Privacy Policy

 
 

Last update: June 2019

Table of contents:

  1. ⧴ General

  2. ⧴ Personal Data we collect and use

  3. ⧴ Use of your Personal Data

  4. ⧴ Disclosing your Personal Data

  5. ⧴ Data retention

  6. ⧴ Security

  7. ⧴ Data transfer

  8. ⧴ Your rights in regard to your Personal Data

  9. ⧴ Changes to this Privacy Policy

  10. ⧴ Contact information

1. General

1.1. Our website www.crowdmedia.com (the “Site”) and the services available through it/contained therein are owned and operated by or on behalf of Crowd Media B.V.; (“data controller”, "we," "our" or "us"). This Privacy Policy applies to all Personal Data that is collected and used by us when you when you visit, register or use the Site or use or register to any service we offer through the Site (‘Services’). Please be advised that the practices described in this Privacy Policy apply only to information gathered through this Site and, where applicable, through our human resources department in connection with this Site, and do not necessarily reflect our practices with respect to information gathered through other websites operated by us or any third-party (including our subsidiaries) or through offline means.

1.2. This Privacy Policy explains the ways in which we may collect, store, use and, in certain
circumstances, disclose (all together “process”) your Personal Data in accordance with all applicable laws.

1.3. Please read this Privacy Policy carefully, and if you have any questions, feel free to contact us. If you do not agree with the terms of this Privacy Policy, then do not browse our Site and/or use our Services available through it/contained therein.

1.4. "Personal Data", as used in this Privacy Policy, means any information relating to an identifiable person who can be, directly or indirectly, identified in particular by reference to an identifier. To give you a clearer idea of the aforesaid definition, Personal Data may include your name and last name, company details, postal address, mobile telephone number, e-mail address, age; basically, any information that may be personally associated with you. In § 2 below, we describe your Personal Data we process.


2. Personal Data we collect and use

We will collect personal information from you in the course of our business, including through your use of our Site, such as when you contact or request information from us, when you subscribe to our news updates, when you engage our Services or as a result of your relationship with one or more of our staff or subsidiaries.

(a) Specific information you provide

When you contact us, or book a consultation with us by filling in our ‘Contact Form’ on our Site, you will provide us with specific information about you, such as your name and last name, email address, company name and the subject of the message you will to send to us.

Also, you will provide us with your email address in case you sign up to our news updates.

Lastly, when you apply to one of our job postings under ‘Careers’, we will collect your name and job title, contact details (including e-mail address and mobile phone number), curriculum vitae, including your age and/or gender and, when required, the information on your immigration status and whether you can lawfully work and if you provide that to us, your education, employment history and similar matters and information that you may provide to us, as well as any other information that might be relevant to potential recruitment to us or any of our subsidiaries. Please note we may also receive data from third-party recruiters, agents and similar organizations as a part of the recruitment process, or as a referral from one of our employees or clients.

(b) Browsing information

When you browse our Site and/or use our Services available through it/contained therein, our servers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your browsing activities, and use of the Services. We may combine this “activity information” with other Personal Data we collect about you.  

Generally, we may use this activity information to understand how our Services and/or Sites are used, track bugs and errors, improve our Services and Site, help us with recruitment purposes, carry out requests made by you on the Site or in relation to our Services, verify account credentials, allow logins, track sessions, prevent fraud, and protect our Services and Siteand for analytics purposes. For more detailed information about these mechanisms and how we collect activity information, see our Cookie Policy.

(c) Social Media Plug-ins

Our Site contains social media plug-ins, such as LinkedIn, Instagram, Facebook, Twitter or YouTube to enable you to follow our profile on these platforms. Please note that visitors of our Site should consult these other platforms’ privacy policies, as we do not have control over information that is submitted to, or collected by, these social media channels.  

3. Use of your Personal Data

3.1. We only use your Personal Data for the purposes described in this Privacy Policy and/or for the purposes described in other privacy notices that we might use for particular services. For any other purposes that are not described in this Privacy Policy, we will use your Personal Data only in case we have obtained an additional prior consent from you or in case we are otherwise authorized or required by law to use your Personal Data for that other purposes; in regard to the latter case, we will inform you about such a scenario.

3.2. We collect and use your Personal Data for the purposes set out below.

For the performance of our agreement with you:

  • To provide the Services you requested;

  • To contact you when you reach us or request information from us through the contact form;

  • To send you the news updates you signed up to;

  • Provision, billing and performance of our Site and our Services contained therein/available through it.

To comply with a legal obligation to which we are subject:

  • Any information referred to above in the section ‘Personal Data we collect and use’ may be used to maintain appropriate business records, to comply with lawful requests by public authorities and to comply with applicable laws and regulations or as otherwise required by law.

For our legitimate commercial interests:

  • Developing new Services, such based on your use of our Services;

  • Auditing, research and (statistical) analysis in order to maintain, protect and improve our Site and our Services contained therein/available through it and to get client insight;

  • The Personal Data referred to above in § 2 may also be used by us:

    • to generate aggregated statistics about the visitors of our Site and Services;

    • to assist in security and fraud prevention;

    • for system integrity purposes (preventing hacking, cheats, spamming, etc.);

    • to facilitate our business operations, to operate company policies and procedures;

    • to enable us to merge, sell, acquire, or transfer assets; and

    • for other legitimate business purposes permitted by applicable law.

For recruitment purposes in the ‘Careers’ section:

  • to assess your suitability for any position you may apply at Crowd Media or any of our subsidiaries, including internships;

  • Where necessary and in accordance with this Policy, we will require references and information to carry out background checks.

For marketing communications:

  • Upon your explicit consent hereto (to the extent such consent is required) your Personal Data may also be used by us in order to inform you about our Services and special events through our news updates. We may contact you via e-mail, telephone, post, SMS or equivalent electronic means - depending on what contact information we have received from you.

