Privacy Policy

PRIVACY POLICY

The website www.the37company.com (hereafter: the "Website") is offered by:

The 37Company
Beeldschermweg 6F
3821 AH Amersfoort
The Netherlands
VAT no. NL 8111.49.948.B.03
info@the37company.com
+31 (0) 33 450 72 50

Feel free to contact us should you have any privacy-related questions. We promise to reply soon.

Click here for contact details

The 37Company’ is a registered trademark of The Surgical Company International B.V.

1. WHY THIS PRIVACY POLICY ?

The 37Company values the right to privacy and strives to protect the personal data we collect and use in due observance with the applicable data protection legislation, such as the EU General Data Protection Regulation of 27 April 2016 (hereinafter: “GDPR”) and/or any amendments thereto or replacements thereof, and/or any similar rules and regulation under any applicable law and related codes of practice governing the use, storage, processing and transfer of personal data.

In view of the above, The 37Company uses a variety of technical and organisational measures to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with applicable data protection laws. Furthermore, those persons who, for and/or on behalf of The 37Company, have access to your personal data, have a confidentiality obligation – including that prescribed by the applicable code of conduct and professional practice.

The 37Company commits to only collect and process personal data which are adequate, relevant and limited to what is necessary for the purposes for which such data are gathered and processed.

For the sake of clarity, personal data is information by which you can be identified as a private individual, regardless of whether The 37Company will actually do this. You are identifiable as soon as it is possible to create a direct or indirect link between one or more data and you as a natural person.

In this Privacy Policy we further elaborate on whose personal data we collect, what personal data we collect, how we collect personal data, for what purposes we use personal data and to whom personal data may be disclosed by us. Further, this Privacy Policy includes important information regarding your rights with respect to the processing of your personal data. Therefore, we encourage you to read this Privacy Policy very carefully.

From time to time, we may need to change our policy contained herein. The most recent version of our Privacy Policy is available on our Website. In case of important changes with regard to our Privacy Policy, we will actively inform you on such changes via our Website. We therefore advise you to regularly consult this section of the Website.

 

2. HOW DO WE COLLECT PERSONAL DATA ?

The 37Company may collect personal information from you in the course of our business dealings, including through your registration on and/or use of our Website, when you request information from us and/or when we (subsequently) enter into a business contract.

Every person who visits or uses our Website (hereinafter: the “User”) discloses a certain amount of personal data, or may be required to provide certain personal data and/or may provide this personal data on its own initiative. The amount of personal data collected becomes more extensive as the User makes more intensive use of the Website and the functionalities thereof. The 37Company sees to it that the data is gathered in an aggregate and anonymous form when such data are used for statistical purposes.

We also use cookies in order to recognise the User and to offer the User a personalised user experience, to remember technical choices, and to detect and correct any errors which might be present on the Website. If you do not want The 37Company to use cookies with your browser, the settings on your browser can be changed so that the cookies are deactivated. If you do not allow the use of cookies and have deactivated the cookies or arranged to have the cookies deactivated, this may have consequences for the ease of use of our Website.

For more information concerning the use of cookies, we kindly refer you to the Cookies Policy of The Surgical Company Group.

 

3. WHO IS RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA ?

The 37Company acting in its capacity of data-controller is solely responsible for the processing and decides alone or in cooperation with others which personal data are being collected as well as the purposes and the technical and organisational means with regard to the processing of such personal data.

The 37Company is in this respect free to rely on certain data processors. A data processor is the natural or legal person who processes your personal data upon request and on behalf of the data controller. The processor is required to ensure the security and confidentiality of the data. Any processor retained by us shall always act on the instructions of The 37Company.

When you visit the Website you explicitly agree to our right to retain the following categories of "processors":

  • Companies we have engaged for marketing purposes;
  • Companies we have engaged for hosting purposes;
  • Companies we have engaged for administrative purposes;
  • Companies we have engaged for communication purposes;
  • Companies we have engaged for statistical purposes.

 

4. ON WHAT LEGAL GROUNDS ARE MY DATA PROCESSED ?

In accordance with the GDPR we gather and process personal data on the bases of the following legitimate business interests:

  • To optimise the use of our Website and execute certain direct marketing activities associated therewith such as distribution of newsletters;
  • To conclude with you as the occasion arises business contracts regarding the provision of our services;
  • For the establishment, exercise or defence of legal claims or proceedings;
  • To comply with certain legal and regulatory requirements.

 

5. WHICH PERSONAL DATA ARE BEING PROCESSED ?

The following categories of personal data are gathered and processed by The 37Company:

  • Personal identification data (name, first name, company);
  • Contact details (phone number, zip code and e-mail address);
  • Electronic identification data (IP address, location, cookies).

