1.Explanation
At Vintura we consider it important that we communicate with customers, associates and applicants in the most personalised way possible. We can only do that if we know who you are and what you want. We treat this data with the utmost care, knowing that it is our responsibility to protect your privacy.
This page explains which data we collect and why. If you have any questions about this privacy state-ment or about the use of cookies, please do not hesitate to contact us. This privacy statement applies to all of Vintura’s services and to all dealings with Vintura. By using this website, you indicate your acknowledgement of this privacy policy.
This Privacy Statement sets forth the privacy policies and practices of Vintura. and its subsidiaries and affiliates (collectively, “Vintura”), as they relate to the collection, use and disclosure of Personal Data (as defined below) in connection with your use of our websites that link to this Privacy Statement (the “Websites”). Please read this Privacy Statement carefully and completely before using the Websites.
This Privacy Statement does not apply to Personal Data processed by Vintura:
– When you apply for a job with us. Please see Applicant Privacy Statement.
– In the course of your employment with us – whether as an employee or independent contractor.
– Where we process Personal Data on behalf of and on the instructions of our customers (i.e., as a processor or a service provider). We are not responsible for the privacy or data security practices of our customers, which may differ from those explained in this Privacy Statement.
– That is subject to certain laws related to clinical trials and research.
The terms “we,” “us,” and “our” refer to Vintura, and the terms “you” and “yours” refer to you, as user of the Websites.
2. What is Personal data
When we use the term “Personal Data” in this Privacy Statement, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual or household. The term does not include aggregated information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual and does not apply to other information that is excluded from privacy protections under applicable law (“Deidentified Data”).
3. How do we collect personal data?
We collect personal data on prospects, customers, applicants and visitors to our office or website. Our purpose in doing so is to provide you with the best possible service. We use personal data that you supply to us or that we collect from you (for instance via the website or LinkedIn). You are not obliged to disclose your personal data to us. However, without that data it will often be difficult to send you a quote or the information/documents that you have requested, to perform work or to invoice you.
For our events we use professional photographers and film-makers. We use the images/footage that they shoot for digital communication via Vintura. We would stress that we treat your privacy with the utmost care. In this respect we comply with the guidelines pertaining to the right to protection of one’s own likeness (‘portretrecht’).
4. Collection and Use of Your Personal Data
What personal data do we collect?
We may collect Personal Data directly from you when you visit our Websites, choose to use services or participate in programs or otherwise provide Personal Data directly to us. Personal Data we collect directly from you may include:
– Contact Information: including name, email address, postal address, and/or telephone number.
– Account Information: including your user ID and password;
– Communications Information: including information provided in messages sent through the forms, product and service preferences and/or behaviors; and future communication preferences;
– Survey Information: information provided when you respond to questions submitted through surveys, e.g. name, contact details, date of birth and gender;
– Marketing Information: personal details (name, contact preferences) provided in order to personalize marketing and promotional communications information based on your activities and interests to the extent it is necessary for legitimate interest purposes.
-CVs and other profile data: information related to your CV and other profile data that is recruitment related
Personal Data We Automatically Collect About You
With your consent, we and our third-party providers may collect certain Personal Data from (or in connection with) your device only when you visit the Websites, use our Services, or view online advertisements. This Personal Data includes:
– Device Data: including internet protocol (IP) address.
We and our third-party providers may use cookies and other related technologies such as, web beacons to automatically collect this information. This helps us analyze how you use and interact with our Websites and distinguish you from other users. It also helps us and our third-party providers to determine products and services that may be of interest to you. For more information about these practices and your choices regarding cookies, please see our Cookie Policy.
Personal Data We Collect from Other Sources and Third Parties
We collect Personal Data from third parties, which we may combine with Personal Data we collect automatically or directly from a user. We may collect the same categories of Personal Data as identified above from the following third parties:
– Your Employer / Company: we may receive your Contact Information and business details, such as business name and department, from your employer / company where you interact with the Websites through your employer / company.Please be advised that any Personal Data provided to us by a third party may also be subject to that third party’s privacy policy.
Some of the Personal Data (e.g., financial account and location data) that we collect, and process may be considered sensitive Personal Data in certain jurisdictions. The processing of such data is necessary for providing services to you and/or personalizing our services and Websites. We adopt appropriate security measures to protect the Personal Data we process, including sensitive Personal Data. We do not expect that our processing of sensitive Personal Data would impact your rights and interests adversely.
5. Retention
Personal Data will be stored and kept as long as needed to carry out the purposes described in this Privacy Statement or as otherwise required by applicable Data Protection Laws. Because these needs can vary for different data types in the context of different services, actual retention periods may vary.
When determining the retention period, we consider various criteria, such as the type of service requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with services, the impact on the services we provide if we delete some Personal Data from or about you, mandatory retention periods provided by applicable law, including Data Protection Laws.
