DATA PROTECTION NOTICE
Klarrio BV needs to collect and process a limited set of personal data as described in this notice.
Collected and processed data are strictly limited to the intended use and purpose and will be protected to the maximum extent in compliance with the applicable privacy and data protection regulations.
Klarrio fully supports your rights as a data subject to review, correct and delete your data, within the legal limitations. Legal obligations may prevent us from deleting all your data.
If you want to contact us, please send an email to firstname.lastname@example.org
Purpose for collecting your data
Execution of contract
Klarrio BV provides system integration services to its customers and uses your personal data for its business purposes such as:
- Communication in scope of project definition, implementation and delivery
- Providing appropriate support on the provided services
- Knowledge transfer on the provided services or technology as applicable
- Exchanging contracts, invoices and other commercial or legal documents
- Visitor management logbook for security of Klarrio’s premises
Your personal data may be processed for communication purposes (via e-mail, phone, social media…) such as:
- Providing information on Klarrio BV’s services
- Interviews in the recruitment process
- Responding to enquiries
- Business interaction (commercial, financial, operational)
- Invitations to and interaction at events (e.g. job Fairs, meetups, trade shows,…)
If you visit our website there are a number of forms that allow you to submit your personal data:
- Requesting access to Klarrio BV resources such as white-papers or other documents
- Submitting your contact details and resume to apply for a job
- Submitting your contact details to participate in contests (e.g. job fairs, …)
- Providing your contact information together with submitting a generic message or question
We don’t use any tracking cookies hence do not collect any personal data via cookies.
Processing your data
In order to conduct its business, Klarrio BV processes personal information for:
- Human resources (recruitment, employee, payroll, training…)
- Legal and contractual obligations
- Publicity, press releases and marketing communication
- Providing Klarrio BV services to customers
- Financial processing (invoices, payments, accounting…)
For the following processing tasks, we collaborate with data processors. These are carefully selected third party companies that process your data on our behalf, but which are not allowed to use this data themselves, including (but not limited to):
- Hosting and managing the Klarrio BV websites (www.klarrio.com, www.tutorrio.com)
- Email and document storage services
- Post and parcel delivery services
- Ticketing systems
Prior to working with these third party companies, Klarrio performs a due diligence on them to ensure GDPR compliance.
How do we collect your data
From you directly
In many cases you provide us your personal data directly, for example when you show interest in our business or when you submit your contact details and resume to apply for open vacancies.
Via our business services
To enter into a business contract with our customers, we collect personal data to comply with contractual requirements.
Via our business partners
In certain conditions we receive professional contact information from business partners, forwarding your data to us on your request or because of legitimate interest.
We will inform you on receipt of the information at first contact with you.
Occasionally, we organize physical or online events, potentially with other commercial partners. When you register to one of our events, this information is registered with a clear data protection notice. In case this information is used for prospecting or direct marketing you’ll be informed at the moment of collection.
When Klarrio BV participates in events organized by others, we may exchange personal information with the objective to establish follow-up communication.
Via social media
Via social media (e.g. LinkedIn) we might get in touch with you and discover personal data that is shared by you via your social media profile and/or direct communication.
Which data is collected
When visiting our websites (www.klarrio.com, www.tutorrio.com) a limited amount of anonymized data is collected using a privacy-focused website analytics solution (https://plausible.io/privacy-focused-web-analytics).
No personal data (such as IP address) is tracked, collected or stored, the data that is collected:
- HTTP referrer: to derive the number of visitors referred from other websites
- Browser: the browser and version used to visit the website used to ensure compatibility
- Operating system: operating system and version used to ensure compatibility
- Device type: desktop, mobile or table type used to ensure website compatibility
- Country, region and city: geo lookup based upon IP address, the actual client IP address and location of the visitor is discarded and not collected or stored (only country, region and city are stored)
If you apply for a job at Klarrio BV, we collect the following personal information which is provided:
- First and last name
- Personal contact information such as email address, phone number, home address
- Curriculum Vitae
- Any additional information that is provided that may be relevant to the hiring process
Whenever a prospect reaches out to Klarrio BV or Klarrio BV identifies a person as potential contact for business development, the following information will be collected and stored:
- First and last name
- Business contact information such as email address, phone number, office address
- Company name and role/title within the company
In order to conduct its business, the following data is collected and stored:
- Contact person information such as name, email address, phone number for defining, executing and delivering a project
- Invoicing and payment data
- Other data that is shared with us or input via projects conducted with you and our products installed at your site. This data is subject to Non-Disclosure Agreements and/or contractual confidentiality agreements.
Partners and suppliers
If you are a partner or supplier, we might process personal data to create legally compliant contracts with you or to ease the cooperation with you.
How is your data protected
State-of-the-art security measures
We secure all personal data when it is collected, transferred, stored or processed in any other way, with state-of-the-art, up-to-date security and technology such as (non exhaustive):
- Access control to all data (strong password policy, MFA, role division…)
- Encryption of data both stored (at rest) and when communicated (in transit)
We will not publish details about the technology in use, but on request and under NDA we can provide required details to our stakeholders, where relevant.
