We are the Dutch company EC Solution Group BV, trading under the name Versa (“we“, or “us“) with our registered office at Van Boetzelaerlaan 40, 2581AK The Hague, the Netherlands and chamber of commerce registration number 52924238. We are a company specialized in creating great luggage tracking products and services.
We process personal data. This privacy statement explains our data processing practices in connection with our website https://versa.company (the “Versa Website“), our products (the “Versa Tracker” and our smartphone app the “Versa App“) and services (the “Versa Subscription“). Personal data processed by us relates to persons who use the Versa Tracker in combination with the Versa Subscription and the Versa App (“end-users“) and other individuals, like persons who are visitors to the Versa Website or subscribe to our newsletter (“visitors“). When we process personal data, we generally act as a controller within the meaning of the General Data Protection Regulation (“GDPR“).
2. How our products and services work
To make our products and services work we use a combination of technologies and features (the Versa Tracker with connectivity to wireless networks, the Versa Subscription and the Versa App), data sources and third-party service providers to allow you to track your baggage while it is in transit during air travel.
We assign a unique identifier (a unique combination of numerical values) to each Versa Tracker. Once you acquire your Versa Tracker, you must download and register via the Versa App and activate your Versa Subscription to use the Versa Tracker. The Versa Subscription enables us to show you where your Versa Tracker is via the Versa App or via a third-party messenger service (e.g. Facebook Messenger). In order to register you must enter your Versa Tracker’s unique identifier and some personal details, such as your name and e-mail address (see paragraph 3 below for a full overview of the personal data that we process).
After your registration and with an active Versa Subscription, you can check the location of your baggage with your Versa Tracker via the Versa App or a third-party messenger service. If a Versa Tracker is in transit it periodically sends its location data to the Versa App. If baggage with a Versa Tracker is at risk to miss, or has missed, its flight, ground handlers can be informed in order to find the baggage with the Versa Tracker. Some airlines can provide you the service of delivering your baggage with the Versa Tracker to the destination address provided by you via the Versa App, third party messenger service or collected by us from itinerary service providers.
3. What personal data do we process
We may process the following data of end-users:
- e-mail address;
- name (first and last);
- booking reference;
- flight number;
- destination address (home, hotel);
- baggage characteristics (including a photo);
- Versa Tracker ID;
- context data: GSM cell towers, Wi-Fi access points, Bluetooth beacons and ADS-B signals transmitted by aircrafts; and
- location data.
We may process the following data of visitors:
- contact details (name and e-mail address and similar data required for communication) and communications content of (potential) customers if a visitor chooses to provide these to us via the Versa Website;
- data with regard to electronic messages originating from or destined for visitors and data that are necessary for the purpose of maintaining contact with these visitors; and
data in connection with a visit to the Versa Website, such as data for the purpose of identifying and communicating with visitors to the website or data recorded to collect statistics with regard to the Versa Website (see paragraph 7 below).
4. For what purpose do we process these data and on what legal basis
We only process personal data if a valid legal basis exists. This means that we will only process the above mentioned data if:
- the processing is necessary for the performance of an agreement with the data subject or in order to take steps at the request of the data subject prior to entering into an agreement (“fulfillment of an agreement”). Where this is the case, you are required to provide the data and a refusal to do so means that we are not able to support your use of the Versa App, the Versa Subscription and the Versa Tracker;
- the processing is necessary to comply with a legal obligation to which we are subject (“legal obligation”);
- the processing is necessary for the purposes of the legitimate interests pursued by us or by another person, and those interests outweigh the interests or fundamental rights of the person whose data are concerned, as is the case, for example, when we use contact details of end-users for sending unsolicited commercial messages for our products and services (“legitimate interest”), the legitimate interest being maintaining contact and expanding our commercial relationship with our customers; or
- the data subject has given his consent to the processing (“consent”).
We may process the personal data of end-users for the following purposes:
- to provide and ensure the well-functioning of our products and services (legal basis: fulfillment of an agreement);
- to improve our products and services (legal basis: our legitimate interest in product development);
- to maintain contact (legal basis: our legitimate interest in maintaining our customer relationships or fulfillment of an agreement); and
- to send promotional (e)mail(s) that we think you may find interesting (legal basis: our legitimate interest in maintaining our customer relationships).
