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Silverfin & Data Protection

Last update: 6 December 2021

ABOUT THIS PAGE

Silverfin may process personal data relating to you, for instance, through the Silverfin platform, or by you browsing on the website www.silverfin.com (“Website”) or due to your commercial relationship and/or communication with Silverfin.

Silverfin respects your privacy and we always strive to act in accordance with the applicable privacy legislation, such as (non-exhaustive): (i) the General Data Protection Regulation 2016/679 of April 27, 2016 (“GDPR”); (ii) the United Kingdom(UK) Data Protection Act 2018 (“UK GDPR”); (iii) the Belgian Privacy Law of 30 July 2018; (iv) the ePrivacy Directive 2002/58/EC of 12 July 2002, including future amendments and revisions thereof; and/or (v) (future) national legislation regarding the implementation of the GDPR (together: “Privacy Legislation”).

This page aims to explain how Silverfin treats such personal information in light of Privacy Legislation.

OVERVIEW

For more information on how Silverfin processes personal data

SILVERFIN’S ROLE

Silverfin as a data controller
Due to, for example, your commercial relationship or recent contact with Silverfin or due to a visit to or action on our “Website”, we may collect, store and otherwise process personal data relating to you or, if you are a company, your employees | representatives, as a data controller.

This processing is done in accordance with our “Privacy Policy”.

You can consult our Privacy Policy here.

Silverfin as a data processor
If Silverfin processes personal data on behalf of a customer in the performance of its obligations under the SaaS agreement (“Agreement”) - in particular with regard to data uploaded or otherwise entered on the Silverfin platform (See in this respect Section 7.3 of the Terms of Use) - the customer will be considered the data controller for the processing and Silverfin the data processor (or the data sub-processor if the Customer is considered the data processor).

The data controller must ascertain that it has complied with its obligations under the Privacy Legislation before passing personal information to Silverfin for processing or before uploading it on the Silverfin platform.

This processing is done in accordance with our “Data Processing Addendum”, which is an integral part of the Agreement. By signing the Agreement, the customer has declared to have read and agreed to the terms of the Data Processing Addendum. In case of any conflict or inconsistency with the terms of the Agreement, this Data Processing Addendum will take precedence over the terms of the Agreement to the extent of such conflict or inconsistency.

You can consult our Data Processing Addendum here.

COOKIES

The Website uses cookies to improve your browsing experience. A cookie is a small text file that is downloaded onto “terminal equipment” (e.g., your computer or smartphone) when the user accesses a website. It allows the website to recognize that user’s device and store information about the user’s preferences or past actions.

For more information on how Silverfin uses cookies and how you can further manage and enable/disable cookies, reference is made to our “Cookie Policy”.

You can consult our Cookie Policy here.

When you visit our Website for the first time, you are prompted via our cookie banner to indicate your cookie preferences (with regard to non-strictly necessary cookies). Please note that you can change your cookie preferences at all times by going to our “cookie preference banner”.

You can access our cookie preference banner here.

SECURITY

Silverfin is ISO 27001 certified which serves as an excellent framework to protect and process your personal information.

In accordance with the Privacy Legislation we have also implemented organizational & technical measures to protect your personal data.

We refer to our Security Policy for an overview of the measures taken.

You can consult our Security Policy here.

YOUR DATA SUBJECT RIGHTS

The Privacy Legislation (e.g. (UK) GDPR) gives you certain rights over your personal data vis-à-vis Silverfin (when acting as a data controller).

For more information on your rights as a data subject, please consult our Privacy Policy. You can consult our Privacy Policy here.

You can exercise your rights by contacting us, as specified below, and by using the Data Subject’s Rights Form.

You can download the Data Subject’s Rights Form here.

COMMUNICATION

You can receive | subscribe to one or more Silverfin communications in order to be updated on any changes we make to the Silverfin platform, be provided with relevant tips & tricks, be informed of upcoming Silverfin events etc.

For more information on the manner in which we collect, store and use your personal data for such Silverfin communications, please read our Privacy Policy. You can consult our Privacy Policy here.

You can always select or modify your communication preferences via our “Communication Preferences Centre”. Furthermore, if you do not wish to receive any direct marketing communication from Silverfin, you can object to the processing of your personal data for such purpose under the Privacy Legislation via said centre (“Yes, I object…”).

Please click on your unique link to the Communication Preferences Centre included in the footer of every Silverfin communication

SUB-PROCESSORS

When acting as data processor, Silverfin may engage certain sub-processors to assist it in providing the services as described in the Agreement and within the scope of the DPA. Accordingly, these sub-processors could have access to the personal data uploaded on the Silverfin platform or otherwise provided to Silverfin.

Silverfin makes sure that the necessary contracts or similar legal binding acts are in place to ensure that these sub-processor treat your personal data in accordance with the Privacy Legislation and the Data Processing Addendum.

The use of sub-processors is governed by our Data Processing Addendum. You can find an overview of our sub-processors in Annex III of the Data Processing Addendum.

You can consult our Data Processing Addendum here.

COMPLAINTS?

You are not satisfied with the manner in which we collect, store or otherwise treat or secure your personal data? We are sorry to hear that, and are prepared to take all measures to remedy this situation. Please do contact us as specified above.

You also have the right to lodge a complaint with the authorized supervisory authority (the Belgian Data Protection Authority) or the data protection authority of (i) your residence or (ii) workplace should you consider that the processing of your personal data infringes the Privacy Legislation. You can send an email to the Belgian Data Protection Authority at contact@apd-gba.be or any other email address provided by the Belgian Data Protection Authority (https://www.dataprotectionauthority.be/contact-us).

CONTACT | FURTHER QUESTIONS

If you would have further queries on how Silverfin handles personal information please contact legal@silverfin.com.