# PRIVACY POLICY --- SnelUBL Document Information: | Version | 1.0 | | --- | --- | | Status | Final | | Date | 15-01-2025 | | Organization | OrangePear B.V. (trading as: SnelUBL) | | Author(s) | SnelUBL Team | | Classification | Public | Change Log: | Version | Date | Status | Change | Author | Responsible | | --- | --- | --- | --- | --- | --- | | 1.0 | 15-01-2025 | Final | First version | SnelUBL Team | SnelUBL Team | --- SnelUBL # 1. Introduction ## 1.1 Background and reason for this document Although SnelUBL does not primarily record personal data, it may be necessary in some cases to record personal data which are necessary for the performance of its services. Having a privacy policy is therefore a necessary requirement for OrangePear B.V. (trading as: SnelUBL). This policy sets out the general principles regarding the processing of personal data and how OrangePear B.V. handles them. ## 1.2 Purpose of this document This document is the elaboration and delivery of the products that fulfill the so-called V2 requirement: Transparency, or Information obligation of the controller. All elaborations are written as 'standard text', the controller will use this text (or a slight adaptation thereof) to fulfill the requirements that the GDPR sets regarding Transparency (Information obligation). --- SnelUBL ## 2. Privacy policy ## Article 1 Definitions In this Policy, the following terms are understood to mean: **Personal data**: any data relating to an identified or identifiable natural person; **Processing of personal data**: any action or set of actions relating to personal data, including in any case the collection, recording, organization, storage, updating, modification, retrieval, consultation, use, disclosure by transmission, distribution or any other form of making available, combining, linking, as well as blocking, erasing or destroying data; **File**: any structured set of personal data, regardless of whether this set of data is centralized or distributed in a functionally or geographically determined manner, which is accessible according to certain criteria and relates to different persons; **Controller**: the natural person, legal person or any other person or administrative body that, alone or together with others, determines the purpose and means of the processing of personal data, in this case OrangePear B.V. (trading as: SnelUBL), located at Neerkanne 32, 1082 BH Amsterdam. **Administrator**: the person who, under the responsibility of the controller, is charged with the (daily) care of the processing of personal data, as well as the storage, deletion and disclosure of data; **Processor**: the person who processes personal data on behalf of the controller under a contract, without being subject to his direct authority; **User**: the person within the meaning of article 7 who is entitled to have knowledge of certain data in a personal register; **Data subject**: the person to whom a personal data relates; **Third party**: anyone who is not the data subject, the controller, the processor, or the person(s) authorized under the authority of the controller or processor to process personal data; **Recipient**: the person to whom the personal data are disclosed; **Competent authority**: the board of the controller; **Data Protection Authority**: the independent government body referred to in article 51 of the General Data Protection Regulation (GDPR) **Consent of the data subject**: any free, specific and informed expression of will by which the data subject accepts that personal data relating to him/her are processed; **GDPR**: General Data Protection Regulation, publication of the European Union L 119/1 dated 4-5-2016; ## Article 2 Scope and objectives of the Policy 2.1 This Policy applies to all personal data processed by or on behalf of the controller. 2.2 This Policy aims to: a. protect the personal privacy of data subjects whose personal data are processed against misuse of that data and against processing of incorrect data; b. prevent personal data from being processed for a purpose other than the purpose for which they were collected; c. guarantee the rights of the data subjects. ## Article 3 Purpose of processing personal data Performing invoice conversion services and converting unstructured invoice documents into digitally structured UBL files. Establishing the identity of users and executing agreements. Classifying documents. Converting unstructured documents into a digitally structured file (UBL format). ## Article 4 Processing of personal data No personal data of a data subject are processed other than described in article 12.3. ## Article 5 Management of (the processing of) personal data Personal data are collected in the name of the data subject. The collection of personal data of the data subject forms the file. ## Article 6 Disclosure of data Personal data are only disclosed to: a. those, including third parties, who lead or are charged with the processing of personal data of data subjects or who are necessarily involved in this; b. others, in the cases referred to in article 6.1 of the GDPR; ## Article 7 Access to personal data 7.1 Without prejudice to any legal regulations in this regard, only the following have access to personal data: a. those, including third parties and others, who are charged with or lead the activities related to the processing of the data or who are necessarily involved in this; b. others, in the cases referred to in article 6.1 of the GDPR; 7.2 The data subject has the right to have knowledge of the personal data relating to him/her that are processed. ## Article 8 Right of access, correction and deletion 8.1 The data subject has the right to have knowledge of the personal data relating to him/her that are processed. 8.2 The data subject has the right to have incorrect data corrected. 8.3 The data subject has the right to have the processing of his/her personal data terminated and the data deleted, unless there is a legal retention obligation. ## Article 9 Security of personal data 9.1 The controller takes appropriate technical and organizational measures to protect personal data against loss or any form of unlawful processing. 