Introduction

This Privacy Statement provides information on the collection, use, sharing and processing of personal information by More Optimal B.V. (registered at Parallelweg 27 's-Hertogenbosch, the Netherlands, the Netherlands) and its affiliates (“More Optimal”, “we” or “us”) in connection with your use of More Optimal websites, including our More Optimal Cloud Platform (“the Websites”), and social media pages that link to this Privacy Statement, your interactions with More Optimal during in-person meetings or at More Optimal events, and in the context of other offline sales and marketing activities. It sets out the purposes of More Optimal’s data processing in respect of the Websites, the use of cookies and your rights in respect of your personal data. More Optimal recommends that you read this Privacy Statement prior to using the Websites.

More Optimal may collect personal data about you, either directly (where you are asked to provide the data) from our online and offline interactions with you, during events, or email or telephone correspondence, from your interactions with our sites or indirectly through third-party data providers. More Optimal will, however, only use these personal data in accordance with the purposes set forth in this Privacy Statement and is committed to safeguarding the personal information collected.

Purpose of processing

More Optimal may collect and process your personal information to conduct its business, to inform and make available products and services that may be of interest to you. The information you provide may be used to contact you when necessary, to notify you about functionality changes to the Websites and to offer services that you may find helpful (provided you have not opted out to receive such services); to respond to your requests; to allow you to use our Cloud Platform if you or your company has become a customer, to deliver functionality on our sites; to administer our subscriptions; to market and tailor products and services to your or your company’s interests; to engage in transactions with and process orders; to develop, improve the performance of, and secure our sites, products and services; to deliver support to you on your use of our products and to comply with applicable laws such as to comply with an opt-out request.

Who will use the personal data?

More Optimal will be responsible for the use of the personal data in respect of the Websites.

If More Optimal uses the services of firms with which it has a strategic alliance and/or other service providers, including distributors or resellers, service providers, and public, government, judicial and law enforcement entities, More Optimal – where necessary – will also provide your personal data to those other firms and/or service providers.

Other than as described above, More Optimal will not sell, distribute or make available your personal data to third parties outside of its own organisation without your prior consent, unless obliged to do so under law, codes of conduct and professional practice or a court order.

What data will be used?

More Optimal can process information about you collected both offline and online.

• Offline information about you originates from our interactions with you during in-person meetings or at More Optimal events, conferences, workshops or gatherings;
• Online information about you originates from your activities on our sites, for example, in relation with your More Optimal accounts, (pre-)sales inquiries or from your interactions with More Optimal via electronic communication tools such as email or telephone. Information about you may also be provided by third party sources, such as data aggregators who may not have a relationship with you.

Online information about you may also originate from the use of cookies and similar technologies (for example, pixel tags and device identifiers) on our sites or sites of third parties.

If you order licenses, make inquiries, ask questions, make comments, apply for a position and/or make use of other services through the Websites (hereinafter to be referred to jointly as 'the Services'), you may be required to provide certain personal data and/or you may provide this data on your own initiative. More Optimal will use this data for the purpose of:

• making the Websites available to its users;
• optimising More Optimal's Services, whether provided via the Websites or otherwise;
• processing your job application.

If you have submitted questions and/or comments by e-mail and/or requested other Services through the Websites, More Optimal may use your personal data to contact you for the purpose of responding to those questions and/or comments and providing those Services.

Information about you that More Optimal may collect and process includes:

• name and physical address, email addresses, and telephone numbers;
• photographs and testimonials;
• transactional data, including products and services ordered, financial details and payment methods;
• company data such as the name, size and location of the company you work for and your role within the company;
• data from surveys and publicly available information, such as social media posts;
• unique IDs such as your mobile device identifier or cookie ID on your browser;
• IP address and information that may be derived from IP address, such as geographic location;
• information about a device you use, such as browser, device type, operating system, the presence or use of "apps", screen resolution, and the preferred language;

More Optimal will not retain your personal data longer than is necessary for the purposes described above, unless this data is necessary for complying with a statutory retention obligation, or (if longer) after the retention period under the applicable laws and regulations, codes of conduct and professional practice has expired. At your request or after expiry of the relevant retention periods, your personal data will be deleted. If there is any information 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 the data.

