Who is responsible for the use of my data?
CSFL is the cont roller when you visit our websites. As the processor, if you contact us with a privacy-
related question, we will refer you to the organization that is the controller.
When I visit the website, which data do you use, for what purpose do you use this data , and how long do you store it?
Our website,www.ChooseASmokefreeLife.comis used to provide general information about the Company, our people, andabout working at CSFL.
For clients we also have dedicated websites and apps:
[to be completed when video store is open]
For these websites and site-based apps, we collect usage data: your IP address, the pages you visit, when you visit thosepages, and (where applicable) the previous/subsequent site you visit. We use this data for various reasons, including: togenerate usage statistics; to provide for (additional) functionality on the sites; to manage the sites by resolving any technicalfaults or improving accessibility to certain parts of the sites; and safeguarding the security of our IT systems. We retain thisdata for 12 days, unless stated otherwise. We process this data to ensure that you can visit a functional and secure websitesand apps. In certain cases, we may use an external hosting provider to serve the websites and apps, in other cases we hostourselves. This means that for those websites where we use a hosting provider, the personal data collected when you visitour website will be transferred to the hosting provider (as a processor).
Our special websites mentioned above also allow you to create anaccount. If you decide to create an account, we will collectyour email address and your password. We use this data to register you with our website and provide you with access to thewebsite. We use your email address to restore your password and to sendyou updates about our service. Some of thewebsites also process further data about you for additional purposes:
For[the video website]: for some users, we automatically add more information to your profile, such as your smoking/vapinghistory. By doingso we know for what engagements we could contact you. We may make this profile data also available toothers on the platform. In addition to the usage data mentioned above, we also collect the access type (Download, View,Print). We retain usage data for 1year.
Forgoods and/or services sold to you: we use your email address to remind you to submit fee updates. We process this dataon the basis of our interest to perform our services as agreed with you, our client. We retain this data for as long as you havean account with us. We may retain this data for seven years after the data was submitted.
What cookies do you use, and for what purpose?
When you visit a website of CSFL, cookies are placed on your computer. CSFL uses two types of cookies:
Necessary cookies: CSFL uses a cookie in order to offer the website’s basic functionality and to remember your cookiesettings. This cookie is called _gat. It is stored for 24 months. If the _gat-cookie is used to throttle the request rate, then it isstored for 1 minute.
Cookies for analytics: CSFL uses cookies to generate anonymous user statistics to make our websites more user-friendly. Wedo this through Google Analytics, a web analysis service offered by Google Inc. (Google). Google uses aggregated statisticalinformation to provide CSFL with an understanding of how visitors are using our websites. To protect your privacy, we haveconfigured Google Analytics to only store part our visitors’ IP address and to not share data with others. Google may onlyprovide this information to third parties if it has a statutory duty to do so or to the extent that the third parties are processingthe information on Google’s behalf. We have signed a data processor agreement with Google. We use the following cookiesfor this purpose: _ga and _gid. These are stored for 24 months and 24 hours respectively.
If you want, you can turn off Google Analytics tracking forChooseASmokefreeLife.com: On Off
In addition, we may use the following cookies: (i) DWRSESSIONID and cfusi for securitypurposes, stored during thesession, (ii) FK, dwp and rsu for authentication purposes, FK stored for1 day, dwp and rsu stored for100 daysand (iii)ROUTEID to improve performance, stored during the session.
When you provide services, which data do yo u use, for which purpose do you use this data, and for how long do you store it?
CSFL is generally engaged in selling books and rendering services in the field of overcoming nicotine dependency. In thecourse of selling such books and providing those services, we process personal data of different categories of people. Theseinclude clients and clients’ contact persons, We also process some of the personal data mentioned above for internal know-how and administrative purposes. For example, we store relevantfiles (after attempting to remove most personal data) andsome of our interactions with others in our internal know-how repository, to retrieve this information at a later date.
We do this processing on the basis of our clients’ legitimate interest in establishing, exercising and defending their rights, onthe basis of our own commercial interest to offer high quality services and we may also do this because we are legallyobliged to.
We will also use the contact details (name, address, email address) of our client (or their contact person) to send invoices.We do this to enable us to collect fees for our services, as part of the performance of the agreement between us and ourclient.
