1. Introduction
At TestLapp BV (the company that runs the PasteAway site and software), we carefully deal with privacy and privacy-sensitive data, to comply with the General Data Protection Regulation (GDPR) and the Telecommunications Act. We will consider as much as possible the European Commission's January 1 2017 proposal to replace the ePrivacy Directive from 2002 with a new ePrivacy Regulation. For example, in the ePrivacy Regulation proposal conditions are attached to the use of cookies and to sending newsletters.
In this privacy and cookie statement we inform you about which personal data we process, for which purposes we process personal data, the way we process personal data, how you can exercise your privacy rights and other information about how we handle personal data. Personal data is data that can be used to identify an individual or which can be linked to an individual.
This privacy and cookie statement applies to the usage of the PasteAway websites (like www.pasteaway.com and admin.pasteaway.com, hereafter: “the Websites”) and the related services, like subscribing to our newsletter, making purchases in our webshop, usage of our clipboard manager software and the hosting of your clips in our cloud-storage. When processing personal data, we make a distinction between the various users of the Websites, namely the website visitor, the trial user and the customer.
2. For which purposes is PasteAway processing personal data?
PasteAway processes various personal details of you by means of the Websites, depending on how you use the Websites and our services.
The website visitor
For website visitors, PasteAway processes personal data for the following purposes:
- for statistical purposes, like measuring the number of visitors to the various pages of the Websites and tracking how visitors reached the Website and from which countries, in order to improve the Websites
- to measure the effectiveness of our marketing efforts and costs
- for customer support, to answer your questions about our software and services
The trial-user
Users can sign up for a free trial of our software and services, using their email address, after which he becomes a trial-user. For trial-users, PasteAway processes personal data for the following purposes (in *addition* to the purposes listed above for visitors):
- to send you the information you need to get started with the trial software
- to create and process a personalized account for using our software and services
- to store and process your clip content on our servers
The customer
When users subscribe to one of our paid services (subscription software), that user becomes a customer. For customers, PasteAway processes personal data for the following purposes (in *addition* to the purposes listed above for visitors and trial-users):
- to let you place orders in our web-shops, to process your orders and to deliver the services you purchased
- to send you product update notifications
- to provide the services you are entitled to as a paying customer (product updates, unlimited storage, etc…)
3. Which personal data is collected by PasteAway and for how long?
PasteAway does not store personal data for longer than is necessary for the purposes mentioned above. With the exception of the data that we have to store longer because the law obliges us to do so. The retention period for personal data depends on the groups defined above (website visitors, trial-users and customers):
The website visitor
For website visitors, PasteAway processes the following personal data:
- IP-adres, user-agent, referrer, identifiers in cookies and statistical data about the pages visited.
This data is stored for 3 months and will be removed afterwards.
The trial-user
For trial users, PasteAway processes the following personal data, in *addition* to the data listed above for website visitors:
- E-mail adres.
- Username.
- Password (encrypted).
- The content of your clips
If the trial-users doesn’t become a customer, his personal data is stored for 6 months and will be removed afterwards.
The customer
For customers, PasteAway processes the following personal data, in *addition* to the data listed above for website visitors and trial-users:
- First name, last name
- Address and zip code
- Country
Personal data for customers is retained as long as the customer is using our software and services, plus 1 year after the customer stops using them. When the customer stops using our services, he can request that his account and all data stored will be removed (directly).
Financial data is processed for tax purposes and must be retained for seven years and will be removed afterwards.
In case the user contacts customer support email conversations is stored for 3 years and will be removed afterwards.
All other data processed for users on the Websites will be deleted if the processing is no longer necessary for PasteAway.
4. Accuracy and responsibility
When you provide personal information to PasteAway, you are personally responsible for the accuracy and for keeping it up-to-date. PasteAway is not liable, except for intent or gross negligence, for inaccuracies or consequences of activities that are undertaken on the basis of incorrect or incomplete information provided by you.
5. To whom is PasteAway providing personal data?
PasteAway does not provide any personal data to third parties, except for the processors we use for customer support, email broadcasts, the management and maintenance of the Website, as well as the services offered there, such as the online processing of payments. Appropriate processing agreements have been concluded between PasteAway and these processors, which include a confidentiality clause. The processors of PasteAway are not allowed to process the personal data for other purposes.
PasteAway only provides personal data to third parties outside the European Union if an appropriate level of protection for personal data is available in the country concerned.
In some cases PasteAway is legally obliged to provide certain personal data to third parties. For example, it is possible that the police will request information from us in the context of a fraud investigation. In that case, we are legally obliged to provide this information.
6. Security
We take appropriate security measures to limit abuse of and unauthorized access to your personal data. In this way we ensure that only the necessary persons have access to the data, that access to the data is protected and that our security measures are checked regularly.
7. How is PasteAway using cookies?
What are cookies and similar techniques?
