Privacy Policy

ToolsGroup B.V., having its place of business at Teleportboulevard 110, 1043 EJ, Amsterdam, the Netherlands, and its affiliates or subsidiaries listed below (”ToolsGroup”, “our”, “we” or “us”) attaches a great deal of value to your privacy. This privacy policy is meant to help you understand our privacy practices, including what personal data we collect, why we collect it, what we do with it, and how we protect it, as well as your individual rights. This privacy policy applies to our website, applications, social media pages, and other platforms that link to this privacy policy (the “Services”).

ToolsGroup Includes:

ToolsGroup B.V.
Teleportbouleveard 110
1043 EJ Amsterdam, The Netherlands
T +31 85 2100107
E  nl-info@toolsgroup.com

ToolsGroup Colombia S.A.S.
Autopista Norte # 97-50 Of. 1007
110221 – Bogotá, Colombia
T +57 315 328 3002

ToolsGroup Deutschland GmbH
Fünf Höfe, 8th Floor, Theatinerstr. 11
80333 – Munich, Germany
T +49 89 71042 2343
F +49 89 74042 2000
E  dach-info@toolsgroup.com

ToolsGroup Italy S.r.l.
Corso Monforte 54
20122 – Milano, Italy
T +39 02 87064250
F +39 02 48022811
E  it-info@toolsgroup.com

ToolsGroup Inc.
75 Federal St, Suite 920
02110 – Boston, MA, USA
T +1 617 263 0080
F +1 617 263 0450
E  us-info@toolsgroup.com

ITP Tecnologica SL
C/Tarragona, 149-157, 1ª Planta
08014 – Barcelona, Spain
T +34 93 4125768
F +34 93 4125864
E  es-info@toolsgroup.com

Please be aware that countries located outside Europe may not have the same level of data protection as European countries.

Personal Data That We Process

Personal data means all information about an identified or identifiable natural person who can be directly or indirectly identified. According to the law, grounds are needed for any processing of personal data. We collect the following personal data from you:

  • Contact Information – If you submit an inquiry, register for an account, or provide information through the Services, we may collect your contact information. This may include your name, email address, company name, mailing address, demographic information, and phone number. And by submitting any form, ToolsGroup may send you emails about improving supply-chain planning and optimisation. You may unsubscribe at any time.
  • Location Data – While navigating the Services, your mobile device or browser may share your location data, both through WiFi and GPS. We will collect this information based on the settings of your phone and browser.
  • Usage Information – When you use the Services, our servers may automatically record information, including your Internet Protocol address (IP Address), browser type, referring URLs (e.g., the site you visited before coming to the Services), domain names associated with your internet service provider, information on your interaction with the Services, and other such information.
  • Employment Information – If you apply for employment, we will collect your employment and work history, as well as other personal data related to your potential employment. This may include your education and employment history, address and contact information, demographic information, and any other information included in your resume or application.
  • Communication Information – We may collect audio, electronic, or visual information; any data in any files uploaded, emailed or otherwise provided by customers; the contents of your communications with us, whether via e-mail, social media, telephone or otherwise, and inferences we may make from other personal data we collect.



Our basic principle is that we never collect and process any more personal data about you than is strictly necessary.

How We Collect Your Personal Data

We May Collect Your Personal Data Directly From You – For example, if you register for an account through the Services, or request or purchase products, services, or information from us.

We May Also Collect Personal Data From Third Parties – For example, we may work with business partners, subcontractors, advertising networks, analytics providers, and search information providers, who may provide us with personal data about you.

Through Online Tracking Technologies – We and our service providers may use cookies, device identifiers, and similar technologies such as pixels, web beacons, and local storage to collect usage and browser information about how you use the Services.

Cookies are small files – usually consisting of letters and numbers – placed on your computer, tablet, phone, or similar device, when you use that device to visit a website.  A cookie can help us recognize your device the next time you visit the Services, provide you with access to certain functions on the Services, and/or register your usage of the Services. Cookies can be “persistent” or “session” cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser. Cookies can be divided into first-party cookies and third-party cookies. First-party cookies are set by us and third-party cookies are set by another party.

There are other technologies such as pixel tags, web bugs, web storage and other similar files and technologies that may carry the same functions as cookies. We will refer to cookies and similar technologies simply as “cookies”.

We process the information collected through cookies to personalize content and ads, to provide social media features, and to analyze the traffic on the Services. You can decide whether or not to accept cookies. You can accept or opt out of cookies via our Cookie Declaration or through your browser settings.

If you’d like to instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser, which are listed below. For any other web browser, please visit your web browser’s official web pages.


You can learn more about the specific cookies and tracking technologies we use in our Cookie Declaration.

Through Analytics – We use analytics services, including Google Analytics, to assist us with analyzing our website traffic through cookies and similar technologies.  For more information on Google Analytics’ processing of your Personal Information, please see https://policies.google.com/technologies/partner-sites?hl=en-US.  You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics through our Cookie Declaration.

