1.1 We are committed to safeguarding the privacy of our website visitors, service users, individual customers and customer personnel. This includes, but is not limited to, the PublishOne application and the PublishOne | Microsoft Word add-in.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 In this policy, “we”, “us” and “our” refer to Disk’Ad Publishing and Communication B.V. For more information about us, see Section 11.
2. The personal data that we collect
2.1 In this Section 2 we have set out the general categories of personal data that we process[ and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data].
2.2 We may process data enabling us to get in touch with you (“contact data“).
2.3 We may process your website or services user account data (“account data“).
2.4 We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data“).
2.5 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use.
3. Purposes of processing and legal bases
3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
3.2 Operations – We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.3 Relationships and communications – We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business.
3.4 Record keeping – We may process [your personal data] for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
3.5 Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
3.6 Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.7 Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
4. Retaining and deleting personal data
4.1 This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
4.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
4.3 We will retain your personal data as follows:
(a) account data will be retained for a minimum period of one month following the date of closure of the relevant account, and for a maximum period two months following that date; and
(b) usage data will be retained for a maximum period of six months following the date of collection.
4.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5. Your rights
5.1 In this Section 7, we have listed the rights that you have under data protection law.
5.2 Your principal rights under data protection law are:
(a) the right to access – you can ask for copies of your personal data;
(b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure – you can ask us to erase your personal data;
(d) the right to restrict processing – you can ask us to restrict the processing of your personal data;
(e) the right to object to processing – you can object to the processing of your personal data;
(f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
5.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens/my-rights/what-are-my-rights_en.
5.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
6. About cookies
6.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
6.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
6.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
7. Cookies that we use
8. Cookies used by our service providers
9. Managing cookies
9.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
(d) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
10.1 We may update this policy from time to time by publishing a new version on our website.
11. Our details
11.1 This website is owned and operated by Disk’Ad Publishing and Communication B.V.
11.2 We are registered the Netherlands under registration number 33273591, and our registered office is at Laarderhoogtweg 25, 1101 EB Amsterdam, the Netherlands.
11.3 Our principal place of business is Laarderhoogtweg 25, 1101 EB Amsterdam, the Netherlands.