Use of cloud services
Some operations at Klarrio BV are based on cloud services. In any case, we ensure that your data is always processed and stored within the EU, or if data processing in the EU is not preferable or possible, we will avoid the use of cloud services.
We ensure that we only allow reliable partners to process your data, verifying that they will process data in compliance with the requirements of this data protection notice and the privacy regulations.
Klarrio BV operates in line with ISO 27001 principles and implements an ISMS to comply with applicable legislation depending on the region of our service offering.
Where and how long do we store data?
We store data with EU headquartered companies and geographically within the EU as much as possible. Only when this is impossible within reasonable effort, data may be stored outside the EU when an appropriate level of data protection is guaranteed in conformance with the GDPR.
We store your data for as long as necessary for the above-mentioned purposes.
Personal data will not be stored for any longer period than is reasonably justifiable based on the reasons for its processing and the legitimate needs arising from this. These storage periods do not violate your right to be forgotten.
When the deletion of your data would violate the rights and regulations of third parties (such as transaction data), we will have to keep the data to comply with the regulations of those third parties.
Legal basis for the processing of your data
Execution of contract
We need to process some of your personal data to deliver our services and comply with our contractual and legal obligations.
In some cases, we are legally obligated to process certain information about you, for example, because of tax and VAT, when we have to send you invoices.
Public and vital interest
In limited situations, defined by law we might need to process personal data due to public or vital interest, for example in case of (medical) emergency.
We may also process your data if you have provided explicit consent, for example:
- when you request to be contacted or send an enquiry e.g. via our website
- when you send us your personal data to apply for an open vacancy
If you are a customer or more generally in an existing trade relationship with us, we will send you information about our products and services based on a legitimate interest to act upon the trade relationship.
At any time, you can contact us to exercise your rights, via the contact methods as listed in the ‘Contact us’ section below.
Right to withdraw consent
In case the processing of your personal data is based on consent, you have the right to withdraw this consent at any time. The withdrawal of consent does not affect the lawfulness of the processing before its withdrawal and does not imply that data processed before the withdrawal is deleted.
Right to access your data
You are always entitled to know:
- which personal data we have collected and stored about you
- how, where and for how long this data is stored and processed
Right of rectification
You have a right to request and correct the data we have about you.
Right to be forgotten
You can exercise your ‘right to be forgotten’ or request that we suspend the processing of your data.
You can also refuse any form of direct marketing, profiling or automatic decision-making by informing us about your refusal.
We will comply with the above requests as soon as possible and within the required response times as defined by the law (ref. GDPR). In case of violation of Klarrio BV’s rights or neglection of obligations from your side, we can reasonably limit the exercise of your right to be forgotten.
Right to data portability
If processing is based on consent or necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract, and if such processing is automated, you have the right to receive the personal data concerning you, which you provided, in a structured, commonly used and machine-readable format and to transmit such data to another controller. However, this right is limited in case portability would cause harm to the rights of others.
Right to object
You have the right to object to the processing of your personal data for non-essential services at any time as long as the exclusions mentioned in Art. 17.3 of the GDPR do not apply.
Any essential business communication of Klarrio BV is not considered direct marketing.
Right to restrict processing
You have the right to restrict processing of personal data in the circumstances mentioned in Art.18.1 of the GDPR, for example in case you contest the accuracy of the personal data.
Right to lodge a complaint
If you are of the opinion that we are not handling your data correctly, then we want to be informed of your objections so that we can investigate these and rectify the situation, when necessary. Please see the ‘Contact us’ section below for contact details.
If you think we did not handle your complaint according to your expectations, you are entitled to file a complaint to the data protection authority in your country of residence.
You can find the full list of EU authorities on this page: ttps://edpb.europa.eu/about-edpb/about- edpb/members_en.
Please be aware that you’ll be asked to contact us first, as you are expected to expedite the process with the data controller first, before you escalate to the data protection authority.
Applicable data protection legislation
This Data Protection Notice must be read in such a way that it complies with the ‘Data Protection Regulations’, including the applicable international, European (e.g. GDPR), and national legislation and binding recommendations and regulations, issued by other data protection and privacy authorities.
In case you have questions in relation to the processing and storage of your personal data as described in the privacy declaration, you can address your inquiry to our data protection officer at our CDO office.
Please contact us via email email@example.com or by letter to our corporate HQ in the corresponding country to the attention of the Data Protection and Privacy Office.
Your inquiry will be processed within the legal term of maximum 1 month.
This policy was last reviewed and updated on January 2024
© 2024 – Klarrio BV
Plantin en Moretuslei 1A
Tel: +32 (0)3 296 87 06
VAT: BE 0655.941.021
Data Protection Notice
All Rights Reserved