This data processing agreement applies between the user of Vintoo as data controller and Greenwolf Holding B.V. as processor. It applies when the user uploads, imports, adds, analyses or otherwise has third-party personal data processed via Vintoo, for example via an Excel or CSV file, search or manual entry.

This agreement forms part of the terms and conditions of Vintoo. In case of conflict between this data processing agreement and the terms and conditions, this agreement prevails insofar as it concerns processing of personal data on behalf of the user.

The user determines which personal data is uploaded, for what purpose it is used and what actions are performed with the data. The user is the data controller for that purpose. Greenwolf Holding B.V. processes this personal data only for the benefit of the user and in accordance with this agreement, unless a legal obligation requires otherwise.

Processing consists of receiving, storing, analysing, enriching, structuring, displaying, exporting and deleting personal data entered, uploaded, added or otherwise processed by the user in Vintoo.

The purpose of processing is to provide the service: qualifying leads, analysing companies and contact persons, showing match scores and signals, generating example messages, enriching lead information and making exports available to the user.

Processing may relate to personal data such as name, business email addresses, business phone numbers, job title, employer, company name, website, LinkedIn profile, location, notes, tags, lead status, interaction data and other data the user uploads or enters. The user is responsible for not uploading data that is not necessary for use of Vintoo.

Processing may relate to customers, prospects, leads, business contact persons, company employees and other persons whose data the user uploads or enters in Vintoo.

The user must not upload or process special categories of personal data via Vintoo, such as data concerning health, religion, political opinions, race or ethnic origin, criminal data, biometric data or trade union membership. If the user uploads such data anyway, this is entirely at the user's own expense and risk.

Greenwolf Holding B.V. processes personal data only in accordance with the user's instructions, as set out in this agreement, the terms and conditions, the privacy policy and the user's settings or actions within Vintoo. If Greenwolf Holding B.V. believes an instruction conflicts with the GDPR or other privacy law, Greenwolf Holding B.V. will inform the user.

Greenwolf Holding B.V. ensures that persons with access to personal data are bound by confidentiality or have an appropriate statutory duty of confidentiality.

Greenwolf Holding B.V. takes appropriate technical and organisational measures to protect personal data against loss, misuse, unauthorised access, unlawful alteration and unlawful disclosure. These measures may include access restrictions, secure connections, logging, backups, rights management and limiting access to production data.

Greenwolf Holding B.V. may engage sub-processors to provide Vintoo, such as hosting providers, database providers, AI services, email providers, payment providers, logging services and support tools. Greenwolf Holding B.V. ensures that appropriate agreements on protection of personal data are made with sub-processors. The current list of sub-processors may be made available via the website, the application or on request.

Greenwolf Holding B.V. may add or replace sub-processors. For material changes, Greenwolf Holding B.V. will inform the user via the website, the application or by email. The user may object if a change demonstrably leads to increased privacy risk. If the parties cannot find a solution, the user may terminate use of the service.

If personal data is processed outside the European Economic Area, Greenwolf Holding B.V. provides appropriate safeguards as required under the GDPR, such as standard contractual clauses or other valid transfer mechanisms.

Greenwolf Holding B.V. provides reasonable assistance to the user in complying with GDPR obligations, including data subject requests, security measures, data breaches, data protection impact assessments and questions from supervisory authorities. Where this assistance goes beyond normal use of the service, reasonable costs may be charged.

If a data subject contacts Greenwolf Holding B.V. directly about personal data processed on behalf of the user, Greenwolf Holding B.V. will forward the request to the user where possible. The user is responsible for handling the request substantively, unless Greenwolf Holding B.V. acts as controller for its own processing.

Greenwolf Holding B.V. will inform the user without undue delay once Greenwolf Holding B.V. becomes aware of a data breach relating to personal data processed on behalf of the user. Greenwolf Holding B.V. provides available information the user reasonably needs to assess the breach and, if necessary, report it to the supervisory authority or data subjects.

Greenwolf Holding B.V. provides information reasonably necessary to demonstrate compliance with this agreement. An audit is only possible after prior written notice, at most once per year, during office hours, without disrupting service and by an independent expert bound by confidentiality. Audit costs are borne by the user unless the audit shows material non-compliance by Greenwolf Holding B.V.

Personal data uploaded or entered by the user is retained while the account is active or as long as needed to provide the service. The user may delete data via Vintoo or request deletion via info@vintoo.nl. After account termination, personal data is deleted or anonymised within 30 days, unless legal obligations, security, fraud prevention, backups or disputes require longer retention.

Personal data may temporarily remain in backups. Backups are not actively used for normal processing and are overwritten or deleted according to the regular backup policy.

After termination of the agreement, the user may export available data while the account remains accessible. Greenwolf Holding B.V. then deletes or anonymises personal data, unless legal obligations or legitimate security interests require longer retention.

The user warrants that personal data has been lawfully obtained and is lawfully processed in Vintoo. The user informs data subjects where required, ensures a valid legal basis, does not upload more data than necessary and does not use the data for spam, misleading practices, unlawful marketing or other prohibited purposes.

Liability of Greenwolf Holding B.V. under this agreement is limited as set out in the terms and conditions, unless mandatory law provides otherwise. The user indemnifies Greenwolf Holding B.V. against claims arising from unlawful upload, import, instruction or use of personal data by the user.

This agreement applies for as long as Greenwolf Holding B.V. processes personal data on behalf of the user via Vintoo.

Questions about this data processing agreement can be sent to info@vintoo.nl.