This Privacy Policy explains how Viggo BV ("Viggo", "we", "us" or "our") collects and uses personal data when you use the Hospitality TV Launcher application, the Viggo content management system (the "CMS"), our website viggosmarthotel.com and related services (together, the "Service"). It also explains your rights under the EU General Data Protection Regulation ("GDPR") and the Dutch GDPR Implementation Act (UAVG).
Viggo BV
Nassaukade 338 O, 1053 LW Amsterdam, The Netherlands
Chamber of Commerce (KvK) number: 58119388
Email for privacy matters: support@viggo-sntv.com
We have not appointed a Data Protection Officer, as this is not required for our activities. All privacy questions can be sent to the address above.
Our role depends on whose data it is and why it is processed:
| Purpose | Personal data | Legal basis (GDPR Art. 6(1)) |
|---|---|---|
| Creating and managing CMS accounts for hotels and business customers | Name, business email address, phone number, company name, login credentials, account settings | Performance of a contract (b) |
| Providing, operating and securing the Service, including the in-room TV application | Device identifiers, IP address, app version, technical logs, error and diagnostic data, the room or device the TV is linked to | Performance of a contract (b); legitimate interest in keeping the Service secure and working (f) |
| Location features in the application, only if enabled | Approximate device location, only with your permission on the device | Consent (a), which you can withdraw at any time in your device settings |
| Subscriptions, invoicing and payments | Billing contact details, company details, subscription and payment history (we do not store card details) | Performance of a contract (b); legal obligation for tax and bookkeeping records (c) |
| Customer support and answering questions sent through our website or by email | Name, email address, the content of your message | Performance of a contract (b), or our legitimate interest in answering enquiries (f) |
| Improving the Service using statistics | Usage data, where possible aggregated or pseudonymised | Legitimate interest in improving our products (f); consent where required for analytics on devices or our website (a) |
| Service announcements and newsletters to business customers | Name, business email address | Legitimate interest in informing existing customers about similar services (f), with an opt-out in every message; consent for others (a) |
| Complying with the law and handling disputes | Relevant records | Legal obligation (c); legitimate interest in establishing or defending legal claims (f) |
Where we rely on legitimate interest, you may object at any time (see section 8). Where we rely on consent, you may withdraw it at any time, without affecting processing that took place before. Providing data needed for a contract is necessary to use the Service; other data is optional.
We do not sell personal data, we do not use it for profiling with legal or similarly significant effects, and we do not make decisions about you based solely on automated processing.
We only share personal data where necessary for the purposes above:
We aim to store personal data within the European Economic Area (EEA). Some of our service providers, or their sub-processors, may process data outside the EEA, for example in the United States. In that case we make sure the transfer is protected by one of the safeguards in the GDPR: an adequacy decision of the European Commission (such as the EU-US Data Privacy Framework, for US companies certified under it), or the European Commission's Standard Contractual Clauses together with additional measures where needed. You can ask us for more information about these safeguards using the contact details in section 1.
| Data | Retention period |
|---|---|
| CMS account data | For as long as the account is active, and up to 12 months after it is closed |
| Technical logs and diagnostic data | Up to 13 months |
| Support requests and website enquiries | Up to 24 months after the matter is closed |
| Invoices and financial records | 7 years, as required by Dutch tax law |
| Hotel guest data processed for a hotel | As instructed by the hotel in our data processing agreement |
After these periods we delete the data or anonymise it so that it can no longer identify you.
We use appropriate technical and organisational measures to protect personal data, including encrypted connections (HTTPS/TLS), access controls and regular updates. No system is completely secure, but if a personal data breach occurs that is likely to result in a risk to you, we will notify the Dutch Data Protection Authority and, where required, the people affected.
Under the GDPR you have the right to:
To exercise these rights, email support@viggo-sntv.com. We will respond within one month; this can be extended by two further months for complex requests, in which case we will let you know. We may ask you to confirm your identity. Exercising your rights is free of charge.
You also have the right to lodge a complaint with a data protection authority. In the Netherlands this is the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl). You can also complain to the authority in the EU country where you live or work.
Our website and application use cookies and similar technologies that are strictly necessary for them to work. We only use analytics or marketing cookies, or similar technologies on your device, with your prior consent, which you can withdraw at any time. We currently do not use analytics or marketing cookies on our website or in our application.
The Service is not directed at children. Business accounts are for adults only. We do not knowingly collect personal data from children under 16 on the basis of consent. If you believe a child has provided personal data to us, please contact us and we will delete it.
The in-room application is a launcher: it lets guests open third-party apps and services, such as streaming apps. When you use a third-party app or website, its own privacy policy applies and we are not responsible for how it processes your data. We recommend signing out of personal accounts at the end of your stay.
We may update this Privacy Policy, for example when our Service or the law changes. The "Last updated" date above shows when it was last changed. If we make significant changes, we will inform business customers by email or through the Service before they take effect.
Viggo BV, Nassaukade 338 O, 1053 LW Amsterdam, The Netherlands
Email: support@viggo-sntv.com
Website: viggosmarthotel.com