PRIVACY
NOTICE
Last
updated July 30, 2021
Thank you for
choosing to be part of our community at Digitum
("
Company
",
"we", "us", "our"). We are committed to
protecting your personal information and your right to privacy. If you have any questions or
concerns about this privacy notice, or our practices with regards to your personal information,
please contact us at pp@digitum.nl.
When you
visit our website https://digitum.nl/ (the
"Website"),
and more generally, use any of our services (the "Services",
which include the
Website
), we appreciate
that you are trusting us with your personal information. We take your privacy very seriously. In
this privacy notice, we seek to explain to you in the clearest way possible what information we
collect, how we use it and what rights you have in relation to it. We hope you take some time to
read through it carefully, as it is important. If there are any terms in this privacy notice that
you do not agree with, please discontinue use of our Services immediately.
This privacy notice applies
to all information collected through our Services (which, as described above, includes
our
Website
), as well as, any
related services, sales, marketing or events.
Please read this
privacy notice carefully as it will help you understand what we do with the information
that we collect.
TABLE OF
CONTENTS
1. WHAT
INFORMATION DO WE COLLECT?
Personal information you disclose to
us
In
Short: We collect
personal information that you provide to
us.
We collect
personal information that you voluntarily provide to us when you
express an interest in obtaining information
about us or our products and Services, when you participate in activities on the
Website
or otherwise when you contact
us.
The personal
information that we collect depends on the context of your interactions with us and the
Website
, the choices you make and the products and features you use. The personal
information we collect may include the following:
Personal
Information Provided by You. We collect
email addresses;
names;
and other similar information.
All personal
information that you provide to us must be true, complete and accurate, and you must notify us
of any changes to such personal information.
Information automatically
collected
In
Short: Some
information — such as your Internet Protocol (IP) address and/or browser and
device characteristics — is collected automatically when you visit our
Website
.
We
automatically collect certain information when you visit, use or navigate the
Website
. This information does not reveal your specific identity (like your name or
contact information) but may include device and usage information, such as your IP address,
browser and device characteristics, operating system, language preferences, referring URLs,
device name, country, location, information about how and when you use our
Website
and other technical information. This information is primarily needed to
maintain the security and operation of our
Website
, and for our internal analytics and reporting purposes.
Like many
businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice:
digitum.nl/cookies.
The information
we collect includes:
- Log and
Usage Data. Log and usage data is service-related, diagnostic, usage and
performance information our servers automatically collect when you access or use our
Website
and which we record in log files.
Depending on how you interact with us, this log data may include your IP address, device
information, browser type and settings and information about your activity in the
Website
(such as the date/time stamps
associated with your usage, pages and files viewed, searches and other actions you take such
as which features you use), device event information (such as system activity, error reports
(sometimes called 'crash dumps') and hardware settings).
- Device
Data. We collect device data such as information about your computer, phone, tablet
or other device you use to access the
Website
. Depending on the device used, this device data may include information
such as your IP address (or proxy server), device and application identification numbers,
location, browser type, hardware model Internet service provider and/or mobile carrier,
operating system and system configuration information.
- Location Data.
We collect location data such as
information about your device's location, which can be either precise or imprecise. How much
information we collect depends on the type and settings of the device you use to access the
Website
. For example, we may use GPS and other
technologies to collect geolocation data that tells us your current location (based on your
IP address). You can opt out of allowing us to collect this information either by refusing
access to the information or by disabling your Location setting on your device. Note
however, if you choose to opt out, you may not be able to use certain aspects of the
Services.
2. HOW DO WE
USE YOUR INFORMATION?
In Short: We
process your information for purposes based on legitimate business
interests, the fulfillment of our contract with you, compliance with our
legal obligations, and/or your
consent.
We use personal
information collected via our
Website
for a variety of business purposes described below. We process your personal
information for these purposes in reliance on our legitimate business interests, in order to
enter into or perform a contract with you, with your consent, and/or for compliance with our
legal obligations. We indicate the specific processing grounds we rely on next to each purpose
listed below.
We use the
information we collect or receive:
- To
facilitate account creation and logon process. If you choose to link your
account with us to a third-party account (such as your Google or Facebook account), we use
the information you allowed us to collect from those third parties to facilitate account
creation and logon process for the performance of the contract.
- To
post testimonials. We post testimonials on our
Website
that may contain personal
information. Prior to posting a testimonial, we will obtain your consent to use your name
and the content of the testimonial. If you wish to update, or delete your testimonial,
please contact us at
pp@digitum.nl
and be sure to include your name, testimonial location, and
contact information.
