trinckle 3D GmbH, Grimmstr. 12 C 10967 Berlin, Germany (afterwards trinckle, Trinckle, we, our or us) is operating www.trinckle.com and any related software. Trinckle is a data controller and needs to gather and use certain information (data processing) about individuals (data subjects) that can identify directly or indirectly a natural person – processing of a data subject´s personal data.
These include visitors to our website, customers, suppliers, business contacts, employees and other people the organization has a relationship with or may need to contact for business or information delivery. This policy describes:
- which reasons we have to process your personal data
- what data is processed
- where the data is being processed
- what is the legal purpose for data processing
- what rights the data subject has and how he or she can exercise these rights
Furthermore it will describe how this personal data is collected, handled and stored through internal processes to meet the company’s data protection standards and to comply with the law.
Which reasons do we have for processing your personal data?
Depending on the object of business we have different reasons for processing your personal data.
Such reasons can be:
- preparing, performing and analyzing demonstrations of our software
- improving the user experience
- analyzing user behavior
- informing our audience about news regarding our product and the industry
- engaging potential clients
What personal data is being processed?
Depending on the depth of the business relationship, we collect personal data to provide a better service and offering.
Such data can include:
- personal data that can directly identify you, such as, but not limited to your name, your address, your e-mail address, voluntary responses to questions about your business and needs, your behavior within our software while actively logged in to an account.
- personal data that can indirectly identify you, such as, but not limited to your IP-address, data we gather for statistical analysis (browsing behavior). We use multiple tracking and analyzing tools to collect information about the use of our website as well as of our Software. These include Google Analytics, Google Tag Manager, LinkedIn and Hubspot which provide an anonymous dataset that indicates how and where users interacted with our website, duration of visit, entry and exit points to our website and for those who have also opted in to Google’s Data Policy, demographic statistics about the user.
- personal data that can indirectly identify you, such as, specific tracking of website use and behavior in response to emails or online ad behaviors who have opted-in to a further level of tracking of personal behavior as part of a request to better serve them as potential customers for our software platforms.
- any other data you send us or include within the platform. This could also be sensitive data such as your biometrical data whenever you upload a certain type of 3D-model.
Where the data is being processed?
Our data is stored on servers provided by Amazon Web Services, Inc., Google LLC, Microsoft Corporation, LinkedIn Corporation, and Hubspot, Inc. in the European Union or overseas, whereas those are all active members of the EU-US privacy shield and with which trinckle has order data processing agreements.
Where it is needed and only for as long as necessary is personal data also processed and stored on local machines such as laptop and desktop computers.
What is the legal purpose for processing the data?
trinckle only processes personal data when we have a legitimate purpose for doing so. These purposed vary with the different reasons and objects of businesses.
Some of the purposes can include:
- you giving us consent
- processing is necessary for the performance of a contract
- processing is necessary for compliance with a legal obligation to which the controller is subject
What rights does the data subject have?
The data subject can exercise certain rights such as, but not limited to, the right to be informed what, where and who is processing and controlling data by reading this privacy notice.
Further rights can be exercised by writing an E-mail firstname.lastname@example.org we will answer to all enquires in a reasonable period of time.
Further rights include:
- the right to erasure of his or her personal data (the right to be forgotten)
- the right to rectification of his or her personal data
- the right to restrict the processing of his or her personal data
- the right to receive all personal data concerning him or her in a commonly used, machine-readable format
- all rights detailed in EU-GDPR Art. 12 – 23
Trinckle Data Protection Policy
Why this policy exists
This data protection policy ensures that trinckle:
- Complies with data protection law and follow good practice
- Protects the rights of their staff, customers and partners
- Is open about how it stores and processes individuals’ data
- Protects itself from the risks of a data breach
The EU General Data Protection Regulation describes how organisations — including trinckle— must collect, handle and store personal information. These rules apply regardless of whether data is stored electronically, on paper or in other formats. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully. The Data Protection Act is underpinned by eight important principles.
These principles state that personal data must:
- Be processed fairly and lawfully
- Be obtained only for specific, lawful purposes
- Be adequate, relevant and not excessive
- Be accurate and kept up to date
- Not be held for any longer than necessary
- Be processed in accordance with the rights of data subjects
- Be protected in an appropriate manner
- Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection
People, Risks and Responsibilities
Data Protection Policy scope
This policy applies to:
- The head office of trinckle
- All branches of trinckle
- All staff and volunteers of trinckle
- All contractors, suppliers and other people working on behalf of trinckle
This policy applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR.
