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Privacy Policy

This Privacy Policy statement is made by Apostle consisting of all the entities listed. collectively, "Apostle", "we", "us" or "our") and is effective as of 25th May 2018. It applies to all our divisions: Apostle & Apostle Connect.

Apostle’s Privacy Commitment

Apostle has been concerned about customer and user privacy for almost 9 years, long before it became fashionable, politically correct or legally binding to take such a stance. We ask for as little information as possible and only collect what we feel is necessary to conduct business, or for the specific transaction in question. We let our customers know what information we have about them and give them the option to cancel certain commitments. Yet, by far our biggest commitment is that we do not make a single dollar from advertising revenue - never have, never will - not even from the free editions of our products. This means we avoid the fundamental conflict of interest between collecting customer information and fuelling advertising revenue, and the inevitable compromises in customer privacy that this entails. The purpose of this policy is to make explicit what information we collect about our customers and users, how we will use it and how we will not. This policy is unfortunately longer than we would like, but we need to be unambiguous on all relevant issues. We will try to keep the language as simple and direct as possible.

Content of the Privacy Policy

This Privacy Policy applies to all of the Apostle websites that link to this Privacy Policy. It also applies to the products and services Apostle offers through these websites and our mobile applications. This Privacy Policy is divided into three parts:

Part I – Information collected and managed by Apostle

This section deals with the way Apostle collects and uses information about visitors to the website, potential customers, users of products and services of Apostle, and others who contact Apostle through forms or email addresses published on or linked to our websites.

Part II – Information processed by Apostle on your behalf

This section deals with how Apostle handles data that you entrust to Apostle when you use our products and services, or when you share personal or confidential information with us when requesting customer support.

Part III – General

This section covers topics relevant to both Part I and Part II, and other general topics such as the security commitments of Apostle and how we will notify you when we change this Privacy Policy.

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Part I – Information collected by Apostle

What information does Apostle collect?

We only collect information about you if we need it for a legitimate purpose. Apostle will only have information about you if (a) you have provided the information yourself, (b) Apostle has collected the information automatically, or (c) Apostle has obtained the information from a third party. Below, we describe the different scenarios that fall under each of these three categories and the information that is collected in each category.

Information you provide to us

1. Signing up for an account: When you sign up for an account to access one or more of our services, we ask for information such as your name, email address, job title and company name to complete the account sign-up process. You will also be asked to choose a password to access the 8account created. You may also provide us with additional information, such as your photo and language, but we do not require that information to sign you up for an account.
2. Event registrations and other form submissions: We record information that you submit when you (i) register for an event, including webinars or seminars, (ii) subscribe to our newsletter or other mailing list, (iii) submit a form to download a product, white paper or other materials, (iv) participate incompetitions or respond to surveys, or (v) submit a form to request customer support or contact Apostle for any other purpose.
3. Payment processing: When you buy something from us, we ask you to provide your name, contact information and credit card or other payment account information.‍
4. Testimonial: If you give us permission to post testimonials about our products and services on websites, we may include your name and other personal information in the testimonial. You will have an opportunity to review and approve the testimonial before we post it. If you wish to update or remove your testimonial, please contact us at privacy@apostle.nl.‍
5. Interactions with Apostle: We may record, analyse and use your interactions with us, including e-mail and chat conversations with our sales and customer support professionals, to improve our interactions with you and other customers.

Information that we collect automatically

1. Browser, Device and Server Information: When you visit our websites, we collect information that web browsers, mobile devices and servers make available, such as the Internet Protocol address, browser type, language preference, time zone, referring URL, date and time of access, operating system, mobile device manufacturer and mobile network information. We include this data in our log files to gain more insight into the visitors to our websites.
2. Information from cookies and first party tracking technologies: We use temporary and permanent cookies to identify users of our services and to improve the user experience. We embed unique identifiers in our downloadable products to track product usage. We also use cookies, beacons, tags, scripts, and other similar technologies to identify visitors, track web site navigation, gather demographic information about visitors and users, understand the effectiveness of email campaigns, and provide targeted visitor and user engagement by tracking your activities on our websites. We use first-party cookies and third-party cookies/other tracking technologies on our websites.
3. Information from application logs and mobile analytics: We collect anonymous information about your use of our products, services, and mobile applications from application logs and in-house 9usage analysis tools, and use it to understand how your business use and needs can improve our products. This information includes clicks, scrolls, accessed features, access time and frequency, generated errors, performance data, used storage space, user settings and configurations, and devices used for access and their locations.

