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Privacy Policy
1.1 Policy statement
This privacy policy describes some of the ways Blue Century gathers, uses, discloses, and manages a customer or client's data. It fulfills legal requirements (such as GDPR) to protect a customer or client's privacy. Personal information can be anything that can be used to identify an individual, not limited to the person's name, address, date of birth, marital status, contact information, ID issue, and expiry date, financial records, credit information, medical history, where one travels, and intentions to acquire goods and services.
2 The Privacy Policy
Blue Century ("us", "we", or "our") operates the https://prod.vemasys.com website (hereinafter referred to as the "Service"). This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data. We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from https://prod.vemasys.com
3 Definitions

  • Service

    • Service is the https://prod.vemasys.com website operated by Blue Century

  • Personal Data

    • Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

  • Usage Data

    • Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

  • Cookies

    • Cookies are small files stored on your device (computer or mobile device).

  • Data Controller

    • Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
    • For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

  • Data Processors (or Service Providers)

    • Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
    • We may use the services of various Service Providers in order to process your data more effectively.

  • Data Subject (or User)

    • Data Subject is any living individual who is using our Service and is the subject of Personal Data.
4 Information Collection and Us
We collect several different types of information for various purposes to provide and improve our Service to you.
4.1 Types of Data Collected
4.1.1 Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:
  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Cookies and Usage Data
4.1.2 Usage Data
We may also collect information on how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data
4.1.3 Location Data
We may use and store information about your location if you give us permission to do so ("Location Data"). We use this data to provide features of our Service, to improve and customise our Service. You can enable or disable location services when you use our Service at any time by way of your device settings.
4.1.4 Tracking Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service. Examples of Cookies we use:
  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.
4.2 Use of Data
Blue Century uses the collected data for various purposes:
  • To provide and maintain our Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues
4.3 Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)
If you are from the European Economic Area (EEA), Blue Century legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.Blue Century may process your Personal Data because:
  • We need to perform a contract with you
  • You have given us permission to do so
  • The processing is in our legitimate interests and it is not overridden by your rights
  • For payment processing purposes
  • To comply with the law
4.4 Retention of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside Belgium and choose to provide information to us, please note that we transfer the data, including Personal Data, to Belgium and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Blue Century will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.
4.6 Disclosure of Data
4.6.1 Business Transaction
If Blue Century is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.
4.6.2 Disclosure for Law Enforcement
Under certain circumstances, Blue Century may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
4.6.3 Legal Requirements
Blue Century may disclose your Personal Data in the good faith belief that such action is necessary to:
  • To comply with a legal obligation
  • To protect and defend the rights or property of Blue Century
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability
4.7 Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
4.8 Our Policy on "Do Not Track" Signals under the California Online Protection Act (CalOPPA)
We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
4.9 Your Data Protection Rights under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Blue Century aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
  • The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where Blue Century relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
4.10 Service Providers
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
4.11 Payments
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).
We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information. The payment processors we work with are:
Apple Store In-App Payments
Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/
4.12 Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
4.13 Children's Privacy
Our Service does not address anyone under the age of 18 ("Children"). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
4.14 Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
4.15 Contact Us
If you have any questions about this Privacy Policy, please contact us:
  • By email: gdpr@bluecentury.eu
4.16 Privacy Incident Management
If you have any questions about this Privacy Policy, please contact us:
  1. Privacy incidents need to be reported by co-workers or a monitoring system. All reported Privacy incidents need to be properly documented following predefined incident handling procedures. Even in situations where the incident can be resolved immediately, the Privacy incident should be formally reported;
  2. Initial handling of reported Privacy incidents shall be done by the Service Desk. The service desk agent is responsible for identifying a Privacy incident and assigning the incident to the correct resolver group;
  3. The handling of security incidents should mainly follow the same steps as defined in the regular incident management procedure of Blue Century. If after the incident is contained, the root cause is not yet known, it should be further analysed through the problem management process of Blue Century;
  4. The security team resolving the incident is be responsible for:
    1. Determining whether the reported event is actually a Privacy incident;
    2. Determining whether or not personal data is affected;
    3. Performing an impact analysis and classifying the incident in terms of priority;
    4. When necessary, ensuring that an incident handling team is established including the chief protection officer in case of a (possible) personal data breach within Blue Century internally or the data protection officer contact of the client in case of a (possible) personal data breach with the customer;
  5. In depth analysis of Privacy incidents shall be handled by an incident handling team which is formed after an incident identification. The size and composition of the incident handling team will depend on the type of incident and its impact. External Privacy Experts can be added to the team when needed;
  6. All Privacy Incidents will be reported to the Security Office. Corrective measures will be implemented using the problem management process:
    1. Defining corrective measures in collaboration with the data owners;
    2. The incident or problem ticket has the corrective actions documented;
    3. Follow up on the execution of the corrective measures;
  7. The incident handling team shall be responsible for:
    1. Assess the incident using the available information and gathering additional relevant information;
    2. Perform a detailed impact analysis. If necessary, the event could be reclassified;
    3. Documenting the incident in an incident report which is attached to the ticket when closing;
  8. The analysis of Privacy incidents will follow the generic Blue Century incident management process. Specifically, for Privacy incidents we can distinguish following phase:
    1. Preparation: This phase deals with preparing for incidents by e.g. establishing policy and formal response strategies & plans;
    2. Identification: This phase deals with the detection of events and determination of whether these events can be considered a Privacy incident;
    3. Containment: The primary purpose of this phase is to limit the impact of the incident and prevent any further damage from happening;
    4. Eradication: This phase deals with the actual removal and/or restoration of affected systems;
    5. Recovery: The purpose of this phase is to bring affected systems back into the production environment carefully, in order to insure this will not lead to another incident;
    6. Lessons Learned: The purpose of this phase is to complete any documentation that was not done during the incident, as well as any additional documentation that may be beneficial in future incidents. The overall goal of this phase is to learn from the incident that occurred and improve the incident handling team’s performance and provide reference materials in the event of a similar incident;
  9. Every Privacy incident will result in the creation of an incident report, this report contains at least:
    1. Priority classification of the Privacy incident;
    2. Observations of the Privacy incident;
    3. Root-cause analysis of the incident;
    4. Incident Impact on confidentiality, integrity and availability;
    5. Overview of the corrective measures taken to resolve the Privacy incident. In case of workaround on the measures to limit the impact;
    6. Optionally proposed preventive measures (lessons learned);
  10. Blue Century co-workers who report a Privacy incident will receive updated on the analysis of the incident and mitigating actions taken on a timely manner;
  11. The information of the Privacy incident is always be classified as confidential;