Last update: July 5th, 2024

This privacy notice informs you about how Scantrust collects, uses, and protects your personal data when you visit our website or make use of our solutions. We are committed to respecting your privacy and adhering to our obligations under the General Data Protection Regulation (GDPR).

1. Who we are

Scantrust is a provider of cloud-based connected packaging solutions for anti-counterfeiting, EU digital wine labels, supply chain traceability, enterprise QR codes and digital product passports. We prioritise personal data protection and are committed to maintaining adequate standards of privacy and security.

In this privacy notice, we outline how we collect, use, and safeguard your personal data when you interact with our website or make use of our solutions. We recognise the importance of transparency and trust in our relationship with you, and we are committed to ensuring that your personal data is handled responsibly and in accordance with applicable data protection laws and regulations.

The data controller responsible for your personal data is:

Scantrust S.A. [“we”, “us”, “our”]

EPFL Innovation Park, PSE-D
CH-1015 LAUSANNE
Switzerland

contact@scantrust.com

2. Scope of the privacy notice

This privacy notice applies to the following categories of people:

• Website visitors
• Staff of our customers
• End users of our solutions
• Staff of our partners
• Staff of our suppliers
• Newsletter subscribers
• Job applicants
• Participants of our trainings and webinars
• Investors
• Leads

This notice does not apply to employees of Scantrust.

3. How we use your personal data

We use your personal data for the following purposes:

 

