The data collected when you visit this website is collected, processed, and used by Sunbytes (“Sunbytes”, “we” or “us”) in its capacity as the website provider. You can find further information about Sunbytes under “About us”. We are deeply committed to protecting your personal data. We, therefore, handle your personal data with the utmost care and in accordance with the respective data protection requirements under the law. This data privacy statement sets out which data is collected when you access this website, the purpose for which the data is collected, and the way in which we collect, process, and use this data, as well as your rights in relation to these activities.
- Information about the collection of personal data and the reasons for processing
(1) Personal data is any information that relates to your person, e.g. your name, address, email address or user behavior. The purpose of processing said data is the presentation of our company and our services online.
(2) The controller pursuant to Article 4 Paragraph 7 of the EU’s General Data Protection Regulation (GDPR) is: Sunbytes
Office in the Netherlands:
Europalaan 500, Unit 4.0.3, 3526 KS Utrecht
Office in Vietnam:
55 Nguyen Van Giai Street, Da Kao Ward, District 1, Ho Chi Minh City
Europalaan 500, Unit 4.0.3, 3526 KS Utrecht
Contact information for our data protection officer:
You can also contact the office by post at the company address, c/o “Data protection officer “.
(3) When you contact us by email or using a contact form on our website, we store the data you provide (your last name, first name, company and email address) so we can answer your questions. We delete the data submitted in this context once its storage is no longer required, or restrict processing where there are legal requirements to retain the data.
(4) Where we contract service providers to deliver specific elements of our offering or if we want to use your data for advertising purposes, we will inform you in detail about the relevant processes. We will also specify the defined criteria for the duration of storage.
2. Your rights
(1) You have the following rights regarding personal data pertaining to you:
- Right of access (Art. 15 GDPR),
- Right to rectification or erasure (Art. 16 and 17 GDPR),
- Right to restriction of processing (Art. 18 GDPR),
- Right to object to processing (Art. 21 GDPR),
- Right to data portability (Art. 20 GDPR),
- Right to withdraw consent (Art. 7 Para. 3 GDPR).
(2) Furthermore, you have the right to lodge a complaint with a supervisory authority regarding the processing of your personal data by us.
3. Collection of personal data during visits to our website
(1) When using the website for purely informational purposes, i.e. if you do not register an account or provide any other type of information, we will only collect personal data that your browser sends to our server. When you visit our website, we collect the following data that are technologically necessary in order for us to display our website and safeguard its reliability and security (pursuant to Art. 6 Para. 1 (1, f) GDPR):
- Date and time of access
- Referrer URL of the website from which our site was accessed
- IP address of the computer used to access our website
- Browser type and version
- Data transfer volumes
- Success or error during loading
(2) In addition to the aforementioned data, cookies are stored on your computer when you access our website. Cookies are small text files that are stored on your hard drive by your browser and that allow certain information to be shared with the site that installs the cookies (in this case, us). Cookies cannot run programs or transfer viruses to your computer. They simply serve to make websites more user-friendly and efficient.
a) This website uses the following types of cookies, whose scope and functions are explained below:
- Transient cookies (see b)
- Persistent cookies (see c).
b) Transient cookies are automatically deleted when you close your browser. They include session cookies, which store a “session ID” that allows various requests from your browser to be assigned to the same session. This means your computer will be recognized if you return to our website. A session ID does not store your name or your IP address or similar data. Session cookies are deleted when you log out or close your browser.
c) Persistent cookies are automatically deleted after 12 months. You can delete the cookies at any time under the security settings in your browser.
d) You can configure your browser settings as you wish, for example to reject third-party cookies or all cookies. Please note that you may not have access to all the functions of this website if you choose to do this.
e) Where we use third-party cookies, we will notify you in advance.
In addition to differentiating between transient and persistent cookies, there is also a distinction made between essential and non-essential cookies.
The use of non-essential cookies (e.g. functional or advertising cookies) requires your consent, which you provide before the cookies are switched on via our cookie consent function and that you can withdraw at any time without reason. This is pursuant to Art. 6 Para. 1 (a) of the GDPR.
