Privacy Notice

Last updated: January 24, 2023

Who are we and what do we offer?

We are TrueClicks B.V. (“TrueClicks”). We provide alerts, recommendations, and optimizations to our users by analyzing advertising data from Google Ads and Microsoft Advertising.

We provide these through our software application, which can be accessed via https://app.trueclicks.com (the Service).

We also provide product and company information on our Website https://www.trueclicks.com

The use of our website and service collectively: our Services.

Privacy Notice

This is our Privacy Notice. In this document we explain what kind of Personal Data we collect via our Services. We also explain what role we have in the processing of Personal Data, how long we retain them and what rights you have as a data subject.

Personal Data and Controller

We process Personal Data. Personal Data means all information by which a person can be directly or indirectly identified. Under the General Data Protection Regulation (GDPR) we are the so-called Controller of your Personal Data. If you have questions about the processing of your Personal Data, you can always contact us through the contact details listed at the bottom of this Privacy Notice.

Personal Data:	Purpose(s):	Legal basis:
If you use (any of) our Services, including our free trial: – First name, last name, email address, location, IP address, signup date, login dates, and usage data, such as clicks and pageviews within our Service. – Changes made in Google Ads and/or Microsoft Advertising in the last 30 days (if any). Only if the email address matches an existing TrueClicks user. Other users of these advertising platforms will be anonymized. In addition, we may process: – communications about our Service (only if you contact us about our Service).	We use these data to: – provide you with the Service as requested by you or your employer (our customer); – answer any questions you may have about the Service; – send invoices; and – improve our application based on aggregate usage data of our features.	We may process these data because this is necessary: – to perform our contract with you, i.e. to provide you with the Service, – for our legitimate interest to deliver our Services to you or your employer, or – for our legitimate interest in research and develop our Services.
Payment information: We only process personal payment data if payments are concluded by one-person businesses such as contractors and freelancers. Name, e-mail address, invoicing details, bank details (account number, IBAN and BIC-code if paying by invoice or SEPA direct debit), and a VAT identification number.	We use these data to: – process and administer payments; – maintain our list of accounts receivable and outstanding invoices; and – include in our administration on behalf of the tax authorities.	We may process these data because we have a legitimate interest to conduct our financial administration and invoice our Services. We are also legally obligated to store (some of) these data under tax law. We use an external payment processing provider for credit card and SEPA direct debit payments, Stripe. Please check their Privacy Policy, to see how Stripe handles Personal Data.

Personal Data we may process if you visit our website, or contact us:

Personal Data:	Purpose(s):	Legal basis:
Technical information: Information on your device type, browser type, session date and time, and IP address.	We use these data to: – adapt our Website to the used device; – enable you to use our Website; and – improve the usability of our Website.	We may process these data because we have a legitimate interest in doing so, i.e., to provide you with a good functioning Website and improve our Services for our Users.
Via our social media pages: Information of visitors who leave a comment or otherwise post something on our social media pages, including the Personal Data within these comments and/or posts.	We use these data to: – contact the visitors in reply of their post and/or comment via our social media pages; and – process the feedback left on our social media pages.	We may process these Personal Data because we have a legitimate interest in processing these data and because the visitors voluntarily made public such information.Our social media pages are also controlled by the social medium itself. Please check their own privacy notices to see how each social medium handles Personal Data: LinkedIn: Privacy Policy Meta: Privacy Center Twitter: Privacy Policy
If you contact us: Your name, e-mail address, and the content of the correspondence.	We use these data to: – answer your questions and/or handle any complaints; – support you in using our Services; and – improve our Services as a result of questions and feedback from you.	We may process these data because we have a legitimate interest in contacting and assisting you based on your comment or question and in improving our Services as a result of the questions and feedback we receive.

Cookies

We may use functional, tracking, and/or analytical cookies on our Website. A cookie is a small text file that can be stored on your device when visiting the Website. This text file identifies your browser and/or device. When revisiting our Website, the cookie ensures that your browser/device is recognized.

How long do we keep the Personal Data?