- Request
feedback. We may use your
information to request feedback and to contact you about your use of our
Website
.
- To
enable user-to-user communications. We may use your information in order to
enable user-to-user communications with each user's consent.
- To
manage user accounts. We may use your information for the purposes of
managing our account and keeping it in working order.
- To
send administrative information to you. We may use your personal
information to send you product, service and new feature information and/or information
about changes to our terms, conditions, and policies.
- To
protect our Services. We may use your information as part of our efforts
to keep our
Website
safe and secure (for example,
for fraud monitoring and prevention).
- To
enforce our terms, conditions and policies for business purposes, to comply with legal
and regulatory requirements or in connection with our contract.
- To respond to
legal requests and prevent harm. If we receive a subpoena or other
legal request, we may need to inspect the data we hold to determine how to respond.
- Fulfill and
manage your orders. We may use your information to fulfill and manage
your orders, payments, returns, and exchanges made through the
Website
.
- Administer prize
draws and competitions. We may use your information to administer prize
draws and competitions when you elect to participate in our competitions.
- To deliver and
facilitate delivery of services to the user. We may use your information to
provide you with the requested service.
- To respond to
user inquiries/offer support to users. We may use your information to
respond to your inquiries and solve any potential issues you might have with the use of
our Services.
- To
send you marketing and promotional communications. We and/or our third-party
marketing partners may use the personal information you send to us for our marketing
purposes, if this is in accordance with your marketing preferences. For example, when
expressing an interest in obtaining information about us or our
Website
, subscribing to marketing or
otherwise contacting us, we will collect personal information from you. You can opt-out of
our marketing emails at any time (see the "WHAT ARE YOUR PRIVACY
RIGHTS?"
below).
- Deliver
targeted advertising to
you. We may use your
information to develop and display personalized content and advertising (and work with third
parties who do so) tailored to your interests and/or location and to measure its
effectiveness.
For more information see our Cookie Notice:
digitum.nl/cookies
.
3. WILL
YOUR INFORMATION BE SHARED WITH
ANYONE?
In
Short: We only share
information with your consent, to comply with laws, to provide you with services, to
protect your rights, or to fulfill business obligations.
We may
process or share your data that we hold based on the following legal basis:
- Consent: We may process your data if you
have given us specific consent to use your personal information for a specific
purpose.
- Legitimate
Interests: We may process your
data when it is reasonably necessary to achieve our legitimate business interests.
- Performance
of a Contract: Where we have
entered into a contract with you, we may process your personal information to fulfill
the terms of our contract.
- Legal
Obligations: We may disclose your
information where we are legally required to do so in order to comply with applicable
law, governmental requests, a judicial proceeding, court order, or legal process, such
as in response to a court order or a subpoena (including in response to public
authorities to meet national security or law enforcement requirements).
- Vital
Interests: We may disclose your
information where we believe it is necessary to investigate, prevent, or take action
regarding potential violations of our policies, suspected fraud, situations involving
potential threats to the safety of any person and illegal activities, or as evidence in
litigation in which we are involved.
More
specifically, we may need to process your data or share your personal information in the
following situations:
- Business
Transfers. We may share or
transfer your information in connection with, or during negotiations of, any merger,
sale of company assets, financing, or acquisition of all or a portion of our business to
another company.
- Vendors, Consultants and Other Third-Party
Service Providers. We may share your data with third-party vendors,
service providers, contractors or agents who perform services for us or on our
behalf and require access to such information to do that work. Examples include:
payment processing, data analysis, email delivery, hosting services, customer
service and marketing efforts. We may allow selected third parties to use tracking
technology on the
Website
, which will enable
them to collect data on our behalf about how you interact with our
Website
over time. This
information may be used to, among other things, analyze and track data, determine
the popularity of certain content, pages or features, and better understand online
activity. Unless described in this notice, we do not share, sell, rent or trade any
of your information with third parties for their promotional purposes.
We have contracts in place with our data processors,
which are designed to help safeguard your personal information. This means that they
cannot do anything with your personal information unless we have instructed them to
do it. They will also not share your personal information with any organization
apart from us. They also commit to protect the data they hold on our behalf and to
retain it for the period we instruct.
- Affiliates. We may share your
information with our affiliates, in which case we will require those affiliates
to honor this privacy notice. Affiliates include our parent company and any
subsidiaries, joint venture partners or other companies that we control or that
are under common control with us.
4.
