CONTROLLER AND CONTACT DETAILS
The controller concerning the use of your personal data in the context of the services provided by NSM will always be New Skool Media B.V., with its registered office in Amsterdam and principal place of business at (1114 AE) Spaklerweg 53 in Amsterdam-Duivendrecht (Chamber of Commerce no. 60745967).
YOU ARE NOT REQUIRED TO PROVIDE PERSONAL DATA
As a rule, you are not obliged to provide personal data. You always have the choice whether you want to enter your personal data. However, the provision of personal data is required for a number of services, such as taking out a subscription. When we ask you to provide personal data, we will always indicate which data is necessary to be able to make use of the service in question, and which data is optional. We will also indicate the consequences of refusing to provide this data.
PERSONAL DATA AND PURPOSES OF THE PROCESSING OPERATIONS
NSM obtains personal data in a variety of ways, which it uses for various purposes.
Purchasing a subscription, product or service
When you take out a subscription on one or more publications by NSM, or purchase (through one of our webshops) products (such as publications) or services (such as training courses) from NSM, we will process your contact details (including your name, address, telephone number, and email address) and transaction details (including your bank and payment details). We also process certain data about your use, such as the status of your subscription(s) and data you have provided to us in the context of – for example – an event for which you sign up.
We use this data to be able to implement and deliver the agreed subscriptions, products and/or services. The legal basis for this is the implementation of the agreement we have concluded with you.
We can use your data for purposes of analysis and optimisation (at a non-personal level). The legal basis for this is a legitimate interest of NSM in improving and optimising our products and services.
Visiting an NSM website
NSM offers various websites. If you visit (one of) our websites, we collect a number of data about your visit and the device you have used to visit our website, such as your IP address, your browsing behaviour, and your interests. We do this using cookies and similar technologies.
We use this data to improve the use of our websites, to make you targeted offers, and to be able to show you content and advertisements tailored to your preferences and interests. We can combine your data with data that has been collected in the context of your purchase or your use of our various products or services. This data is used to create a profile, to enable us to offer you better services and to better tailor the content of these products and services (including websites and apps) to your preferences.
The legal basis for the use of personal data collected using cookies and similar technologies depends on the type of cookies. Insofar as we use functional cookies, the basis is the implementation of the agreement. The use of analytical cookies and cookies with minor consequences for your privacy is based on the legitimate interest of NSM in improving and optimising its website. Other cookies, such as tracking cookies, can only be placed after your prior permission. The cookie statement [link] contains more information about which cookies are placed for which purposes and by which parties.
Use of apps
We can use the data collected within an app for purposes of analysis and optimisation (at a non-personal level). The legal basis for this is a legitimate interest of NSM in improving and optimising our apps.
You can create an account on certain NSM websites. An account gives you access to certain (premium) content and makes it easier for you to place orders in the future. You must provide certain (personal) data when you create an account. You can also configure and change certain interests.
The basis for the processing of your personal data in this context is the implementation of the agreement concluded with you, which concerns the creation and implementation of your account..
We can use the data collected within an account for purposes of analysis and optimisation (at a non-personal level). The legal basis for this is a legitimate interest of NSM in improving and optimising our products and services.
Communications from NSM
You can subscribe to communications from NSM in various manners, for example by subscribing to one or more of our newsletters. The newsletter will be tailored to your preferences and interests as much as possible if we are aware of these and if you have given permission for this. If you have an account, you can manage the topics about which you want to receive messages.
After you have purchased one of or our products and/or services, we can send you communications about similar products of services offered by NSM, unless you have indicated at the time of your purchase that you do not to appreciate this. The legal basis for this is a legitimate interest of NSM in deploying marketing activities.
You can always unsubscribe from communications from NSM using the link at the bottom of each received message. You cannot unsubscribe from messages that are necessary for handling orders and other necessary service messages.
We can use a tracking link to see whether your open one of our websites through our newsletters, and recognise you when you visit our websites. This enables us to track which actions you take following the receipt of the email, and to measure the efficiency of our newsletter. We do this using cookies [link]. The legal basis for this is your permission.
When you download one of our apps, you will be asked if you want to receive push messages. You can always change your choice using the app settings.
Participating in online campaigns and competitions
We can offer you the opportunity to participate in online campaigns and competitions through various channels. The data you share with us in this case will be used to carry out the online campaign or competition in order to implement the agreement concluded with you.
We can use the data collected in the context of a campaign for purposes of analysis and optimisation (at a non-personal level). The legal basis for this is a legitimate interest of NSM in improving and optimising our products and services.
You can place messages and contact other users on certain NSM websites. The information you provide will be used to show it on the website in question. The basis is the implementation of the agreement we have concluded with you.
NSM can be found on various social media channels, including Facebook, Instagram, and YouTube. When you follow us on social media, we may be given access to part of your profile data. We can use this information to measure and improve our reach on social media. The basis is a legitimate interest of NSM in improving its social media activities.
NSM also makes use of (marketing) services provided by third parties, such as Facebook Custom Audiences. This enables NSM to target a specific group on social media. NSM can share hashed email addresses with third parties to enable these parties to target people for marketing campaigns. The legal basis for these forms of processing will always be your prior permission.
