Lastly updated: November 2021
Controller:
Dealroom.co B.V. (“Dealroom”) having its registered office at Cornelis Dirkszstraat 27-2, 1056 TP Amsterdam, the Netherlands and registered with the Chamber of Commerce under number 59237368. Thanks for visiting https://ddrmvp.wpengine.com. This statement is compliant with the General Data Protection Regulation (GDPR).
Your privacy is of utmost importance to us. To help you understand how we assessed our legitimate interest as a legal basis for some of our data processing, we have created this statement. If you have any questions or concerns after reading this statement, please do not hesitate to contact us at privacy@wp.dealroom.dev.
Legitimate interest as a legal ground for data processing
We may only process your data subject to one of the limited legal grounds specified in the GDPR. In our Privacy Statement we specified which legal ground we have for the various types of data and data processing which are part of our services. For the legal basis of legitimate interest an assessment was made on behalf of Dealroom of the interests of Dealroom on one hand and your interests, fundamental rights and freedoms as the data subject on the other. This balancing test assesses whether your interests should override ours. We have had professionals look into our data processing activities and requested their legal opinion on whether we could rightfully base parts of our processing (as specified categories in the Privacy Statement) on the legal ground of legitimate interest. To this extent, they carefully assessed every data point processed and concluded that the impact on your interests, rights and freedoms is mainly low as the information provided is publicly known. In accordance with the opinion of the Article 29 Data Protection Working Party (now: European Data Protection Board), the following five elements have been taken into account for each legitimate interest assessment:
- Importance to Dealroom – which interest does Dealroom.co have in collecting or aggregating a data category?
- Categories of personal data processed – which categories of personal data are necessary to achieve Dealroom’s interest?
- Foreseeability for the data subject – can the data subject reasonable expect that their data will be used for Dealroom’s interest?
- Implemented safeguards – how does Dealroom.co handle the data? Implemented safeguards may, for example, include implemented retention periods, providing an easily accessible manner to object, applying data minimization, and clearly informing about data collection and use. Please note that these safeguards follow from the general requirements of the GDPR and should always be taken into account.
- Likely impact on the data subject – to what extent does Dealroom’s collection and use of the data impact the privacy of the data subject?
The conclusion of this assessment is that in their opinion Dealroom may use ‘legitimate interest’ for all the processing of data in the specified categories in the Privacy Statement. For inferred data which is used for profiling, Dealroom is convinced that it may claim a legitimate interest for data processing as well. The data used is limited and the impact on the individual is medium. Although we have been informed that the Article 29 Data Protection Working Party writes in its guidelines that profiling may under circumstances not be based on a legitimate interest if it concerns data brokerage, we feel that this exception does not apply. We collect and share information (as part of profiles) for others to base business decisions on. As we do not influence or categorize the data shared, but only regroup and organize already publicly available information, the exception for data brokerage made in the GDPR is not applicable to us. As such we are convinced that we may ground certain processing of your data on the grounds of legitimate interest.
This assessment is however subjective.
If you feel that your interests should be weighed out otherwise or have not been treated correctly in the abovementioned assessment, you may at any time address your concerns or objection. You will find a special button on the website to this extent. We will promptly register your objection and cease using any data which is based on the legitimate interest ground which your objection concerns. This may influence your use of our services.
Contact
If you have any questions regarding this statement, please do not hesitate to contact us at: privacy@wp.dealroom.dev.