Information we collect from third parties

1. Referrals: If someone has referred one of our products or services to you through one of our referral programmes, that person may have provided us with your name, email address and other personal information. You may contact us at privacy@apostle.nl to request that we remove your information from our database. If you provide us with information about another person, or if another person provides us with your information, we will only use that information for the specific reason for which it was provided to us.
2. Information from our resale partners and service providers: If you contact one of our resalepartners, or otherwise express your interest in one of our products or services to them, the resale partner may provide Apostle with your name, email address, company name and other information. If you register for or participate in an event sponsored by Apostle, the event organiser may share your information with us.
3. Information from social media sites and other publicly available sources: When you interact or engage with us on social media sites such as Facebook, Twitter and Instagram through posts, comments, questions and other interactions, we may collect such publicly available information, including profile information, to enable us to connect with you, improve our products or better understand the reactions and concerns of users. Please note that once collected, this information may remain with us even if you delete it from the social media sites.
4. Apostle may also add and update information about you from other publicly available sources.

In addition to the purposes listed above, we may use your information for the following purposes:

1. To communicate with you (for example, by email) about products you have downloaded and services you have signed up for, changes to this Privacy Policy, changes to the Terms of Service, or important notices;
2. To inform you about new products and services, upcoming events, offers, promotions, and other information we think will be of interest to you;
3. To ask you to participate in surveys, or to request feedback on our products and services;
4. To set up and maintain your account, and to do all other things necessary to provide our services, such as enabling cooperation, providing website and mail hosting, and backing up and restoring your data;
5. To understand how users use our products and services, to monitor and prevent problems, and to improve our products and services;
6. To provide customer support, and to analyse and improve our interactions with customers;
7. To detect and prevent fraudulent transactions and other illegal activities, to report spam, and to protect the rights and interests of Apostle, its users, third parties and the public;
8. To update, expand and analyse our data, identify new customers, and offer products and services that may be of interest to you;
9. To analyse trends, manage our websites, and track navigations of visitors on our websites to understand what visitors are looking for and to better serve them;
10. To monitor and improve marketing campaigns and to make suggestions that are relevant for the user.

Purposes for using information

In addition to the purposes mentioned above, we may use your information for the following purposes:

Legal bases for collecting and using information

Legal processing bases applicable to Apostle: When we process your personal data, we have a basis for doing so. Most of our information collection and processing activities are usually based on (i) contractual necessity, (ii) one or more legitimate interests of Apostle or a third party that do not outweigh your data protection interests, or (iii) your consent. Sometimes, we are required by law to collect your data, or we need your personal data to protect your vital interests or those of another person.

Withdrawal of consent: Where we rely on your consent as the legal basis, you have the right to withdraw your consent at any time, but this does not affect processing that has already taken place.

Notification of legitimate interests: When we invoke legitimate interests as a legal basis and these legitimate interests are not specified above, we will clearly explain to you what these legitimate interests are at the time we collect your information.

Your choice in the use of information

Opt out of non-essential electronic communications: You may opt-out of receiving newsletters and other non-essential communications by using the 'unsubscribe' function included in all such communications. You will, however, continue to receive notices and essential transaction emails.

Disable cookies: You can disable browser cookies before visiting our websites. However, if you do so, you may not be able to use certain features of the websites properly.

Optional information: You may choose not to provide optional profile information, such as your photograph. You may also remove or change your optional profile information. You can always choose not to complete non mandatory fields when filling out a form linked to our Sites.

With whom do we share your information?

We do not sell personal information. We share your information only in the ways described in this Privacy Policy, and only with parties who have taken appropriate confidentiality and security measures. The parties that process personal data on our or your behalf are:

• IT suppliers and service providers
• Cookie service providers
• Payment service providers
• Partners and consultants
• Marketing and advertising partners
• Resale partners

Employees and independent contractors: Employees and independent contractors of all Apostle entities have access to the information covered by Part I on a “need-to-know” basis. We require all employees and independent contractors of Apostle entities to comply with this Privacy Policy for the personal information we share with them.

Third-party service providers: We may need to share your personal information and aggregated or identified information with external service providers that we engage with, such as marketing and advertising partners, event organisers, web analytics providers, and payment processors.