Processing activity	General description of purposes	Lawful basis	Categories of data	Retention period
Website, analytics & marketing
Website analytics	We analyse website traffic to determine how visitors use our site and in what ways we can improve.	Legitimate interest Article 6(1)(f) of the GDPR	IP address Country Type of browser Type of operating system	1 day
Use of cookies	We make use of cookies and other tracking technologies to ensure that our website functions properly, remember user preferences, maintain sessions and track user behaviour across different sites.	Consent Article 6(1)(a) of the GDPR We rely on your consent for the use of non-essential cookies. Legitimate interest Article 6(1)(f) of the GDPR When we make use of essential cookies, we rely on our legitimate interest to ensure that the website functions properly	IP address Time of request Mode of server request Country Type of browser Type of operating system Session duration	See section 4 for the retention period of the various cookies used
Receiving requests through website forms	Website forms allow us to receive and respond to demo requests from potential customers	Consent Article 6(1)(a) of the GDPR By filling out the website form and checking the consent box, you give us the permission to use the information you have provided in the form to handle your request, set up a demo account for your organisation and contact you to facilitate your request.	First and last name Email address Phone number Name of company Request message Location	Until deletion is requested
Organising events and webinars	We sometimes organise events and host webinars to create brand awareness, to discuss product updates and latest industry topics	Legitimate interest Article 6(1)(f) of the GDPR We host webinars in our legitimate interest to promote our brand and inform about our products and services	First and last name Email address Event to be attended	Until deletion is requested
Registering for an event or webinar	You may sign up to attend an event or webinar that we have organised	Consent Article 6(1)(a) of the GDPR In order to sign you up for a webinar, we rely on your consent to provide the required information. We also request that you give additional optional consent to be invited in the future to similar events or webinars	First and last name Email address Event to be attended	2 years
Managing the Scantrust social media accounts (LinkedIn, Instagram and X)	We operate an account on the stated social platforms to maintain a credible social and professional presence. When you engage with us on these platforms, we can see the details you have made available on your social profile.	Legitimate interest Article 6(1)(f) of the GDPR	First and last name (or username) Profile information (depending on the privacy settings of your account)	n/a as we do not process this information further
Sharing customer reviews	Our customers often find our products satisfactory. When they do, we sometimes request a review from them. We share the reviews of satisfied customers to increase positive brand perception.	Consent Article 6(1)(a) of the GDPR	First and last name Job title Name of organisation Review	Direct identifiers are retained until the end of the customer relationship. The reviews and case studies themselves remain on our website..0
Product and server security
Securing the Scantrust platform	We are interested in ensuring that the Scantrust platform is a safe and secure environment for our customers.	Legitimate interest Article 6(1)(f) of the GDPR We do this in our legitimate interest to ensure the security of the Scantrust platform and prevent system attack and abuse.	IP address	100 days
Maintaining server logs	We store certain information in log files to prevent system attack and for fraud / abuse prevention, incident management, forensics and error investigation.	Legitimate interest Article 6(1)(f) of the GDPR We maintain logs in our legitimate interest to secure our software environment and infrastructure.	Scan time Device / phone model Serial number Scan reason (to query or verify) IP address	100 days
Maintaining scan logs	In order to provide our service to our customers and ensure that our products work correctly i.e QR codes display properly, we process technical information of devices constituting the scan log.	Performance of a contract Article 6(1)(b) of the GDPR We maintain scan logs to ensure the correct functioning of our products and generally fulfil the contract that our customers and end users have with us.	Scan time Unique scan ID User ID Country and city Device / phone model Serial number Scan application (Scantrust App or otherwise) Scan reason (to query or verify) Location (GPS when scanning with the App and when scanning without the App if the GPS popup is accepted) First 3 bytes of the IP address (when scanning without the App) Product scanned	100 days
Acquiring statistical data	We derive aggregate information on usage based on log files to gain insight into product usage and for product improvement	Legitimate interest Article 6(1)(f) of the GDPR We acquire statistical data in our interest to derive aggregate information on usage and continuously improve our products	Scan time Unique scan ID User ID Country and city Device / phone model Serial number Scan application (Scantrust App or otherwise) Scan reason (to query or verify) Location (GPS when scanning with the App and when scanning without the App if the GPS popup is accepted) First 3 bytes of the IP address (when scanning without the App)	100 days
