Privacy Policy

Privacy Policy  

We at Garnet Instruments Ltd. (“Company”, “we”, “us”) respect your privacy and want you to  understand how we collect, use, and share personal data about you – our visitors, users and customers. 

Unless stated otherwise in this Privacy Policy (“Policy”) with regard to your personal data we are controller within the meaning of the General Data Protection Regulation (EU) 2016/679 (“GDPR”). This means we have certain statutory duties and responsibilities regarding our processing.  

This Policy addresses our personal data collection practices and describes your rights. Unless we state otherwise, this Policy applies when you visit or use the Company website(s), https://www.garnetinstruments.eu/ – our social media channels and related platforms (“Platforms”). 

Contact information 

Garnet Instruments Ltd.

Windmolen 22 7609 NN

europe@garnetinstruments.com

1. WHAT PERSONAL DATA WE COLLECT   

Personal Data You Provide To Us 

We collect personal data you provide directly to us. For example, we collect personal data when you create an online account, sign up to receive our emails, communicate with us on the Platforms or via third-party social media sites, or order our products or services. The type of personal data we may collect include your: 

• Contact information: name,  

email address,  

address, phone number, company name 

• Financial information: bank account number, payment status, invoices and receipts 

• Communication information: any personal data you include in your communication with us, such as replies to emails  

• Account information: username/login name, password, account-ID, Platforms preference and settings 

• Identifying information: social media handles 

• Other information: any other information you choose to provide 

• Location data: our mobile App requires location services to be enabled for its technical functionality. We do not process or use your location data for any other purposes, such as tracking. 

Automatically Collected Personal Data through Tracking Technologies 

When you visit or use the Platforms, we may use cookies, pixels, tags, web beacons, and other tracking technologies to collect information about your browsing and purchasing behavior.  The type of information we may collect include:  

• Device data: type of browser you use, device type and model, your IP address 

Usage data: access times,  

pages viewed,  

time spent on pages,  

links clicked,  

the referring link through which you accessed the website,  

• conversion information. 

1. WHAT WE USE YOUR PERSONAL DATA FOR  

We use your personal data for the following purposes: 

• provide the products and services you request; 

• process transactions and send you related information (i.e., confirmations and receipts); 

• respond to your comments, questions and requests and provide customer service; 

• communicate with you about products, services, offers, promotions, and provide news and information we think will be of interest to you; 

• send you technical notices, updates, security alerts, and support and administrative messages; 

• better tailor our Platforms to your interests and needs; 

• carry out profiling activities in order to learn more about you; and 

• offer you tailored advertising based on your behavior on our Platforms;  

• comply with legal obligations applicable to the Company. 

We will only process your personal data based on the following legal bases: 

• You have given your consent to the processing of your personal data; 

• The processing is necessary for the performance of a contract; 

• The processing is necessary for us to comply with our legal obligations; 

• The processing is necessary for our legitimate interest, except where such interests are overridden by your interests or fundamental rights and freedoms. 

1. WHO WE SHARE YOUR PERSONAL DATA WITH 

Publicly Shared Personal Data 

Any personal data that you voluntarily choose to share in a public area of our Platforms (e.g., by posting a comment to a blog post or leaving a review) will be available to anyone who has access to that content. 

To Company Employees and Contractors  

We may share your personal data within the Company to our employees and contractors, only to the extent necessary for the performance of their tasks (e.g. in order to deliver our services and products to you). 

Third-Party Service Providers  

We use third-party service providers to collect and process your personal data on our behalf.  In such cases, these third-party service provides are only allowed to use your personal data for the purposes described above and only in accordance with our instructions. Examples include data analysis, marketing and advertising services, email and hosting services, customer services and support, hosting customer accounts, processing credit card payments, and collecting customer research or satisfaction surveys. They have access to the personal data needed to perform their functions. When we share your personal data with these third-party service providers, who process personal data on our behalf, we will ensure that your personal data is protected in accordance with the GDPR and the terms of this Policy through data processing agreements we have concluded with these third-party service providers. 