4. Contact by email or the contact form
(1) When you contact us by email or using a contact form on our website, the data you provide (name, email address, phone number) is stored by us so that we can answer your questions. Any such data will be deleted once its storage is no longer required, or processing will be restricted if the data must be retained by law. This data is processed pursuant to Art. 6 Para. 1 (b) of the GDPR, where processing is necessary for the performance of a contract or in order to take steps prior to entering into a contract. In all other cases, processing is in our legitimate interests (Art. 6 Para. 1 (f) GDPR) because we have a legitimate interest in processing your enquiries efficiently.
(2) Where we contract service providers to deliver specific elements of our offering or if we want to use your data for advertising purposes, we will inform you of the relevant processes in detail. We will also specify the defined criteria for the duration of data storage.
5. Our newsletter
When you subscribe to our newsletter, you agree to its receipt and the related processes as described. We send newsletters and other electronic messages with advertising information (hereinafter “newsletter”) only with your consent or as permitted by law. To register for the newsletter, it is sufficient to provide your name, title, company and email address. Subscription to our newsletter is based on the double opt-in method: after registering, you will receive an email from us where we ask you to confirm your registration. This is necessary to ensure that no third parties can register with your email address. Newsletter subscriptions are logged to ensure the registration process is transparent in accordance with legal requirements. This includes storing the date and time of registration and confirmation. Any changes to the data stored by your email provider are also logged.
Distribution of the newsletter is based on the consent of the recipient pursuant to Art. 6 Para. 1 (a), Art. 7 GDPR. It is in our interest to ensure the newsletter system is user-friendly and secure, which serves both our legitimate business interest as well as the expectations of users, and which also provides us with proof of consent.
Unsubscribing from the newsletter
You can unsubscribe from the newsletter by withdrawing your consent at any time. A link to unsubscribe can be found at the end of each newsletter. We may store withdrawn email addresses for up to three years before deleting them, based on our legitimate interests, in order to provide proof of prior consent. This data shall only be processed for the purpose of mounting a defence against any potential claims. Individual requests for email deletion can be made any time, provided you also confirm having given prior consent.
Our newsletter provider
The newsletter is distributed using Mailchimp, a service provided by The Rocket Science Group, LLC 675 Ponce de Leon Ave NE Suite 5000 Atlanta, GA 30308 USA. Mailchimp’s data privacy terms can be viewed here: https://mailchimp.com/gdpr/
Our provider is contracted based on our legitimate interests pursuant to Art. 6, Para. 1 (f) GDPR and based on an agreement pursuant to Art. 28, Para. 3 (1) GDPR. To ensure you receive the newsletter and to enable any data required in this context to be shared with the provider, you must first provide your consent (Art. 6, Para. 1 (a) GDPR) (cf. § 5, Para. 1). The provider may use the recipient’s data in an anonymized way, i.e. without assigning it to a user, in order to optimize and improve its service, e.g. to optimize the distribution and presentation of the newsletter or for statistical purposes. However, the provider will not use the data of newsletter recipients to write to them or share their data with third parties.
6. Web analytics and tracking tools
We use Google Analytics to analyze the use of our website and related statistics. The resulting data is used to optimize our website and advertising measures.
Google Analytics is a web analytics service operated and provided by Google (Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; in Europe: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland).
Your data is processed based on your prior consent pursuant to Art. 6, Para. 1 (a) and Art. 49, Para. 1 (a) GDPR.
Type of personal data
During your visit to our website, the following data is collected i.a.:
- User-related data
- IP address (abbreviated format, so that it cannot be individually assigned)
- Origin (country and town/city)
- Language Operating system
- Device (PC, tablet or smartphone)
- Browser and all add-ons that are used
- Screen resolution
Origin of your visit (i.e. the website or advertisement you came to us from)
- Which files were downloaded?
- Which videos were viewed?
- Which advertising banners were clicked on?
- Where did the user go?
- Did they click on other pages on the site, or did they leave the site completely?
- How long did the user stay?
