Data Protection Policy
Data Protection Policy
Version: March 2021
At TinQwise, we deal with a substantial amount of data. This statement describes the comprehensive Data Protection Policy of TinQwise created to ensure that user data is handled responsibly and consistently. This policy covers the accessibility, storage, retention, and disposal of all data held by TinQwise. Our commitment is to safeguard the Information we collect and to meet all applicable data protection regulations.
What Information do we collect about you on behalf of our clients?
When you interact with the TinQwise Growth Platform, we may collect your personal data or other Information. This data includes:
- First and last name
- Contract start date
- Job title and additional similar business information
- Learning insights, including metrics and Information regarding your use and interaction with the TinQwise Growth Platform.
By creating an account, you are giving your consent for this data to be stored at TinQwise.
Typically, the third-party services are software that we integrate with (e.g., Business Intelligence Tools). If there is an integration with an external tool, TinQwise may access various Information associated with authorised users, such as employee ID, contract start date, and job functionality.
Authorised users should check the privacy settings and notices in these third-party services to understand what data may be disclosed to TinQwise. When a third-party service is enabled in your Growth Platform, TinQwise is authorised to connect and access other Information made available to TinQwise in accordance with our agreement with the provider of the third-party service and any permission(s) granted by our customer (including by its authorised user(s)). Examples of Information which TinQwise may receive in this manner include whether you successfully created a new account or interacted with a third-party application in a way that is attributable to TinQwise usage activity. We do not receive or store passwords for any of these third-party services when connecting them to the services.
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Our platform does not collect sensitive data.
How do we use your Information?
TinQwise stores your data for the following purposes:
- Communication: We use your account information for emails and in-app notifications.
- Learning Insights: We use platform activity data to gain user behaviour and engagement insights. This Information is used to improve learning experiences and make them more effective.
- To improve our product and services: We use your data to help resolve technical issues and investigate product bugs or outages.
Automated data processing
- We do not make automated decisions based on automated data processing. Automated decisions refer to decisions made by computer software without any involvement of a human being, such as a TinQwise employee.
How do we store and secure confidential data?
a. Data storage and security
TinQwise takes the security of data very seriously. To ensure the safety and security of your data, we utilise various security technologies and procedures to prevent unauthorised access, use, or disclosure. These steps consider the sensitivity of the Information we collect, process and store and the technology’s current state.
Given the nature of information processing technology, TinQwise cannot guarantee that Information during transmission through the internet or while stored on our systems or otherwise in our care will be absolutely safe from intrusion by others. When you click a link to a third-party site, you will be leaving our site, and we don’t control or endorse what is on third-party sites.
b. Retention of personal data
The time we retain the Information we collect about you depends on the type of Information and how we collect and store it. Once a reasonable period has passed, we will delete or anonymise your data. If we cannot do so, we will securely store your Information and isolate it from further use until possible deletion.
Information Sharing and Disclosure
Users: We will display your Personal Information on your profile page and elsewhere in the web application according to the preferences you set in your account. Any information you choose to provide should reflect how much you want other TinQwise Growth Platform Users to know about you. We recommend that you guard your anonymity and sensitive Information, and we encourage you to think carefully about what Information you disclose on your profile pages. You can review and revise your profile information at any time. You should be aware that the administrator, as well as specially designated support personnel to provide support for technical issues you may face, may be able to: access Information in and about your account; access communications history, including file attachments for your account; disclose, restrict, or access information that you have provided or that is made available to you when using your account, including your Content; and controls how your account may be accessed or deleted.
Third Parties: We do not sell your Personal Information or Content and will not share or disclose any of your Personal Information or Content with third parties except as described in this policy. We do not share Personal Information about you with third parties for their marketing purposes (including direct marketing). Service Providers, Business Partners and Others: For security, service operation and management purposes, TinQwise also uses third-party services that provide the same or better level of protection as TinQwise. Third-party vendors and providers supply the necessary hardware, networking and storage to run the TinQwise services. These third parties have access to your Personal Information only for purposes of performing these tasks on our behalf.
Compliance with Laws and Law Enforcement: TinQwise cooperates with the government, law enforcement officials, and private parties to enforce and comply with the law. We will disclose any information about you to the government or law enforcement officials or private parties as we, in our
sole discretion, believe necessary or appropriate to respond to claims and legal process, to protect the property and rights of TinQwise or a third party, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be or to pose a risk of being, illegal, unethical, inappropriate or legally actionable.
Children: Our services are not directed to children. We do not knowingly collect Personal Information from children. If we become aware that a child has provided us with Personal Information, we will take steps to delete such Information. If you become aware that a child has provided us with Personal Information, please get in touch with us directly.
Business Transfers: We may share or transfer your Information (including your Personal Information) in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. You will be notified on any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.
What is TinQwise’s general data protection policy?
TinQwise believes implementing and maintaining the procedures and rules outlined in this document is crucial to creating a secure data environment. Additionally, we have implemented several additional policies to enhance data protection further, including:
- Two-step authentication for all logins to maximise security for TinQwise employees and customers.
- All employees are required to sign a confidentiality clause in their contracts clause (in Dutch): “Gebruik je gezonde verstand alsjeblieft. Als je aan iets werkt dat vertrouwelijk is, ga er dan niet over opscheppen in bijvoorbeeld de kroeg. Dat kan ons op dure boetes komen te staan. Wij rekenen op jouw discretie. Besef dat wij als TinQwise vaak geheimhoudingsverklaringen tekenen met onze klanten en die gelden dan voor alle TinQers. We hebben het dan over alle informatie die niet algemeen bekend is bij de gemiddelde Nederlander."
- External resources are also required to sign a separate confidentiality contract, “Geheimhoudingsverklaring” (version 2.0 d.d. October 27, 2017) and Inkoopvoorwaarden 5.0 d,d, October 27, 2017) in which this Data Protection Policy is also covered.
All suppliers who provide data storage applications/software must complete the “Quality Assurance Checklist” (version 1.0.0).
We have appointed a Data Security Officer responsible for monitoring and improving how we handle all data within TinQwise, including those handled by TinQwise employees and other involved individuals. This officer ensures that our practices comply with the latest privacy laws and undergoes regular Data & Privacy training.
Although TinQwise owns the code, databases, and all rights to the Qollab LXP service, Customers retain ownership, control and all rights to their records and data, which are their property.
Some general contact information
If you have any questions regarding your data our this policy, please do not hesitate to contact us.
Phone: 035 538 5656