Privacy policy for website users based on GDPR specifications

We are delighted you are visiting our website and thank you for your interest in our company and our Services.

Data protection and data security are very important to us with regard to the use of our Services.

We would therefore like to take this opportunity to inform you about the personal data we eventually collect and what we use this data for.

We will use your personally identifiable information for a number of reasons, for example, to contact you by mail, phone or online regarding our services and events and for marketing, advertising and sale efforts.

We may disclose personally identifiable information to trusted affiliates, independent contractors and business partners who will use the information for the purposes outlined before.

We NEVER disclose aggregate, personal data to investors and potential partners.

Finally, we NEVER transfer information collected from you otherwise than for legal or fiscal reason.

As far as any data are transferred to third parties outside the EU we will care for equivalent security measures.

Please note that information submitted to us via the internet can at no time be fully secured.

You may withdraw your permission to use your personal data at any time by giving us notice at contact@virtualtek.io.

We kindly ask you to routinely read this privacy policy as changes to legislation or our internal corporate processes can necessitate an adaptation of its content. You can call up, save and print out this privacy policy at any time under “Privacy Policy”.

§ 1 Controller and scope

The controller in the meaning of the EU General Data Protection Regulation (hereinafter: GDPR), other national data protection laws of member states and additional data protection regulations is:

VIRTUALTEK SPRL
RUELLE DES COLONS 14
4252 OMAL
BELGIUM
Tel.: +32 23159786
E-Mail: contact@virtualtek.io
Website: www.virtualtek.io

This privacy policy applies to the website(s) of VIRTUALTEK SPRL that is accessible via the domain www.virtualtek.io, www.virtualtek-elearning.com and various subdomains and connected domains (hereinafter: “our website”).

§ 2 Data Protection Officer

Data Protection Officer is Arnaud SIMONIS CEO of VIRTUALTEK SPRL.

§ 3 Principles of data processing

The term personal data refers to all information that relates to an identified or identifiable natural person. It includes, for instance, information such as your name, address, professional telephone number, email address, IP address and user behavior. Information that does not allow us to establish a connection to you as a person (or would only allow such a connection with an unreasonable amount of effort), for instance anonymized information, is not classed as personal data. Processing personal data (for instance collecting, querying, using, storing and transferring personal data) always requires a legal basis or your consent. Processed personal data is deleted as soon as the purpose for which it was collected is fulfilled and statutory retention periods no longer apply.

Insofar as we process your personal data in order to provide specific services to you, the following serves to inform you of the concrete processes, the scope and the purpose of data processing, the legislation on which it is based and the duration of storage in each case.

§ 4 Individual processing activities

1. Website provision and use

a. Type and scope of data processing
When you call up and visit our website, we collect personal data that your browser automatically sends to our server. This information is stored temporarily in a so-called log file. When you use our website, we collect the following data needed for technical reasons to display the website and guarantee its security and stability:

• IP address of the requesting computer
• Date and time of access
• Name of the URL and the requested file
• The results of your actions to deliver your completude certification when a certain score is attempted in your course

b. Legal basis
Art. 6 Para. 1 (f) GDPR serves as the legal basis for data processing activities detailed in the preceding. Processing the specified data is an essential part of making the website accessible and therefore serves a legitimate interest of our company.

c. Duration of storage
The specified data will be deleted as soon as it is no longer needed to display the website. Collecting the data is essential to making the website available; storing the data in log files is essential to operating the website. The user therefore has no option to object to collection and storage. In some cases data may be stored for other purposes if required by law.

2. Registration / User account

a. Type and scope of data processing
Our website offers you an option to register as a user by submitting your personal data. We use your processed data to create a personalized user account for you that you can use to access specific content and services such as completing a elearning training. We process your email address so we can send you new login details should you happen to forget them and your completude certification. You can see in detail which personal data we process during registration from the following overview:

• ID
• First name
• Last name
• Username
• Company
• Email address

b. Legal basis
Processing the preceding personal data serves the fulfillment of a contract between your company and VIRTUALTEK SPRL or the implementation of pre-contractual activities in accordance with Art. 6 Para. 1 (b) GDPR.