- Subscriptions made
- Files downloaded
Google processes data on website use on our behalf and is contractually obliged to implement measures to safeguard the confidentiality of said data. Google also processes this data for its own purposes (e.g. for creating profiles or connecting it to potential Google accounts). The data collected using cookies during your visit to our site is usually sent to a Google server in the USA and stored there for analysis.
Duration of storage
Google Analytics stores cookies in your web browser for two years from the time of your last visit. These cookies contain a randomly generated user ID that allow you to be recognized in future visits to the site.
The logged data is stored together with the randomly generated user ID, which enables the analysis of an anonymized user profile. We automatically delete this user-related data after 26 months.
This website uses IP anonymization (or IP masking). This means that, within member states of the European Union and the European Economic Area, a user’s IP address is abbreviated and anonymized for transmission. Only in exceptional cases will the full IP address first be sent to a Google server in the USA and then abbreviated there. Google will use this information on behalf of the operator of a website to analyze use of the website, compile reports on website activity and provide additional services related to use of the website and the internet.
You can prevent this type of processing by taking the following steps:
It is possible to configure your browser so that cookies are not stored. However, this may mean that not all the functions of our website are available to you.
Additionally, Google has a browser add-on to prevent this data from being collected. You can find the add-on here: https://tools.google.com/dlpage/gaoptout?hl=en
As an alternative to the browser add-on, if you’re using a smartphone or tablet you can prevent data from being collected by Google Analytics by clicking here. This installs a cookie to prevent data collection. If you visit our website again using a different device or browser, or if you delete your cookies, you will have to allow the cookie again.
As a US company, Google is subject to the CLOUD Act. This gives American federal law enforcement the right to obtain data stored by Google.
You can find more information on data privacy at Google here: https://policies.google.com/privacy?hl=en
To protect any information you submit using the contact form on our website, we use the reCAPTCHA service provided by Google LLC. (Google), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. This service helps to distinguish between messages sent by humans or those fraudulently sent by automated bots, and includes the transmission of your IP address and potentially additional data required by Google for the reCAPTCHA service. For this purpose, your entry is sent to Google and processed there. Because IP anonymization is activated on our website, your IP address is first abbreviated by Google if you reside in a member state of the European Union or another state participating in the agreement in the European Economic Area. Google analyzes this information on our behalf in order to evaluate your entry. Google does not merge the IP address shared by your browser for reCAPTCHA with any other data.
7. YouTube videos
There are videos embedded on our website that we have published on YouTube. YouTube (YouTube LLC, 901 Cherry Avenue, San Bruno, CA 94066, USA) is a service provided by Google (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). If you access a video on our website, a connection is established with the YouTube servers so you can watch the video. This also transfers the information to the servers of this platform that you have visited our website.
If you are signed in to YouTube, YouTube will assign this information to your personal user account. The data collected about you is processed by YouTube and potentially sent to countries outside the European Union or European Economic Area. We have no influence over the type and scope of data processed by the company, the way in which it is processed or used, or the transfer of this data to third parties, particularly in countries outside the European Union.
You can prevent this data from being assigned to your account by logging out of your YouTube account prior to using our website and deleting the corresponding cookies.
You can find more information in the data privacy statement: policies.google.com/privacy. Independent of the data processed on our website, you also have the option to opt out with Google (see policies.google.com/privacy) and to delete your own data (see policies.google/privacy/infodelete)
These options are subject to the discretion of Google, which we have no influence over. We only share the data once you have actively clicked on a video in order to play it. This represents your consent to use the video service and to the necessary data transmission. This is pursuant to Art. 6, Para. 1 (a) and (f) GDPR.
8. Sharing our web pages
We use interactive elements on our website, i.e. share buttons for
- LinkedIn (small “in”)
- Twitter (bird symbol)
- Facebook (small “f”)
- Email (envelope symbol)
to simplify the sharing process, make it easier for users to recommend our website and to allow our company to gain more visibility. We use the plug-ins for these services for this purpose. To protect your data and privacy, we employ the two-click method for social media recommendations. Using this method means that our web pages feature inactive buttons that do not transfer any data to the relevant providers. However, you have the option of activating the buttons manually and connecting to your preferred network (= first click). Once you’ve logged in, you can then make your recommendation in a second step (= second click). If you are already logged in to the relevant social media platform, it may assign your visit to our website to your profile immediately after the second click. The visit will only be visible to others in your user account based on the service’s privacy settings, e.g. only to a certain group of people in your network or public.