We will not process or store any Personal Data that we do not need. We store Personal Data for as long as we need it for the above purposes unless we are legally obliged to retain the Personal Data for a longer period. In this respect, we apply the following retention periods:

Personal data of potential customers. These data are stored as long as necessary to determine whether we enter into an agreement with a potential customer and for a maximum period of 2 years after our last contact.
Personal data of Users. These data are stored as long as the User’s TrueClicks account is active and for a maximum period of 2 years after.
Newsletters. We retain the Personal Data used for sending newsletters until you unsubscribe from our newsletter.
Personal Data in our correspondence. This data is stored as long as necessary to handle your message/question/complaint and for a period of 2 years thereafter.
Personal Data in our records for the (tax) authorities. This data is stored for 7 years unless we are legally obliged to retain the data for a longer period.
Personal data of job applicants. We store these Personal Data for a maximum of 4 weeks after the application process unless the Applicant has given us permission to store the Personal Data for (up to) 1 year.

After the expiry of the aforementioned retention period(s), we may process and retain certain Personal Data to comply with legal retention obligations and/or for fraud/misuse investigations or to substantiate a (judicial) claim. In such events, we will retain the Personal Data separately and only use such Personal Data for the aforementioned purposes.

Do we share your Personal Data with others?

Processors

We use third parties (Processors) who support us in providing our Services. Within this context these Processors receive Personal Data from us which they process on our behalf. For instance, we use Processors for building and maintaining our Website and platform, for customer relationship management, communication systems and hosting our data.

These Processors may only use or disclose the data collected and processed by us within the scope of our instructions to them. We enter into a data processing agreement with all of our Processors.

Controllers

We may also share your Personal Data with external controllers in the following cases:

Tax authorities: We are legally obliged to include (some of) the Personal Data in our financial administration, which has to be shared with the national tax authority. The tax authority will process these Personal Data in accordance with its own privacy policies.

Payment processing Stripe: only when paying by credit card or SEPA direct debit.

If you are a TrueClicks user, your colleagues with team management permissions can see when you last logged into TrueClicks.

Apart from the above, we will not share your Personal Data with third parties unless we are legally obliged to do so.

Export of Personal Data outside the European Union

We may transmit Personal Data to parties outside the European Union if one of our Processors or Controllers is established outside the European Union. The Personal Data will be transferred to parties that provide an adequate level of protection through the use of EU Standard Contractual Clauses (SCCs). You may contact us if you wish to receive more information or a copy of these SCCs we concluded in this scope where necessary.

Changes of the Privacy Notice

The Privacy Notice may be changed from time to time. Please check our Privacy Notice frequently. The new Privacy Notice will be effective immediately upon posting on our Website. If we change our Privacy Notice significantly, then we will state so on our Website together with the revised Privacy Notice.

Your rights as a data subject and our contact data

You have the right to...
Access ...obtain confirmation as to whether or not your personal data are being processed by us, and, if that is the case, access to the (categories of) personal data and information about our processing activities and a copy of your personal data.	Restriction of processing ...obtain confirmation as to whether or not your personal data are being processed by us, and, if that is the case, access to the (categories of) personal data and information about our processing activities and a copy of your personal data.
Rectification ...obtain rectification of any inaccurate personal data concerning you. You also have right to have incomplete personal data concerning you completed.	Data portability ...receive the personal data you have provided to us in a structured, commonly used and machine-readable format and to transmit those data to another controller or have us do that for you under certain circumstances.
Erasure ...obtain the erasure of your personal data under certain circumstances, for example if the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.	Object ...object to our processing of your personal data based on (among others) legitimate interest under certain circumstances. You may always object to the processing of your personal data for direct marketing purposes.

You are always entitled to file a complaint with a data protection supervisory authority if you believe that we are not processing your personal data in accordance with the GDPR. In the Netherlands, the supervisory authority for data protection is:

Autoriteit Persoonsgegevens
If you have questions or concerns about this Privacy Notice or your privacy, you can contact us at support@trueclicks.com

TrueClicks B.V.
Singel 542 1017 AZ Amsterdam
The Netherlands

E: support@trueclicks.com
W: https://trueclicks.com

Chamber of Commerce: 60703725