9.2 These measures guarantee, taking into account the state of the art and the costs of implementation, an appropriate level of security given the risks that the processing and the nature of the data to be protected entail. ## Article 10 Right to object The data subject may at any time object to the processing of his/her personal data for direct marketing purposes. If the data subject exercises this right, the processing of personal data for this purpose must be terminated immediately. ## Article 11 Retention periods Personal data are retained in accordance with the processing register and applicable legal retention obligations. Invoice documents are processed and deleted after conversion, unless there is a legal retention obligation. ## Article 12 Former data subjects 12.1 The controller may decide to establish processing regarding former data subjects. 12.2 Processing takes place only for: a. maintaining contacts with former data subjects; b. sending information to former data subjects; c. calculating, recording and collecting contributions and donations, including placing claims in the hands of third parties, as well as other internal management activities; d. handling disputes and exercising audit control. e. Converting a readable format to a digitally structured format 12.3 No personal data are processed other than: a. name, first names, initials, titles, gender, citizen service number, date of birth, address, postal code, place of residence, telephone number and similar data required for communication, as well as bank account number of the data subject; b. data for the purpose of calculating, recording and collecting contributions and donations. c. an administration code that contains no other information than referred to under a through c. 12.4 Personal data are only disclosed to: a. those, including third parties, who are charged with or lead the activities referred to in paragraph 2 or who are necessarily involved in this; b. others, in the cases referred to in article 6.1 of the GDPR; 12.5 Personal data are deleted upon a request to that effect from the data subject or upon his/her death. ## Article 13 Processor agreements 13.1 OrangePear B.V. (trading as: SnelUBL) uses processors and enters into a processor agreement with them. ## Article 14 Complaints 14.1 If the data subject is of the opinion that the provisions of this Policy are not complied with by the institution, he/she should contact the controller. 14.2 If the submitted complaint does not lead to an acceptable result for the data subject, he/she may contact the Data Protection Authority. ## Article 15 Google Analytics 15.1 The SnelUBL website uses Google Analytics, a web analytics service provided by Google Inc. ("Google"). Google Analytics uses "cookies" (text files placed on your computer) to help the website analyze how visitors use the site. The anonymous information about your use of the website generated by the cookie is transferred to and stored by Google on servers in the United States. Google uses this information to track how this website is used, to compile reports on website activity for the owner of this website (OrangePear B.V.) and to provide other services related to website activity and internet usage. Google may only provide this information to third parties if Google is legally required to do so, or insofar as these third parties process the information on behalf of Google. Google will not combine your IP address with other data that Google has. You can refuse the use of cookies by choosing the appropriate settings in your browser. However, we point out that in that case you may not be able to use all the features of this website. By using this website, you consent to the processing of information by Google in the manner and for the purposes described above. 15.2 Cookies Only an Analytics cookie is used on this website. 15.3 Privacy legislation and Analytics As described below in the official statement that Google Analytics users must place on their website, this website uses Google Analytics. This program provides important statistics about visitor numbers, pages visited, traffic sources and other essential information that allows us to continuously improve this website for users. These statistics are anonymous and cannot be traced back to a specific person or user. No use is made of 'behavioral targeting' with which you see special content based on your click behavior; your browsing behavior remains completely anonymous. Data from contact forms are never processed or stored in Analytics. 15.4 Google Analytics uses a cookie, which is a small file stored on your computer. We have configured Google Analytics in accordance with privacy legislation, so that no prior consent from the user is required. 15.5 IP addresses are masked and data are not shared The Google Analytics cookie is a 'first party cookie', meaning that the cookie is officially owned by SnelUBL and not by Google. This cookie is not used for advertising or other commercial purposes. OrangePear B.V. has a processor agreement with Google. In addition, Google Analytics is configured so that IP addresses are anonymized, so that data can never be traced back to you or your IP address. Furthermore, no information is shared from the SnelUBL Analytics account with Google or other parties. This makes the SnelUBL Analytics cookie a non-privacy-sensitive first-party cookie that is necessary to ensure the quality and security of snelubl.nl. The Analytics cookie remains valid for 6 months. 15.6 Opt-out If you prefer to block the Analytics script entirely, you can download a Google Analytics opt-out plugin here: https://tools.google.com/dlpage/gaoptout. With this plugin, your visit will no longer be counted in the statistics of all websites that use Google Analytics. ## Article 16 Entry into force and citation title This Policy may be cited as Policy for processing data subject data and enters into force on January 15, 2025. The Policy has been established by the management of OrangePear B.V. --- **Contact Information:** OrangePear B.V. (trading as: SnelUBL) Neerkanne 32 1082 BH Amsterdam The Netherlands Phone: 023 200 25 29 Email: snelubl.support@orangepear.com Website: www.snelubl.nl