Privacy Policy — Villa Nelmar

Your privacy is important to our website. This Privacy Policy covers what we collect and how we use, disclose, transfer and store your information.
1. Identity of Villanelmar
If there are any questions regarding this Privacy Policy you may contact us using the information below.
Our customers may submit inquiries regarding personal data protection, privacy and security matters to CEO of Villanelmar.
2. What information do we collect?
You may visit our site anonymously.
If you choose to register on our website, four categories of data to and on behalf of you will be processed:
“Account data”
When you register for an account on our site, place an order, subscribe to our newsletter or respond to a survey, basic contact details are collected such as the e-mail address and name of your contact person, company name, address, phone number, VAT number, preferred language and currency, any purchase order number, any e-mail address of invoice receivers and masked credit card or bank account details.
“Configuration data”
We collect your direct input to our cloud service Cookiebot (the “Service”) after login, like the domain name(s) of the website(s) where you implement the Service and configuration of the content, looks and behavior towards website visitors (“End Users”).
“End User Data”
Data generated by End Users browsing your website(s) using the Service. When an End User submits a consent from your website(s), the following data are automatically logged at Villanelmar:
•The End User’s IP number in anonymized form (last three digits are set to ‘0’).
•The date and time of the consent.
•User agent of the End User’s browser.
•The URL from which the consent was submitted.
•An anonymous, random and encrypted key value.
•The End User’s consent state, serving as proof of consent.

The key and consent state are also saved in the End User’s browser in the first party cookie “CookieConsent” so that the website can automatically read and respect the End User’s consent on all subsequent page requests and future End User sessions for up to 12 months. The key is used for proof of consent and an option to verify that the consent state stored in the End User’s browser is unaltered compared to the original consent submitted to Villanelmar.

If you activate the Service feature “bulk consent” to enable consent for multiple websites by a single End User submission, the Service will also store a separate random, unique ID with the End User’s consent. If all of the following criteria are met, this key will be stored in an encrypted form in the third party cookie “CookieConsentBulkTicket” on the End User’s browser:
•You enable the bulk consent feature in the Service configuration.
•The End User allows third party cookies through browser settings.
•The End User has disabled “Do Not Track” through browser settings.
•The End User accepts all or at least “preferences” types of cookies when consenting.
“System Generated Data”
The Service automatically creates and stores meta data on basis of the other types of data, e.g.:
•Subscription data, like start date, latest invoice date and the result of a mandatory VAT number validation. Issued invoices are stored so that you may access any issued invoices from within the Service Manager.
•Definitions of the cookies found when the Service has scanned your website(s), including reports on the result of each scan.
•Aggregated statistical data on End User consents.
You can issue instructions to Villanelmar through configuration and/or execution of relevant functions offered by the Service from the Service Manager. If a specific instruction regarding personal data cannot be carried out through the Service Manager, you may send instructions to us through the help desk provided at www. Villanelmar.com/helpdesk.

You will be informed by Villanelmar about relevant changes concerning the Service, such as the implementation of additional functions, by e-mail, if you subscribe to Villanelmar’s newsletter from the account settings page in the Service Manager.
3. What do we use your information for?
Any of the information we collect from you may be used for one or more of the following purposes:
3.1. To personalize your experience (the information will help Villanelmar better respond to your individual needs);
3.2. To enable you to control the user experience towards End Users and enable the Service to automatically apply the End User’s consent to other websites of yours;