These service providers are authorized to use your personal information only as necessary to provide these services to us.

Resale partners: We may share your personal data with our authorised resale partners in your region for the sole purpose of contacting you about products you have downloaded or services you have signed up for. We will give you an option to opt-out of further co-operation with that partner.

Other cases : Other scenarios in which we may share the same information covered in Parts I and II are described in Part III.

Your rights in relation to information we hold about you as a processor

If you are located in the European Economic Area (EEA), you have the following rights with regard to the information Apostle stores about you. Apostle undertakes to provide you with the same rights, regardless of where you live.

Right to access: You have the right to access (and, if necessary, obtain a copy) of the categories of personal information we store about you, including the source of the information, the purpose and period of processing, and the persons to whom the information is disclosed.

Right to rectification: You have the right to update the information we hold about you or to correct any inaccuracies. Based on the purpose for which we use your information, you may instruct us to include additional information about you in our database.

Right to erasure: You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer needed for the purpose for which it was originally collected.

Right to restrict processing: You may also have the right to request that we restrict the use of your data in certain circumstances, for example, if you have objected to our use of your data but we need to verify whether we have compelling legitimate grounds to use it.

Right to data portability: You have the right to transfer your data to a third party in a structured, commonly used and machine-readable format in circumstances where the data is processed with your consent or by automated means.

Right to object: You have the right to object in certain circumstances to the use of your information, such as the use of your personal information for direct marketing.

Right to lodge a complaint: You have the right to lodge a complaint with the appropriate supervisory authority if you have a grievance against the way we collect, use or share your information. In the Netherlands, you can lodge a complaint with the Dutch Data Protection Authority.

Retention of information

If you have contacted us, we will keep the information for as long as is necessary for this contact or for up to 6 months after we last had contact with you, because we want to be sure that we have dealt with your question or complaint properly.

If you have subscribed to our newsletter, we will keep your data until you unsubscribe from the newsletter.

In the context of the services we provide, we store your personal data for up to 2 years after the service has ended. We store some data longer, based on the statutory retention period.

We will store information relating to application processes for up to 4 weeks after the position has been filled. If you give us permission to do so, we will save your application data for another year.

Sometimes we may store your information longer, as permitted or required by law, such as to maintain suppression lists, prevent abuse, if required in connection with a legal claim or proceeding, to enforce our agreements, for tax, accounting, or to comply with other legal obligations. When we no longer have a legitimate reason to process your information, we will delete or anonymise your information from our active databases. We will also store the information securely and isolate it from further processing on backup drives until deletion is possible.

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Part II – Information processed by Apostle on your behalf

Information entrusted to Apostle and its purpose

Information provided in connection with services: You may entrust information that you or your organisation ("you") manage to Apostle, in connection with the use of our services or the request fortechnical support for our products. This includes information about your customers and your employees (if you are a data controller) or data that you store and use on behalf of another person for a specific purpose, such as a customer to whom you provide services (if you are a processor). The data may either be stored on our servers when you use our services, or transferred or shared with us as part of a request for technical support or other services.

Data from mobile devices: If you choose to allow this, our mobile application will have access to the camera and photo library of your mobile device. Our application needs this access to provide its services. You can disable the access of the mobile application to this information at any time by changing the settings on your mobile device. (All information entrusted to Apostle is collectively referred to as "Service Data").

Ownership and control of your service data

We recognise that you are the owner of your Service Data. We offer you full control of your Service Data by allowing you to (i) access your Service Data, (ii) share your Service Data through supported third party integrations, and (iii) request the export or deletion of your Service Data.

How do we use service data?

We process your service data when you give us instructions via the various modules of our services. For example, when you send inputs via Apostle, we need access to your photo library or camera (for a snapshot) in order to complete the request.

Push notifications

If you have enabled notifications on our mobile application, we will push notifications through a push notification provider, such as Apple Push Notification Service and Google Cloud Messaging. You can manage your preferences for push notifications or disable these notifications by turning notifications off in the application or device settings.

With whom do we share service data?