 

Basis for Processing

Depending on where you reside, we may need a legal basis for processing the personal data we collect from you. Our legal basis for processing the personal data described in this privacy policy will depend on the personal data concerned and the context in which we process it.  We process personal data from you:

  • where we need it to perform a contract with you;
  • where the processing is in our legitimate interests (including the purposes described, above, in How We Use Personal Data);
  • where the processing is necessary for us to meet our applicable legal obligations; or
  • if we otherwise have your consent.

How We Use Personal Data

To the extent permitted by applicable law, we may use personal data to:

  • operate the Services and provide support to our business functions;
  • fulfill customer requests, such as to create an account or complete customer purchases;
  • protect against criminal activity, claims and other liabilities;
  • send you information about our company, products, services, and promotions;
  • respond to reviews, comments, or other feedback provided to us;
  • support and personalize the Services and our advertising efforts;
  • protect the security and integrity of the Services;
  • provide customer support;
  • the extent required for benchmarking, data analysis, audits, developing new products, enhancing the Services, facilitating product, software and applications development, improving the Services or our other offerings, conducting research, analysis, studies or surveys, identifying usage trends, as well as for other analytics purposes;
  • meet our contractual requirements;
  • comply with applicable legal or regulatory requirements and our policies;
  • respond to inquiries related to employment opportunities;
  • market, advertise, and provide the Services and our other offerings; and
  • the extent necessary for any other lawful purpose for which the personal data is collected.

Sharing Personal Data

We may share your personal data in the following circumstances:

  • For Legal Obligation or Safety Reasons – When we have a good faith belief that access, use, preservation or disclosure of personal data is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of the Terms of Use, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of ToolsGroup, its users, or the public against harm.
  • In the Case of a Merger or Sale – If and when we are involved in a merger, acquisition, or any form of transfer or sale of some or all of its business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding. Personal data may be transferred along with the business. Where legally required we will give you prior notice and if you have a legal right to do so, an opportunity to object to this transfer.
  • To Service Providers – When we hire a service provider to help operate the Services or our business, we may give access to personal data as necessary to perform the service for ToolsGroup.  This may include service providers that operate our Services, send our communications, or run our promotions.
  • To Business Partners – We may share personal data with our trusted business partners.  For example, we may share your personal data with a company when we co-sponsor a promotion or service.  These partners and affiliates may use your personal data to, among other things, send you information or contact you about their services and products.

Who Processes Your Personal Data

ToolsGroup B.V., mentioned above, is responsible for collecting and processing your personal data.

Issuing Your Personal Data to Third Parties

Your personal data is forwarded to third parties if this is necessary for the execution of the agreement you have concluded with us, if we have a statutory obligation to do so, or in instances whereby we use an external service provider during the execution of our work.

If we use third-party services, a data processing agreement will be concluded with these third parties insofar as required to guarantee that your data will also be treated confidentially by these third parties and exclusively within the framework of the purpose we have determined.

Transfer of Your Personal Data Outside of Europe

ToolsGroup operates at a global level and therefore may need to transfer personal data to other countries where we operate, including in North and South America, South Africa, United Kingdom and Australia.

When we export your personal data to a different country, we will take steps to ensure that such data exports comply with the GDPR. For example:

  • For transfers within the European Economic Area (EEA), we guarantee that the same levels of protection will apply
  • For transfers to other ToolsGroup entities and/or to other third parties outside of the EEA, these are carried out pursuant to European Commission approved clauses and/or with your explicit consent.

Links to Third-Party Websites

We are not responsible for the practices employed by any websites or services linked to or from the Services, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing personal data to third parties, since any personal data disclosed will be subject to the applicable third party’s privacy policy.

Security

We use our commercially reasonable efforts to protect the confidentiality and security of personal data we process. However, despite these efforts to store personal data in a secure operating environment, we cannot guarantee the security of personal data during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of personal data, we cannot guarantee that our security measures will prevent third parties such as hackers from illegally obtaining access to personal data.

Children’s Privacy

We do not knowingly collect or solicit any personal data from children under the age of 16.  In the event that we learn that we have collected personal data from a child, we will promptly take steps to delete that information. If you are a parent or legal guardian and think your child has given us their personal data, you can contact us using the information listed in this privacy policy.

Your Choices and Controls

Depending on where you live, you may have the right to exercise certain controls and choices regarding our collection, use, and sharing of your personal data. To opt-out of marketing communications please email us at privacy@toolsgroup.com or by following the instructions included in the email or text correspondence.

Please note that, even if you unsubscribe from certain correspondence, we may still need to contact you with important transactional or administrative information, as permitted by law.  Additionally, if you withdraw your consent or object to processing, or if you choose not to provide certain personal data, we may be unable to provide some or all of our services to you.

To exercise other rights with respect to your personal data, please contact us using the information found below.

California Residents

This Section applies to our collection and use of “Personal Information” if you are a resident of California, as required by the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”). This Section describes (1) the categories of Personal Information, collected and disclosed by us, subject to CCPA, (2) your privacy rights under CCPA, and (3) how to exercise your rights.

When we use the term “Personal Information” in the context of the CCPA, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household.

