Privacy Policy

last changed: 20 May 2018

In the following policy statement, SVC refers to the service offered by Heads First (the "Company" or "We") through the web application and API (the "Service"). This Privacy Policy explains (i) what information we collect through your access and use of our Service (ii) the use we make of such information; and (iii) the security level we provide for protecting such information. By visiting and using the Services provided there, you consent to the terms outlined in this privacy policy.

Legal Framework

The Company is domiciled solely in the Netherlands and all hosting infrastructure is located solely within the Netherlands, and thus governed by the laws and regulations of the Netherlands. Under Dutch law, the technical means for lawful interceptions of customer communications is governed by the Dutch law 'Wet op de inlichtingen- en veiligheidsdiensten' (Wiv2017).

Data Collection

Our company's overriding policy is to collect as little user information as possible to ensure a satisfying user experience when using the Service. Service's user data collection is limited to the following:

Data Use

We use the data you provided at account creation when addressing you (salutation) via automated or personal communications. We may use account activity data to find and resolve issues regarding the operation of the Service (bugs). Any user data that we do have will never be shared except under the circumstances described below in Data Disclosure. We do NOT do any analysis on the limited data we do possess.

Data Storage

All servers used in connection with the provisioning of the Service are located in the Netherlands and wholly owned and operated by Heads First. Offline backups may be stored periodically.

Data Retention

Active accounts will have data retained indefinitely. When an account is closed, data is immediately deleted from production servers. Deleted data may be retained in our backups for up to 14 days.

Data Disclosure

As an Internet application provider we are not obliged to provide the technical means for lawful interception. We will only disclose the limited user data we possess if we receive notice from the Dutch Public Prosecutor's office Midden-Nederland or the Dutch Police regarding a relevant court order.

Data Protection

We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. It is important for you to protect against unauthorised access to your password and to your computer. Be sure to sign off when you finish using a shared computer.

Data Inspection

Users have the right to inspect their own user data. They can do so by signing in as usual, or, alternatively, by an inquiry in writing.

Modifications to Privacy Policy

Company reserves the right to periodically review and change this policy from time to time and we will notify users who have enabled the notifications preference. Continued use of the Service will be deemed as acceptance of such changes.