Granting access to our staging environment	We sometimes allow customers access to the Scantrust staging environment. We do this to enable them to experience a mirror implementation of how the platform functions.	Performance of a contract Article 6(1)(b) of the GDPR Access to our staging environment occurs in line with the agreement entered into with customers or as a pre-contractual step towards concluding a contract with potential customers.	First and last name Email address Job title Name of organisation Phone numbers	Until the end of the customer relationship
Receiving suspected counterfeiting reports	This allows us to receive user-initiated suspected counterfeit reports and communicate the same to our customers.	Performance of a contract Article 6(1)(b) of the GDPR As part of our service contract with customers, we are obliged to enable this function within our products and communicate counterfeit reports to customers.	Name Email address Location Counterfeit report / message	Counterfeit reports are maintained as long as, and until the end of the customer relationship
Product verification on the Scantrust Apps (public and enterprise)	When you scan a QR code, we process technical information to authenticate and verify the codes and to detect counterfeits	Performance of a contract Article 6(1)(b) of the GDPR As part of our service contract with customers and the individuals who use the Scantrust App, we are obliged to enable this function for product verification.	GPS Location Device information for compatibility check (QR code scanner, Authenticate Secure Graphic and GPS location)	100 days
Logging in to the Scantrust enterprise App	Customers who make use of the Scantrust platform are able to also use the Scantrust enterprise App on the go. We require login credentials to secure customers’ enterprise accounts.	Performance of a contract Article 6(1)(b) of the GDPR We are obliged to secure enterprise accounts of our customers from unlawful and unauthorised access even when accessed from the Scantrust enterprise App	Email address Password Name of organisation Role	Until the end of the customer relationship
Project management
Setting up customer accounts	When we enter into a contract with our customers, we enable the set up of their account on the Scantrust platform for the efficient use of the service	Performance of a contract Article 6(1)(b) of the GDPR This is done in line with the terms of the customer contract.	First and last name Email address Job title Title (mr./ms.) Company name Password	Until the end of the customer relationship
Scheduling and hosting meetings with customers	We sometimes organise meetings with customers to understand their unique needs, their use of the platform as well as the project scope.	Performance of a contract Article 6(1)(b) of the GDPR This is done in order to be able to understand customer needs and fulfil the terms of the customer contract.	First and last name Email address	Until the end of the customer relationship
Training customers on the use of the Scantrust platform	We train customers on the use of the Scantrust platform to help customers get started and harness the full capacities of the platform	Performance of a contract Article 6(1)(b) of the GDPR This is done in line with the terms of the customer contract.	First and last name Email address	Until the end of the customer relationship
Collaborating with printing partners	This collaboration is aimed at enabling customers and their printing partners’ systems to integrate with the Scantrust platform.	Performance of a contract Article 6(1)(b) of the GDPR This is done in line with the terms of the customer contract.	First and last name Email address Job title (optional) Title (mr./ms.) Company name	Until the end of the customer relationship
Training printing partners	We train printing partners to ensure that they are able to correctly obtain, download and print QR codes from the Scantrust platform.	Performance of a contract Article 6(1)(b) of the GDPR This is done in line with the terms of the customer contract to ensure seamless printing of customer QR codes.	First and last name Email address Company name	Until the end of the customer relationship
Managing customer projects until the platform is live	We manage customer projects to support our customers, especially in the staging environment, until they are ready to go live on the Scantrust platform.	Performance of a contract Article 6(1)(b) of the GDPR This is done in line with the terms of the customer contract.	First and last name Email address Company name	Until the end of the customer relationship
Finance, Accounting and Reporting
Paying invoices	We settle invoices in order to pay vendors for the service supplied and fulfil the terms of the service agreement.	Performance of a contract Article 6(1)(b) of the GDPR This is done in line with the terms of the supplier contract.	Name of supplier staff (where applicable) Name of organisation (supplier name) Email address Address of supplier Phone number Payment details	As long as the supplier contract exists / 10 years thereafter
Authorising / keeping track of new customers	We approve new customers to keep track of our customer list and track payments due from them.	Performance of a contract Article 6(1)(b) of the GDPR This is done in line with the terms of the customer contract.	Name of contact person for the customer Name of organisation Email address Billing address Billing items	As long as the customer contract exists / 10 years thereafter
Authorising / keeping track of new suppliers	We approve new suppliers to keep track of our supplier list and track payments due to them.	Performance of a contract Article 6(1)(b) of the GDPR This is done in line with the terms of the supplier contract.	Name of contact person for the supplier Name of organisation (supplier name) Email address	As long as the customer contract exists / 10 years thereafter