Online Advertising Services 

We may use third-party advertising services to deliver advertising about our products and services on our Platforms, as well as other websites and applications you use. The ads may be based on information we have collected (as outlined above) and information these advertising providers know about you based on their tracking data. The ads can be based on your recent activity or activity over time and across other sites and services and may be tailored to your interests. 

Analytic Services 

We may use third-party browser and mobile analytics services on the Platforms. These services use tools to help us analyze your use of the Platforms, including information like the third-party website you arrive from, how often you visit, events within the Platforms, usage and performance data, and purchasing behavior. We use this data to improve the Platforms and provide information, products and services that may be of interest to you. 

Law Enforcement, Legal Process and Compliance  

We may disclose your personal data (1) if we are required or permitted to do so by applicable law or legal process (such as a court order or subpoena), (2) to law enforcement authorities or other government officials to comply with a legitimate legal request, (3) when we believe disclosure is necessary to prevent physical harm or financial loss, (4) to establish, exercise or defend our legal rights, (5) in connection with an investigation of suspected or actual fraud or illegal activity or (6) otherwise with your consent. 

Change of Ownership 

We reserve the right to transfer to relevant third-parties any personal data we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation) or other business combination. In such case, we will require the relevant third parties to provide comparable levels of protection as we provide with respect to the personal data we share. 

1. KEEPING YOUR PERSONAL DATA SECURE 

We have appropriate security measures in place to prevent personal data from being accidentally lost, or used or accessed in an unauthorized way. We limit access to your personal data to those who have a genuine business need to know it.  Those processing your personal data will do so only in an authorized manner and are subject to a duty of confidentiality. 

We also have procedures in place to deal with any suspected date security breach.  We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. 

1. YOUR RIGHTS  

The GDPR a number of rights  that you may exercise in the context of our processing of your personal data. Please note that we may not be required to comply with your request. In such instances, we will let you know if that is the case. In summary, your rights include: 

• Right to information: You have the right to understand how we use your personal data. This Policy is designed to provide that transparency;  

• Right of access: You can request a copy of the personal data we hold about you and to learn details about how we use it;  

• Right to rectification: You have the right to ask us to correct any mistakes in your personal data which we hold; 

• Right to erasure: You have the right to ask the erasure of your personal data in certain situations. For example, if the personal data is no longer necessary for the original purpose for which they were collected, if personal data has become obsolete, or if you withdraw your consent to the grounds on which personal data is processed. However, this will need to be balanced against other factors. For example, we may not be able to comply with your request due to certain legal or regulatory obligations; 

• Right to data portability: You may have the right in certain situations to request us to transfer your personal data which you have provided to us, in a structured, commonly used and machine-readable format to a third party of your choice; 

• Right to object: You have the right to object to the processing of your personal data which is based on our legitimate interests. Unless we have overriding legitimate grounds for the processing, we will stop processing your personal data when you raise an objection. In addition, you have the right to object at any time to the processing of your personal data for direct marketing; 

• Right to restriction of processing: Under certain circumstances you are entitled to ask us to (temporarily) stop the processing of your personal data, for example, where you think that the personal data we hold about you may be inaccurate or where you think that we no longer need to use your personal data;  

Right to withdraw consent: You have the right to withdraw your consent at any time. We will stop processing your personal data which is based on consent as soon as possible after the withdrawal. However, withdrawing your consent does not affect the lawfulness of the processing before the consent was withdrawn; 

• Rights relating to automated individual decision-making: You have the right not to be subjected to a decision being taken solely by automated means, including profiling, which produce legal effects concerning you or similarly significantly affect you; 

• Right to submit a complaint: You have the right to lodge a complaint to the (local) data protection authority in the jurisdiction, where you live or where an alleged infringement takes place. As a rule, the lead supervisory authority for the Company is the Dutch Data Protection Authority and should be contacted. This is different if you issue regards a purely local matter. In such event, please consult the local supervisory authority.   

