Your data, handled properly.

What kind of company are we?

VC4 is the owner and developer of the OSS solution IMS (Inventory & Management System) and Service2Create (S2C). Service2Create (S2C) is our next-generation cloud-native, low-code/no-code platform, enabling all industries to manage network inventory infrastructure efficiently, automating tasks, and optimizing workflows with ease. IMS is a powerful multi-user application that offers fast and user friendly functionalities for registering and managing a wide range of telecommunications networks and platforms.

General information

Legal notice

Reporting a security issue

Privacy-sensitive data

VC4 B.V. takes the privacy of its employees, clients, suppliers and visitors very seriously and will process and use your personal information in a secure manner. VC4 B.V. complies with the laws and regulations relating to the protection of personal data that are submitted to us by the General Data Protection Regulation (GDPR).

This policy applies to all personal data, that is collected and used by VC4 B.V. The data relates to customer data that you have provided to us, but also information from your visits to our website; see also our Cookie Policy.

VC4 B.V. uses your data only if you give permission or if VC4 B.V. needs your data to deliver products or services to you (or if this has already happened). VC4 B.V. does not sell your personal information to third parties. VC4 B.V. makes the data available only to third parties that are involved in the execution of the agreement between VC4 B.V. and you. If and when VC4 B.V. processes your data in any other way, this requires your (explicit) permission.

VC4 B.V. collects only minimal data necessary for handling our contractual obligations for our employees and customers. We also collect only the minimum data from visitors to our website (see data processing below).

Data processing

From visitors to our website

In general you can visit our website without providing us with personal information.

Purposes for data collection

However, VC4 B.V., like many other websites, collects certain non-identifiable automatic information about the users of its websites, such as the IP address of your computer, the type of browser you use, the date and time of access to the website, the region from which you visit our website, the website through which you arrived on our website, the pages and parts of the website you are visiting and which information you are viewing.

This collected data is used to optimise the content of our website and our Google Ads campaign to the wishes and needs of the visitors of our website.

If a visitor to our website www.vc4.com leaves personal information on the contact page, this information is used in addition to the aforementioned, to send this visitor our information package. We will not send unwanted newsletters or other information.

You can find more information in our Cookie Policy.

From employees

Employees are also understood as: applicants, flex workers, employees and self-employed without personnel.

Purposes for data collection

VC4 B.V. will use the personal data collected about employees for the following purposes:

1. to enter into and maintain an employee / employer relationship or a personnel / employment mediation relationship with you, or to enter into and maintain a relationship aimed at acquiring / performing assignments;
2. to assess your suitability for a specific position or assignment and to record your availability;
3. to be able to enter into agreements with you, our client(s) and / or relations and to be able to execute and comply with them;
4. to comply with our reintegration obligations;
5. to promote and stimulate your personal development, including training and education, and to allow you to participate in (online) tests and to generate test results;
6. to possibly guide you to a new employment position during long-term illness or redundancy;
7. for management purposes including management information such as (internal and external) controls, audits and accountants check and the promotion and maintenance of operational safety;
8. to allow you to access and use our IMS environment;
9. to comply with applicable laws and regulations.

From clients

Among Clients means VC4 B.V.: the client, who has signed a contract with us for the delivery of our software product IMS.

Purposes for data collection

The information that we have in our possession of our Clients is general basic information (company name, company address, and contact details). This data is used to sign the contract between the client and VC4 B.V. to draw up. In addition, these data are used to send the correct invoice.

The same data are also used for the Processing Agreement.

From suppliers

Suppliers means: the supplier, who, on the basis of an agreement, provides services to VC4 B.V.

Purposes for data collection

The data that VC4 B.V. has in her possession of our Suppliers are general basic data (company name, company address, and contact details). In addition, we also have the bank account number of our suppliers on which the payment must take place. The data is used to make the invoice payment correctly.

In addition, the data is used to draw up the Processing Agreement between Supplier and VC4 B.V.

Principles for data processing

General

Under the General Data Protection Regulation (GDPR) VC4 B.V. cannot just process personal data. We must have a so-called legal basis for this. There are possible 6 legal bases, on which VC4 B.V. may process the ordinary personal data. These legal bases are:

1. Consent of the person concerned.
2. The data processing is necessary for the execution of an agreement.
3. Data processing is necessary for compliance with a legal obligation.
4. Data processing is necessary to protect the vital interests.
5. Data processing is necessary for the fulfilment of a task of general interest or exercise of public authority.
6. The data processing is necessary for the representation of the legitimate interests.

Legal basis of the processing

VC4 B.V. bases the data that they process on the following bases:

• Consent of the person concerned (base 1).
• Data processing is necessary for the execution of an agreement (base 2).
• Data processing is necessary for compliance with a legal obligation (base 3).
• Data processing is necessary for the representation of legitimate interests (base 6).

VC4 B.V. does not sell your data

VC4 B.V. does not sell or provide your personal information to third parties and only makes this information available to third parties that are involved in providing the agreed services. Our employees and hired third parties are obliged to respect the confidentiality of your data. To this end, our employees have signed an NDA. We have concluded a processor agreement with hired third parties.

Additionally, we have entered into a Data Processing Agreement with HubSpot Inc. to gather and process data from the HubSpot forms operating on our website. This Data Processing Agreement can be found here. Should you wish to view a signed PDF of this agreement you can download it here: HubSpot Data Processing Agreement.

S2C Designer Site Survey (mobile app)

This section covers the S2C Designer Site Survey mobile application, used by authorized field surveyors to record premises for network survey and design on behalf of VC4's clients.