Purchasing stock	We make stock purchases to acquire the necessary stock for company use.	Performance of a contract Article 6(1)(b) of the GDPR This is done in line with the terms of the supplier contract.	Name of contact person for the supplier (where applicable) Email address Job title Team Name of organisation (name of supplier) Price of stock Bank details	10 years
Fundraising	As a startup, we sometimes organise events to raise funds for operations from investors.	Legitimate interest Article 6(1)(f) of the GDPR We conduct fundraising campaigns to attract and secure investment funding from investors in our interest to continue operating as a trusted anti-counterfeiting software provider.	Name of investor Passport details Name of company Address	As long as the investment continues
Reporting	We present financial results to stakeholders such as investors and Board members.	Legitimate interest Article 6(1)(f) of the GDPR We present financial results in our legitimate interest to ensure transparency and foster trust from stakeholders.	Email address	10 years
Financial reporting and annual auditing	We provide periodic reports on the company’s liquidity and capital status to comply with the law and carry out audits.	Legal obligation Article 6(1)(C) of the GDPR We conduct audits and provide period reports to comply with Article 725 of the Swiss Code of Obligations	Auditor signature Contact name Contact email address Name of organisation (name of auditor) Address of organisation	10 years
Sales
Collecting contact information at trade shows	We attend or organise trade shows where we collect contact information of potential customers to follow-up with them in the future.	Legitimate interest Article 6(1)(f) of the GDPR We do this in our legitimate interest to increase brand awareness and potentially meet new customers.	First and last name of contact person Email address Mobile number Job title Name of organisation Address of organisation	Until the recipient unsubscribes
Communicating with leads and managing contact details of leads interested in Scantrust products	We manage the contact details of leads to be able to contact them for follow up discussions, understand their needs and expectations in relation to our products	Legitimate interest Article 6(1)(f) of the GDPR We do this in our legitimate interest to convert leads to customers and keep operations ongoing	First and last name of contact person Email address Mobile number Name of organisation (name of Lead) Job title of contact person Address of organisation	Until opt-out
Managing lead lifecycle	We do this to categorise and manage leads progression through the sales pipeline e.g Sales qualified lead, Sales qualified lead with meeting occurred, Opportunity.	Legitimate interest Article 6(1)(f) of the GDPR We do this in our legitimate interest to measure sale strategy success and convert leads to customers	Full name of contact person for Lead Email address Name of organisation (name of Lead) Job title Mobile number Lead status Lifecycle stage Date of communication Location	Deleted immediately the lead opts out or 3 years, whichever is earlier.
Onboarding customers	We support in customer onboarding to enable customers register to the e-label product	Performance of a contract Article 6(1)(b) of the GDPR	First and last name of contact person for customer Email address Mobile number Name of organisation Address of organisation	Until the customer contract ends
Sorting registrations for the free version of our products Migrating customers to the free version with access to only 3 e-labels	We assess free version requests to determine the order of priority. Based on request or payment status, we are able to upgrade or downgrade customer accounts from the paid to the free version of the u-label	Performance of a contract Article 6(1)(b) of the GDPR	Full name of contact person for customer Email address Company name Country Company website Number of employees	Until the customer contract ends
Offboarding customers	We offboard customers to terminate their subscription based on request or in accordance with clause 7C of the e-label Terms of Service.	Performance of a contract Article 6(1)(b) of the GDPR	First and last name of contact person for customer Email address Name of organisation Billing address Billing contact Billing phone Billing email	Until the customer contract ends and the offboarding process is complete
Negotiating, contracting and closing deals with customers	We do this to negotiate, enter into contracts and close deals with leads, converting them to customers.	Performance of a contract Article 6(1)(b) of the GDPR	First and last name of contact person Email address Name of organisation Billing address Billing contact Billing phone Billing email	Until the customer contract ends
Managing customer relationships	We manage customer relationships to ensure customer satisfaction and efficient management of customer lifecycle.	Legitimate interest Article 6(1)(f) of the GDPR The interest pursued is customer satisfaction.	First and last name of contact person for customer Email address Name of organisation Address of organisation	Until the customer contract ends
Managing referral programs	This enables Scantrust to offer to partners, 10% of the revenue generated by partner referrals	Performance of a contract Article 6(1)(b) of the GDPR	First and last name of contact person Email address Name of organisation Address of organisation Signature (Referral Agreement) Job title	As long as the referral agreement is valid
Offering and enabling the use of discount codes for e-labels	By enabling the use of discount codes, we are able to honour coupon codes issued to partners and customers aimed at increasing sales and boosting profit margin.	Performance of a contract Article 6(1)(b) of the GDPR	First and last name Email address Name of organisation Address of organisation Coupon code	As long as the referral agreement is valid