We retain our files for 20 years after our services to you are completed.After this period, we will offer to return originaldocuments which were provided by the client, and we will securely destroy all files.
Prior to most engagements, we collect certain information to verify the identity of the client. CSFL retains this information fora period of five years after the termination of the relationship or the performance of the services or the transaction.
Sometimes, we share information processed in the course of providing services, including with lawyers from other firms,other advisors to clients, and courts. But only if this is possible within the boundaries of the strict confidentiality imposed onlawyers and notaries. In some cases, this is because you have given us permission, and in other cases, this is because ourclients have a legitimate interest in establishing, exercising or defending their legal rights.
When you digitally sign documents through Docusign in the context of our services, we collect your email-address, IP-address and an image of your signature, as well as the time and date on which you used the service. We store thisinformation in the matter related to the document you signed, anduse it to document the signing process. We do thisbecause we have a legitimate interest in retaining evidence of the signing. This data is available to all parties on behalf ofwhich this document is signed, who may be located outside of the United States, European Union or the European EconomicArea.
When I provide goods or services to CSFL, which data do you use, for what purpose do you use this data, and for how long do you store it?
When you do business with us, we will collect certain data about you. Often this information, (such as your name, emailaddress and phone number), is provided by yourself in the course ofdoing business with us. We register what services orgoods are provided, and payment details. And, sometimes, we will ask for other information, such as smoking/vaping history.
If you are a freelancer, we will also store the contract that we have with you. We use this information to process and handleincoming invoices, to create a balance sheet and an overview of profits and losses, to file tax returns, to create internalfinancial reports, and to arrange for an audit by an accountant.
The basis for thehandling of invoices is the performance of our contract with you. The basis for creating a balance sheet andan overview of profits and losses, and to create internal reports on finances, is because we are legally obliged to do so andbecause we have an interest in administering our finances. The filing of tax claims and the performing of an audit by accountis done because we are legally obliged to do so. We retain invoices we receive and the contracts with suppliers, includingcontact details of suppliers, for a minimum of seven years.
What data do you store in your CRM system, for what purposes do you use this data, and for how long do you store it?
CSFL uses a company-wide system to keep track of its contacts. For most persons, we store the name, email address, andphone number. We sometimes also store additional information about someone, such as gender, mailing language, homeaddress, birthday, and other personal data. We also keep track of the mailings we send to this person. For our Alumni, wealso note when someone has completed a course. If, in the past, you have been a client of CSFL, were subscribed to ournewsletters, or have worked with CSFL, your records are probably in this system.
We use this data to address you personally and ensure thatpersons within the company who are communicating with youknow your relevant personal details. We also use this data to get a better overview of your process. Lastly, we use this tosend you newsletters, updates about our company and invitations to our events. If you are not yet a subscriber, you cansubscribe by sending an email to info@chooseasmokefreelife.com. You can always unsubscribe from receiving newslettersor change your preferences by sending an email to the same address. We use your data on thebasis of our interest inbuilding and maintaining our network of personal contacts. We delete your data if it has not changed in 36 months and youhave not received a mailing via our CRM-system during this period.
How do you secure my data?
CSFL takes office-wide security measures as part of its information security framework. Technical measures include the useof access controls and firewalls, virus scanners, traffic monitoring, penetration tests, and encryption of laptops, phones andUSB-sticks. Organizational measures include a clear screen policy, confidentiality provisions, screening of personnel, privacyand security training and awareness, and implementing controls in contracts with suppliers.
What happens when you receive an order to disclose p ersonal data?
While this is unlikely, we may be required to disclose personal data by a court order or to comply with other legal orregulatory requirements. We will do everything we reasonably can to notify the persons involved before we disclose thesedata unless we are legally restricted from doing so.
To whom can I address my questions and requests for inspection, correction and removal of my personal data, and what other rights do I have?
You are entitled at any time to request inspection, correction, removal,or restriction of the processing of your personal databy CSFL. In addition, in some cases you have the right to receive your data in a structured format (i.e., data portability).Please send your request, as well as other privacy-related questions you might have, to our Data Protection Officerat dpo@ChooseASmokefreeLife.com.