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Huts by the Water

Privacy Policy

Introduction

Gira Group B.V. ("Gira Group", "we" or "us") offers Data Protection, Cyber and Information Security, Enterprise Risk Management and Compliance services across all domains in the industry. This Privacy Policy (“Notice” or "Policy") covers the Personal Information that Gira Group collect through gira.group and other websites or applications that post a link to this Notice.

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Please note that this Policy does not cover the handling of Personal Information when Gira Group is processing Personal Information on behalf of our customers. Our customers will act as Controllers for any Personal Information related to them or Personal Information that third parties share with us in connection with the use of our services. Gira Group will typically act as a Processor in accordance with applicable Service and/or data processing agreements (“Agreement/s”). 

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This Policy informs you about how we collect, use, disclose, and store Personal Information in our role as a Controller of Personal Information when you: 

  • including when you ask us to contact you. Interact or use our Website,

  • Register and/or attend our events conferences, or webinars (“Event” or collectively “Events”). 

  • Provide your Personal Information for the purposes of administering our services and managing our relationship with you in any manner (collectively “Services”) e.g. collecting your Personal Information to process an invoice for accounting purposes. 

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Definitions

  • Personal information means information that (either in isolation or in combination with other information) enables you to be directly or indirectly identified (“Personal Information” or “Personal Data”)

  • Data controller or a Business (“Controller”) is a party that sets out the purposes and means of processing of Personal Information. Data processor or a Service Provider/Contractor/Third Party (“Processor” or “Third Party”) is a party that processes Personal Information on the Controller’s behalf.

Personal Information Gira Group collects

Personal Information you provide to us

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From Website or Events: We collect Personal Information that you choose to provide to us, for example, on our online form, when you interact with a chat bot on our Website, or if you register for any Events. If you contact us through the Website, we will keep a record of our correspondence.

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From the Services:  We receive and store the Personal Information you provide directly to us. For example, when contracting for a service, we collect Personal Information, such as name, e-mail address, postal address, phone number, job title, etc. We may collect and store media, documents, or other information you provide to us. We collect commercial information, such as records of the purchased Services or information related to requests of our services. 

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Personal Information we automatically collect

When you use the Website: When you visit our Website, we collect Internet or other electronic network activity information through the use of cookies and other trackers. Depending on your tracking preferences, the information we collect may include for example your device’s Internet Protocol (“IP”) address, referring website, what pages your device visited, and the time that your device visited our Website. We also rely on analytics and tools used to prevent spam and other security risks related to the use of abusive automated software. You can choose your preferences with regards to the cookies and other trackers by accessing the preference center on our Website. Visit our Cookie Policy more information on the types of cookies and other trackers we use on our Website. 

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When you use the Services: Internet or other electronic network activity information is also collected when you use the Services: 

  • Information collected by cookies and other tracking technologies – we use various technologies to collect information, including saving cookies to users’ computers. 

  • Customer feedback – While using the Services, you may be asked to provide feedback (e.g., after receiving help from our support team). Providing this feedback is entirely optional. 


Information we collect from trusted third parties 

If your Personal Information has been collected as (i) you interacted or used our Website, (ii) you registered and/or attended our Events, and/or (iii) part of the Services, your Personal information, as stored in our CRM service provider, may be enriched or updated to ensure it is accurate and up to date, and we achieve the purpose for which it was originally collected. Please note that we will also obtain non-personal information related to your organization’s name, structure, industry, and similar attributes through the use of third parties’ data sets, for the purpose of enriching or updating your Personal Information we already hold. 

How long do we store your Personal Information

We store your Personal Information for different time periods depending on the category of Personal Information and the nature of relationship that you have with us. We determine how long we need Personal Information on a case-by-case basis, but our goal is to keep your Personal Information for as short period as possible to achieve the purpose for which Personal Information is collected.

 

We consider the following criteria when we are making decisions on how long we will retain your Personal Information: 

  • The category of Personal Information. 

  • Whether the Personal Information is typically deleted based on specific schedules, such as marketing information. 

  • Whether the Personal Information is necessary to operate or provide our services. For example, account information may be retained for a longer period of time based on the Agreement you have with us. 

  • How long we need to retain the Personal Information to comply with our legal obligations.

  • Our legitimate interests or legal purposes, such as network improvement, fraud prevention, record-keeping, promoting safety, security and integrity, or enforcing our legal rights.

How can you exercise your privacy rights

You may have certain rights relating to your Personal Information, depending on your location and subject to local applicable laws. These rights may include, subject to any exceptions or limitations:

  • The right to know what Personal Information is being collected and for what purpose.  

  • The right to know what Personal Information is being “sold” or “shared”, for what purpose and the categories of recipients of your Personal Information.

  • The right to access your Personal Information.

  • The right to have your Personal Information rectified, corrected or updated.

  • The right to have your Personal Information deleted, including from any third parties where your Personal Information has been sold, shared or disclosed.  

  • The right to opt out of the “sale” or “sharing” of your Personal Information. 

  • The right to object to the processing of your Personal Information.

  • The right not to be subject to any automated decision making and profiling.  

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If you would like to access, review, update, correct, and delete any Personal Information we hold about you, or exercise any other privacy rights available to you, you can either by email or by filling out the Contact Us form. Our privacy team will review your verifiable privacy rights request (“Privacy Rights Request”) and respond to you as quickly as possible. If we are unable to comply with your request due to an exception or limitation, we will explain this in writing. If we need more time, we will inform you of the reason and extension period in writing. 

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If you would like an authorized agent to make a Privacy Rights Request on your behalf, the agent may do so by filling out this request form. We will ask for written, signed permission that the agent has been authorized to act on their behalf. Once written authorization is provided, we will review your Privacy Rights Request and respond to you as quickly as possible. We will respond directly to the e-mail address provided by the authorized agent regarding the fulfillment of the Privacy Rights Request.

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Gira Group does not collect or use any sensitive categories of Personal Information and does not discriminate against you for exercising your privacy rights. We remind you that you have a right to lodge a complaint with a supervisory authority should you feel unsatisfied with our treatment of your Personal Information. 

Contact Us

You can contact us either by email or by filling out the Contact Us form.

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Controller’s Information:

Gira Group B.V.

John M. Keynesplein 10,

1066 EP Amsterdam,

Netherlands

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If you have questions, requests, or concerns regarding your privacy and rights, please let us know how we can help. 

September 16, 2023

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