We may process the personal data of visitors for the following purposes:
- requested communication with visitors (legal basis: our legitimate interest in maintaining our customer relationships);
- to obtain usage statistics to improve the Versa Website (legal basis: our legitimate interest in maintaining our customer relationships); and
- to send you newsletters that you signed up for (legal basis: our legitimate interest in maintaining our customer relationships).
5. With whom may we share personal data
We may share personal information about end-users and visitors with:
- persons who work for us;
- suppliers (for example hosting providers or the provider that collects the usage statistics for the Versa Website, see paragraph 7 below); and
- others, with the consent of the data subject, or in the case of a legal obligation.
“Persons who work for us” refers to employees of EC Solution Group BV and other persons associated with us (such as partners, consultants and contractors).
“Suppliers” include the following third-party service providers and partners that we work with in order make our products and services work. We only share data that is strictly necessary for the third-party service providers to provide you our products and services:
- location services like Google Maps and Here;
- real-time flight monitor services like AirNav;
- itinerary service providers like TripIt;
- ground handlers like Menzies and Swissport;
- (lost) baggage management systems like SITA and Collins;
- logistical service providers like UnicoBag and DHL; and
6. How we protect your personal data
We apply various technical and organizational measures to protect your personal data against destruction, loss, alteration or unauthorized disclosure or access. These comprise administrative, physical and technological measures. Persons who work for us are bound to secrecy and must abide by our instructions aimed at the adequate protection of your data.
7. Cookies on the Versa Website
Our website applies cookies, as we use Google Analytics, a service that provides us insight into the manner in which the Versa Website is used. This relates to statistics of use like the number of unique visitors, the pages visited and the average duration of a visit. We have concluded a processing agreement with Google to ascertain that personal data that are collected for us in the context of Google Analytics, are only used to give us insight into the manner in which the Versa Website is used. We have also adapted the settings of the service in such a way that the data may not be deployed by other Google services, and that the last digits of all the IP-addresses collected in this scope are immediately erased. This makes it more difficult to link data to a specific visitor.
8. Transfer to countries outside the EEA
Your personal data may be transferred to a country outside the European Economic Area (EEA) that provides a lower level of protection to personal data than the legislation in the EEA. For example, we may use a supplier of online services which is established outside the EEA (for example in the United States of America), and the use of these services may involve a transfer of personal data to the supplier.
If such situation presents itself, and personal data are transferred to a country outside the EEA that provides less legal protection to personal data, we will provide for appropriate safeguards in order for the transfer to take place in accordance with the privacy laws here. We may do this by concluding a contract with the recipient in accordance with a format that the European Commission (article 46.2 GDPR) or a national supervisory authority has approved for this purpose (articles 46.2(e) and 47 GDPR).
9. How long do we retain personal data
We do not retain personal data any longer than necessary. For example: we remove booking references and flight numbers immediately after a flight has ended and we retain other personal data relating to end-users only for 6 months after the Versa Subscription has ended. Personal data relating to visitors is only retained until they withdraw their consent for the newsletters they signed up for or for the limited period of  months that we collect website statistics for.
10. Your rights with regard to your personal data
The laws on the protection of personal data give you the following rights with regard to personal data relating to you:
- the right to request whether or not personal data concerning you is processed, and, if this is the case, to get access to these;
- the right to request rectification and erasure of these data;
- the right to object to the processing or to ask for a restriction of the processing;
- the right to withdraw your consent to the processing, if the processing is based on consent;
- the right to receive your data or have this transmitted to an organization designated by you, in a structured, commonly used and machine-readable format; and
- depending on the country where you live, the right to file a complaint with a supervisory authority that monitors the compliance with the rules for the protection of personal data. In the Netherlands, this is the Autoriteit Persoonsgegevens in The Hague (autoriteitpersoonsgegevens.nl).
We will deal with a request in connection with the exercise of these rights in the manner as prescribed by law. However, these rights are not absolute; they do not apply under all circumstances and the applicable rules provide for exceptions. If we do not grant your request, we will explain to you why.
11. Contact details
In order to exercise the rights described above, you can send an e-mail to firstname.lastname@example.org. You may also use this e-mail address if you wish to file a complaint about the manner in which your personal data have been processed by us. If you are dissatisfied with the manner in which we dealt with your complaint, you can file a complaint with the Autoriteit Persoonsgegevens or, if you reside or work in another country of the EEA, with the supervisory authority in that country.
This statement was amended on 27 August 2019 for the last time.
If we amend this statement in the future, we will publish the amended statement on the Versa Website, stating the date on which the amendments will take effect.