This data is collected at the time of your registration on the Website and when we subsequently provide you use with our services. Other personal data may be collected at a later stage, for instance in the context of after-sales.

 

6. FOR WHICH PURPOSES ARE MY PERSONAL DATA BEING USED ?

The 37Company collects and processes personal information about you in a number of ways, including through your use of our Website and in the course of providing you with our services.

The processing of your personal data is essential for the proper functioning and safe usage of the Website and the adequate provision of our services. The 37Company commits to solely process your personal data for the following purposes:

•    To provide and improve our Website, including monitoring its use for statistical purposes;

  • To provide and improve our services;
  • To provide you with adequate information you may request;
  • Customer management: such as customer administration, order management, deliveries, invoicing, checking creditworthiness, support, complaint monitoring and sending newsletters;
  • To fulfil our legal, regulatory and risk management obligations, including establishing, exercising or defending legal claims.

When visiting the website of The 37Company, some data are being collected for statistical purposes. Such data is necessary to optimise your User experience. These data are: IP-address, probable location of consultation, hour and day of the consultation and the pages which are being consulted. When you visit the Website, you explicitly agree to this collection of data for statistical purposes.

The 37Company reserves the right to suspend or cancel certain operations if personal data is missing, incorrect or incomplete. Furthermore, if and when certain data is incomplete or apparently incorrect, the User has the right to postpone some expected actions temporarily or permanently.

 

7. WHO RECEIVES YOUR PERSONAL DATA ?

Your personal data are processed for internal use within The 37Company only. Your personal data will not be sold, passed on or communicated to any third parties with the exception of the data-processors mentioned under point 3, except in case you have given us your explicit prior consent.

 

8. HOW LONG DO WE STORE YOUR PERSONAL DATA ?

Your data is stored as long as necessary to achieve the ends pursued. They will be erased from our database as soon as they are no longer necessary for the ends pursued or if you exercise your right to erasure.

 

9. WHAT ARE MY RIGHTS ?

9.1 Guarantee of a legitimate and secure process of your personal data

Your personal data are always processed for the legitimate purposes explained in point 6. They are collected and processed in an appropriate, relevant and non-excessive manner, and are not kept longer than necessary to achieve the intended purposes.

9.2 Right to access

If you can prove your identity, you have the right to obtain information about the processing of your data. Thus, you have the right to know the purposes of the processing, the categories of data concerned, the categories of recipients to whom the data are transmitted, the criteria used to determine the data retention period, and the rights that you can exercise on your data.

9.3 Right to rectification or your personal data

Inaccurate or incomplete personal data may be corrected. It is primarily the responsibility of the User to make the necessary changes in his "user area", but you can also request us in writing.

9.4 Right to erasure (or "right to be forgotten")

You also have the right to obtain the erasure of your personal data under the following assumptions:

  • Your personal data are no longer necessary for the intended purposes;
  • You withdraw your consent to the processing and there is no other legal ground for processing;
  • You have validly exercised your right of opposition;
  • Your data has been illegally processed;
  • Your data must be deleted to comply with a legal obligation.

The deletion of data is mainly related to visibility; it is possible that the deleted data are still temporarily stored.

9.5 Right to limitation of processing

In certain cases, you have the right to request the limitation of the processing of your personal data, especially in case of dispute as to the accuracy of the data, if the data are necessary in the context of legal proceedings or the time required to The 37Company to verify that you can validly exercise your right to erasure.

9.6 Right to object

You have the right to object at any time to the processing of your personal data for direct marketing purposes. The 37Company will stop processing your personal data unless it can demonstrate that there are compelling legitimate reasons for the processing which prevail over your right to object.

9.7 Right to data portability

You have the right to obtain any personal data which you have provided us in a structured, commonly used and machine readable format. At your request, this data may be transferred to another provider unless it is technically impossible.

9.8 Right to withdraw your consent

You may withdraw your consent to the processing of your personal data at any time, for example for direct marketing purposes.

 

10. HOW TO EXERCISE MY RIGHTS ?
If you wish to exercise your rights, you must send a written request and proof of identity by registered mail to The 37Company, Beeldschermweg 6F, 3821 AH Amersfoort, The Netherlands or by email to info@the37company.com. We will respond as soon as possible, and no later than one (1) month after receipt of the request.

 

11. POSSIBILITY TO LODGE A COMPLAINT

If you are not satisfied with the processing of your personal data by The 37Company, you have the right to lodge a complaint with the competent Data Protection Authority (for the Netherlands: https://www.autoriteitpersoonsgegevens.nl).