If you would like to receive a copy of this Section in an alternate format (e.g., printable) or language, please contact us using the information in this privacy policy.


Categories of Personal Information Collected, Used, and Shared

In accordance with California law, we may have collected and share the following categories of Personal Information within the past 12 months:

  • Identifiers – A real name, Internet Protocol address, email address, and online identifiers.
  • Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – e.g., a  name, address, telephone number, education, employment, employment history. Some Personal Information included in this category may overlap with other categories.
  • Internet or other similar network activity – Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
  • Geolocation data – Physical location or movements.
  • Protected classification characteristics under California or federal law – Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
  • Professional or employment-related information – Current or past job history or performance evaluations.

We share each of these categories of Personal Information with our service providers to the extent necessary for them to facilitate our business purposes.  We also share this Personal Information for the purposes set forth above in this privacy policy.


Your California privacy rights

If you are a resident of California, you may have the following rights:

Privacy Right Description
Notice The right to be notified of what categories of Personal Information will be collected at or before the point of collection and the purposes for which they will be used and shared.
Access The right to request the categories of Personal Information that we collected in the previous twelve (12) months, the categories of sources from which the Personal Information was collected, the specific pieces of Personal Information we have collected about you, and the business purposes for which such Personal Information is collected and shared. You may also have the right to request the categories of Personal Information which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your Personal Information.
Data Portability The right to receive the Personal Information you have previously provided to us.
Erasure The right to have your Personal Information deleted. However, please be aware that we may not fulfill your request for deletion if we (or our service provider(s)) are required or permitted to retain your Personal Information for one or more of the following categories of purposes: (1) to complete a transaction for which the Personal Information was collected, provide a good or service requested by you, or complete a contract between us and you; (2) to ensure our website integrity, security, and functionality; (3) to comply with applicable law or a legal obligation, or exercise rights under the law (including free speech rights); or (4) to otherwise use your Personal Information internally, in a lawful manner that is compatible with the context in which you provided it.
To Opt Out We do not knowingly sell your Personal Information. But if we did, you have the right to opt out of the sale of your Personal Information.



If you would like to exercise your rights listed above, please send (or have your authorized agent send) an email to privacy@toolsgroup.com. Please note: you will not be discriminated against in any way by virtue of your exercise of the rights listed below, which means we will not deny goods or services to you, provide a different prices or rates for goods or services to you, or provide a different level or quality of goods or services to you.

We must verify your identity before fulfilling your requests.  If we cannot initially verify your identity, we may request additional information to complete the verification process. Any Personal Information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification.  If you are an authorized agent making a request on behalf of a California consumer, we will also need to verify your identity, which may require proof of your written authorization or evidence of a power of attorney.

We may deny certain requests, or only fulfill some in part, as permitted or required by law.  For example, if you request to delete Personal Information, we may retain Personal Information that we need to retain for legal purposes (e.g., tax accounting).  You have a right not to receive discriminatory treatment by any business when you exercise your California privacy rights.

The CCPA gives California Consumers the right to lodge a complaint with the California Attorney General’s office. The Attorney General’s office may be contacted at https://oag.ca.gov/contact/consumer-complaint-against-business-or-company or by telephone at: (916) 210-6276.

Your Privacy Rights

You have the right to:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data.
  • Request restriction of processing of your personal data.
  • Request the transfer of your personal data to you or to a third party.
  • Withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of these rights or would like further information about your rights, you can send us an email at privacy@toolsgroup.com. We will inform you as soon as possible, but no later than one month, regarding which personal data we have processed and whether we will, or can, meet your request to delete, alter or transfer. Depending on the nature of your request, we may need to verify your identity.

If you have any complaints about our data processing, please contact us at the e-mail address or telephone mentioned below. We would also like to point out that you can submit a complaint to a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning your personal data.  We encourage you to first reach out to us, so we have an opportunity to address your concerns directly before you do so

For Which Period of Time ToolsGroup Keeps Your Personal Data

All personal data which you issue to us will not be saved for any longer than is necessary for the purpose for which it was collected. In any event we will keep the personal data you issued for the period necessary to carry out the assignment you issued and to process any claims. Certain data is subject to a statutory retention period. For example, we have an administrative and fiscal duty to retain some personal data for at least seven years. Therefore, we keep invoices and payment details for this time period.

If we no longer need your personal data for the purpose for which it has been collected, and at the end of the aforementioned retention periods, ToolsGroup will destroy and/or anonymize the personal data in question. However, it may also be the case that we will continue to keep the personal data for archiving purposes, in connection with legal proceedings, or for historical or scientific research, or for statistical purposes.

Amendments

This privacy policy may be amended from time to time if there is cause to do so. We may provide you with an updated privacy policy if material changes are made. Unless otherwise indicated, any changes to this privacy policy will apply immediately upon posting.

Contact

If you have any questions regarding our data processing, please submit them to:

ToolsGroup B.V.
Teleportbouleveard 110
1043 – EJ Amsterdam, The Netherlands
T +31 85 2100107
E  nl-info@toolsgroup.com