Unless we are required or permitted by law to keep your Personal Data for a longer period of time (e.g., in pending litigation matters or where the law requires us to), when this Personal Data is no longer necessary to carry out the purposes for which we process it, we will delete your Personal Data or keep it in a form that does not permit identifying you. If there is any Personal Data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of that Personal Data.
6. Purposes and Legal Bases for Processing Personal Data
We process Personal Data for the following purposes (and as required where you or we are located in the EEA/UK in reliance on the following legal bases):
Subject to applicable Data Protection Laws, you have a right to object to the processing of your Personal Data where that processing is carried out for our legitimate interests. You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of service-related communications (e.g., account verification, updates to features of the Websites, technical and security notices).
In certain jurisdictions, applicable Data Protection Laws may require that we obtain your consent for the processing of your Personal Data. In such circumstances, we will process your Personal Data based on your consent. In appropriate circumstances, your consent may be implied by your conduct.
7. Consequences of Not Providing Personal Data
Where we need to collect the abovementioned categories of Personal Data by virtue of a legal obligation or in light of a contract entered or to be entered into with you, and you do not provide this Personal Data when requested, we may not be able to comply with our legal obligations, provide you with the services or perform the contract we have or are trying to enter into with you. In such case, we may have to terminate our relationship with you.
8. Sharing Your Personal Data
We may share your Personal data with the following third parties:
– Cencora Affiliates: we may share your Personal Data with our subsidiaries and affiliates for the same purposes as are described above.
– Service Providers: we engage third-party service providers to perform business / operational services for us or on our behalf and to whom we will disclose Personal Data. These third parties include, for example, providers of website hosting, IT services, analytics services, and payment processing services.
– Your Employer / Company: we may disclose your Personal Data to your employer / company if you interact with our Websites through your employer / company.
– Transactions: we may disclose Personal Data to a third-party during negotiation of, in connection with, or as an asset in a corporate business transaction. Personal Data may also be disclosed in the event of a transfer, sale or merger of all or a portion of Vintura’s assets, in the event of an insolvency, bankruptcy, or receivership or other corporate change involving us or our affiliates.
9. Disclosing information as required by law and similar disclosures
We may disclose Personal Data we have about you: (i) if we are required to do so by law, regulation, or legal process, such as a court order or subpoena; (ii) in response to requests by government agencies, such as law enforcement authorities; (iii) when we believe a disclosure is necessary or appropriate to protect against or respond to physical, financial or other harm and injury (iv) in connection with an investigation or suspected or actual unlawful activity.
10. Aggregated information
We may share anonymous usage data on an aggregate basis with third parties to help us perform analysis and make improvements. Additionally, we may share anonymous usage data on an aggregate basis in the normal course of operating our business; for example, we may share information with subsidiary organizations to show trends in the use of our services.
11. Other disclosures
At your direction or request, or when you otherwise consent, we may share your Personal Data for purposes other than those that are listed above.
If you would like to obtain information regarding the names and contact details of the parties with whom we share your Personal Data, their processing purpose and method, the categories of Personal Data shared with them, and the method and procedures for exercising your rights with them, please contact us using the contact details set out at the end of this Privacy Statement. Please note however that we may not be able to fulfil this request in all instances.
12. Your Privacy Rights
You may have certain privacy rights with respect to your Personal Data, including as follows:
- Right to Object: you have the right to object at any time to the processing of Personal Data on grounds relating to your particular situation, including a right to object to the processing of your Personal Data for processing performed on the basis of legitimate interest, unless we are able to demonstrate overriding compelling legitimate grounds.
- Right to Know/Access: You have the right to obtain confirmation from us as to whether we are processing your Personal Data and the right to access and receive a copy of such Personal Data.
- Right to Delete/Erasure: In some cases, you may request the deletion or erasure of Personal Data concerning you.
- Right to Rectify/Correct Inaccurate Information: If we process inaccurate, incomplete, or outdated Personal Data, you have the right to rectification.
- Right to Withdraw Consent: Once you have consented to the collection of your Personal Data, you may withdraw your consent at any time. Please note that your withdrawal of consent would not affect the lawfulness of processing based on consent before it was withdrawn.
- Right to Data Portability: You have the right to receive the Personal Data concerning you in a structured, commonly used and machine-readable format and the right to transmit that information to another company where feasible.
- Right to Restrict: You have the right to restrict us from processing Personal Data under certain circumstances e.g. you contest the accuracy of your Personal Data or when you believe that we are processing your Personal Data beyond the original purpose.
- Right to Lodge a Complaint: You have the right to lodge a complaint with the competent data protection supervisory authority. You can, for example, contact the supervisory authority in the EU Member State of your residence, place of work or place of alleged infringement.
