Privacy Notice
1. Who we are
This website, umboralis.com, is operated by UMBORALIS Hirgun B.V., a company established in the Netherlands and registered with the Dutch Chamber of Commerce (KvK) under number 42167653.
You can contact us at hello@umboralis.com. We are the controller for the personal data in our e-mail correspondence with you (section 3). Our hosting and e-mail provider may also process personal data for its own purposes; we have not yet established whether or to what extent (section 5). Who is responsible for the technical data processed when the website is delivered has not yet been established (section 3). Our company details are in the Legal Notice.
2. What this website does and does not do
This website is informational. It has no contact form, no user accounts and no comment or sign-up function. The website’s own code does not set cookies, does not use local storage or similar techniques, does not use analytics or advertising tools, and does not load scripts, fonts or images from other parties’ servers.
The e-mail address on the website is a link: when you select it, your own e-mail program opens. What happens to a message after you send it is described below.
3. Personal data we process and why
When you send us an e-mail at hello@umboralis.com
Personal data: your e-mail address, your name if it is shown, the content of your message and any information you choose to include, any attachments, and the date and time.
Purpose: to read and answer your message and to keep a record of the correspondence.
A message may also contain personal data about other people, for example a colleague or business contact named in it. The source of that data is then the sender of the message, and we use it for the same purposes.
When you visit this website
Personal data: our hosting provider may process technical connection data when the website is delivered. We have not yet established which data this includes, how long it is kept, or whether the provider processes it on our behalf or for its own purposes. For that reason this notice does not list data categories or retention periods for this data.
Purpose: to deliver, secure and maintain the website.
We do not ask for special categories of personal data (such as health data). Please do not include sensitive or confidential information in your e-mail.
4. Legal basis
We rely on a legal basis for each purpose:
- Answering enquiries and keeping general correspondence: our legitimate interest in receiving and answering business enquiries (Article 6(1)(f) GDPR).
- Ongoing business correspondence and cooperation: our legitimate interest; where you are yourself the counterparty, or have asked us to take steps before entering into an agreement with you, that agreement or those steps (Article 6(1)(b) GDPR).
- Contracts, invoices and correspondence that is relevant for legal purposes: a legal obligation where a specific legal obligation applies (Article 6(1)(c) GDPR), otherwise our legitimate interest.
- Technical connection data when the website is delivered: this depends on who is responsible for that data, which has not yet been established. Where we are responsible, we rely on our legitimate interest in a secure and functioning website.
We do not rely on consent for these purposes.
5. Who receives your data
We use Mijndomein for the hosting of this website and for our e-mail service. Mijndomein may work with service providers of its own. According to Mijndomein, its processing arrangements form part of its general terms and conditions.
We have not yet established which of the data described in this notice Mijndomein processes on our behalf and which it processes for its own purposes, or which service providers are involved.
6. International transfers
We have not yet confirmed in which countries our hosting and e-mail provider, and any service providers it uses, process personal data. We therefore cannot yet say whether personal data is transferred outside the European Economic Area, or which safeguards would apply.
7. How long we keep your data
Our rule for e-mail correspondence is:
- General correspondence without follow-up: a maximum of 12 months after the last substantive contact.
- Ongoing business correspondence: for as long as it is necessary for the contact or the cooperation.
- Contracts, invoices and correspondence that is relevant for legal purposes: for as long as the applicable legal and business obligations require.
Each year, in October, we review the stored correspondence and remove what is no longer needed under these rules. This yearly review does not replace the need to remove correspondence in good time once it is no longer needed. Nothing is deleted automatically, so correspondence that has passed these limits may remain stored until it is removed.
A message we delete may remain for some time in the mailbox’s trash or in copies held by our e-mail provider; we have not yet established for how long. For technical connection data kept by our hosting provider, we have not yet established what is kept or for how long.
8. Cookies and similar technologies
At the time of writing, the website’s own code sets no cookies and uses no local storage, session storage or similar techniques. We have not yet confirmed whether our hosting service sets cookies when the website is delivered.
9. Security
Access to our mailbox is protected by sign-in. No method of transmission or storage is completely secure.
10. Your rights
Under the GDPR you may ask us for access to your personal data, rectification, erasure, restriction of processing, and data portability where it applies, and you may object to processing that is based on our legitimate interests.
To use these rights, e-mail hello@umboralis.com. We may need to verify your identity before we act on a request, and we ask only for what is needed for that. We answer within one month; where the law allows we may extend this period, and we will tell you why.
11. Complaints
If you have a concern, please contact us first so that we can address it. You also have the right to lodge a complaint with the Dutch data protection authority, the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl).
12. Changes to this notice
We may update this notice. The current version is always available on this website, with its date.
13. Contact
UMBORALIS Hirgun B.V. · Didamseweg 70, 6901 JT Zevenaar · KvK 42167653 · Netherlands · hello@umboralis.com · +31 6 21703825