
This Privacy Policy outlines how we collect, use, and protect your personal data in compliance with the Dutch General Data Protection Regulation (AVG/GDPR) and relevant telecommunications laws, particularly concerning our email marketing campaigns. Your privacy is of utmost importance to us.
1. Basis for Processing Your Personal Data: Consent (Opt-in)
For our commercial email campaigns, the primary legal basis for processing your personal data is your explicit, voluntary, and specific consent (opt-in). This means we will only send you commercial emails if you have actively and clearly indicated your agreement.
Key Principles of Consent:
•Voluntary, Specific, and Informed: Your consent must be freely given, without coercion, and not made a condition for accessing other services. The request for consent will clearly state the purpose for which these emails will be sent and how you can withdraw your consent at any time.
•Unambiguous Action: The action you take to provide consent must be clear and unambiguous, leaving no doubt about what you are consenting to.
•Right to Information: We are committed to informing you about your rights regarding your personal data and the purposes of our data processing activities.
2. Handling Existing Data and Lists
Existing Email Lists:
If you were on our email list prior to the implementation of these AVG/GDPR guidelines, we have initiated (or will initiate) an opt-in campaign to re-obtain your active consent. Contacts who do not respond or provide renewed consent will be marked as inactive and will no longer receive commercial emails from us.
Data Retention:
We maintain a digital record within our Customer Relationship Management (CRM) system of the exact time and date of your subscription. This record serves as proof of valid opt-in, demonstrating that your consent was obtained in accordance with AVG/GDPR requirements.
3. Exceptions and Other Applicable Legislation
Transactional Emails:
Emails related to an already agreed-upon transaction, such as order confirmations, shipping updates, or the delivery of a purchased digital product (e.g., an e-book), are considered transactional. These emails fall under an exception and do not require separate opt-in consent.
B2B Marketing:
While the AVG/GDPR also applies to Business-to-Business (B2B) marketing campaigns, the principle of 'legitimate interest' may play a role as a legal basis for processing, in addition to explicit consent. This is considered in conjunction with the Dutch Telecommunications Act. We ensure that our B2B marketing activities are conducted with due consideration for your rights and interests.
4. Your Rights and Unsubscription
Right to Unsubscribe:
Every commercial email you receive from us will include a clear and easily accessible option to unsubscribe. Upon unsubscription, you will immediately cease to receive commercial emails from us. This process will be implemented without undue delay.
Right to Withdraw Consent:
As a data subject, you have the right to withdraw your consent at any time. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal. You can exercise this right by using the unsubscribe link in our emails or by contacting us directly.
Other Data Subject Rights:
In accordance with AVG/GDPR, you also have the right to:
•Access: Request access to the personal data we hold about you.
•Rectification: Request correction of inaccurate or incomplete personal data.
•Erasure (Right to be Forgotten): Request the deletion of your personal data under certain conditions.
•Restriction of Processing: Request that we restrict the processing of your personal data under certain conditions.
•Data Portability: Request to receive your personal data in a structured, commonly used, and machine-readable format.
•Object: Object to the processing of your personal data under certain conditions.
To exercise any of these rights, please contact us using the details provided below.
5. Contact Us
If you have any questions about this Privacy Policy or our data processing practices, please contact us at [email protected].