Legal basis

For personal information collected about you in the EEA, our basis for processing is the following:

• In order to communicate adequately with you and to respond to your requests, we need to process information about you and therefore have a legitimate interest in processing this information.
• In order to engage in transactions with customers, suppliers and business partners, and to process purchases and downloads of our products and services, we need to process information about you as necessary to enter into or perform a contract with you or your company.
• We process personal information for marketing and sales activities based on your consent where so indicated on our sites at the time your personal information was collected, or further to our legitimate interest to market and promote our products and services.
• We process personal information for recruitment purposes based on your consent when you apply for a job with us.
• We rely on our legitimate interest to analyse, develop, improve and optimize our sites, products and services, and to maintain the security of our sites, networks and systems.
• In order to comply with applicable laws and regulations, such as to comply with a court order or other legal process, or to process an opt-out request.

Sensitive data

More Optimal does not seek to collect sensitive personal data (such as data revealing political opinions, religious beliefs or data concerning health or sex life) through the Websites. If More Optimal does seek to collect such data, your prior consent hereto will be asked. Please note that, by providing More Optimal with unsolicited sensitive personal data you consent to our using those data as described above. More Optimal has in place adequate levels of protection for sensitive data.

Security

More Optimal has put appropriate technical and organisational measures in place in order to safeguard your personal data against loss or any form of unlawful use. Those persons who, on behalf of More Optimal, have access to your personal data, have a confidentiality obligation.

Your rights

You have certain rights regarding your personal data, subject to local data protection laws. These may include the following rights:

• to access your personal data held by us (right to access);
• to access your personal data held by us (right to access);
• to erase/delete your personal data to the extent permitted by other legal obligations (right to erasure; right to be forgotten);
• to erase/delete your personal data to the extent permitted by other legal obligations (right to erasure; right to be forgotten);
• to transfer your personal data to another controller to the extent possible (right to data portability);
• to object to any processing of your personal data carried out on the basis of our legitimate interests (right to object). Where we process your personal data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
• not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making"); Automated Decision-Making currently does not take place on our websites;
• to the extent we base the collection, processing and sharing of your personal data on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.

To exercise your rights, please contact our Data Protection Officer at privacy@moreoptimal.nl. We try to respond to all legitimate requests within one month and will contact you if we need additional information from you.

If you believe that More Optimal is not processing your personal data in accordance with the requirements set out in this Statement or applicable European Economic Area (EEA) data protection laws, you can at any time lodge a complaint with the data protection authority of the EEA country in which you live or with the data protection authority of the country or state in which More Optimal has its registered seat.

Cookies and log files

More Optimal and its partners may gather and analyze information regarding usage of the Websites, including domain name, the number of hits, the pages visited, previous/subsequent sites visited and length of user session including for advertising and targeting or personalization purposes. This information may be gathered by using a cookie. A cookie is a small unit of information which can be passed to your browser and placed on your devices while you are on the Websites. You can choose to deactivate the use of cookies by altering the settings of your browser. If you have deactivated the cookies, it might have consequences for the ease of use of the Websites. The Websites automatically generate log files that register the use by you and other users of the Websites. More Optimal maintains user data, such as source addresses of pages requested, IP (internet protocol) addresses and domain names, dates and times of page requests, links from other websites and other parameters in the URLs (universal resource locators). Log files of user actions in our More Optimal Cloud Platform will be used for the sole purpose to support you in using the application. In addition, these log files and data will be used, on an anonymous basis, for statistical purposes and for improving the Services offered via the Websites.

Third party sites

Please note that this Privacy Statement does not extend to third party sites linked to the Websites. More Optimal may include links to third party websites and these third parties or other parties present on these websites may gather information about you. More Optimal will not be responsible for the content of these websites or the actions of these third parties and other parties present on these websites. More Optimal recommends that you read their policies on the use of personal data.

How to contact More Optimal

If you have any questions about this Privacy Statement or our data processing activities, please contact us at privacy@moreoptimal.nl.

Amendments

More Optimal reserves the right to modify sections of this Privacy Statement at any time, for example to comply with legal requirements or to meet changing business needs. Please check this statement from time to time for any changes. If we plan to use personal data for a new purpose, we update our privacy information and communicate the changes to individuals before starting any new processing.