The Levenue Platform is operated and managed by LevenueB.V., a
private company with limited liability incorporated under the
Dutch law, having its seat in Breda, The Netherlands, and its
registered office at Markendaalseweg 44, 4811KC Breda, The
Netherlands and registered with the Dutch Commercial Register
under number 862436400. Levenue B.V. controls the collection and
processing of any personal data that you provide to us in relation
to the Levenue Platform. Where services are provided to you by any
affiliate of LevenueB.V., the entity providing the service will be
responsible for the processing of your personal data. This privacy
policy applies to all such entities. Levenue B.V. and any such
entities are jointly referred to in this privacy policy as
"Levenue", "we" or "us".
Levenue collects personal data when you use the Platform, register
as a user and contact us. "Personal data" is any information that
relates to you or any identified or identifiable individual and
that identifies you or that individual either directly from that
information or indirectly, by reference to other information that
we have access to.
Levenue is committed to respecting and protecting the privacy of
the individuals on whom it holds information. All your personal
data will be processed in accordance with applicable data
protection laws, including the European Regulation 2016/679 on the
protection of natural persons with regard to the processing of
personal date and on the free movement of such data (the "General
Data protection Regulation" or "GDPR"), as amended from time to
time.
This privacy policy describes the personal data that we collect
from you, the purposes of our processing of your personal data,
the legal basis for our processing of your personal data, whether
any third parties may access your personal data, the retention
period applicable in respect of your personal data, and your
rights regarding your personal data. This privacy policy applies
to the relationship between you and Levenue, together with the
relevant provisions of the Terms of Use of the Platform
https://www.levenue.com/terms
and the Cookies Policy
https://www.levenue.com/cookies.
1. Contact details
If you have any question regarding this privacy policy or our
processing of your personal data or if you want to exercise your
rights with regards to your personal data, you may contact us at:
Levenue B.V. Markendaalseweg 44,
4811KC Breda, The Netherlands,
legal@levenue.com
Levenue B.V. Markendaalseweg 44,
4811KC Breda, The Netherlands,
legal@levenue.com
2. Personal data we collect
2.1
When you use the Platform, we collect the following categories
of personal data:
2.1.1
identification data suchas user account information (if
any), name, email address;
2.1.2
technical data such as your IP address, your operating
system, your browser type;
2.1.3
behavioural data such as the manner in which you use the
Platform and how you interact with the Platform.
2.2
When you register for a user account, we collect the following
categories of personal data:
2.2.1
contact information such as email address, name and surname,
telephone number and address;
2.2.2
biographical information such as employer and job title;
2.2.3
communication preferences such as preferred language;
2.2.4
technical data such as your IP address, your operating
system.
2.3
If you contact us to inform us of any queries you may have, we
will collect the following categories of personal data:
2.3.1
identification data and contact information such as you user
account (if any), email address or phone number;
2.3.2
the content of your correspondence with us.
2.4
When you register for our newsletter, we collect the following
categories of personal data:
2.4.1
identification data and contact information such as you user
account (if any), email address or phone number;
2.4.2
technical data such as information on your device and your
IP address;
2.4.3
behavioural data such as links opened, click throughs;
2.4.4
communication preferences.
3. The purposes of our processing of your personal data
We collect your personal data for the following purposes:
a)
to allow you to access and use the Platform;
b)
to set up and maintain your user account and your access to
youraccount;
c)
to communicate with you and provide you with appropriate
support;
d)
to improve, effectively present and personalise our services
by using the analytical services of third parties to
evaluate your use of the website, create reports on the
activity, collect demographic data, analyse performance
data, and collect other data on our website and Internet
usage. These third parties use cookies and other technology
to help analyse the data and to provide the data to us.
Please see our Cookie Policy
https://www.levenue.com/cookies
for more info;
e)
for fraud and money laundering prevention and detection and
to comply with applicable laws and regulations;
f)
to match users trading on the Platform to the organisations
on behalf of such trading is effectuated, in order to ensure
that such user is entitled to effectuate that trade.
We are committed to safeguarding and protecting your personal
data and using it lawfully, fairly and in a transparent way, in
compliance with the GDPR, and we will only collect and process
your personal data for the specified and explicit purposes
listed above.
4. Legal basis for the processing of your personal data
We are allowed to process your personal data if a legally
permitted reason applies. These include the following:
a)
Performance of the agreement: we are allowed to process your
personal data to communicate with you before entering into our
business relationship, to deliver our services and to fulfil a
contract with you. For example, we need your contact details
to be able to create a user account.
b)
Legitimate interest: we may process your personal data when it
is in our legitimate interest to do so. For instance, we
collect your behaviour data to improve our services and the
Platform.
c)
Consent: we may also process your personal data if we have
your express consent, e.g. when you register for a newsletter
or when you agree to the use of specific cookies.
d)
Legal obligation: we may process your personal data to comply
with our legal and regulatory obligations, such as anti-money
laundering and fraud and crime prevention.
5. Retention and deletion
Levenue may retain your personal data as necessary for internal
analytical purposes, or to provide you with services that you have
requested, comply with its legal obligations, resolve disputes and
enforce agreements (e.g. settlement). The criteria used to
determine the retention periods include:
a)
how long the personal data is needed to provide the services
and operate the business;
b)
the type of personal data collected; and
c)
whether Levenue is subject to a legal, contractual or similar
obligation to retain the data (e.g., mandatory data retention
laws, government orders to preserve data relevant to an
investigation, or data that must be retained for the purposes
of litigation or disputes).
