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 svc.headsfirst.nl 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 svc.headsfirst.nl 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:
- Account creation: email address, name, password (stored encrypted).
- Account activity: orders created by using the Service, automated email messages created
and sent by the Service.
- Communicating with us: your communications with the Company, such as support
requests, bug reports, or feature requests may be saved by our staff.
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.