Updated: November, 2021
Protecting your privacy is important to FabLab Factory. This Privacy Statement explains how FabLab Factory processes Personal Data collected through websites, products, and services (“applications”), including those distributed by our resellers and other channel partners, and through in-person and digital events, webinars, surveys, marketing activities, and visits to our premises (along with applications, collectively our “offerings”). References to “FabLab Factory,” “we,” or “our” means FabLab Factory BV.
We may display supplemental privacy notices on occasion, such as when we believe additional transparency would help you make an informed choice about whether to provide Personal Data. For example, you may see a supplemental privacy notice explaining a particular data collection program, or you may see a supplemental privacy notice when registering for an event.
This Privacy Statement describes how we process Personal Data for our own purposes. We also process Personal Data on behalf of our customers subject to a written contract. We do not control the data processing or protection practices of our customers, which may differ from those set out in this Privacy Statement.
“Personal Data” is information that identifies, or can reasonably be linked directly or indirectly to, an identifiable person. Personal Data does not include information that is anonymous, de-identified, or aggregated, as those terms may be defined under applicable law. For purposes of this Privacy Statement, “Personal Data” and “personal information” have the same meaning and are used interchangeably.
What Information Does FabLab Factory Collect About You?
- Business partners (such as educational organizations, schools, fablabs).
Information you provide us:
We collect information directly from you, such as when you sign up for an account or use our offerings, register a product or service, sign up for our newsletter or for one of our events, interact with one of our events, surveys, activities or with social media, visit our premises, or otherwise contact us. The types of information we may collect from you include:
- Your contact details, such as your name, telephone number, physical and/or email addresses, and any other contact details you provide to us.
- Commercial information, such as details about your subscription plans, the offerings that you have purchased, used and/or expressed interest in, and events you have attended.
- Financial account information, such as payment information you provide when making a purchase of or through an offering (a third party processes these transfers on our behalf as described below).
- Education information, such as your educational background.
- Protected characteristics, such as your date of birth (where applicable).
- Visual, audio, and electronic information, such as your picture or signature; records of our interactions, such as correspondence, details of complaints and their resolutions, service records; your preferences, including your preferred tools, experience, language, and the frequency at which you wish to receive marketing communications.
- Your details regarding raffles, subscribe and win, lead generation campaigns, contests or sampling-activation. Any data shared by you when participating to a raffle, subscribe and win, lead generation campaign, contest or sampling-activation.
- Your ratings and reviews and feedback. The opinions, experiences, preferences and interests and event reviews that you publish on our websites or share with us online or through social media.
When you make purchases through our websites, we use payment processors and do not store credit card or other financial information (other than confirmation that payment in a certain amount has been made). We collect contact and account information from you that we pass through to the payment processor to facilitate the transaction.
Information we obtain or generate:
We automatically collect or generate certain personal information about you based on your interactions with us, such as when you use our offerings, and we may associate that information with your account. The information we collect includes:
- Identifiers, such as unique user identifiers, unique device identifiers, IP addresses, cookie identifiers, information about product licenses, and usernames.
- Internet or other electronic network activity information, such as the website domain visited; which activities and offerings are used, how, and for how long; posts, discussions, and other types of engagement with us, including on our blogs, discussion forums, or chat rooms; the use of any hyperlinks or downloadable content available through the offerings.
- Geolocation information
- Electronic information, such as information about operating systems, device types, information about browsers, information relating to automatic updates and technical errors, information about your use of our offerings, including your preferred tools and experiences, and your engagement with our activities.
- Commercial information, such as records about interest in our offerings or completed purchases.
- Identifying characteristics such as facial templates and eye movement.
- Inferences drawn from any of the personal and offering usage information available to us.
Cookie choices are generally application-, browser-, and device-specific, so you may need to refresh your choices if you visit a different application, use a new browser or device, or clear your browser’s cookies.
Social Networking Data: We may include content, pixels, tags, buttons, or other tools that link to another company’s services and/or platform(s) (“Plugins”). If you use one of our offerings that contains Plugins, information can be transferred directly from your device to a third-party provider of services and/or platforms. We may not control the data collected by Plugins. If you are logged in to a social network, the social network may be able to link your use of our offering to their services and/or platform.
For example, if you interact with a Plugin by clicking on “Like,” “Follow,” or “Share,” or by writing a comment, this information may automatically appear in your profile on the relevant social network service or platform. Even if you are not logged in, the Plugins may send your IP address to social network services and/or platforms. Please note this when using our offerings.
When you connect to a social networking service or platform on a device that is also used by others, these other users may be able to see information that is stored or displayed in connection with your profile on the social networking service page.