If you participate in a market survey conducted by NSM, we will use the data you provide to improve our products and services. The legal basis for this form of processing is the implementation of the agreement.
Contact with our customer service department
When you contact our customer service department, you must provide certain contact details. We will use this data to handle your question or requests in order to implement the agreement we have concluded with you. We can store your question, so we will be able to be of better assistance to you at a later time, and to improve our products and services, based on the legitimate interest of NSM in improving its services.
We will not keep your personal data any longer than necessary for the purpose for which you have provided it, unless it must be kept longer in order to comply with a statutory obligation or to safeguard a legitimate interest of NSM.
More specifically, we observe the following retention periods:
- As a rule, the visible data stored in your account will be kept as long as your account is active. If you have not used your account for twelve (12) months, we will send you a message asking you if you want to keep your account. We will remove your data if you have still not responded after a second reminder.
- We observe a retention period of no more than six (6) months for cookies and similar technologies. (Personal) data collected using cookies, such as information about your Internet use, will also be kept for no more than six (6) months.
- If you have subscribed to one or more of our newsletters, we will keep your contact details to be able to distribute these newsletters, until you have informed us that you no longer wish to receive them.
- We observe a retention period of no more than twenty four (24) months for data we collect for purposes like the provision of services and invoices, to be able to handle orders, and to inform you about their progress.
- Data about your participation in competitions or campaigns will be kept for no more than twelve (12) months.
- We keep data we collect through social media for no more than six (6) months.
- If you contact our customer service, your personal data will be kept for no more than twelve (12) months after handling your issue.
SHARING AND DISCLOSING PERSONAL DATA
Companies within the group of New Skool Media B.V. can be given access to your data based on the legitimate interest of NSM in efficient and effective business operations. All companies within the NSM group will offer the same level of protection. The NSM companies can use your data, among other things, to implement the agreement(s) we have concluded with you and to deploy (targeted) marketing activities to maintain a relationship with you.
We can make use of services provided by third parties for the implementation of our services, such as technical service providers and delivery services. These third parties act as processors for NSM in this context. NSM ensures that these parties offer sufficient guarantees concerning the use of technical and organisational measures. NSM has concluded a processing agreement with these parties which, inter alia, sets out that they solely process personal data based on the instructions of NSM.
NSM may cooperate with partners, for example in the context of the provision of services, a competition, or a campaign. These partners can be involved in the implementation of the agreement we have concluded with you. You will be informed of this in a clear manner before you provide data for this purpose or purchase the service.
In all other cases, NSM will only share personal data with third parties with your express permission, or if NSM is required to do so based on laws and regulations, it is required to do so as a result of legal proceedings and/or if it considers this necessary for the protection of its own interests.
We make all possible efforts to take suitable technical and organisational measures to prevent unauthorised access to, modifications to, disclosure or loss of personal data. For example, we make use of a firewall and have taken encryption measures to ensure unauthorised third parties cannot access any data.
Many of our websites offer you the option of accessing, modifying or removing your own personal data. You can also rely on the following rights:
- Access and correction. You can ask us which personal data about you NSM processes for which purposes and/or request us to modify or correct this data.
Deletion. If you no longer agree to the processing of your personal data by NSM or if you believe that the processing of your personal data by NSM is no longer necessary for the purpose for which you have provided it, you can ask us to remove the personal data in question.
- Objection. You can always object against the use of personal data for direct marketing purposes and/or the (continued) receipt of (certain) marketing information. We will not or no longer send you any marketing information in this case. Any emails and all other marketing information we send you contain an unsubscribe option. When we process data based on a legitimate interest of NSM, you can object against this processing of your personal data. We will discontinue the processing operations if no legitimate grounds exist that prevail over your interests.
- Restriction of the processing operations. JYou can ask us to restrict the processing of your personal data if you have valid reasons for this, for example, if you believe that we process your personal data unlawfully or incorrectly, or if you have objected against the processing of personal data by NSM.
- Data portability. You have the right to (outsource the transfer of) your personal data in a structured, common, and machine-readable format if the processing of personal data by NSM is based on your permission and takes place using automated procedures.
- Withdrawing permission. If the processing of your personal data is based on your (explicit) permission, you will always have the right to withdraw this permission without this affecting the legitimacy of the processing based on this permission before it was withdrawn.
- Complaint. You have the right to submit a complaint to the Dutch Data Protection Authority.
You can exercise one of the rights set out above by sending an email to firstname.lastname@example.org or by sending a letter to New Skool Media B.V., addressed to the Privacy Customer Service Department, Postbus 23620, 1100 EC Amsterdam. NSM will respond as soon as possible, but no later than within four (4) weeks.
TRANFER OUTSIDE THE EEA
NSM will only transfer your personal data to third countries in accordance with applicable legislation for the transfer of personal data to countries outside the EEA if the European Commission has decided that the third party country in question offers a suitable level of protection or has adopted another adequacy resolution (for example, the EU-US Privacy Shield), or if suitable safeguards are offered, such as the use of unaltered default provisions on data protection approved by the European Commission.
In the future, one or more divisions or assets of NSM may be transferred to a third party or NSM may merge with a third party. If this is the case, your personal data can also be transferred to this third party. NSM will always inform you in advance in such case.