WHO WILL YOUR
INFORMATION BE SHARED
WITH?
In
Short: We only share information with
the following categories of third
parties.
We only share and disclose
your information with the
following
categories
of
third parties. If we have
processed your data based on your consent and you wish to
revoke your consent, please contact us using the contact
details provided in the section below titled "HOW CAN
YOU CONTACT US ABOUT THIS
NOTICE?".
-
Performance Monitoring Tools
5.
DO WE USE COOKIES AND
OTHER TRACKING
TECHNOLOGIES?
In
Short: We may use cookies and other
tracking technologies to collect and store your
information.
We
may use cookies and similar tracking
technologies (like web beacons and pixels) to access or store
information. Specific information about how we use such technologies and
how you can refuse certain cookies is set out in our Cookie Notice
:
digitum.nl/cookies
.
6.
HOW LONG DO WE KEEP
YOUR
INFORMATION?
In
Short: We keep your information for
as long as necessary to fulfill the purposes outlined in this
privacy notice unless otherwise required by
law.
We
will only keep your personal
information for as long as it is necessary for the purposes set out in
this privacy notice, unless a longer retention period is required or
permitted by law (such as tax, accounting or other legal requirements).
No purpose in this notice will require us keeping your personal
information for longer than
2 years
.
When we have no ongoing legitimate
business need to process your personal information, we will either
delete or anonymize such information, or, if this is not possible (for
example, because your personal information has been stored in backup
archives), then we will securely store your personal information and
isolate it from any further processing until deletion is possible.
7.
HOW DO WE KEEP YOUR
INFORMATION
SAFE?
In
Short: We aim to protect your
personal information through a system of organizational and
technical security measures.
We
have implemented appropriate technical
and organizational security measures designed to protect the security of
any personal information we process. However, despite our safeguards and
efforts to secure your information, no electronic transmission over the
Internet or information storage technology can be guaranteed to be 100%
secure, so we cannot promise or guarantee that hackers, cybercriminals,
or other unauthorized third parties will not be able to defeat our
security, and improperly collect, access, steal, or modify your
information. Although we will do our best to protect your personal
information, transmission of personal information to and from our
Website
is at your own risk. You should only access the
Website
within a secure environment.
8.
DO WE COLLECT
INFORMATION FROM
MINORS?
In
Short: We do not knowingly collect data
from or market to children under 18 years of
age.
We
do not knowingly solicit data from or
market to children under 18 years of age. By using the
Website
,
you represent that you are at least 18 or that you are the parent or
guardian of such a minor and consent to such minor dependent’s use of
the
Website
.
If we learn that personal information from users less than 18 years of
age has been collected, we will deactivate the account and take
reasonable measures to promptly delete such data from our records. If
you become aware of any data we may have collected from children under
age 18, please contact us at
pp@digitum.nl
.
9.
WHAT ARE YOUR PRIVACY
RIGHTS?
In
Short:
In some regions, such as the
European Economic Area (EEA) and United Kingdom (UK), you have
rights that allow you greater access to and control over your
personal information.
You may review, change, or
terminate your account at any time.
In
some regions (like the EEA and UK), you
have certain rights under applicable data protection laws. These may
include the right (i) to request access and obtain a copy of your
personal information, (ii) to request rectification or erasure; (iii) to
restrict the processing of your personal information; and (iv) if
applicable, to data portability. In certain circumstances, you may also
have the right to object to the processing of your personal information.
To make such a request, please use the contact
details provided below. We will consider
and act upon any request in accordance with applicable data protection
laws.
If
we are relying on your consent to
process your personal information, you have the right to withdraw your
consent at any time. Please note however that this will not affect the
lawfulness of the processing before its withdrawal, nor will it affect
the processing of your personal information conducted in reliance on
lawful processing grounds other than consent.
Cookies and similar
technologies: Most Web browsers are set to accept
cookies by default. If you prefer, you can usually choose to set your
browser to remove cookies and to reject cookies. If you choose to remove
cookies or reject cookies, this could affect certain features or services of
our
Website
.
To opt-out of interest-based advertising by advertisers on our
Website
visit http://www.aboutads.info/choices/.
For further information, please see our Cookie
Notice:
digitum.nl/cookies.
10.
CONTROLS FOR DO-NOT-TRACK
FEATURES
Most
web browsers and some mobile operating
systems and mobile applications include a Do-Not-Track ("DNT") feature or
setting you can activate to signal your privacy preference not to have data
about your online browsing activities monitored and collected. At this stage
no uniform technology standard for recognizing and implementing DNT signals
has been finalized. As such, we do not currently respond to DNT browser
signals or any other mechanism that automatically communicates your choice
not to be tracked online. If a standard for online tracking is adopted that
we must follow in the future, we will inform you about that practice in a
revised version of this privacy notice.