Information we collect from other parties:
We receive and process information from our affiliates and from third-party sources, including
- Employers, business partners, suppliers (e.g., IT service providers), subcontractors, business contact databases, enrichment services, channel partners (e.g., resellers),
- Advertising and media companies that carry out marketing and media activities on our behalf, such as marketing service providers, third-party data aggregators, and social networking services and platforms (e.g., LinkedIn and Facebook).
- Analytics and search engine providers that assist us in the improvement and optimization of our website and apps, such as Google Analytics.
We also receive information from publicly available sources and licensors. The categories of personal information we collect from these sources include:
- Identifiers, such as names, phone numbers, and email addresses.
- Professional information, such as occupations, industries, professional licenses, work experience and employment histories, and other qualifications.
- Education information, such as your educational background.
- Commercial information, such as events you have attended or activities you have participated in.
- Inferences, such as regarding usage information and your preferences, behaviors, and other attributes.
In accordance with applicable law, we may combine your Personal Data with information we collect from other parties to help keep our databases current and accurate, and to provide you with more relevant content, experiences, applications, and other offerings.
How Does FabLab Factory Use The Information It Collects About You?
We use your Personal Data mindfully, and in useful ways, including:
- To validate your identity as necessary to perform our contract with you.
- To deliver services, products, and other offerings, including information such as personalized insights and recommendations, as necessary to perform our contract with you.
- To send you important information, such as about your account or purchases, within the scope of our contract with you.
- To send you information you requested to the extent necessary to perform our contract with you or, when not necessary to perform a contract, in furtherance of our legitimate interest, for example in responding to customer inquiries.
- To maintain and improve the security of, and to troubleshoot any issues relating to, our offerings as necessary to perform our contract with you or, when not necessary to perform a contract, in furtherance of our legitimate interest in protecting our business.
- To anonymize, aggregate, or de-identify your Personal Data so it can no longer identify you in furtherance of our legitimate interest in conducting research and analysis.
- To develop and improve our current and future offerings and your experience, including through the use of automated systems that analyze data using machine learning and other analytic techniques, in furtherance of our legitimate interests or, where needed, with consent.
- To understand the ways our offerings are used and who is using them in furtherance of our legitimate interest in improving our offerings and the overall user experience or, where needed, with consent.
- To analyze information about how you interact or may interact with us or our offerings in furtherance of our legitimate interest in improving our offerings and your experience with us or, where needed, with consent.
- To make strategic decisions concerning our business operations, including reporting on the performance of our business, in furtherance of our legitimate interest in making those decisions or, where needed, with consent.
- To send you learning content, tutorials, suggestions, newsletters, surveys, or other information, including information that may be relevant to your interests or preferences, in furtherance of our legitimate interest in improving your customer experience or, where needed, with consent.
- To send you promotional offers, advertising, or other marketing content in furtherance of our legitimate interest to engage in direct marketing or, where needed, with consent.
- To detect, prevent, or otherwise address non-valid use such as through fraud and software piracy (e.g., to confirm that software is genuine and properly licensed) and to protect you, FabLab Factory, and/or third parties in furtherance of our legitimate interests.
- To enforce, and review compliance with, the legal terms that govern our offerings in furtherance of our legitimate interest in ensuring adherence to the relevant terms.
- To comply with our legal obligations under applicable laws.
- To protect the rights, safety, and property of FabLab Factory, you, or any third party in furtherance of our legitimate interest in protecting us, our users, and third parties.
- For other purposes for which we obtain your consent.
Where we rely on your consent to process Personal Data, you may withdraw your consent at any time by contacting us at the contact details below or as otherwise indicated to you in writing.
Where we rely on our legitimate interests to process your personal information, we balance your rights against ours so that our interest is not overridden by the interests you have to protect your information.
When we process Personal Data about you to comply with legal requirements or to perform our obligations under a contract with you or with our customer through whom you use our offerings, failure to provide such data may prevent or delay our fulfillment of these obligations.
How Does FabLab Factory Disclose Your Personal Data?
We disclose the categories of information described above to the following categories of persons:
- Our service providers, including vendors, consultants, and other service providers who perform services or functions on our behalf, for business purposes. For example, our service providers include companies who support us with marketing, sales, consulting, communications, software maintenance and support, analytics, social media, market research, auditing for valid use, license compliance, security, user verification, localization, and payment processing. Our service providers process your information subject to contractual terms that restrict their ability to use your information.
- Our business partners, such as integration partners, channel partners (e.g., resellers), event sponsors, partners, and attendees, Ad Partners, and FabLab Factory’s App Store publishers, with whom you interact to facilitate your relationship with FabLab Factory and those business partners for any of the purposes described in our or those business partners’ privacy statements.