When accessing the relevant social media platforms, the general terms and conditions and data processing policies of the services shall apply with regard to offering personalized advertising, informing other users of the platform about your activities on our website and ensuring the service is designed in line with user needs.
If you do not want the relevant provider of the aforementioned social media platforms to assign information captured on our website directly to your profile, you must log out before visiting our site.
Ensuring operations are compliant with data privacy regulations is the responsibility of the individual platform providers:
LinkedIn: LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland
Data privacy statement linkedin.com/legal/privacy-policy,
Twitter: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA Responsible for data processing for individuals who reside outside of the United States: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland.
Twitter data privacy statement: twitter.com/privacy
More information on opt-outs: twitter.com/de/rules-and-policies/twitter-cookies
Facebook: Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland
Overview of Facebook plug-ins: developers.facebook.com/docs/plugins
Facebook data privacy statement: facebook.com/about/privacy
You can also get add-ons for your browser to block Facebook plug-ins and the data processing described above, e.g. the script blocker noscript.
9. Our company presence on social media
You can click on the relevant symbols on our website to visit our company profiles on the following platforms:
On these pages, we provide our customers, users and other interested parties with updates on our services. Please note that user data may also be processed outside the European Union. This can result in certain risks for users, e.g. it may be harder to assert user rights.
Furthermore, social media providers usually employ user data for market research and advertising purposes. For example, a user’s behaviour and interests may be used to create a user profile. In turn, these user profiles can then be used to switch on advertising both within and outside platforms that supposedly appeal to the user’s interests. To do this, cookies are usually stored on the user’s computer to store information on user behaviour and interests. Additionally, data can also be stored in user profiles regardless of the device being used (particularly if a user has an account with the relevant platform and is logged in).
By browsing the relevant company pages, you consent to this data being processed (Art. 6, Para. 1 (a) GDPR). Where one of the relevant providers asks for your consent to the data being processed (i.e. by ticking the control box or clicking a confirmation button), this is based on Art. 6 Para. 1 (a) and Art. 7 GDPR.
Please note that if you would like to request more information or assert your user rights, this is best done with the providers themselves. Only the relevant providers have access to user data and can immediately take steps or provide information. However, if you need help with this, feel free to contact us. You can find detailed explanations of the relevant processes and the available opt-outs for each provider at the following links. We are not responsible for this data processing and have no influence over it.
Twitte: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA Responsible for data processing for individuals residing outside of the United States: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland.
Twitter data privacy statement: http://twitter.com/privacy
Facebook: Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland
Data privacy statement: facebook.com/about/privacy
YouTube: YouTube LLC, 901 Cherry Avenue, San Bruno, CA 94066, USA is a service provided by Google (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA)
Data privacy statement: policies.google.com/privacy
10. Objecting to the processing of your data
(1) If you have given your consent for your data to be processed, you have the right to withdraw that consent at any time. Once you have notified us of your wish to withdraw to consent, the processing of your personal data is no longer permissible.
(2) Where the processing of your personal data is based on our legitimate interests, you may object to it. This is the case if the processing is not required for the performance of a contract with you or if you are not actively requested to provide consent, which we will communicate. When exercising your right to object, we would ask that you provide the reasons for which we should not process your personal data in the manner we have. Once you have provided grounds for your objection, we will examine the matter and either discontinue or modify the way in which we process your data, or provide you with our legitimate grounds for continuing to process your data.
(3) You may of course object to the processing of your personal data for the purpose of advertising or data analysis at any time. You can inform us of your objection using the contact information provided in term 1
11. Concluding statement
Our business operations require us to collect and process data. Where data is collected and processed, data privacy and security must be ensured. This is not only a legal concern for us; it is a matter of extreme importance. If you have any questions or suggestions on data privacy and our services, please do not hesitate to get in touch using the contact information given above (see § 1).