11. DO
CALIFORNIA RESIDENTS
HAVE SPECIFIC PRIVACY
RIGHTS?
In
Short: Yes, if you are a resident of
California, you are granted specific rights regarding access to your
personal information.
California Civil Code Section 1798.83, also
known as the "Shine The Light" law, permits our users who are California
residents to request and obtain from us, once a year and free of charge,
information about categories of personal information (if any) we disclosed
to third parties for direct marketing purposes and the names and addresses
of all third parties with which we shared personal information in the
immediately preceding calendar year. If you are a California resident and
would like to make such a request, please submit your request in writing to
us using the contact information provided below.
If you
are under 18 years of age, reside in
California, and have a registered account with
the Website
,
you have the right to request removal of unwanted data that you publicly
post on the
Website
.
To request removal of such data, please contact us using the contact
information provided below, and include the email address associated with
your account and a statement that you reside in California. We will make
sure the data is not publicly displayed on the
Website
,
but please be aware that the data may not be completely or comprehensively
removed from all our systems (e.g. backups, etc.).
CCPA Privacy
Notice
The California Code of
Regulations defines a "resident"
as:
(1)
every individual who is in the State of
California for other than a temporary or transitory purpose
and
(2)
every individual who is domiciled in the
State of California who is outside the State of California for a temporary
or transitory purpose
All
other individuals are defined as
"non-residents."
If this
definition of "resident" applies to
you, we must adhere to certain rights and obligations regarding your
personal information.
What categories of personal
information do we collect?
We have
collected the following categories of
personal information in the past twelve (12) months:
Category
|
Examples
|
Collected
|
|
A.
Identifiers
|
Contact details, such as real
name, alias, postal address, telephone or mobile contact
number, unique personal identifier, online identifier,
Internet Protocol address, email address and account
name
|
NO
|
|
B. Personal information
categories listed in the California Customer Records
statute
|
Name, contact information,
education, employment, employment history and financial
information
|
YES
|
|
C. Protected classification
characteristics under California or federal
law
|
Gender and date of
birth
|
NO
|
|
D. Commercial
information
|
Transaction information,
purchase history, financial details and payment
information
|
NO
|
|
E. Biometric
information
|
Fingerprints and
voiceprints
|
NO
|
|
F. Internet or other similar
network activity
|
Browsing history, search
history, online behavior, interest data, and interactions
with our and other websites, applications, systems and
advertisements
|
NO
|
|
G. Geolocation
data
|
Device
location
|
NO
|
|
H. Audio, electronic, visual,
thermal, olfactory, or similar
information
|
Images and audio, video or
call recordings created in connection with our business
activities
|
NO
|
|
I. Professional or
employment-related information
|
Business contact details in
order to provide you our services at a business level, job
title as well as work history and professional
qualifications if you apply for a job with
us
|
NO
|
|
J. Education
Information
|
Student records and directory
information
|
NO
|
|
K. Inferences drawn from other
personal information
|
Inferences drawn from any of
the collected personal information listed above to create a
profile or summary about, for example, an individual’s
preferences and characteristics
|
NO
|
We may
also collect other personal information
outside of these categories instances where you interact with us in-person,
online, or by phone or mail in the context of:
- Receiving help through our customer
support channels;
- Participation in customer surveys or
contests; and
- Facilitation in the delivery of our
Services and to respond to your inquiries.
How do we use and share your personal
information?
Digitum collects and shares your personal
information through:
- Targeting cookies/Marketing cookies
More information about our data
collection and sharing practices can be found in this privacy
notice
and our Cookie Notice:
digitum.nl/cookies
.
You may contact us
by visiting https://digitum.nl/,
or by
referring to the contact details at the
bottom of this document.
If you are using an authorized agent
to exercise your right to opt-out we may deny a request if the
authorized agent does not submit proof that they have been validly
authorized to act on your behalf.
Will your information be
shared with anyone else?
We may disclose your personal
information with our service providers pursuant to a written
contract between us and each service provider. Each service provider
is a for-profit entity that processes the information on our
behalf.
We may use your personal information
for our own business purposes, such as for undertaking internal
research for technological development and demonstration. This is
not considered to be "selling" of your personal data.