- Our affiliates, for any of the purposes and uses of information described in this Privacy Statement, including providing you with integrated offerings (including administering purchases, services, and payments across our integrated offerings) in furtherance of our legitimate interests.
- Social networking services and platforms to connect with or share information publicly, with service providers, or with your contacts on such services or platforms.
- Persons to whom we are required by law to provide information, such as pursuant to a subpoena or a court order.
- Law enforcement, legal counsel, or other reasonably necessary parties when we have a good faith belief that the disclosure is necessary to prevent or respond to fraud or software piracy, defend ourselves against attacks, or protect the rights, property, and safety of FabLab Factory, our customers, and the public.
- Persons involved in the consideration, negotiation, completion of a business transaction, including the sale, merger, consolidation, acquisition, change in control, transfer of substantial assets, bankruptcy, or reorganization, and any subsequent integration.
In addition, Personal Data may be disclosed as part of any merger, sale or transfer of FabLab Factory’s assets. We may also disclose your Personal Data if we believe we are required to do so by law. We may also disclose your personal information to other parties when we have your consent to do so or when you direct us to, for any purposes requested or permitted by you.
We may share aggregate, anonymous, or de-identified demographic, statistical, and other information regarding use of our offerings with third parties for marketing, analytics, planning, and other purposes. Such information will not specifically identify any particular user.
How Does FabLab Factory Protect Your Data?
We will take reasonable steps to ensure that your Personal Data are properly secured using appropriate technical, physical, and organizational measures, so that they are protected against unauthorised or unlawful use, alteration, unauthorised access or disclosure, accidental or wrongful destruction, and loss.
We take reasonable steps to limit the access employees, contractors, and agents of FabLab Factory have to your Personal Data to those who need to know this data to perform their assigned functions for one of the purposes listed in this Privacy Statement. Furthermore, we contractually ensure that any Third Party supplier processing your Personal Data equally provides for confidentiality and integrity of your data in a secure way.
What Rights And Choices Do You Have?
Subject to the conditions set forth in the applicable law, you have the the following rights with regard to our processing of your Personal Data:
Right of access – You have the right to request confirmation if FabLab Factory processes personal data about you, and if such is the case, access to the personal data and additional information. Upon request, we can also provide you with a copy of the personal data undergoing processing;
Right to rectification – You have the right to request that FabLab Factory corrects, adjusts or completes your Personal Data if we have inaccurate or incomplete data relating to you. We also kindly request you to ensure that changes in personal circumstances (for example, change of address, etc.) are notified to FabLab Factory so that we can ensure that your Personal Data is up-to-date. FabLab Factory will take all reasonable steps to ensure that all Personal Data are correct;
Right to withdraw consent – You have the right to revoke your consent for receiving marketing communications at any time, by following the instructions in any marketing communication or by filling in the form as set out below. If we use your Personal Data based on your consent for other reasons than marketing communication, you can revoke your consent by filling the form as set out below;
Right to delete – You have the right to request deletion of any irrelevant Personal Data we hold about you when (i) the data is no longer necessary in relation to the purposes for which they are collected; (ii) you withdraw your consent and there is no other legal ground for processing; (iii) you object to the processing in case of direct marketing purposes, or – in any other case – there is no overriding legitimate ground for processing; (iv) we unlawfully processed your data. If you have such a request and all requirements are met, we shall make sure that FabLab Factory erases the data of which we are not under a legal obligation to retain;
Right to restriction of data use – You have the right to restrict our use of your Personal Data where (i) you contest the accuracy of the Personal Data; (ii) the use is unlawful but you do not want us to erase the data; (iii) we no longer need the Personal Data for the relevant purposes, but you require them for the establishment, exercise or defence of legal claims; or (iv) you have objected to data use justified on our legitimate interests pending verification as to whether FabLab Factory has indeed compelling interests to continue the relevant data use;
Right to data portability – to the extent that we use your Personal Data for the performance of an agreement with you, and that personal data is processed by automatic means, you have the right to receive all such Personal Data which you have provided to FabLab Factory in a structured, commonly used and machine-readable format, and also to require us to transmit it to another data controller where this is technically feasible;
Right to object – to the extent that we are relying on our legitimate interests to use your Personal Data, you have the right to object to such use, and we must stop such processing unless we can either demonstrate compelling legitimate grounds for the use that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims. You also have the right to object to profiling activities conducted by FabLab Factory;
Right to lodge a complaint – You also have the right to lodge a complaint with a supervisory authority, in particular in your Member State of residence, if you consider that the collection and use of your Personal Data infringes this Privacy Statement or applicable law.
Please log-in to your account to manage your Personal Data and content using our applications. You can also delete your Personal Data and close your account. We may retain certain data about you for legal and internal business purposes, such as fraud prevention, in accordance with applicable laws.
