1. Who is responsible
Milenia is a service of Wibs Digital, Oder 20 Unit G7770, 2491 DC Den Haag, The Netherlands (KVK 62769960, VAT NL002443037B21). Wibs Digital plays two different roles, and the difference matters:
- For the account and contact details of the people who sign up, and for the data our website collects, Wibs Digital is the data controller.
- For the member data an organization enters into the software (names, contact details, payments and so on), the organization is the data controller and Wibs Digital is its data processor. We only process that data on the organization's instructions.
2. What we process
What we hold depends on how you use Milenia:
- Account data: the organization's name, type, address, chamber of commerce (KVK) and VAT number, and a contact person's title, name, e-mail address and phone number.
- Sign-in data: the username, password and pin code of users. Passwords and pin codes are stored in a hashed form, never as plain text.
- Member data entered by the organization: for example names, addresses, birth dates, contact details, membership status and contribution payments, including information taken from uploaded bank statements.
- Technical data: log data such as IP address, browser type and the time of a request, used to keep the service secure and working.
- Messages: when we send you e-mail or WhatsApp messages, such as a confirmation code, we process the address or number and the content.
3. Why we process it, and on what basis
We only process personal data for clear purposes:
- To create and run your account and provide the service (performance of the contract).
- To keep the service secure, prevent abuse and fix errors (our legitimate interest).
- To send service messages such as confirmation codes and important notices (performance of the contract).
- To meet legal obligations, such as keeping invoices for the tax authorities (legal obligation).
- To answer your questions and requests (legitimate interest).
4. Who we share data with
We do not sell personal data. We share it only with providers that help us run the service, and only what they need. Depending on the features you use these are, for example, providers for hosting, e-mail delivery, online payments (such as Stripe and iDEAL), WhatsApp messaging, and the automatic reading of bank statements.
We agree with these providers that they may use the data only for our instructions and must protect it. If the law requires us to disclose data to an authority, we do so only to the extent needed.
5. Transfers outside the EEA
We aim to process data within the European Economic Area. If a provider processes data outside the EEA, we make sure an appropriate safeguard is in place, such as the standard contractual clauses approved by the European Commission.
6. How long we keep data
We keep account data for as long as the account exists and for a limited period afterwards, as needed for invoicing, legal obligations and the settlement of disputes. Member data is kept for as long as the organization keeps it in the software, and follows the organization's own retention rules.
When an account is closed we delete or anonymize the data after a reasonable export period, unless the law requires us to keep something longer.
7. How we protect data
We use technical and organizational measures that fit the risk:
- encrypted connections;
- role-based access, so users only see what their role allows;
- hashed passwords and pin codes;
- separation between organizations, so one organization cannot see another's data;
- activity logging for important actions.
8. Your rights
Under the General Data Protection Regulation (GDPR, in Dutch: AVG) you have the right to access your data, have it corrected or erased, restrict or object to its processing, and receive it in a portable format. Where processing is based on consent you can withdraw it at any time.
To use a right, contact us. If you are not satisfied with our answer, you can complain to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or to the authority in your own country.
9. If you are a member of an organization
If an organization uses Milenia to manage your membership, that organization is responsible for your data. Please contact the organization directly to see, correct or delete your data. We will help the organization to respond to your request.
10. Cookies and similar technologies
We do not use advertising or tracking cookies. We use your browser's local storage for things you ask for, such as remembering your language and theme, and to keep you signed in to your account.
Our website loads fonts and icons from third-party content delivery services (Google Fonts and jsDelivr). Those services receive your IP address when your browser fetches those files.
11. Changes and contact
We may update this policy when our service or the law changes. We publish the new version here with its date, and we tell you about material changes in advance.
Questions about privacy, or want to use a right? E-mail us at info@wibs.nl or write to Wibs Digital, Oder 20 Unit G7770, 2491 DC Den Haag, The Netherlands.