If you would like more information about applicable data retention
policies, please contact our privacy team via the contact details
provided in Section 1. of this privacy policy.
6. Your rights as data subject
Under the GDPR, you are entitled to exercise certain rights
regarding how we use and keep your personal data. You can exercise
your rights by contacting our privacy team via the contact details
provided in Section 1. of this privacy policy. They are the
following:
6.1.1
Right for information and access
You are always entitled to know what personal data we hold
about you and how, where and for how long such personal data
are processed. You therefore have the right to request
information regarding the personal data that we hold and
process concerning you and to access such personal data.
Upon your request, we will provide you with information
and/or access to the personal data that is being processed
and the source of such personal data. Please note that we
may request you to provide us with satisfactory proof of
your identity before complying with your request for
information or access.
6.1.2
Right of rectification and right of erasure
You have the right to request us, free of charge, to rectify
any inaccurate personal data, or to complete any incomplete
personal data, concerning you. You may also have the right,
in certain circumstances, to require us, free of charge, to
erase all your personal data, without undue delay.
6.1.3
Right to object to data processing
You have the right at any time to object to the processing
of your data on grounds relating to your particular
situation. If you object, we will no longer process your
personal data unless we can prove compelling legitimate
reasons for the processing that outweigh your interests,
rights and freedoms, or the processing serves to assert,
exercise or defend legal claims.In case we process your
personal data for direct marketing purposes (such as our
newsletter), and you do not wish to receive advertising, you
have the right to object to this at any time. If we receive
such objection from you, we will stop processing your data
for direct marketing purposes.
6.1.4
Right to withdraw your consent
You may, at any time, withdraw the consent that you have
given to Levenue to the processing of your personal data.
Please note that if you withdraw your consent, that does not
make the data processing carried out by us prior to
receiving your request unlawful.
6.1.5
Right to restriction
You have the right to "restrict" our use of your personal
data where: (i) you contest the accuracy of the personal
data, (ii) the processing is unlawful and you request us to
"restrict" our use of your personal data rather than to
erase it;(iii) we no longer need the personal data for the
original purpose of the processing but they are required by
you for the establishment, exercise or defence of legal
claims; or (iv) you have objected to the processing and
there is a verification of whether our legitimate grounds
can override yours.
6.1.6
Right to data portability
Within the limits set forth in the GDPR, you may request the
portability of your personal data, i.e. obtain that the
personal data you have provided to Levenue be returned to
you or transferred to someone else of your choice, in a
structured, commonly used and machine-readable format.
6.1.7
Right to lodge a complaint with the competent authority
If you are not satisfied with the way we process your
personal data, please contact our privacy team via the
contact details provided in Section 1. of this privacy
policy and we will investigate your concern. You also have
the right to lodge a complaint with a supervisory authority.
In the Netherlands, thesupervisory authority is the
Autoriteit Persoonsgegevens (address:Bezuidenhoutseweg 30,
2594 AV The Hague, The Netherlands, website:
https://autoriteitpersoonsgegevens.nl).
7. Disclosures to third parties and transfers to third parties
2.1
Disclosures and/or to third parties
Other than as set out in this privacy policy, Levenue will
not sell or otherwise disclose your personal data to third
parties without obtaining your prior explicit consent,
unless this is necessary for the relevant purpose set out
in this privacy policy or we are required to do so by law.
We may share personal data with third party cloud providers and service providers who help us to provide, understand, commercialise and improve the Platform and our services. We do not authorise these third-party service providers to use or disclose your personal data except as strictly necessary to perform any services under our supervision or to comply with applicable laws. We seek to provide any such third-party service provider with only the personal data they need to perform their specific function.
Levenue puts in place contractual (including data protection, confidentiality and security provisions) and other organisational safeguards with third-party service provides who have access to your personal data to ensure an adequate level of protection of your personal data.
At the date of this privacy policy, Levenue uses the following third-party providers:
We may share personal data with third party cloud providers and service providers who help us to provide, understand, commercialise and improve the Platform and our services. We do not authorise these third-party service providers to use or disclose your personal data except as strictly necessary to perform any services under our supervision or to comply with applicable laws. We seek to provide any such third-party service provider with only the personal data they need to perform their specific function.
Levenue puts in place contractual (including data protection, confidentiality and security provisions) and other organisational safeguards with third-party service provides who have access to your personal data to ensure an adequate level of protection of your personal data.
At the date of this privacy policy, Levenue uses the following third-party providers:
a) Salt Edge;
b) Vercel;
c) SendGrid;
d) MessageBird;
e) Google – G Suite;
f) AWS;
g) DocuSign;
h) Stripe;
i) Chargebee;
j) Recurly.
2.1
Transfers to third countries
If recipient of your personal data is located in a non-EEA
country and this country is not recognised by the European
Commission as offering an adequate level of data protection,
we will put in place appropriate safeguards to protect your
personal data in accordance with the GDPR, such as the
Standard Contractual Clauses adopted by the European
Commission, if necessary with additional measures.
8. Changes to this Privacy Policy
Levenue reserves the right to change this privacy policy at any
time and from time to time in order to reflect changes in the
services provided on the Platform or the applicable laws. If
Levenue decides to change this privacy policy in the future,
Levenue will post an appropriate notice at the top of this privacy
policy page and/or give you reasonable advance notice through the
Platform. Any non-material change(such as clarifications) to this
privacy policy will become effective on the date the change is
posted and any material changes will become effective thirty (30)
days from their posting on the Platform. The date this privacy
policy was last revised appears at the top of this document. Your
continued use of the Platform after the changes to this privacy
policy become effective signifies that you accept of any such
changes.