We take your privacy seriously. We comply with the new General Data Protection Regulation (“GDPR”), which replaced the different privacy laws in European member states as per 25 May 2018, and other relevant laws and regulations regarding privacy. This legislation will hereinafter be referred to as the “Relevant Legislation”.
Personal Data refers to all the information that could allow you to be directly or indirectly identified. This definition is in accordance with the Relevant Legislation. This is a broad definition: even dynamic IP addresses are considered to be personal data in some circumstances.
We collect and process most personal data on behalf of our customers within the context of our Services. Our customers define the purpose and the means of such processing of personal data, which means they act as “Data Controller” within the meaning of the Relevant Legislation. We only process such personal data following the instructions of our customers and not for our own purposes. Within this context we therefore act as “Data Processor” within the meaning of the Relevant Legislation.
Apart from the processing of personal data for the sake of our customers, we also collect and process some personal data for our own purposes. Within this context we act as Data Controller ourselves within the meaning of the Relevant Legislation.
We adapt as data Processor
As Data Processor we collect and process personal data on behalf of our customers. We process these personal data exclusively to provide our Services to our customers, i.e. to create dynamic video ads through our platform. Our customers are solely responsible for the personal data used in and the distribution of such ads. This implies inter alia that we will never view said personal data or store a copy of them for our own purposes. Furthermore, we will delete these personal data, as soon as our customers ask for this. These and other commitments have been laid down in a data processing agreement between We adapt and our customers.
We adapt as Data Controller
As Data Controller we collect and process the following personal data of our clients and the users of our Website and Console:
|(Personal) Data:||Purpos(es):||Why may we process these Personal Data?|
|If you use our website: IP-address, functional cookies and technical information (i.e. type of browser and operating system) Optional: analytical, tracking and marketing cookies||We use this information to: |
– Analyse (the use of) our Website;
– Improve our Website and Services.
– Show you relevant advertisements based on your interests
|We have a legitimate interest to use technical information, functional cookies and your IP-address, namely to analyse and improve our website. |
We ask for your unambiguous consent to use tracking, marketing and analytical cookies. You may always withdraw your consent.
|If you request a demo on the website: Name, company name, industry, e-mail address and phone number||We use this information to contact you and send you information regarding the demo you requested.||By filling in these data in the demo request on our Website, you give us your unambiguous consent to process these data. You may always withdraw your consent.|
|If you subscribe to our newsletter: E-mail address||We use your e-mail address to send you newsletters about our Services.||By signing up for our newsletter on our Website, you give us your unambiguous consent to process your e-mail address for this purpose. You may always withdraw your consent.|
|Contact information of our clients: Name, phone number and e-mail address||We use this information to contact our client regarding the Services we provide them.||We may process these data, because they are necessary to perform the contract with our clients.|
|Other information of our clients: Company name, payment information and VAT-number||We use this data to: |
– invoice our clients;
– be included in our financial administration for the benefit of the tax authorities;
|We may process these data, because they are necessary to perform the contract with our clients. Also, we are legally obligated to keep a financial administration for the benefit of the tax authorities.|
We adapt as Data Processor:
As Data Processor we store the personal data for our customers as long as the customer in question uses our Services and uses the personal data within this context. If the cooperation with the customer ends, then we will still store the data for 12 months. After this term we will remove or destroy the personal data and all their copies, save we are held by law to store the data for a longer period.
We adapt as Data Controller:
As Data Controller, we remove the personal data as soon as they are no longer necessary for the purposes stated above. In no event will the personal data be stored for more than five years following the date on which they have been changed for the last time.
For the specific retention periods of the cookies we use, please read our cookie statement.
We adapt as Data Processor:
As Data Processor, we process the personal data on behalf of our customers only according to their instructions. We will never share these personal data with someone else, save our customers order us to do so.
However, it is possible that we use the services of “(Sub) Data Processors” (by order of our customers), for instance for storing the data. Within this context such Sub Data Processors will receive personal data. The (Sub) Data Processors must strictly follow our instructions and those of our customers regarding the processing of such personal data. Therefore, they will not use the personal data for their own purposes. We will ensure that all (Sub) Data Processors comply with the requirements of the Relevant Legislation.
The (Sub) Data Processors we may use as Data Processor, with the consent of our customers, are for instance: Google Cloud.
We adapt as Data Controller:
We also use the services of (Sub) Data Processors for the personal data we process for our own purposes.
The (Sub) Data Processors we may use as Data Controller are for instance: Hubspot, DocSend.
Apart from the above, we will not share your data with third parties – unless we are legally obliged to do so.
We may transfer personal data to parties outside the EU, if our customers ask for this or if one of our Sub Data Processors is established outside the EU. The personal data will only be transmitted to countries and/or parties offering an adequate level of protection which meets the European standards.
If we use Sub Data Processors established outside the EU on behalf of our customers and the Sub Data Processor does not offer an adequate level of protection in accordance with the European standards, then we will record this in the agreements with our customer. The customer, being Data Controller, will ensure that the required permission is obtained from the data subjects for the use of these parties.
Transfer of data outside the EU will always be in accordance with the Relevant Legislation (such as Chapter 5 of the GDPR).
We may convert your personal data in non-personal data. This means that the data will be fully and irreversibly anonymized and aggregated: in that case they do not include any personal data anymore, because no identification can take place on the basis of the data. We may share such aggregated data with business partners for analytical purposes, demographic profiling and improving our services.
We protect all the personal data we process from unauthorized or unlawful access, change, disclosure, use and destruction. We take the following technical and organizational measures to protect the data:
We use the following types of cookies:
Functional cookies: Functional cookies are essential to the operation of our Website. They allow you to navigate through our Website and use the functions incorporated in it.
Analytical or statistical cookies: Analytical cookies are used to review the quality and effectiveness of the Website. For instance, we can see how many users visit the Website and what pages are visited. We use this information to improve our Website and services.
Tracking cookies: Tracking cookies follow the click behaviour and surfing behaviour of our visitors.
Marketing cookies: Marketing cookies allow us to show our visitors relevant advertisements based on their interests.
If you do not wish to have cookies sent to your computer, you can change this through the cookie settings of your browser. Bear in mind that some functions or services of our Website may not function, or not so well, without cookies.
You can find (hyper) links on our Website and in the Console which link to the websites of partners, providers, advertisers, sponsors, licensors or any other third parties. We have no control of the content or the links which appear on said websites and we are not responsible for the practices of websites linked to from our Website and Console. Furthermore, these websites, including their content and links, may constantly change. These websites may have their own privacy policies, user conditions and customer policies. Browsing and interaction on any other website, including websites linked to from our Website or Console, are subject to the terms and conditions of such website.
As described in the Relevant Legislation, you have the right to:
If you have any questions, comments or concerns regarding the way in which we process your personal data, please contact us through the contact data below.
1017 GW Amsterdam
Chamber of Commerce number: 66174910
VAT number: NL852521480