Last update: June 2019
Table of contents:
⧴ Personal Data we collect and use
⧴ Use of your Personal Data
⧴ Disclosing your Personal Data
⧴ Data retention
⧴ Data transfer
⧴ Your rights in regard to your Personal Data
⧴ Contact information
circumstances, disclose (all together “process”) your Personal Data in accordance with all applicable laws.
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
(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
3.2. 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
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.
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.
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
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.
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.
8.5. 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.
10. Contact information
For general inquiries or complaints regarding us or our Services, please contact us through our contact form.
You may also contact us by sending a letter to the following address:
Crowd Media B.V.
Piet Heinkade 95B
1019 GM Amsterdam