Digitum
has disclosed the
following categories of personal information to third parties
for a business or commercial purpose in the preceding twelve
(12) months:
- Category B. Personal
information, as defined in the California Customer
Records law, such as your name, contact information,
education, employment, employment history and financial
information.
Digitum
has
not sold any personal information to
third parties for a business or
commercial purpose in the preceding
twelve (12) months. Digitum
will not sell personal information
in the future belonging to website
visitors, users and other
consumers.
Your
rights with respect to your personal
data
Right
to request deletion of the data -
Request to
delete
You can
ask for the deletion of your personal
information. If you ask us to delete
your personal information, we will
respect your request and delete your
personal information, subject to certain
exceptions provided by law, such as (but
not limited to) the exercise by another
consumer of his or her right to free
speech, our compliance requirements
resulting from a legal obligation or any
processing that may be required to
protect against illegal
activities.
Right
to be informed - Request to
know
Depending
on the circumstances, you have a right
to know:
- whether
we collect and use your personal
information;
- the
categories of personal information
that we collect;
- the
purposes for which the collected
personal information is used;
- whether
we sell your personal information to
third parties;
- the
categories of personal information
that we sold or disclosed for a
business purpose;
- the
categories of third parties to whom
the personal information was sold or
disclosed for a business purpose;
and
- the
business or commercial purpose for
collecting or selling personal
information.
In
accordance with applicable law, we are
not obligated to provide or delete
consumer information that is
de-identified in response to a consumer
request or to re-identify individual
data to verify a consumer
request.
Right
to Non-Discrimination for the
Exercise of a Consumer’s Privacy
Rights
We will
not discriminate against you if you
exercise your privacy
rights.
Verification
process
Upon
receiving your request, we will need to
verify your identity to determine you
are the same person about whom we have
the information in our system. These
verification efforts require us to ask
you to provide information so that we
can match it with information you have
previously provided us. For instance,
depending on the type of request you
submit, we may ask you to provide
certain information so that we can match
the information you provide with the
information we already have on file, or
we may contact you through a
communication method (e.g. phone or
email) that you have previously provided
to us. We may also use other
verification methods as the
circumstances
dictate.
We will
only use personal information provided
in your request to verify your identity
or authority to make the request. To the
extent possible, we will avoid
requesting additional information from
you for the purposes of verification.
If, however, we cannot verify your
identity from the information already
maintained by us, we may request that
you provide additional information for
the purposes of verifying your identity,
and for security or fraud-prevention
purposes. We will delete such
additionally provided information as
soon as we finish verifying
you.
Other
privacy
rights
- you
may object to the processing of your
personal data
- you
may request correction of your
personal data if it is incorrect or
no longer relevant, or ask to
restrict the processing of the
data
- you
can designate an authorized agent to
make a request under the CCPA on
your behalf. We may deny a request
from an authorized agent that does
not submit proof that they have been
validly authorized to act on your
behalf in accordance with the
CCPA.
- you
may request to opt-out from future
selling of your personal information
to third parties. Upon receiving a
request to opt-out, we will act upon
the request as soon as feasibly
possible, but no later than 15 days
from the date of the request
submission.
To
exercise these rights, you can contact
us
by visiting
https://digitum.nl/
,
or by referring to
the contact details at the bottom of this
document. If you have a complaint about how we
handle your data, we would like to hear from
you.
12.
DO WE MAKE UPDATES TO
THIS
NOTICE?
In
Short: Yes, we
will update this notice as necessary
to stay compliant with relevant
laws.
We may
update this privacy notice from time to
time. The updated version will be
indicated by an updated "Revised" date
and the updated version will be
effective as soon as it is accessible.
If we make material changes to this
privacy notice, we may notify you either
by prominently posting a notice of such
changes or by directly sending you a
notification. We encourage you to review
this privacy notice frequently to be
informed of how we are protecting your
information.
13.
HOW CAN YOU CONTACT US
ABOUT THIS
NOTICE?
If you
have questions or comments about this
notice, you may
contact our Data
Protection Officer (DPO),
DPO
,
by
email
at
pp@digitum.nl
,
or
by post
to:
Digitum
DPO
__________
Utrecht
Netherlands
14.
HOW CAN YOU REVIEW,
UPDATE, OR DELETE THE
DATA WE COLLECT FROM
YOU?
Based on
the applicable laws of your country, you
may have the right to request access to
the personal information we collect from
you, change that information, or delete
it in some circumstances. To request to
review, update, or delete your personal
information, please
visit:
https://digitum.nl/
.