You can withdraw your consent to the use of your personal data at any time with future effect by sending an email to the email address detailed in clause 1 above or to the data protection officer (cf. clause 2 above).

c. Duration of storage
Processed data will be deleted as soon as the contract is cancelled by your company. It may also be necessary to keep your personal data on record after the fulfillment of a contract to meet contractual or legal requirements. In some cases data may be stored for other purposes if required by law.

d. Cancelling registration
You can cancel your registration as a user at any time. You can also request changes to be made to your personal data on record. To do so, please contact contact@virtualtek.io.
However, if the processed data is required for the purpose of contract performance or pre-contractual activities, it can only be deleted prematurely if contractual or legal obligations allow.

3. Live events and conferences

a. Type and scope of data processing
We hosts many in-person conferences throughout the year (collectively “Events”). If you register for one of our Events, we will access the information in your user account to provide you with information and services associated with the Event, including but not limited to the following personal data:

• Title
• First name
• Last name
• Job
• Cell phone number
• Company
• Address
• Email address

You also agree that photos may be taken at our Events, including those taken by our Exhibitors or other 3rd party vendors.

If you are a presenter at one of our Events, we will collect information about you including your name, employer and contact information, and photograph. We may also make and store a recording of your voice and likeness in certain instances with an appropriate contract.

b. Legal basis
Processing the preceding personal data serves the fulfillment of a contract between you and VIRTUALTEK SPRL or the implementation of pre-contractual activities in accordance with Art. 6 Para. 1 (b) GDPR, with all the Event attendees’ benefits.

c. Duration of storage
Processed data will be deleted as soon as the registration is cancelled or changed on our website or mobile app. It may also be necessary to keep your personal data on record after the fulfillment of a contract to meet contractual or legal requirements. All data related to the live events and conferences will be deleted 30 days thereafter, however, in some cases, data may be stored for other purposes if required by law.

4. Contact form

a. Type and scope of data processing

You can get in touch with us via a contact form made available to you on our website. You will be informed of this privacy policy when you submit your inquiry via the contact form in order to obtain your consent. When you make use of the contact form, the following personal data will be collected and processed via the form:

• Name
• Email address
• Company
• Message content

We require your email address in order to allocate your inquiry and send you a response. Your personal data will not be disclosed to any third party when you use the contact form.

The following (additional) personal data will be required if you wish to be called back:

• Telephone number

b. Legal basis
The processing of data for contact purposes as described above (cf. clause 4 4. a.) is based on the following voluntary declaration of consent pursuant to Art. 6 Para. 1 (a):

Declaration of consent:

By entering my data and clicking the “Send” button, I declare my consent to having my email address, my name and my company for the purpose of responding to my contact inquiry. I have read and accepted the current privacy policy. I can withdraw my consent at any time with future effect by contacting contact@virtualtek.io.

You can withdraw your consent to the use of your personal data at any time with future effect by sending an email to the email address detailed in clause 1 above or to the data protection officer (cf. clause 2 above).

c. Duration of storage
We will delete the personal data collected from you via the contact form as soon as we have dealt with your inquiry and brought the subject matter to a close. In some cases data may be kept on record for other purposes if required by law.

5. Elearning Signup form

a. Type and scope of data processing
The order form consists of data fields you can fill in on our website. Users filling in the order form will enter the following personal data to obtain various services (e.g. score, completude certification and other add-ons) from the controller:

• Username
• First name
• Last name
• Email address

The following (additional) personal data will be required if you wish to be called back:

• Telephone number

b. Legal basis
Processing the preceding personal data serves the fulfillment of a contract between you or your company and VIRTUALTEK SPRL or the implementation of pre-contractual activities in accordance with Art. 6 Para. 1 (b) GDPR.
You can withdraw your consent to the use of your personal data at any time with future effect by sending an email to the email address detailed in clause 1 above or to the data protection officer (cf. clause 2 above).

c. Duration of storage
The duration of storage with regard to the preceding personal data depends on the nature of your contract. Your data will be routinely deleted insofar as the purpose of your communication no longer applies and data storage is no longer necessary.