Apostle and third-party sub-processors: In order to provide services and technical support for our product, the contracting entity engages with other entities and third parties within Apostle

Employees and independent contractors: We may grant access to your service data to our employees and individuals who are involved in providing the services as independent contractors of the Apostle (collectively, our "employees") so that they can identify, analyse and resolve errors. We ensure that the access of our employees to your service data is limited to specific individuals. Our employees also have access to data you intentionally share with us for technical support or to import data into our products or services. We communicate our privacy and security guidelines to our employees and strictly enforce privacy safeguards within Apostle.

Collaborators and other users: Some of our products or services allow you to collaborate with other users or third parties. Entering into a cooperation can enable other employees to view all or part of your profile data.

Other cases: Other scenarios in which we may share information that is common to information covered in Parts I and II are described in Part III.

Retention of information

We retain the data in your account for as long as you choose to use the Apostle services. When you terminate your Apostle user account, your data will eventually be deleted from the active database during the next clean-up that takes place once every 6 months. The data deleted from the active database will be deleted from the backups after 3 months.

Requests from stakeholders

If you believe that we are storing, using or processing your data on behalf of one of our customers, please contact the customer to access, correct, delete, limit or object to the processing of your personal data, or to export it. We will support our customer to comply with your request within a reasonable time.

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Part III – General

Personal data of children

We do not direct our products and services at persons under the age of 18. Apostle does not intentionally collect personal information from children under the age of 18. If we hear that a child under 18 has provided us with personal information, we will take steps to delete such information. If you believe that a child under 18 has provided us with personal information, please write to privacy@apostle.nl with the details, and we will take the necessary steps to delete the information we have about that child.

Locations and international transmission

We share your personal information and service data within the Apostle. By accessing or using our products and services or otherwise providing us with personal information or service data, you consent to the processing, transfer and storage of your personal information or service data within the European Economic Area (EEA).

In order to provide its services, Apostle may provide your personal data to parties established outside the European Economic Area (EEA). Apostle will only do this if there is an adequate level of protection for the processing of personal data. This means, for example, that we use a model agreement of the European Commission or that we make agreements regarding the handling of personal data.

Processing agreement

To enable you to comply with the data protection obligations under the General Data Protection Regulation, we are prepared to sign a Data Protection Agreement (DPA) based on standard contractual clauses. You can request a DPA from Apostle at privacy@apostle.nl. Once we have received your request, we will send you the DPA so you can sign it.

External links on our websites

Some pages of our websites may contain links to websites that are not covered by this Privacy Policy. If you provide your personal information to one of these third party sites, your personal information will be subject to their Privacy Policy. As a safety measure, we recommend that you do not share any personal information with these third parties unless you have reviewed their Privacy Policy and have been assured of their privacy practices.

Social media widgets

Our websites contain social media widgets, such as Facebook "like" buttons and Twitter "tweet" buttons that allow you to share articles and other information. These widgets may collect information such as your IP address and the pages you navigate on the website, and may set a cookie to enable the widgets to function properly. Your interactions with these widgets are governed by the Privacy Policy of the companies that provide them.

Disclosures in accordance with legal obligations

We may be required by law to retain or disclose your personal information and service data to comply with applicable laws, regulations, legal processes, or governmental requests, including meetingnational security requirements.

Enforcing our rights

We may disclose personal information and service data to a third party when we believe such disclosure is necessary to prevent fraud, investigate suspected illegal activities, enforce our agreements or policies, or protect the safety of our users.

Business Transfers

We do not intend to sell our business. However, in the unlikely event that we sell our business or are acquired or merged, we will ensure that the acquiring entity is legally bound to fulfil our obligations to you. We will notify you of any change in ownership or use of your personal information and service details by email or by prominent notice on our website. We will also notify you of any choices you may have regarding your Personal Information and Service Data.

Compliance with this Privacy Policy

We make every effort, including periodic reviews, to ensure that the personal information you provide to us is used in accordance with this Privacy Policy. If you have any concerns about our compliance with this Privacy Policy or how your personal information is used, please write to us at privacy@apostle.nl. We will contact you and, if necessary, coordinate with the appropriate regulatory authorities to effectively address your concerns.

Notification of changes

We may change the Privacy Policy at any time. If we make material changes to the Privacy Policy that affect your rights, you will be notified of the changes by email to your primary email address at least 30 days in advance. If you believe that the updated Privacy Policy affects your rights with respect to your use of our products or services, you may terminate your use by emailing us within 30 days. You will not receive email notification of minor changes to the Privacy Policy.

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