Conducting email campaigns	We conduct email campaign to drive brand awareness for our wine label solution	Legitimate interest Article 6(1)(f) of the GDPR The interest pursued is increased brand awareness and lead-to-customer conversion	First and last name Email address Name of organisation	Until email recipient opts out / unsubscribes
Sending invitations to prospects to register for webinars and the free u-label version	Scantrust invites potential customers to webinars to discuss anti-counterfeiting solutions, drive brand awareness and increase sales.	Legitimate interest Article 6(1)(f) of the GDPR The interest pursued is increased brand awareness and lead-to-customer conversion	First and last name Email address Name of organisation	Until the recipient requests deletion
Recruitment
Receiving job applications and conducting interviews	As job positions become vacant, we advertise them and receive applications from candidates to fill the vacant positions based on our assessment of their skills and qualification during interviews	Performance of a contract Article 6(1)(b) of the GDPR Reviewing CVs and conducting interviews are pre-contractual steps necessary to conclude an employment contract with the successful candidate.	Name of job candidate Email address Mobile number Location Educational qualification Any other information contained in the CV / Application	Applications of unsuccessful candidates are deleted immediately after the end of the recruitment exercise.
Retaining applicant data from speculative applications	We sometimes receive speculative applications from job applicants. If an applicant permits, we will retain this application to be able to contact the applicant when a suitable job position becomes vacant.	Consent Article 6(1)(a) of the GDPR	Name of job candidate Email address Mobile number Location Educational qualification Any other information contained in the CV / Application	3 months
Conducting background checks	Scantrust conducts background checks on the successful candidate to verify records and information provided.	Legitimate interest Article 6(1)(f) of the GDPR As an anti-counterfeiting business, we conduct background checks in our interest to ensure that our employees have the minimum clearance level for the job and to ensure that referrals, qualifications and certificates are authentic.	Name Referees Social security record Previous employer referral	Until the end of the employment
Support
Receiving and responding to support requests from customers	We receive and respond to support requests to ensure that our customers receive the help they request and are able to continue seamless use of Scantrust products.	Performance of a contract Article 6(1)(b) of the GDPR	First and last name of contact person for customer Email address Name of company Type of enquiry (general, product feedback, billing, change request, onboarding/training, etc.) Business impact (urgent, high, medium, low) Company plan (Scantrust enterprise, etc.) Support request message Attachments (file, image)	Until the end of the customer relationship
Meeting with customers	In some cases, we schedule meetings with customers to discuss their support request in more detail and the solutions either via telephone or video conferencing.	Performance of a contract Article 6(1)(b) of the GDPR	First and last name of contact person for customer Email address Phone number Meeting notes Name of organisation	Until the end of the customer relationship
Analysing customer success	This is to ensure that customers achieve their desired goals with Scantrust products	Legitimate interest Article 6(1)(f) of the GDPR Ensuring customer success and satisfaction is in our interest to remain the leading provider of anti-counterfeiting software with high customer success rate	First and last name of contact person for customer Name of organisation Job title Email address	Until the end of the customer relationship
Requesting customer feedback / review	We want to let people know how effective our products are. This is why we request feedback and review from our customers.	Legitimate interest Article 6(1)(f) of the GDPR Customer feedback is one of the ways through which we improve and increase brand awareness by sharing positive reviews.	First and last name of contact person for customer Name of organisation Job title Email address Feedback / review	Until the end of the customer relationship
Applying product discount for case studies	We incentivise our customers to provide case studies to understand in detail, how our products have helped customers achieve their objectives and determine areas of improvement.	Performance of a contract Article 6(1)(b) of the GDPR	First and last name of contact persons for customer Name of organisation Job title Email address	Until the end of the customer relationship
Customer onboarding and training	We onboard and train customers to enable them make effective use of Scantrust products.	Performance of a contract Article 6(1)(b) of the GDPR	First and last name of contact person for customer Email address Name of organisation	Until the end of the customer relationship
Receiving and sharing counterfeit reports	We enable end users to share counterfeit reports within our products as part of the terms of our service. This helps customers investigate and potentially take action against counterfeits. It also helps to keep the end user safe.	Performance of a contract Article 6(1)(b) of the GDPR	Email address Phone number Address Choice to be contacted Additional information	Until the end of the customer relationship
Applying partnership discount to customers	Scantrust offers partnership discounts to subscription customers	Performance of a contract Article 6(1)(b) of the GDPR	First and last name of contact persons for customer Name of organisation Job title Email address	Until the end of the customer relationship

