We recommend that you check this statement from time to time to see if it has been changed.
Version 1, date 29-4-2022