3.3.To improve our website (Villanelmar continually strives to improve our website offerings based on the information and feedback we receive from our customers);
3.4.To identify you as a contracting party;
3.5.To enable secure login for you in the Service Manager at cookiebot.com;
3.6.To establish a primary channel of communication with you;
3.7.To enable Villanelmar to issue valid VAT invoices and to process transactions (your information will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the service requested);
3.8.To enable automated handling of the subscriptions;
3.9.To produce and display cookie declarations to End Users and store and display scan report(s) to you;
3.10.To provide you with aggregated information on the choices of the End Users regarding accepted cookie types and generate a graphical representation in the Service Manager; and/or
3.11.To send periodic e-mails (The e-mail address you provide for order processing, may be used to send you information and updates pertaining to your order, in addition to receiving occasional company news (if accepted), updates, related product or service information, etc.)
If at any time you would like to unsubscribe from receiving future e-mails, you can cancel your account after login by clicking on “Cancel my account”
.4. Legal basis
4.1. EU General Data Protection Regulation (GDPR)
The processing of your data is either based on your consent or in case the processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract, cf. GDPR art. 6(1)(a)-(b).
If the processing is based on your consent, you may at any time withdraw your consent by contacting us using the contact information in clause 1.
In order to enter into a contract regarding the purchase of Villanelmar Service, you must provide us with the required personal data. If you do not to provide us with all the required information, it will not be possible to deliver the Service.
5. How do we protect your information?
Villanelmar implements the following technical, physical and organizational measures to maintain the safety of your personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized use, unauthorized modification, disclosure or access and against all other unlawful forms of processing.
5.1. Availability
The Service utilizes the extensive features of the cloud environment to ensure high availability, like full redundancy, load balancing, automatic capacity scaling, continuous data backup and geo-replication along with a traffic manager for automatic geographical failover on datacenter level disasters. All failover mechanisms are fully automated.
No personal data is stored permanently outside Villanelmar cloud platforms. The physical security is thereby maintained by Villanelmar subcontractors, see clause 7. Microsoft’s datacenters comply with industry standards such as ISO 27001 for physical security and availability, e.g. by using security staff around the clock, two-factor access control using biometric and card readers, barriers, fencing, security cameras and other measures.
5.2. Integrity
To ensure integrity, all data transits are encrypted to align with best practices for protecting confidentiality and data integrity. E.g. all supplied credit card information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway provider’s database only to be accessible by those who are authorized to access such systems and who are required to keep the information confidential.
For data in transit, the Service uses industry-standard transport protocols between devices and Microsoft datacenters and within datacenters themselves.
5.3. Confidentiality
All personnel are subject to full confidentiality and any subcontractors and subprocessors are required to sign a confidentiality agreement if not full confidentiality is part of the main agreement between the parties.

Whenever personal data is accessed by authorized personnel the access is only possible over an encrypted connection. When accessing the data in a database, the IP number of the person accessing the data must also be pre-authorized to obtain access.
Any device being used to access personal data is login protected by Villanelmar Azure Active Directory (AAD), Microsoft’s cloud based identity and access management service, and has Villanelmar corporate antivirus solution installed. If any personal data are temporarily stored on a device, the storage unit on the device must also be strongly encrypted.
On premise devices storing personal data temporarily is at all times, except when not being actively used or relocated under uninterrupted supervision, locked in a safe. Personal data are never stored on mobile media like USB sticks and DVD’s.
5.4. Transparency
Villanelmar will at all times keep you informed about changes to the processes to protect data privacy and security, including practices and policies. You may at any time request information on where and how data is stored, secured and used. Villanelmar will also provide the summaries of any independent audits of the Service.
5.5. Isolation
All access to personal data is blocked by default, using a zero privileges policy. Access to personal data is restricted to individually authorized personnel. Villanelmar Security and Privacy Officer issues authorizations and maintains a log of granted authorizations. Authorized personnel are granted a minimum access on a need-to-have basis through our AAD.
5.6. The ability to intervene
Villanelmar enables your rights of access, rectification, erasure, blocking and objection mainly by providing built-in functions for data handling in the Service Manager, by offering the option to send instructions through Villanelmar helpdesk and also by informing about and offering the customer the possibility of objection when Villanelmar is planning to implement changes to relevant practices and policies.
The overall responsibility for data security lies with Villanelmar Data Protection Officer who educates and updates all personnel on the data security measures outlined in Villanelmar security handbook and this Privacy Policy.
5.7. Monitoring
Villanelmar uses security reports to monitor access patterns and to proactively identify and mitigate potential threats. Administrative operations, including system access, are logged to provide an audit trail if unauthorized or accidental changes are made.

System performance and availability is monitored from both internal and external monitoring services.
5.8. Personal Data breach notification
In the event that your data is compromised Villanelmar will notify you and competent Supervisory Authority(ies) within 72 hours by e-mail with information about the extent of the breach, affected data, any impact on the Service and Villanelmar action plan for measures to secure the data and limit any possible detrimental effect on the data subjects.
“Personal data breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed in connection with the provision of the Service.
6. How we use cookies
See Villanelmar’s Cookie Declaration at www. Villanelmar.com/cookie-declaration for information on the cookies we use.
7. Do we disclose any information to outside parties?
Villanelmar does not sell, trade or otherwise transfer to outside parties any personally identifiable information.
This does not include trusted third parties or subcontractors who assist us in operating our website, conducting our business, or servicing you. Such trusted parties may have access to personally identifiable information on a need-to-know basis and will be contractually obliged to keep your information confidential.
We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect our or others’ rights, property, or safety. Furthermore, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
7.2 Legally required disclosure
Villanelmar will not disclose the customer’s data to law enforcement except when instructed by you or where it is required by law. When governments make a lawful demand for customer data from Villanelmar, Villanelmar strives to limit the disclosure. Villanelmar will only release specific data mandated by the relevant legal demand.
If compelled to disclose your data, Villanelmar will promptly notify you and provide a copy of the demand unless legally prohibited from doing so.

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