A cookie is a small text file that is placed on or read from your computer during your visit to the Websites, for example in the browser of your computer, tablet or smartphone. Through this text file data is stored or read, including personal data. On the basis of this (personal) data you can be recognized on a later visit.
JavaScripts and web beacons are examples of similar techniques that, together with cookies, enable a system to collect information (via Javascripts), store it in small, simple text files (cookies) and then send it (web beacons). This happens in our Websites, but also in our newsletters. We can use this to see who opened newsletters and which links in the newsletter were clicked. All these techniques together are called 'cookies'.
For what purposes does PasteAway use cookies?
- Technically necessary cookies: these cookies are necessary to enable the technical operation of our Websites.
- Functional cookies: these cookies are used to provide necessary functionality of our Websites, such as the possibility to save preferences, a shopping cart, remember a login and other functionalities, whether or not within the duration of the session in question . For example, a cookie is placed to remember that you have placed an order in your shopping cart but have not yet fully completed it.
- Analytical cookies: PasteAway uses Google Analytics and other analytical cookies in a privacy friendly way to analyze how visitors use our Websites. For example, PasteAway can improve the user-friendliness of the Websites in this way. With Google Analytics, personal details of visitors are processed.
Which (personal) data is collected by PasteAway via cookies?
PasteAway collects your IP address and MAC address (where possible anonymous), surfing and click behavior, cookie identifiers, technical characteristics (such as the browser you use and the resolution of your computer screen), from which websites you arrived on one of the PasteAway Websites (referrer), when and for how long you visit or use our Websites, whether you use the functionalities of our Websites and which pages you visit on our Websites.
How can you avoid cookies (even more)?
By changing the settings of your browser, you can indicate that your browser is not allowed to accept cookies (from our Websites). If your browser does not accept cookies from our Websites, it is possible that you cannot use to certain functionalities of our Websites or you may not be able to use any functionalities. If you wish to oppose the cookies of Google Analytics, you can set this in your browser by refusing cookies from Google (Analytics) via your browser or by clicking here.
8. Visitor and user rights
Because your personal data is processed by PasteAway, you have certain rights. These rights are explained below. As a trial user and as a customer, you can exercise the right of access and the right to improve, supplement and delete your personal data via your account on admin.pasteaway.com.
In addition, you can send an email request for execution for one or more of the following rights to support@pasteaway.com. To prevent abuse, we ask you to identify yourself adequately by sending a copy of a valid proof of identity. Do not forget to hide your BSN and your passport photo on the copy.
Right of access and the right to get a copy
- At your request, PasteAway will provide you with access to and a copy of your processed personal data via the Websites within a maximum of four weeks.
- Before you get access to and a copy of the processed data, PasteAway will verify your identity.
- PasteAway may refuse the access to and the copy of the processed data if the request is excessive or if this is necessary to ensure the protection of you or the rights of others.
Right for improvement, addition, restriction or removal
- If access to you has been granted or a statement has been made about your personal data, you can request PasteAway in writing to correct, supplement, delete or restrict the personal data processed via the Websites, if these are incorrect, if they are incomplete or unnecessary for the purpose of the processing or if they are otherwise processed in violation of a statutory provision. The changes to be made must be stated in the request.
- PasteAway will send you a response within four weeks, indicating the extent to which the request is being met. If a request is refused, the reason for this willl be indicated.
- PasteAway will ensure that a decision to improve, supplement, remove and / or restrict is carried out within four weeks.
- PasteAway will also inform each recipient to whom the personal data have been disclosed if necessary. In the decision, PasteAway will include to which recipient the information is provided.
Right to object
- At any time, you can object in writing to processing your data (I) for direct marketing, (II) for scientific or historical research or for statistical purposes or (III) due to personal circumstances.
- PasteAway will send you a decision on this within four weeks. As long as no decision has been taken on the objection, a limitation of the processing of your personal data can be made on request.
- PasteAway will terminate the processing immediately if it considers the objection well-founded.
Right to data portability
- If PasteAway agrees to your request for a copy of your personal data, this will be provided to you in a structured, commonly used and machine-readable format. The right of portability of personal data applies if the processed personal data have been processed on the basis of your consent or if this was necessary for the execution of an agreement. Only the digitally processed personal data will be provided to you.
- You have the right to transfer those personal data to another controller.
9. How to contact PasteAway?
For questions, requests or complaints regarding the processing of your personal data, please contact us at support@pasteaway.com. We are happy to help you if you have a complaint about the processing of your personal data. If, for any reason, you are not happy about how we deal with your request, then, under the privacy legislation, you also have the right to file a complaint with the data protection supervisor, the Dutch Data Protection Authority. You can contact the Dutch Data Protection Authority for this.
10. Changes to the privacy and cookie statement
We may change this privacy and cookie statement from time to time. Changes will be published on our Websites. It is therefore advisable to consult this privacy and cookie statement regularly, so that you are aware of these changes.