 

Where required, Scantrust will retain your details for a period of time to comply with a legal obligation, Article 6(1)(c) of the GDPR. For instance, when you opt out of emails about product updates and features, we process information necessary to implement your choice and ensure that we never contact you again to ensure compliance with Article 7(1) of the GDPR. Please note that if your information is processed for a different purpose, for instance, when a valid customer contract exists, we may contact you in the course of the normal customer relationship such as customer support and training.

 

4. Cookies and tracking technologies

Scantrust collects website and platform usage data to analyse how end users and customers use our products. We also analyse usage data to identify what areas of our website and products need improvement. We collect anonymous statistical data about the use of this website to optimise our online presence as well as for marketing and sales purposes. The data is collected on servers operated by AWS within Europe (Ireland) Region.

 

We make use of cookies and other tracking technologies to gain insight into usage patterns. The table below highlights the cookies and trackers we make use of on our website and across our products

 

Cookie or tracker name	Presence	Provider	Type	Categorisation	Duration
Player	Website	Video Vimeo	Session	Functional	1 year
vuid	Website	Video Vimeo	Session	Functional	2 years
__hs_gpc_banner_dismiss	Website	Hubspot	Persistent	Analytics	6 months
__hssc	Website	Hubspot	Session	Analytics	30 minutes
__hssrc	Website	Hubspot	Session	Analytics	deleted immediately after the session
__hstc	Website	Hubspot	Persistent	Analytics	2 years
hubspotutk	Website	Hubspot	Persistent	Analytics	2 years
messagesUtk	Website	Hubspot	Persistent	Analytics	2 years
Firebase	Mobile App	Google	Persistent	Functional	Until device cache is cleared i.e as long as the tracker is retained on the device
Amplitude	Mobile App	Amplitude	Persistent	Analytics	Until device cache is cleared i.e as long as the tracker is retained on the device
Google Analytics	Platform	Google	Persistent	Analytics	Until device cache is cleared i.e as long as the tracker is retained on the device
Plausible	Platform	Plausible	Persistent	Analytics	Until device cache is cleared i.e as long as the tracker is retained on the device

 

5. Data recipients and international data transfer

We make use of third-party service providers in delivering some of our services or to fulfil our legal obligations for legal and tax purposes. Where service providers are located outside the EU, we will ensure to implement appropriate transfer safeguards as approved under the GDPR such as the use of standard contractual clauses or the EU-US Data Privacy Framework and the Swiss-US Data Privacy Framework.

We make use of the following services:

• Docusign
• Google
• LinkedIn
• Slack
• Zoom
• Apollo
• H3 Solutions
• Senders (Kuyozo)
• Twilio
• Zendesk
• Hubspot
• Adobe Creative
• Browser stack
• Clay
• Vimeo
• F-secure
• Iubenda
• Genesis cloud
• AliCloud
• Apple Developer
• Amazon Web Services
• Circle CI
• Cloudflare
• DataDog
• Digital Ocean
• Ghost Inspector
• GUROCK.COM DEV TOOLS
• IcCube
• JetBrains
• ELCA security
• Lucid Chart
• MaxMind
• Pusher
• Paddle.net
• Pushy Pro
• OVH
• Redshift
• Sentry
• Tableau
• TYPEFORM S.L
• WorkOS
• WORLD-TEXT.COM
• Zapier.com
• Zeplin

When you interact with our products, contact us for support, make an inquiry or apply to an open position within our organisation, your personal data may be transferred to, and processed in, countries outside of the EU by our third-party service or providers or other Scantrust entities as listed below:

1. Scantrust B.V
   Kingsfordweg 151, 1043 GR
   Amsterdam, The Netherlands
2. Scantrust China Limited
   Changle Lu Lane 672, No.33,
   Renmei building, Room 201,
   JingAn district, Shanghai, China
   上海市静安区长乐路672弄33号人美楼201室
3. Scantrust Limited
   Room 602, Chung Wai Commercial Building, 447-449 Lockhart Road,
   Causeway Bay, Hong Kong

These transfers are conducted in compliance with the GDPR. We take measures to safeguard your data by implementing appropriate safeguards, such as:

• Transferring data only to countries on the adequacy decision list approved by the European Commission or
• Entering into standard contractual clauses approved by the European Commission with the recipient of data

6. Security measures (technical and organisational)

At Scantrust, we implement technical and organisational measures to safeguard personal data.

We utilise advanced encryption technologies to protect data both in transit and at rest. All devices are equipped with 0S-encrypted drives, including all RDS databases. Load balancers only allow API and web traffic over HTTPS encrypted with TLA1.2 above. Access control measures prevent unauthorised access to data processing facilities, information systems. We are committed to maintaining the integrity and confidentiality of your personal data, employing industry best practices to provide a secure environment for the processing and storage of your data.

In addition, our employees undergo security training during onboarding and commit to a non-disclosure agreement, thereby ensuring the confidentiality of information. Our employees receive password protected devices and make use of 2-factor authentication for separate levels of user identification. Access logs are maintained and the databases are restricted to only those employees with the required clearance level to access them. An industry-standard level of protection is implemented to prevent the copying, alteration, removal or data manipulation of information, thereby ensuring information integrity. We also implement separation control which keeps user database separate from the scan data.

We inherit some security measures from service providers such as transfer and input control to query logs using Cloudwatch Log Insights, availability control to prevent accidental data destruction and make backup copies available and performance monitoring to detect errors.