To exercise any of your rights, please make a request via email@example.com.
Upon receipt of your email, we shall respond to your request consistent with applicable law. Consistent with applicable law, we may ask for proof of your identity before fulfilling your request, and we may ask for additional forms of verification depending on the nature of the personal information requested.
Certain jurisdictions grant individuals additional rights with respect to their Personal Data. Depending on where you live or applicable law, you may also have the right to:
- Object to our processing of your Personal Data
- Have us block or anonymize your Personal Data, as appropriate
- Receive a copy of your Personal Data to transfer it to a third party
- Opt-out of certain direct marketing communications
- Opt-out of certain disclosures of your personal information to third parties
- Not be denied a good or service for exercising your rights, though you may be provided a different level of service or charged a different rate or price consistent with applicable law
- Lodge a complaint with the relevant data protection authority in the jurisdiction in which you are located
These rights may be limited in some circumstances by local law. For example, even if you ask us to delete your personal information, we may need to retain it to complete transactions you have requested, to comply with our legal obligations, or for other limited business purposes as required or permitted by law. To exercise applicable rights, please contact us.
Where we process Personal Data on behalf of our customers, we may refer the request to the relevant customer and cooperate with their handling of the request, subject to any special contractual arrangement with that customer.
What Are FabLab Factory’s Data Retention Practices?
We will retain your Personal Data for as long as necessary to provide you with the offerings that you are using or have requested, for the establishment, exercise or defense of legal claims, and as needed to comply with our legal obligations. Data may persist in copies made for backup and business continuity purposes for additional time.
Does FabLab Factory Transfer Your Personal Data Across National Borders?
In most cases your Personal Data will be processed within the EU. However, please be informed that FabLab Factory may transfer and process any Personal Data you provide to us to countries other than your country of residence. The laws of these countries may not provide the same level of protection to your Personal Data. FabLab Factory or Third Party suppliers we use will therefore seek to ensure that all adequate safeguards are in place and that all applicable laws and regulations are complied with in connection with such transfer. This means that we entered into legally necessary contracts with recipients of your data, including standard contractual clauses as approved by supervisory authorities where required. If you wish to obtain a copy of the safeguards that we use to protect Personal Data transferred across borders, please contact us using the information in the “How to contact us” section below.
What Are FabLab Factory’s Marketing And Advertising Practices?
You can opt out of the use of your information by Ad Partners for online behavioral advertising by using the Digital Advertising Alliance’s Your AdChoices tool. The Your AdChoices tool may not work if your browser does not accept third-party Cookies, and if you delete Cookies, use a different browser, or use a different computer, you will need to use the tool again to renew your opt out.
As described above, you can change your Cookie preferences. Cookie choices are generally application-, browser-, and device-specific, so you may need to refresh your choices if you visit a different application, use a new browser or device, or clear your browser’s cookies.
FabLab Factory currently does not respond to “do not track” signals.
How Does FabLab Factory Protect Children And Student Data?
At FabLab Factory, we care deeply about children’s privacy and protecting their data.
Most of our applications are made for the general public and are designed for adult users. We refer to these applications as “general interest applications.” We do not knowingly collect Personal Data from children in connection with general interest applications. Certain applications are appropriate for and are intended for use by children. We refer to these applications as “Children’s applications.”
Our Children’s Privacy Statement applies to Personal Data collected from certain child and student users of FabLab Factory offerings, including Children’s applications. If there is a conflict between our Children’s Privacy Statement and our Privacy Statement, the Children’s Privacy Statement sets the standard for how we process children’s Personal Data. For more information, please refer to our Children’s Privacy Statement.
Is The Personal Data You Give Us Ever Displayed Publicly?
As always, we urge you to be mindful when deciding to disclose Personal Data, including on our offerings. Our offerings may allow you to post content, including comments and “likes,” that can be visible to the public.
In some cases, you can limit who can view or access the information and content you post. In other cases, the information and content might be available to registered members of the offering, or even to the general public. Your name, username, profile image, or email address (particularly if this is your username) may be posted along with any message or other content you post through some of our offerings.
If you are posting information you do not want to be disclosed publicly, make sure you are using an offering that allows you to control who sees information you have posted.
Will This Privacy Statement Change?
We may change this Privacy Statement to reflect changes in the law, our data handling practices, or the features of our business. We will show the date the Privacy Statement was last updated to help you know when we change it. If we make material changes to our Privacy Statement, we will endeavor to provide you with notice before such changes take effect, such as through prominent notice on our website or services or by email.
How To Contact Us?
If you want to contact us, please use the following contact information. When you do so, please tell us the name of the offering about which you are contacting us:
By email at: firstname.lastname@example.org
Data protection officer: To contact our data protection officer, please use the following contact information: email@example.com.