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1. Introduction

At Proton 27 (the company that runs the Manula site and software), we carefully deal with privacy and privacy-sensitive data, to comply with the General Data Protection Regulation (GDPR) and the Telecommunications Act. We will consider as much as possible the European Commission's January 1 2017 proposal to replace the ePrivacy Directive from 2002 with a new ePrivacy Regulation. For example, in the ePrivacy Regulation proposal conditions are attached to the use of cookies and to sending newsletters.

In this privacy and cookie statement we inform you about which personal data we process, for which purposes we process personal data, the way we process personal data, how you can exercise your privacy rights and other information about how we handle personal data. Personal data is data that can be used to identify an individual or which can be linked to an individual.

This privacy and cookie statement applies to the usage of the Manula.com websites (like www.manula.com and admin.manula.com, hereafter: “the Websites”) and the related services, like subscribing to our newsletter, making purchases in our webshop, usage of our manual creation software and the hosting of your manuals on our servers. When processing personal data, we make a distinction between the various users of the Websites, namely the website visitor, the trial user and the customer.

2. For which purposes is Manula processing personal data?

Manula processes various personal details of you by means of the Websites, depending on how you use the Websites and our services.

The website visitor

For website visitors, Manula processes personal data for the following purposes:

The trial-user

Users can sign up for a free trial of our software and services, using their email address, after which he becomes a trial-user. For trial-users, Manula processes personal data for the following purposes (in *addition* to the purposes listed above for visitors):

The customer

When users subscribe to one of our paid services (subscription software), that user becomes a customer. For customers, Manula processes personal data for the following purposes (in *addition* to the purposes listed above for visitors and trial-users):

3. Which personal data is collected by Manula and for how long?

Manula does not store personal data for longer than is necessary for the purposes mentioned above. With the exception of the data that we have to store longer because the law obliges us to do so. The retention period for personal data depends on the groups defined above (website visitors, trial-users and customers):

The website visitor

For website visitors, Manula processes the following personal data:

This data is stored for 3 months and will be removed afterwards.

The trial-user

For trial users, Manula processes the following personal data, in *addition* to the data listed above for website visitors:

If the trial-users doesn’t become a customer, his personal data is stored for 6 months and will be removed afterwards.

The customer

For customers, Manula processes the following personal data, in *addition* to the data listed above for website visitors and trial-users:

Personal data for customers is retained as long as the customer is using our software and services, plus 1 year after the customer stops using them. When the customer stops using our services, he can request that his account and all data stored will be removed (directly).
Financial data is processed for tax purposes and must be retained for seven years and will be removed afterwards.

In case the user contacts customer support email conversations is stored for 3 years and will be removed afterwards.
All other data processed for users on the Websites will be deleted if the processing is no longer necessary for Manula.

4. Accuracy and responsibility

When you provide personal information to Manula, you are personally responsible for the accuracy and for keeping it up-to-date. Manula is not liable, except for intent or gross negligence, for inaccuracies or consequences of activities that are undertaken on the basis of incorrect or incomplete information provided by you.

5. To whom is Manula providing personal data?

Manula does not provide any personal data to third parties, except for the processors we use for customer support, email broadcasts, the management and maintenance of the Website, as well as the services offered there, such as the online processing of payments. Appropriate processing agreements have been concluded between Manula and these processors, which include a confidentiality clause. The processors of Manula are not allowed to process the personal data for other purposes.

Manula only provides personal data to third parties outside the European Union if an appropriate level of protection for personal data is available in the country concerned.

In some cases Manula is legally obliged to provide certain personal data to third parties. For example, it is possible that the police will request information from us in the context of a fraud investigation. In that case, we are legally obliged to provide this information.

6. Security

We take appropriate security measures to limit abuse of and unauthorized access to your personal data. In this way we ensure that only the necessary persons have access to the data, that access to the data is protected and that our security measures are checked regularly.

7. How is Manula using cookies?

What are cookies and similar techniques?

A cookie is a small text file that is placed on or read from your computer during your visit to the Websites, for example in the browser of your computer, tablet or smartphone. Through this text file data is stored or read, including personal data. On the basis of this (personal) data you can be recognized on a later visit.

JavaScripts and web beacons are examples of similar techniques that, together with cookies, enable a system to collect information (via Javascripts), store it in small, simple text files (cookies) and then send it (web beacons). This happens in our Websites, but also in our newsletters. We can use this to see who opened newsletters and which links in the newsletter were clicked. All these techniques together are called 'cookies'.

For what purposes does Manula use cookies?

Which (personal) data is collected by Manula via cookies?

Manula collects your IP address and MAC address (where possible anonymous), surfing and click behavior, cookie identifiers, technical characteristics (such as the browser you use and the resolution of your computer screen), from which websites you arrived on one of the Manula Websites (referrer), when and for how long you visit or use our Websites, whether you use the functionalities of our Websites and which pages you visit on our Websites.

How can you avoid cookies (even more)?

By changing the settings of your browser, you can indicate that your browser is not allowed to accept cookies (from our Websites). If your browser does not accept cookies from our Websites, it is possible that you cannot use to certain functionalities of our Websites or you may not be able to use any functionalities. If you wish to oppose the cookies of Google Analytics, you can set this in your browser by refusing cookies from Google (Analytics) via your browser or by clicking here.

8. Visitor and user rights

Because your personal data is processed by Manula, you have certain rights. These rights are explained below. As a trial user and as a customer, you can exercise the right of access and the right to improve, supplement and delete your personal data via your account on admin.manula.com.

In addition, you can send an email request for execution for one or more of the following rights to privacy@manula.com. To prevent abuse, we ask you to identify yourself adequately by sending a copy of a valid proof of identity. Do not forget to hide your BSN and your passport photo on the copy.

Right of access and the right to get a copy

Right for improvement, addition, restriction or removal

Right to object

Right to data portability

9. How to contact Manula?

For questions, requests or complaints regarding the processing of your personal data, please contact us at privacy@manula.com. We are happy to help you if you have a complaint about the processing of your personal data. If, for any reason, you are not happy about how we deal with your request, then, under the privacy legislation, you also have the right to file a complaint with the data protection supervisor, the Dutch Data Protection Authority. You can contact the Dutch Data Protection Authority for this.

10. Changes to the privacy and cookie statement

We may change this privacy and cookie statement from time to time. Changes will be published on our Websites. It is therefore advisable to consult this privacy and cookie statement regularly, so that you are aware of these changes.

11. Cookie declaration