6. Contact options on our website

Our website offers you various options to contact us by email:

• General Contact: contact@virtualtek.io

a. Type and scope of data processing
Every user of this website can send their inquiries to this email address. Email inquiries are processed by the appropriate department. The data we collect in this case is limited to the email address of the email account you used to contact us and any other personal data you disclose to us within the scope of your inquiry.

b. Legal basis
The lawfulness of data collection is based on Art. 6 Para. 1 (f) GDPR as both you and we have an interest in contacting and communicating with one another and we as a company have a legitimate interest in processing the data detailed in the preceding in order to respond to your inquiry.

c. Duration of storage
The duration of storage with regard to the preceding personal data depends on the nature of your inquiry. Your data will be routinely deleted insofar as the purpose of your communication no longer applies and data storage is no longer necessary (or once we have finished handling your inquiry).

§ 5 Disclosing data

We will only disclose your data to third parties if:

• You have explicitly granted your consent in accordance with Art. 6 Para. 1 p. 1 (a) GDPR
• To do so is lawful and necessary to fulfill our contractual obligations towards you in accordance with Art. 6 Para. 1 p. 1 (b) GDPR
• We are obligated to do so by law in accordance with Art. 6 Para. 1 p. 1 (c) GDPR
• Disclosure is necessary to protect our legitimate interest or to assert, exercise or defend legal claims in accordance with Art. 6 Para. 1 p. 1 (f) GDPR and there is no reason to assume that you have an overriding interest in non-disclosure worthy of protection.

§ 6 Use of cookies

a. Type and scope of data processing
Our website uses cookies. Cookies are small files that are sent to and stored by your browser when you visit our web pages. Certain technical cookies are essential as some of our website’s functions will not work without them. Other cookies enable us to carry out a range of analyses. Cookies can, for instance, recognize your browser and send certain information to us when you return to our website. Cookies enable us to make our website more effective and user-friendly for you as they can help us to understand how you use our website and your preferred settings (for instance country and language settings). If third parties use cookies to process information, this information will be collected directly from your browser. Cookies do not cause any damage to your end device. They cannot execute programs and do not contain viruses.
Our website uses different kinds of cookies whose type and function are explained in the following.

b. Legal basis
The legal basis for processing personal data using cookies is Art. 6 Para. 1 (f) GDPR on account of the purposes described in the preceding (cf. clause 6. a.). If you have granted your consent to the use of cookies in response to a notice (“cookie banner”) on the website, then lawfulness is also based on Art. 6 Para. 1 p. 1 (a) GDPR.

c. Duration of storage
As soon as the data transmitted to us via the cookies is no longer required to achieve the purposes described above, this information is deleted. Further storage may take place in individual cases if this is required by law.

d. Configuration of browser settings
Most browser are set to accept cookies by default. You can, however, configure your browser so that it only accepts certain cookies or none at all. Please note, however, that you may not be able to use all the functions of our website if its cookies are deactivated in your browser settings. You can also use your browser settings to delete cookies already stored in your browser. In addition, you can set your browser to inform you whenever a cookie is about to be stored. As browsers differ in regards to their functionality, please refer to your browser’s help menu for information on adjusting configuration options.
We recommend installing specific plug-ins if you want to see a comprehensive overview of all third parties with access to your web browser.

