Last updated: August 12, 2022

This GDPR Compliance Statement sits in line with our Privacy Policy, is supplemental and applies to all European Union Citizens that are using our services. As such Vzy proceeds with all data processing procedures (e.g., collection, processing, and transmission) in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation). Nothing in this Statement is intended to contradict or limit the applicability of the information provided in our Privacy Policy.

The following provides you with an overview of the type of data collected and how it is used and passed on, the security measures we take to protect your data and how you can exercise your rights.

Personal data is information that makes it possible to identify a natural person. This includes in particular, your name, date of birth, address, telephone number, e-mail address, but also your IP address. Anonymous data as such only exists if no personal reference to the user can be made.

The Data Controller

In accordance with Art. 24 GDPR, the person responsible for the processing of personal data when using our website at www.vzy.co, www.vzy.io and our application at https://app.vzy.co/ (hereinafter our “Platform”) is:

Vzy, Inc. 

2055 Limestone Rd Ste 200c, 

Wilmington, DE, 19808, USA

Web: www.vzy.co   

E-mail: hey@vzy.co

Categories of data subjects and types of data processed

During the course of using our Platform and services, we process the following types of data from visitors and users:

  • inventory data (e.g., names, addresses),

  • contact data (e.g., e-mail, telephone numbers),

  • content data (e.g., text entries, messages, testimonials),

  • usage data (e.g., web pages visited, interest in content, access times), and

  • meta/communication data (e.g., device information, IP addresses).

Purpose of the processing

The Purpose of processing personal data are:

  • provision of the online offer, its functions, and contents,

  • responding to contact requests and communicating with users,

  • security measures, and

  • reach measurement/marketing.

Relevant legal basis

The following legal basis, unless specifically described below apply to the processing of your personal data:

  • the legal basis for obtaining consent is art. 6(1)(a) and art. 7 GDPR,

  • the legal basis for processing in order to fulfil our services and carry out contractual measures and respond to enquiries is art. 6(1)(b) GDPR,

  • the legal basis for processing in order to fulfil our legal obligations is art. 6(1)(c) GDPR, and

  • the legal basis for processing in order to protect our legitimate interests is art. 6(1)(f) GDPR. 

Security of your personal data

We take appropriate technical and organizational measures in accordance with Art. 32 GDPR, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to, input, disclosure, ensuring availability and segregation of the data. We also have procedures in place to ensure the exercise of data subjects' rights, deletion of data and response to data compromise. Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and through data protection-friendly default settings (Art. 25 GDPR).

Cooperation with processors and third parties

If, in the course of our processing, we disclose data to other persons and companies (Amazon AWS, Stripe, Netlify, MongoDB, Google, Sendy.co, Cloudflare CDN, Digital Ocean), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties is necessary for the performance of the contract, you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.). If we commission third parties to process data on the basis of a so-called "order processing agreement", this is done on the basis of Art. 28 GDPR.

Transfers to third countries

Our main operations are based in the USA and your personal data is generally processed, stored and used within in the USA. In some instances, your personal data may be processed outside the USA. If and when this is the case, we take steps to ensure there is an appropriate level of security, so your personal data is protected in the same way as if it was being used within the USA.

Your rights

These rights are standardized in the GDPR. This includes:

  • the right to information (Art. 15 GDPR),

  • the right to rectification (Article 16 GDPR),

  • the right to erasure (Article 17 GDPR),

  • the right to restriction of data processing (Article 18 GDPR),

  • the right to data portability (Article 20 GDPR),

  • the right to object to data processing (Article 21 GDPR),

  • the right to revoke any consent you have given (Art. 7 (3) GDPR), and

  • the right to lodge a complaint with the competent supervisory authority (Art. 77 GDPR).

Please contact us at any time with questions and suggestions regarding data protection and to enforce your rights as a data subject. 

Cookies 

Cookies" are small files that are stored on your device. Different information can be stored within the cookies. We may use temporary and permanent cookies and will explain this in our Cookie Policy. The legal basis for the use of cookies is either your consent or our legitimate interest.

Deletion of data

The data processed by us will be deleted or its processing restricted in accordance with Articles 17 and 18 GDPR. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. I.e., the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law.

Business-related processing

In addition, we process:

  • Contract data (e.g., subject matter of the contract, term, category of customer), and

  • Payment data (e.g., bank details, payment history).

of our customers, prospective customers for the purpose of providing contractual services, service and customer care, marketing, advertising, and market research.

Contractual services

We process the data of our customers within the scope of our contractual services. In doing so, we process:

  • inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., e-mail, telephone numbers), 

  • content data (e.g., content used when you use our application and services including text entries, images and video), 

  • contract data (e.g., subject matter of contract, term), 

  • payment data (e.g., bank details, payment history), 

  • usage data and metadata (e.g., in the context of evaluating and measuring the success of marketing measures). 

As a matter of principle, we do not process special categories of personal data, unless these are components of commissioned processing.  The purpose of the processing is the provision of contractual services, billing, and our customer service.  We process data that is necessary for the justification and fulfilment of contractual services and point out the necessity of their disclosure. Disclosure to external parties only takes place if it is necessary in the context of the service. 

When processing the data provided to us within the scope of providing our services, we act in accordance with the instructions of the client as well as the legal requirements of order processing pursuant to Art. 28 GDPR and do not process the data for any other purposes than those specified in the service.

We delete the data after the expiry of statutory warranty and comparable obligations. The necessity of storing the data is reviewed every three years; in the case of statutory archiving obligations, the deletion takes place after their expiry. 

In the case of data disclosed to us by the user within the scope of a service, we delete the data in accordance with the specifications of the service, in principle after the end of the service.

Administration, financial accounting, office organization, contact management

We process data within the scope of administrative tasks as well as organization of our business, financial accounting, and compliance with legal obligations, such as archiving. 

In doing so, we process the same data that we process in the context of providing our contractual services. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e., tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services. 

The deletion of data with regard to contractual services and contractual communication corresponds to the information mentioned in these processing activities.

In this context, we disclose or transmit data to the tax authorities, consultants such as tax advisors or auditors as well as other fee offices and payment service providers.

Furthermore, we store information on suppliers and other business partners on the basis of our business interests, e.g., for the purpose of contacting them at a later date. This data, most of which is company-related, is stored permanently.

Contact

When contacting us (e.g., via e-mail or social media), the user's details are processed for the purpose of handling the request and its processing. The user's details may be stored in a customer relationship management system or comparable enquiry organization. We delete the enquiries if they are no longer necessary. We review the necessity every two years; furthermore, the legal archiving obligations apply.

Data Breaches/Notification

Databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised, and the notice will be accompanied by a description of action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible after which the breach was discovered.

Children’s Privacy

Our services are restricted to users who are 18 years of age or older. We do not knowingly collect personal data from anyone under the age of 18. If you suspect that a user is under the age of 18, please contact us.

Changes

Because we’re always looking for new and innovative ways to improve our Platform and services, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.

This GDPR Compliance Statement was last updated on Friday, August 12, 2022

Vzy, Inc.