4. Disclosing your Personal Data

We do not sell or otherwise transfer your Personal Data to third-parties except in cases as described in this Privacy Policy. We will share your Personal Data with:

  1. Service Providers. We may engage third-party vendors, agents, service providers, hosting providers and affiliated entities to provide services to us, such as billing services, support for IT services and recruitment services. In providing their services, they may access, receive, maintain or otherwise process Personal Data on our behalf. Consistent with applicable legal requirements, we take commercially reasonable steps to require third-parties to adequately safeguard your Personal Data and only process it in accordance with our instructions.

  2. Third-parties in case of legal requirement. We will also disclose your  Personal Data if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes (e.g. tax authorities); when we believe necessary or appropriate to disclose personal data to law enforcement authorities, such as to investigate actual or suspected fraud or violations of law, breaches of security, or breaches of this Policy; to respond to any claims against us; and, to protect the rights, property, or personal safety of us, our customers, or the public.

  3. Corporate Transaction. In addition, information about customers or clients may be disclosed as part of any merger, sale, transfer of our assets, acquisition, bankruptcy, or similar event.

5. Data retention

We will only process your Personal Data for as long as we need it in order to be able to provide our Services to you, to execute any other functions as described herein and/or to fulfill any legal
requirements.

We retain your Personal Data for as long as required to satisfy the purpose for which they were collected and used, unless a longer period is necessary for our legal obligations (such as storing your details for billing purposes) or to defend a legal claim. As statutory retention periods can vary depending on the record at stake, please contact us for more information.

6. Security

Protecting your Personal Data is important to us. We use industry standard technology to protect your Personal Data. We take reasonable steps to ensure that your Personal Data are properly secured using appropriate technical, physical, and organizational measures, so that they are protected against unauthorised or unlawful use, alteration, unauthorised access or disclosure, accidental or wrongful destruction, and loss. Unfortunately, no data transmission over the Internet and via mobile communications networks can be guaranteed to be 100% secure. As a result thereof, while we are committed to protecting your Personal Data, we cannot ensure or warrant the security of any information you transmit to or through us.

7. Data transfer

Your Personal Data may be transferred to -and maintained on- computers located outside of your state, province, country or governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

Where we are legally required to do so, we have legally acceptable mechanisms in place that ensure an adequate level of protection for the transfers of Personal Data to parties outside your jurisdiction. For example, for data transfers from EU/EEA to countries outside this region, we have European Commission-approved Standard Contractual Clauses or similar safeguards in place, allowing such data transfers.

8. Your rights in regard to your Personal Data

8.1. In the following you will find a list with all individual rights you have in regard to the Personal Data we hold about you:

Your right of access

If you ask us, we will confirm whether we are processing your personal information and, if necessary, provide you with a copy of that personal information (along with certain other details). Please note that you might need to send us a copy of your passport ID or any other legal document that may verify your identity, too; this verification procedure is necessary in order to protect your Personal Data from unauthorized access through any other person.

Your right to rectification

You are entitled to request to have it rectified, if the personal information we hold about you is inaccurate or incomplete. If you are entitled to rectification and if we have shared your personal information with others, we will let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.


Your right to erasure

In certain circumstances, you can ask us to delete or remove your personal information such as where we no longer need it or if you withdraw your consent (where applicable), provided there is no overriding legitimate interest for continuing the processing. If you are entitled to erasure and if we have shared your personal information with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.


Your right to restrict processing

In certain circumstances, you can ask us to 'block' or suppress the processing of your personal information, such as where you contest the accuracy of that personal information or you object to us. If you are entitled to restriction and if we have shared your personal information with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.

Your right to data portability

In certain circumstances, you have the right to obtain personal information you have provided us with (in a structured, commonly used and machine readable format such as Microsoft Excel) and to reuse it elsewhere or to ask us to transfer this to a third-party of your choice.

Your right to object

You can ask us to stop processing your personal information, and we will do so, if we are:

  • relying on our own or some else’s legitimate interest to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or

  • processing your personal information for direct marketing purposes.

Your right to withdraw consent

If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

Your right to lodge a complaint with the supervisory authority

You have, at any time moving forward and in any case, the right to lodge a complaint with your relevant data protection authority if you think that we have violated your rights and/or are not in compliance with any applicable Personal Data protection regulation.

8.2. Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process.

8.3. Please note that we might not be able to provide you with our Services anymore in case you have exercised any of your rights described above. However, any time you reuse our Service after exercising any of the aforesaid rights, your then provided Personal Data may be processed, without regard to your previously exercised right(s), in accordance with the provisions of this Privacy Policy.

8.4. Erasing your Personal Data will delete the data only in our database. These deletions will not delete Personal Data that may have already been shared with or collected by third-parties, all as provided above in this Privacy Policy. Unless it is impossible or involves disproportionate effort, we will take reasonable steps to contact any other recipient of your Personal Data and request the deletion of your Personal Data.

8.5. With regard to any respective request as described above that you may place, we have 1 (one) month from the date of your request to fulfill said request.

9. Changes to this Privacy Policy

We may make changes to this Privacy Policy from time to time. To ensure that you are always aware of how we use your personal information, we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. Therefore, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.


10. Contact information

We welcome your comments regarding this Privacy Policy.

For general inquiries or complaints regarding us or our Services, please contact us through our contact form.

If you have any questions or you want to exercise your rights as set out in this Privacy Policy, please contact us by sending an email to privacy[at]crowdmobile.com.

You may also contact us by sending a letter to the following address:

Crowd Media B.V.

Piet Heinkade 95B

1019 GM Amsterdam

The Netherlands