- Right to Opt-out of the Sale of Personal Data: We do not sell your personal data and we do not collect any Sensitive Personal Information for the purpose of inferring characteristics about you. If you consent, we do share certain information with business partner organizations to market our services, but you can opt-out of such sharing by rejecting cookies that are not strictly necessary.
- Right to Non-Discrimination: we will not discriminate against you for exercising any of your privacy rights.
You may exercise these rights by contacting us at privacy@cencora.com. In order to protect your privacy, we may take steps to verify your identity before fulfilling your request.
14. International Transfer of Personal Data
In connection with the delivery of our services, we may, for operational (non-commercial) reasons, share personal data with third parties working on our behalf. We regulate any such processing in processing agreements. These agreements ensure that any parties working on our behalf will protect the security and confidentiality of your data.
The Personal Data we collect may be transferred to and stored in countries or provinces outside of the jurisdiction you are into locations where we and our third-party service providers have operations, including in the USA. For example, if you are accessing a Website hosted in the USA (e.g., by Cencora Corporation) from the EEA, UK or Switzerland, your Personal Data will be processed outside of the EEA, the UK and Switzerland, respectively.
Vintura has entered into intra-group data transfer agreements to ensure the lawful transfer of Personal Data between the Cencora companies.
European Transfers: If you are located in the EEA, UK, Switzerland or other countries which restrict the transfer of Personal Data, we comply with applicable data protection laws when transferring your Personal Data outside of these areas. In particular, we may transfer your Personal Data to countries for which adequacy decisions have been issued; implement appropriate and suitable safeguards such as the European Commission’s Standard Contractual Clauses or the Addendum B.1.0 issued by the Information Commissioner of the UK for the transfer of Personal Data to our U.S. headquarters, other offices or third parties, where applicable, or where required, we will ask you for your prior consent.You may contact us using the details below to obtain information regarding the safeguards we use to legitimize the cross-border transfer of Personal Data.
15. Security of Your Personal Data
We use appropriate technical, administrative and physical safeguards to protect Personal Data from loss, misuse or alteration. We limit access to Personal Data to those employees, agents, contractors and other third parties who have a business need to know. You acknowledge and agree that no organization can guarantee the absolute security of Personal Data, and any transmission of Personal Data is at your own risk.
16. Protection of Children
Vintura will not knowingly collect, use or disclose Personal Data from a Child without obtaining prior consent from a person with parental responsibility (parent or guardian) where required by applicable law. Vintura abides by laws protecting the privacy of Children. Should a user whom we know to be under 18 provide Personal Data to us, we will use that information only to respond directly to that Child to inform him or her that we must have parental consent before receiving information about him or her and then delete it.
17. Links to Other Sites
Our Websites may provide links to third party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Statement, this Privacy Statement does not apply to, and we are not responsible for, any Personal Data practices of third-party websites and online services or the practices of other third parties. To learn about the Personal Data practices of third parties, please read their respective privacy policies.
18. Modifications and Updates to Privacy Statement
Vintura may update and modify this Privacy Statement from time to time. If we make material changes to this Privacy Statement, we will notify individuals by email to their registered email address, by prominent posting on our Websites, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.
Contact Us
If you have any questions about our privacy practices or this Privacy Statement, or if you wish to submit a request to exercise your rights as detailed in this Privacy Statement, please contact us using the contact details set out below.
Vintura
Stadsplateau 6
3521 AZ Utrecht
+31 (0)35 54 33 540
privacy@cencora.com
Exercising Your Rights and How We Will Respond
To exercise your access or deletion rights, or to ask a question about your data subject rights, please contact us at the following:
Vintura
Stadsplateau 6
3521 AZ Utrecht
+31 (0)35 54 33 540
privacy@cencora.com
We will first acknowledge receipt of your request within 10 business days of receipt of your request. We will then provide a substantive response to your request as soon as we can, generally within 30 days from when we receive your request, although we may be allowed to take longer to process your request under certain circumstances. If we expect your request is going to take us longer than normal to fulfill, we will let you know.
We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations.
In some cases, the law may allow us to refuse to act on certain requests. If this is the case, we will endeavor to provide you with an explanation as to why.
If you have a complaint, you can also submit it to the Dutch Data Protection Authority (‘Autoriteit Persoonsgegevens’).
Verification of Identity – Access or Deletion Requests
We will ask you for two or three pieces of personal data and attempt to match those to information that we maintain about you.
If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial.
Authorized Agents
You may designate an agent to submit requests on your behalf. The agent can be a natural person or an entity that is registered.
If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our verification process. Specifically, if the agent submits requests to access, know, correct, or delete your personal data, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the request on your behalf. We will also require that you verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request.
Do Not Track Signals
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals.
Accessibility
We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at info@vintura.com.
Last Updated: October 2024