§ 7 Tracking and analysis tools

We use tracking and analysis tools to ensure our website is continuously optimized and its design is suitable for its purpose. Tracking measures also enable us to collect statistical data with regard to user behavior on our website and to use the insights gained to further improve our online offering for you. These interests justify the use of tracking and analysis tools described below in accordance with Art. 6 Para. 1 p. 1 (f) GDPR. If you have granted your consent to the use of cookies in response to a notice (“cookie banner”) on the website, then lawfulness is also based on Art. 6 Para. 1 p. 1 (a) GDPR. The purpose of tracking and analysis tools and the data they process can also be referenced from the following descriptions. You can use our website’s cookie settings to activate and deactivate your selection of tracking and analysis tools at any time.

1. Google Analytics

This website uses Google Analytics, a web analysis service of Google Inc., 1600 Amphitheatre Parkway, Mountainview, CA 94043 USA (“Google”). Google Analytics uses so-called cookies. Cookies are small text files that are stored on your computer and enable an analysis of your use of the website.
The information generated by the cookies about your use of the website, for instance the time, location and frequency of your visits, is usually transmitted to and stored on a Google server in the United States. The collection of other personal data in addition to your IP address by the cookies set by Google Analytics cannot be ruled out when Google Analytics is used. Please note that Google may disclose this information to third parties if required to do so by law or if a third party processes the information on behalf of Google.

Google will use this information on behalf of the website operator for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website and internet usage to the website operator. According to Google, Google will not associate the IP address transferred by your browser within the context of Google Analytics with any other data held by Google.

You can prevent the storage of cookies on your computer by adjusting the corresponding settings in your browser. Please note, however, that you may not be able to use all the functions of this website in full if you do so.

The collection of other personal data in addition to your IP address by the cookies set by Google Analytics cannot be ruled out. In addition to deactivating tracking cookies as described in the preceding, you can also prevent Google Analytics from collecting information about your use of the website and transferring it to Google Analytics by downloading and installing the browser plug-in available under: https://tools.google.com/dlpage/gaoptout?hl=en.
This plug-in prevents information about your visit to the website from being sent to Google Analytics. The plug-in does not prevent any other form of analysis.
This website uses Google Analytics with the “anonymizeIp” extension to ensure the best possible protection of your personal data. The code deletes the last 8 bits of IP addresses so that your IP address is anonymized when it is collected (so-called IP masking). Google truncates and therefore anonymizes IP addresses in Member States of the European Union as well as in other countries that are party to the Agreement on the European Economic Area before they are sent to the USA. Only in exceptional cases is the full IP address sent to and truncated by a Google server in the USA.

With this consent, you also consent to the transmission of your usage behavior to Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043) in the United States. Google reserves the right to use the data received for other purposes and to link your data to others. The US is considered by the European Court of Justice to be a country with an inadequate level of data protection by EU standards. In particular, due to the absence of an adequacy decision and without appropriate safeguards, there is a risk that your data may be processed by US authorities for control and monitoring purposes, possibly without any redress.

2. Hubspot

We use “Hubspot” technology in general and, in particular, conversion tracking. Hubspot is Customer Relationship Management service provided by HubSpot Ireland Limited, HubSpot House, One Sir John Rogerson’s Quay, Dublin 2, Ireland, Attention: Legal, (with copy to HubSpot, Inc.).

Our website uses the HubSpot tracking code. Learn more about cookies set in a visitor’s browser by HubSpot.

The data collected by conversion cookies serves to create conversion statistics for Hubspot customers who use conversion tracking. Customers receive information on the number of users who clicked on their messages and were subsequently transferred to a website with a conversion tracking tag. However, they do not receive any information that would allow users to be personally identified.

If you do not want to participate in conversion tracking, you can prevent this by adjusting your browser’s settings accordingly so that, for instance, setting cookies is generally prohibited. You can also deactivate conversion tracking cookies by adjusting your browser so that only cookies from “googleadservices.com” are blocked.

§ 8 Hyperlinks

Our website contains so-called hyperlinks to websites operated by other providers. Activating a hyperlink will transfer you directly to the website of the corresponding provider. You can recognize the transfer by the change of URL, for example. We cannot accept any liability for the confidential use of your data on these websites as we have no influence on the compliance of these companies with data protection regulations. Please refer directly to the website concerned to obtain information on how your personal data is handled.