All employees of Scantrust are bound by strict internal policies to ensure efficient data protection management and organisational control e.g. Scantrust security policy.

7. Automated individual decision making

Scantrust does not make use of automated decision making in contexts that produce a legal consequence or considerable adverse effect on data subjects.

8. Links to other websites

This website may contain links to external websites. Scantrust is not responsible for the privacy practices or the content of those websites. We therefore recommend that you familiarise yourself with privacy practices of these organisations by reading their privacy notices.

9. Data subject rights available to you

The following rights are available to you as provided under the GDPR:

• The right of access

You have the right to obtain information about what data we process about you, the purpose(s) of the processing, the recipients of the data and the duration of storage.

• The right to rectification

You have the right to request the rectification of inaccurate data or incomplete data.

• The right to erasure

You have the right to request deletion of your data where:

• Data is no longer necessary
• You have objected to the processing under our legitimate interests and no convincing evidence was provided that these interests override your freedoms and liberties
• The processing takes place unlawfully

• The right to restriction

You have the right to request that your data is restricted for further processing in the following cases:

• You contest the accuracy of the data;
• You believe the processing is unlawful;
• You believe your data is no longer needed in relation to the purpose of its collection.

• The right to portability

You have the right to receive the personal data we process about you in a structured, commonly used, machine-readable format, and to request the direct transmission of that data to another organisation of your choice.

• The right to object

You have the right to object to processing carried out in our legitimate interest. Processing will be ceased until we have been able to demonstrate compelling legitimate grounds overriding your rights and freedoms.

• The right to lodge a complaint with a supervisory authority

You have the right to contact a data protection authority of your choice and formulate a complaint. We kindly request that you contact us first to mutually find a solution in case of any concerns.

10. Responsible Disclosure Policy

We consider the security of our systems a top priority. But no matter how much effort we put into system security, there can still be vulnerabilities present.

If you discover a vulnerability, we would like to know about it so we can take steps to address it as quickly as possible. We would like to ask you to help us better protect our clients and our systems.

Please do the following:

• E-mail your findings to dpo@scantrust.com.
• Do not take advantage of the vulnerability or problem you have discovered, for example by downloading more data than necessary to demonstrate the vulnerability or deleting or modifying other people’s data;
• Do not reveal the problem to others until it has been resolved;
• Do not use attacks on physical security, social engineering, distributed denial of service, spam or applications of third parties; and
• Do provide sufficient information to reproduce the problem, so we will be able to resolve it as quickly as possible. Usually, the IP address or the URL of the affected system and a description of the vulnerability will be sufficient, but complex vulnerabilities may require further explanation.

What we promise:

• We will respond to your report within 3 business days with our evaluation of the report and an expected resolution date;
• If you have followed the instructions above, we will not take any legal action against you in regard to the report;
• We will handle your report with strict confidentiality, and not pass on your personal details to third parties without your permission;
• We will keep you informed of the progress towards resolving the problem;
• In the public information concerning the problem reported, we will give your name as the discoverer of the problem (unless you desire otherwise).

We strive to resolve all problems as quickly as possible, and we would like to play an active role in the ultimate publication on the problem after it is resolved.

11. Data Protection Officer (DPO) contact

Our Data protection Officer appointed by Scantrust B.V. in the Netherlands monitors and oversees data protection compliance in all Scantrust entities. We encourage you to contact us at DPO@scantrust.com to exercise your data subject rights or if you have any privacy related concerns. If you are not satisfied with the way that we have handled your request, you have the right to lodge a complaint with the supervisory authority.

The details of the responsible supervisory authority in Switzerland are:

The Dutch Personal Data Authority

Hoge Nieuwstraat 8

2514 EL The Hague

(+31) – (0)88 – 1805 250

https://autoriteitpersoonsgegevens.nl/

Postal address

PO Box 93374

2509 AJ The Hague

12. Changes to this privacy notice

This privacy notice may be modified at any time to keep up with changing regulations and changes within Scantrust. The date of the last update is visible at the top of this page. Each visit or interaction with our products will be subject to the latest version of our privacy notice. We encourage you to regularly review our privacy notice to stay informed about our data protection practices.