What the app collects

• Precise location (GPS): the coordinates of the surveyed building, the standing point at the property boundary and the exact cable-entry point. This is the core deliverable of a survey.
• Photos: a photo of the building's front and a close-up of the cable-entry point.
• Building details: building type, number of dwellings/connections, number of floors, and optional notes.
• Files: documents or images the surveyor attaches to a surveyed object (for example an inspection report), picked through the phone's own file picker.
• Agreements recorded on site: when a landowner or other party gives consent on site, their name (and organisation), optionally an e-mail address to receive a copy, their handwritten signature and where and when it was signed. The signed document is produced by the S2C Designer platform; a copy is e-mailed only to the parties who asked for one. Once the platform confirms an agreement is signed, these personal details are removed from the phone; an agreement still waiting for a signature keeps them on the phone until it is signed.
• Device information: when the device is linked to an organization (by scanning a pairing QR code or entering an activation code), we register the device name, model, platform and app version to manage the session. No password is stored on the device.

How it is used

Solely to perform the network site survey and feed the results into network design in the S2C Designer platform (app functionality). The data is not used for advertising, profiling or tracking.

Where it is stored and who can access it

Survey data is stored on VC4's S2C Designer backend within the client organization's own environment. It is not sold and not shared with third parties. The app contains no advertising and no third-party analytics SDKs.

Transmission

All data is transmitted over an encrypted (HTTPS) connection.

Map tiles

To draw the map, the app requests map images (tiles) of the area on screen from the OpenStreetMap Foundation (tile.openstreetmap.org, street map) and from Esri (server.arcgisonline.com, aerial imagery), over HTTPS. Such a request carries only what any web request carries: the device's IP address, the app's user-agent (the app name, the Android version, the device model and the web-engine version) and the position of the tile (which shows the map area being viewed). No survey data, GPS position or account data is sent with it. The app keeps no map tiles of its own: the phone's web engine may cache viewed tiles for as long as the map servers' own caching headers allow, to draw them again. The map needs an internet connection.

Retention and deletion

On the device, data is held only until it is synced to the backend, and is removed when the surveyor logs out or the device is unlinked. Stored survey data can be deleted by the organization via the S2C Designer platform.

Permissions

• Camera, to photograph the building and the cable-entry point.
• Precise location, to record the building's coordinates.

Both are used only during an active survey.

Transfer in EU or outside EU

Your data will not be used for purposes other than those mentioned above. VC4 B.V. will not pass on data to other organisations (within or outside the EU).

Retention period of the data

The data is stored depending on the purpose. A retention period of 5 years applies to the data of ex-employees. The details of our clients are kept as long as they have an agreement with VC4 B.V. And of the visitors of our website, who have filled in an information request, we will maintain a storage period of 1 month.

The rights of the person concerned

The right of inspection

The Person Concerned is of course entitled to inspect the data used and / or retained by us. In this document VC4 B.V. already provides information about what data is processed.

The person concerned can inspect the personal data VC4 B.V. retained and in addition get access to the way in which these personal data is processed or will be processed.

Specifically for our employees, VC4 B.V. has a digital personnel file, allowing them to inspect the data themselves, which VC4 B.V. has saved.

Correction and removal

At all times VC4 B.V. shall cooperate in correcting the recorded data at the request of The Person Concerned. The Person Concerned must submit a supplementary statement to VC4 B.V., so that the data will be recorded correctly.

At the request of ex-employees, ex-clients and website visitors, we will also remove the information requested by them.

VC4 B.V. will certainly delete the data if:

• The personal data is no longer necessary for the purposes for which we have used this data;
• The consent of the person concerned is withdrawn (see next point);
• The person concerned objects to the processing of the data. If there are no compelling reasons for this processing, we will delete the data;
• If the personal data have been processed unlawfully.

Revocation of given permission

The Person Concerned has the right to withdraw his consent at any time at VC4 B.V. Withdrawal of the consent takes effect at the moment we receive the written request.

Unchanged, we leave the situation before the date of the withdrawal. We will notify The Person Concerned who has given his consent for withdrawal. With us, withdrawing consent is as simple as giving it.

Submitting a complaint

If you, as a Data Subject, have a complaint about the use of your personal data by VC4 B.V., please report this to us first. Please indicate that you have a complaint and we will try to handle this complaint satisfactorily.

If you and VC4 B.V. cannot come to a joint solution, you can go to court; see the Dutch Data Protection Authority. You can also give the Dutch Data Protection Authority a tip about your complaint. They may decide to start an investigation as a result of your tip.

Obligation to provide the personal details

Both employees, clients, suppliers and visitors to our website are, of course, not obliged to have their data processed by us. However, there are consequences to this. If the Person Concerned does not wish to cooperate with our request to process the personal data, we can:

• Not accept an employee because we are unable to draw up an employment contract or take out a pension insurance for the future employee.
• Not deliver our software to a potential client, because we cannot deliver our software if we do not have basic client data (company name, address and location and email address for correspondence) in our possession. Secondly we cannot charge for this purchase. So we won't deliver our software.
• Not go into an agreement with the potential supplier because the data to conclude a contract are missing. Also a processing agreement cannot be agreed upon.
• Not provide you more information as a visitor to our website.

Automated individual decision making including profiling

Profiling, the automated processing of personal data, is a well-known phenomenon in the marketing profession (and beyond). VC4 B.V. does not use this.

Your data will only be used by us for the realization or the execution of an agreement between you and VC4 B.V.

Data from other organizations

VC4 B.V. does not use data from other organizations when processing personal data.