If you would like to exercise any of the above rights, please submit your request or complaint to us by sending an e-mail.  

We may ask you to identify yourself (e.g., account number, user name, registration details or address).; In that case, we will ask you to submit certain information to ensure that your are the correct person whose personal data is involved. In addition, you should provide us sufficient information to which your request relates (e.g., any account or reference numbers).  

Email Communications: If you would like to unsubscribe from any email marketing communications we send you, you can click on the unsubscribe link at the bottom of the message. 

Cookies and “Do Not Track” Signals: Most web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to remove or reject cookies, but note that doing so does not necessarily affect third party flash cookies used in connection with the Platforms. Further information about deleting and blocking cookies can be found at http://www.allaboutcookies.org. 

Many web browsers support Do Not Track technology. To learn more about Do Not Track, visit: http://www.allaboutdnt.org/. 

Company currently does not have the ability to recognize Do Not Track Signals. 

Personal Data from Third Parties: To manage the personal data we receive about you from a social media site or other third parties, you will need to follow the instructions from that party for updating your personal data and changing your privacy settings, where available. The personal data we collect is covered by this Policy and the personal data the third-party collects is subject to such third party’s privacy practices. Privacy choices you have made on any third-party site will not apply to our use of the personal data we have collected directly through our Platforms. 

1. THIRD-PARTY SITES 

The Platforms may contain features or links to websites and services provided by third parties. Any personal data you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Platforms. We are not responsible for the content or privacy and security practices and policies of third party sites or services to which links or access are provided through the Platforms. We encourage you to learn about third parties’ privacy and security policies before providing them with your personal data. 

1. DATA TRANSFERS 

When processing your personal data for the purposes specified above, it is possible that your personal data will be processed by us and by some third parties with whom we share your personal data in or accessed from countries located outside the European Economic Area (“EEA”).  

In such situations, we will provide appropriate safeguards that provide an adequate level of protection for your rights and freedoms as a data subject in accordance with the GDPR. We do this, for example, by relying on an adequacy decision as adopted by the European Commission in keeping with article 45 GDPR,¹ concluding contracts based on standard contractual clauses for data transfers issued by the European Commission, or other appropriate safeguards as provided in articles 46-49 GDPR. 

If you wish to receive further information on the international data transfer of your personal data, please contact us by using the contact information as provided at the top of this Policy. 

1. DATA RETENTION 

In principle, we will retain your personal data no longer than necessary for the purpose(s) for which we process your personal data and in accordance with (local) legal obligations. After a retention period, we will delete or anonymize your personal data, unless we retain certain of your personal data for another purpose. We will only do so if we have a legal ground to retain your personal data. We will ensure that personal data are only accessible for that other purpose. 

Personal data we collect about you as a website visitor will not be kept longer then necessary. The retention period differs for each cookie. We keep all personal data in your account for one year after your last use, unless there are reasons to retain the personal data in your account longer or to comply with a legal (tax) obligation (for example 7 years after the end of a tax year in certain jurisdictions). In addition, if you are on the mailing list for the marketing communication we will delete your personal data upon request (by clicking in the unsubscribe link at the bottom of the message).  

If you wish to have more information about our retention periods, please contact us via the contact information as provided at the top of this Policy. 

1. OUR POLICY CONCERNING MINORS 

Minors should not use the Platforms. If we learn that we’ve collected personal data from a minor, we will take reasonable steps to delete it. Parents who believe that the Company may have collected personal data from a minor can submit a request that it be removed by contacting us via the contact information as provided at the top of this Policy. 

1. CHANGES AND UPDATES TO THIS POLICY 

We may change this Policy from time to time. If we make changes, we will notify you by revising the date at the top of this Policy, and in some cases, we may provide you with additional notice (such as sending you an email notification). We encourage you to review the Policy whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy.