his policy was most recently amended on 26th July 2021.
Envision and your personal data
Welcome to Envision Technologies B.V. ("Envision," "we," "us" or "our"). Envision provides a fast and an accurate image recognition utility. After an image is taken, using the built in camera capture feature, it then defines the image for the user.
Envision Technologies B.V.
Wilhelmina van Pruisenweg 35
If you are a client of us, or your company is a client of ours and you have contacted us for information on our products or services, then this policy is for you. Furthermore, this policy is important to all persons who visit or used our services or websites or persons who have subscribed to newsletters (all are hereafter referred to as Users), and persons who have applied for a job with us. The Services and its content are not directed at persons under the age of 18.
• By using our Service you understand that we are providing a platform for you to take, define, and share images ("User Content"), by the Service. User content may be encrypted and stored in our cloud services, to provide our Users with back up of their content. We do not access, review or monitor User Content. We do not use User Content or process it in any way other than providing the User with encrypted backing of the data, except as provided in this policy. Further information concerning why we process data will be set out in this policy.
What is personal data?
Personal data is information that says something about you. The best known forms of personal data are your name, address, email address, age and date of birth. Personal data also includes your bank account number, your phone number and for example your IP address. We collect the following types of information:
Information you provide us directly:
Communications between you and Envision by email. For example, we may send you Service-related emails (e.g., changes/updates to features of the Service, technical and security notices). Note that you may not opt out of Service-related emails. If you have given permission, we can send you our newsletter by email. Note that for the newsletter there is an unsubscribe option included with which you can indicate that you are no longer interested in our newsletter.
We use third-party analytics tools, such as Google Analytics and Mixpanel Analytics, to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Service, including the web pages you visit, add-ons, and other information that assists us in improving the Service. We collect and use this analytics information only for improving the Service experience. Our use of Google Analytics is in line with the advice share by the Dutch Data Protection Authority. We have a processor agreement with Google and sharing data is turned off, next to masking the last numbers of IP-address. We will not use other Google services in combination with Google Analytics. For information on opt-out possibilities we refer to our cookie statement.
Log file information:
Log file information is automatically reported by your browser each time you make a request to access (i.e., visit) a web page or app. It can also be provided when the content of the web page or app is downloaded to your browser or device.
When you use our Service, our servers automatically record certain log file information, including your web request, Internet Protocol ("IP") address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our Users which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service
When you use a mobile device like a tablet, a phone or Envision Glasses to access our Service, we may access, collect, monitor, store on your device, and/or remotely store one or more "device identifiers." Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device's operating system or other software, or data sent to the device by Envision.
Metadata is usually technical data that is associated with User Content. For example, Metadata can describe how, when and by whom a piece of User Content was collected and how that content is formatted.
What is the legal basis for our processing of your personal data?
Processing of personal data is only allowed when it is based on one of the “grounds” permitted by law. This means that we may use your personal data for one or more of the following permitted reasons:
- necessary to perform our contract with you
- to serve our legitimate interest or those of others
- when you have given your consent
Examples of our legitimate interests [and those of third parties] that allow us to process your personal data are as follows:
- To improve the services provided by us and third parties that we work with.
- To understand and offer resolutions as part of our customer support.
- To assess security risks and threats to us or to third parties we work with.
If you have given us your consent for the processing of your personal data, you may withdraw this consent at any time. You can send a request to this effect to email@example.com.
For what purposes do we use your personal data?
We use your personal data to help make our operations and our services as effective, reliable, and efficient as possible. We do this for the following purposes:
- provide Envision features and services to you,
- manage and improve the Envision website, app and services,
- analyse how you use Envision,
- provide you with relevant information related to Envision and its services,
- provide you with marketing that is relevant to you,
- diagnose technical problems and maintain security,
- provide, improve, test, and monitor the effectiveness of our Service,
- develop and test new products and features,
- monitor metrics such as total number of visitors, traffic, and demographic patterns,
- diagnose or fix technology problems,
- automatically update the Envision application on your device,
- provide personalized content and information to you and others, which could include online ads or other forms of marketing.
If we would like to use your personal data for any other purposes than those listed below, we can only do so if this is in line with the purpose(s) for which we have initially have collected your personal data. Otherwise, we first need to obtain a new ground to process your personal data for those other purposes.
Processing User Content
Envision may process User Content only if the following applies:
The User concerned has given his/her informed consent for one or more specific purposes (“opt-in”). Envision is then allowed to process the User Content until the User objects to such processing (“opt-out”) or once the purpose for which Envisions processes the User Content is reached.
The aforementioned specific purposes are (exhaustive list):
- processing is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof (e.g. fixing bugs)
- processing is necessary for compliance with a legal obligation to which Envision is subject;
- processing is necessary for improving the Services.
Other parties using your personal data
We will not rent or sell your Personal Data to third parties outside Envision (or the group of companies of which Envision is a part) without your consent, except as noted in this Policy.
Parties with whom we may share your information:
- Our (IT) service providers that support us in providing the Services to you. We may share your Personal Data with organizations that help us provide the Service to you ("Service Providers"). Our Service Providers will be given access to your information as is reasonably necessary to provide the Service under reasonable confidentiality terms.
- Our third-party advertising partners. We may share Personal Data (such as cookie data) with third-party advertising partners to allow the third-party partners, among other things, deliver targeted advertisements that they believe will be of most interest to you through ad networks.
- Authorities. Sometime its necessary to provide your personal data to competent (public) authorities, if required to do so by laws and regulation or by judicial process or if we reasonably believe that such action is necessary to;
- comply with the law and the reasonable requests of law enforcement;
- protect the security or integrity of our Service;
- exercise or protect the rights, property, or personal safety of Envision, our Users or others.
What happens in the event of a change of control?
Use of your personal data for direct marketing purposes
We might use your Personal Data for our direct marketing campaigns. The kinds of direct marketing we might use are:
- Social Media Advertising, which could include messaging or communication directed at you based on your Personal Data.
- Search Engine Advertising, which could include messaging or communication directed at you based on your Personal Data.
- Email marketing, which could include messaging or communication directed at you based on your Personal Data and preferences.
Other websites and services
We do work with profiles. Our profiles are used for mostly technical reasons. We would create profiles of our User based on their app usage and data for the following purposes:
- To detect fraud or suspicious activity.
- To understand the use of our service based on different target audiences.
- To conduct design research of certain types of user behaviour.
- To provide promotional offers based on usage and activity.
- To run A/B testing of new and upcoming features or changes.
- To project future scenarios of payment or non-payment patterns.
To ensure the highest possible level of protection for your information, we invest in our systems, procedures and people.
Personal data outside Europe
We primarily store your personal data in Europe, but may also use other locations around the world. For example your information collected through the Service may be stored and processed in the United States or any other so call ‘third country’ in which Envision, a company in the same group of companies as Envision or Service Providers maintain facilities. When we do transfer your data to a third country we will use the transfer mechanism as approved by the GDPR (such as Standard Contractual Clauses approved by the European Commission, your consent or sending it to a country that received an adequacy decision of the European Commission.
Retention periods of your data
As set out under the General Data Protection Regulation, we keep personal data in any event for as long as is necessary to achieve the purpose. The law does not stipulate specific storage periods for personal data. Other legislation may specify minimum storage periods, however. If it does, we are under the obligation to observe these periods. Such legislation includes tax laws or laws governing financial undertakings specifically. Another reason for which we may keep your data longer is if we become involved in a lawsuit or other legal proceedings.
What rights do you have?
Right to object to processing for direct marketing purposes
If you no longer want to receive offers for our products and services, you can unsubscribe at any time. All marketing messages include this possibility, and you can follow the link at the bottom of the marketing messages to exercise this right easily.
Right of access, right to rectification, right to be forgotten, right to restriction of processing
- You have the right to access your data. For this purpose, you can ask us what data are registered and what they are used for.
- You have the right to have the data Envision collects from you corrected, changed or supplemented if these are incorrect or incomplete.
- You have the right to ask who has access to your data. You can ask us what data are registered and who has/has had access to them.
- In certain legal instances, you have the right to have your data erased.
- In certain legal instances, you have the right to have less data processed by us.
- You have the right to object to the processing of your personal data by us.
Right to data portability
If we process your personal data on the basis of your consent or on the basis of the contract we concluded with you we can arrange that you receive the data that you have provided to us, which we store by automated means, so you can provide the data to another party you choose. This is referred to as data portability. Information which is processed for the purpose of a Legal Obligation or Legitimate interests is not covered by this obligations.
Right to object to profiling
It may be the case that you do not want us to use your personal data for profiling. Sometimes, however, we are allowed to do this, for instance to prevent fraud, manage risks or investigate unusual transactions, even if you object to the processing of data. In such situations, we will of course comply with the law.
Do you have a complaint or want to ask a question?
You also have the right to take your complaint to the Data Protection Authority (Autoriteit Persoonsgegevens).
Changes to the law or our services and products may affect the way in which we use your personal data. If this happens, we will publish an updated version of our policy on our website or in our apps. Please review it periodically.