IPROTECT Access – Privacy Policy
Data protection is of a particularly high priority for the management of TKH Security B.V. for the use of the applications of TKH Security B.V.
The processing of personal data, such as name, address, e-mail address, or telephone number of a data subject is in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to TKH Security B.V.
By means of this data protection declaration, our enterprise would like to inform the users of the IPROTECT Access application of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.
As the controller, TKH Security B.V. has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed.
- Definitions
The data protection declaration of the TKH Security B.V. is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.
In this data protection declaration, we use, inter alia, the following terms: - Personal data
Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. - Data subject
Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing. - Processing
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. - Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future. - Profiling
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. - Pseudonymisation
Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person. - Controller responsible for the processing
Controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law. - Processor
Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller. - Recipient
Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing. - Third party
Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data. - Consent
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her. - Name and address of controller
Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
TKH Security B.V.
Platinastraat 65
2718 SZ Zoetermeer
The Netherlands
Phone: +31 79 363 8111
E-Mail: privacy@tkhsecurity.com
- Processing of personal data
When using our app, we are processing the following personal data: - Device identification number, Mobile device ID, E-Mail address, temporary security key
If you use a mobile phone (or another mobile device, tablet, etc.), we generate a randomly generated identification number (Mobile Device ID) for the device identification number assigned to the respective device. This mobile device ID is device-bound and is used for every mobile access of the assigned device. If a new device is registered or the app is reinstalled, a new Mobile Device ID will be generated for this new installation.
When a signal is sent from the registered app using the Mobile Device ID described above, the code-issuing agency creates a randomly generated, one-time, temporary security key. This is then used for authentication to the Access Control System (ACS system).
When you present your mobile device to a reader that requests a code, your Mobile Device ID is extracted from a token and sent to the ACS system for access validation.
The ACS system assigns a randomly generated ID, which then serves as an access code.
In this respect, we process the device identification number of the mobile phone you are using (or the device identification number of another mobile device you are using for the app).
In addition, we need your e-mail address for authentication to the app and for the access you have requested. This will be deleted as soon as you have authorized our app.
The following data processed by us and described above are considered personal data:
- Device identification number
- Mobile device ID
- Temporary security key
- E-mail address
As soon as your access has been generated, the mobile device ID and the randomly generated access code assigned to it will be deleted. - Server logs
When using our app, we process your access data when you use the app for the purpose of providing the services of the app.
This data is stored for the duration of the provision of our app and deleted as soon as you have been deleted as a user of the app.
- Routine deletion or blocking of personal data
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to. If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
- Rights of the data subject
- Right to access
Each data subject shall have the right to obtain from the controller at any time, free of charge, information as to whether personal data concerning him or her are being processed; if this is the case, it has a right to information about this personal data and to the following information:
- the purposes of the processing;
- the categories of personal data being processed;
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
- where possible, the envisaged period for which the personal data will be stored or, if this is not possible, the criteria for determining that period;
- the existence of a right to rectification or erasure of personal data concerning them or to restriction of processing by the controller or a right to object to such processing;
- the existence of a right of appeal to a supervisory authority;
- if the personal data are not collected from the data subject, all available information on their origin;
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the General Data Protection Regulation and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
- If personal data are transferred to a third country or to an international organisation, the data subject has the right to obtain information about the appropriate safeguards pursuant to Article 46 of the General Data Protection Regulation in connection with the transfer. - Right to rectification
Any data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller. - Right to be forgotten
Each data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase the personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- The data subject withdraws consent to which the processing is based according to Article 6(1) GDPR, or Article 9(2) GDPR, and where there is no other legal ground for the processing.
- The data subject objects to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) GDPR.
- The personal data have been unlawfully processed.
- The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
- The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.
- If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the controller, he or she may, at any time, contact any the controller. The controller shall promptly ensure that the erasure request is complied with immediately. Where the controller has made personal data public and is obliged pursuant to Article 17(1) GDPR to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. The controller will arrange the necessary measures in individual cases. - Right of restriction of processing
Each data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
- The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
- The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
- The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
- The data subject has objected to processing pursuant to Article 21(1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
- If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the controller, he or she may at any time contact any employee of the controller. The controller will arrange the restriction of the processing. - Right to data portability
Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format.
He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) GDPR or point (a) of Article 9(2) GDPR, or on a contract pursuant to point (b) of Article 6(1) GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others. In order to assert the right to data portability, the data subject may at any time contact any employee of the controller. - Right to object
Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) GDPR. This also applies to profiling based on these provisions.
The controller shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims. If the controller processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the controller to the processing for direct marketing purposes, the controller will no longer process the personal data for these purposes. In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the controller for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest. In order to exercise the right to object, the data subject may contact any employee of the controller. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications. - Automated individual decision-making, including profiling
Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, the controller shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of the controller - Right to withdraw data protection consent
Each data subject shall have the right to withdraw his or her consent to processing of his or her personal data at any time.
If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact the controller. - Legal basis for the processing
When using our app, Art. 6 (1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If you use our app, this use is based on your consent.