§ 9 Right of access

The GDPR stipulates that you as a data subject whose data is processed have the following rights:

• Pursuant to Art. 15 GDPR, you can request information with regard to your personal data processed by us. In particular, you can request information in relation to the purposes of the processing; the categories of personal data concerned; the categories of recipients to whom the personal data has been or will be disclosed, including recipients in third countries or international organizations; the envisaged period for which the personal data will be stored; the existence of the right to request from us the rectification or erasure of your personal data or restriction of processing of your personal data or to object to such processing; the existence of the right to lodge a complaint; the source of your personal data to the extent that it was not collected by us; and the existence of automated decision-making, including profiling and any meaningful information about the particulars thereof.
• Pursuant to Art. 16 GDPR, you can demand the immediate correction of incorrect or incomplete personal data stored by us.
• Pursuant to Art. 17 GDPR, you have a right to request the erasure of your personal data stored by us insofar as processing is not required for the purpose of exercising the right of freedom of expression and information; for compliance with a legal obligation; for the performance of a task carried out in the public interest or in the exercise of official authority vested in us; or for the establishment, exercise or defense of legal claims.
• Pursuant to Art. 18 GDPR, you have a right to restrict our use of your personal data if you contest the accuracy of the data; the processing is unlawful; we no longer need the personal data, but it is required by you for the establishment, exercise or defense of legal claims. Your right pursuant to Art. 18 GDPR remains unaffected if you have lodged an objection to data processing in accordance with Art. 21 GDPR.
• Pursuant to Art. 20 GDPR, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format; you also have the right to have your data transmitted to another controller.
• Pursuant to Art. 7 Para. 3 GDPR, you have the right to withdraw previously granted consent at any time. Consequentially, we will not be permitted to continue processing your data on the basis of your consent in the future.
• Pursuant to Art. 77 GDPR, you have the right to lodge a complaint with a supervisory authority. You can contact the supervisory authority of the Member State of your habitual residence, place of work or place of the alleged infringement.

§ 10 Right to object

In relation to the processing of your personal data on the basis of legitimate interests in accordance with Art. 6 Para. 1 p. 1 (f) GDPR, you have the right pursuant to Art. 21 GDPR to object to your data being processed on grounds relating to your particular situation or if your objection concerns direct marketing. With regard to direct marketing, you have a general right to object without providing a specific reason and we are required to take appropriate action.

§ 11 Data Portability

You may request a copy of your personal data in an electronic format that you can take to other service providers by contacting us at contact@virtualtek.io. We will respond to your request within 30 days.

§ 12 Account Closure and Data Deletion

You may request to close your account according to the following conditions. All contracts and services must be cancelled or finished prior to closure. If there are any active contracts or services in the account, the account cannot be closed. You will no longer be able to log into your account after it is closed. Upon closing your account, it may take up to 30 days for account data to be deleted. After deletion, you will no longer be able to access your account and your account will be unrecoverable. Data that is necessary for the bookings or services you have placed may be retained if it is required for our legitimate business purposes or legal or contractual record keeping requirements.

§ 13 Data safety and security measures

We undertake to protect your privacy and to treat your personal data confidentially. We have implemented extensive technological and organizational measures to prevent the manipulation, loss or misuse of your personal data stored on our servers. These measures are routinely reviewed and adapted to reflect technological developments. They include the use of acknowledged encryption methods (SSL or TLS).
Please note, however, that the structure of the internet makes it possible for persons and institutions outside of our sphere of control to disregard data protection regulations and the security measures detailed in the preceding. In particular, data that is transmitted without prior encryption – for instance by email – can be read by third parties. We have no technological influence in this regard. It is the user’s responsibility to protect the data provided by them from misuse by way of encryption or other suitable means.