This can include:
- Names of individuals
- Postal addresses
- Email addresses
- Telephone numbers
- …plus any other information relating to individuals that supports the purpose of our business.
Data Protection Risks
This policy helps to protect trinckle from some very real data security risks, including:
- Breaches of confidentiality. For instance, information being given out inappropriately.
- Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
- Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
Everyone who works for or with trinckle shares responsibility for ensuring that data is collected, stored and handled appropriately. Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.
However, these people have key areas of responsibility:
- The board of directors is ultimately responsible for ensuring that trinckle meets its legal obligations.
- The Data Protection Officer is responsible for:
- Keeping the board updated about data protection responsibilities, risks and issues.
- Reviewing all data protection procedures and related policies, in line with an agreed schedule.
- Arranging data protection training and advice for the people covered by this policy.
- Handling data protection questions from staff and anyone else covered by this policy.
- Dealing with requests from individuals to see the data trinckle holds about them (also called ‘subject access requests’).
- Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
- The Head of IT is responsible for:
- Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
- Performing regular checks and scans to ensure security hardware and software is functioning properly.
- Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
- The Head of Sales and Marketing is responsible for:
- Approving any data protection statements attached to communications such as emails and letters.
- Addressing any data protection queries from journalists or media outlets like newspapers.
- Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.
General Staff Guidelines
- The only people able to access data covered by this policy are those who need it for their work.
- Data must not be shared informally. When access to confidential information is required, employees can request it from their direct managers.
- Trinckle will provide training to all employees to help them understand their responsibilities when handling data.
- Employees must keep all data secure, by taking sensible precautions and following the guidelines below.
- In particular, strong passwords must be used and they should never be shared.
- Personal data should not be disclosed to unauthorised people, either within the company or externally.
- Data must be regularly reviewed and updated if it is found to be out of date. If no longer required, it must be deleted and disposed of.
- Employees must request help from their manager or the data protection officer if they are unsure about any aspect of data protection.
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.
When data is stored on paper, it must be kept in a secure place where unauthorised people cannot see it. These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
- When not required, the paper or files should be kept in a locked drawer or filing cabinet.
- Employees must make sure paper and printouts are not left where unauthorised people could see them, like at the printer.
- Data printouts must be shredded and disposed of securely when no longer required.
- When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
- Data must be protected by strong passwords that are changed regularly and never shared between employees.
- If data is stored on removable media (like a CD or DVD), these must be kept locked away securely when not being used.
- Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
- Servers containing personal data should be sited in a secure location, away from general office space.
- Data is backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
- Data are not saved to not approved devices such as laptops, USB-sticks or other mobile devices like tablets or smartphones.
- All servers and computers containing data are protected by approved security software and a firewall.
Personal Data Use
Personal data is of no value to trinckle unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:
- When working with personal data, employees will ensure the screens of their computers are always locked when left unattended.
- Personal data will not be shared informally.
- Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
- Personal data should never be transferred outside of the European Economic Area.
- Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.
The law requires trinckle to take reasonable steps to ensure data is kept accurate and up to date. The more important it is that the personal data is accurate, the greater the effort trinckle should put into ensuring its accuracy.
It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
- Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
- Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
- Trinckle will make it easy for data subjects to update the information trinckle holds about them. For instance, via the company website.
- Data must be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it must be removed from the database.
- It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.
Subject Access Requests
All individuals who are the subject of personal data held by trinckle are entitled to:
- Ask what information the company holds about them and why.
- Ask how to gain access to it.
- Be informed how to keep it up to date.
- Be informed how the company is meeting its data protection obligations.
- Ask trinckle to delete all their personal data (right to be forgotten)
- Ask for machine readable copy of their personal data
If an individual contacts the company requesting this information, this is called a subject access request.
Subject access requests from individuals should be made by email, addressed to the data controller at email@example.com. The data controller can supply a standard request form, although individuals do not have to use this.
The data controller will provide the relevant data within a reasonable time frame. The data controller will always verify the identity of anyone making a subject access request before handing over any personal information.
Disclosing Data for other Reasons
In certain circumstances, the GDPR allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances, trinckle will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.
Trinckle aims to ensure that individuals are aware that their data is being processed, and that they understand:
- How the data is being used.
- How to exercise their rights.
To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.