Version 2.0
8 November 2024
This privacy statement (“Privacy Statement”) sets out the functioning of the Tripolis-Park APP (“APP”) provided by Wolf ITdev B.V. for the Tripolis-Park (“Building”) with the objective to answer any privacy related questions and - as far as any personal data may be processed - to inform the person that downloads the APP (“user” or “you”) about all privacy related rights.
If you have any questions, please feel free to contact us.
1.1 Wolf ITdev B.V. (“Wolf ITdev”, “we”, “us” or “our”) provides IT solutions for smart buildings. We attach great importance to the protection of the privacy and personal data of the users of our solutions including the APP. The APP has therefore been created with the objective to avoid the processing of personal data of the users. This Privacy Statement explains to you how the APP functions, how the use of personal data is avoided, to what extent processing of personal data might take place and your rights in relation to such processing.
2.1 The scope of this Privacy Statement is limited to processing activities to which the General Data Protection Regulation (“GDPR”) and its national implementation acts apply.
3.1 We will only process personal data in accordance with the applicable privacy legislation and as described in this Privacy Statement.
4.1 It may be the case that providing certain personal data such as technical data identifying your telephone to the app platform is required when downloading the APP. We do not receive any details of such information from the relevant Appstore.
4.2 The APP requires the active use of Bluetooth technology on your device. When used in the Building, the device on which the APP is installed will make contact with Bluetooth Beacons which are installed in the Building. These Bluetooth Beacons are sensors registering that a (random) device on which the APP is installed is present in the Building on a certain location within the Building. A device present in a certain building space can subsequently be used to control functions like lights and temperature in the relevant space. Basically, this means that you can use your telephone as a remote control to personalize settings for light and temperature within the room.
4.3 No device data (MAC-adress / IP-address or other data) are exchanged with these sensors or subsequently with the building infrastructure to use the controls.
4.4 No activities of a specific device are logged on a system.
4.5 The APP enables you to obtain information about the occupation of accessible spaces within the Building. The level of occupation is not measured by ‘counting’ devices using the APP but through temperature measurement.
4.6 The system only notices the live presence of an anonymous device in a certain space within the building but cannot follow the movements of a specific anonymous device through the Building.
5.1 Based on the description of the functioning of the APP we believe that as far as any data is processed by us, such data should be considered anonymous.
5.2 We do not have any interest in and take no steps to identify any APP users. If and insofar the processing of any data in relation to the use of the APP by us would be regarded the processing of personal data because of any additional information that we would receive or have access to, such processing would be based on our legitimate interests in providing the APP. We believe that the risk that this will happen is small and given the fact that no data is stored about the presence of specific devices, the impact can only be very limited as a result of which our legitimate interests would outweigh your right to privacy in those specific cases.
5.3 In case a situation would occur in which personal data may be processed more extensively in relation to the use of the APP we will provide you with information about the(se) other purpose(s) and all relevant further information prior to that further processing.
6.1 At present no personal data in relation to the use of the APP is shared with third parties.
7.1 We take appropriate organizational and technical security measures to prevent misuse of the APP and to avoid any breach of security.
8.1 In principle, we do not store any personal data in relation to the use of the APP.
9.1 In relation to our processing of your personal data, you have the below privacy rights. For more information on your privacy rights, please be referred to this webpage of the European Commission.
9.2 The exercise of the abovementioned rights is free of charge and can be carried out by phone or by e-mail via the contact details displayed below. If requests are manifestly unfounded or excessive, in particular because of the repetitive character, we will either charge you a reasonable fee or refuse to comply with the request.
9.3 We may request specific information from you to help us confirm your identity before we comply with a request from you concerning one of your rights.
9.4 We will provide you with information about the follow-up to the request without undue delay and in principle within one month of receipt of the request. Depending on the complexity of the request and on the number of requests, this period can be extended by another two months. We will notify you of such an extension within one month of receipt of the request. The Applicable privacy legislation may allow or require us to refuse your request. If we cannot comply with your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
10.1 For any questions, comments or requests on how we handle your personal data, you may contact us via [email protected].
11.1 Wolf ITdev is entitled at all times to delete your personal data without notice. In such a case, we owe no compensation to you as a result of the termination of the account.
11.2 If provisions from this Privacy Statement are in conflict with the law, they will be replaced by provisions of the same purport that reflects the original intention of the provision, all this to the extent legally permissible. In that case, the remaining provisions remain applicable unchanged.
11.3 Wolf ITdev reserves the right to change this Privacy Statement on a regular basis. Where required, we will inform you of updates made to this Privacy Statement. The current version is always available on our website www.tripolis-park.nl. This Privacy Statement was last amended and revised on 8 November 2024.
12.1 In this Privacy Statement, the following definitions apply:
12.2 Other terms that are defined in the Applicable privacy legislation, such as personal data, (joint) controller, processor, data subject and processing will have the meaning as described in the applicable privacy legislation.