Ronald van Loon
Effective Date: 23 April 2020
1. General information
• “Personal data” refers to any information relating to a natural person who can be identified, directly or indirectly, by using such information;
• “Processing” refers to collecting, storing, deleting, using, disclosing, and transferring of your personal data;
• “Data controller” refers to an entity that determines the purposes and means of the processing of personal data; and
• “Data processor” refers to a natural or legal person, public authority, agency or other body which processes personal data on behalf of the data controller.
Data controller. The legal entity responsible for the processing of your personal data through the Website is Digital Transformation Institute having a principal place of business at Heidestein 2, 3452LL, Vleuten, the Netherlands (“we” and “us”).
About the Website. The Website provides access to a database containing Internet-based live and recorded educational content (e.g., videos, webinars, articles, video articles, and whitepapers) from leading business experts (the “Services”).
▪ If we are required by law to do so;
2. Processing of personal data
2.1 What personal data we collect
We adhere to data minimisation principles and collect only a minimal amount of personal data that is necessary for ensuring your usage of all features of the Website and the provision of the Services. We collect your personal data in several instances that are described below.
Personal data that we obtain from you directly. We collect personal data that you submit to us directly.
- When you register a user account on the Website, we collect your:
- First and last name;
- Email address;
- Phone number;
- Address (optional);
- Company name (optional);
- Your role in the company (optional); and
- Any other information you decide to provide us voluntarily.
- When you use the Services, register for events though the Website, or submit requests on the Website, we collect:
- Registration data (as defined above);
- Information about the Services used by you; and
- Information about the events that you register for.
- When you register to receive our strategies/coaching materials/other educational content, we collect your:
- Email address;
- Full name;
- Company name; and
- Phone number.
- When you contact us through the chat functionality available on the Website or by email, we collect your:
- Email address; and
- Information that you decide to provide us in your message.
- When you submit any user content through the Website, we collect the personal data that may be made available in that content.
Personal data obtained from third parties. We may receive your personal data from third parties, such as our affiliates, service providers, social media websites, and other publicly available sources. Please note that your personal data will be obtained only in compliance with the applicable data protection laws, privacy notices of the respective third party, and your individual privacy settings. For example, when you access the Website or use the Services through your social media account (e.g., Twitter, LinkedIn, Instagram, Facebook, and YouTube), we collect the personal data that you authorise your social media provider to make available to us (e.g., your public social media profile).
Sensitive data. We DO NOT collect any sensitive data about you (e.g., your health information, opinion about your religious and political beliefs, racial origins, sexual orientation, and memberships in professional or trade associations), unless you, at your sole discretion, decide to make such sensitive data available to us (e.g., though the chat functionality available on the Website).
Failure to provide personal data. If you fail to provide us with the personal data when requested, we may not be able to perform the requested operation and you may not be able to use the full functionality of the Website, receive the Services, or get our response.
2.2 Purposes of processing of personal data
We respect strictest data protection principles. Thus, we collect and process your personal data only for specified, explicit, and lawful purposes. In short, we will use personal data only for the purposes of enabling you to use the Website, delivering the Services, maintaining and improving the Website and the Services, conducting research about our business activities, administrative purposes, and replying to your enquiries. The detailed purposes for which your personal data is used and the lawful bases on which we rely are specified in the table below.
3. Non-personal data
When you visit the Website and use the Services, we may collect certain technical non-personal data specified in this section. Non-personal data does not allow us to identify you in any manner. In case your non-personal data is aggregated with certain elements of your personal data in the way that allows us to identify you, we will treat such aggregated data as personal data.
What non-personal data we collect. The non-personal data collected by us includes:
Purposes of non-personal data. We collect your non-personal data for:
Your feedback. If you contact us, we may keep records of any questions, complaints or compliments made by you and the response, if any. Where possible, we will de-identify your personal data. Please note that de-identified personal data is also considered to be non-personal data.
Aggregated and de-identified data. If we combine your non-personal data with your personal data in a way that allows us to identify you as a natural person, we will handle such aggregated data as personal data. If your personal data is de-identified in a way that it can no longer be associated with a natural person, such de-identified data will not be considered personal data and we may use it for any business purpose.
4. Marketing communication
We will send you our direct marketing communication, including newsletters, brochures, promotions, and advertisements, send you messages through your social media account, or contact you by any other means with the aim to offer you our Services only if you provide us with your contact details and prior consent to receive such marketing communication. Your voluntary subscription to our marketing materials constitutes such consent. Please note that, if you have previously used our Services (e.g., ordered a coaching session), we have the right, from time to time, to send you information about our other Services that are similar to the Services already used by you. You can unsubscribe from receiving such information at any time.
Marketing through social media. Please note that we will send you marketing-related messages through your social media account only if (i) we are authorised by the social media provider, (ii) your individual privacy settings allow us to do so, (iii) you have provided your consent to the social media provider or to us directly to receive such messages, and (iv) it is in compliance with applicable data protection laws.
Opt-out from marketing communication. If you have provided us with your consent to receive direct marketing communication and, at some point, you would like to stop receiving such communication, you can easily opt-out by:
Informational notices. Please note that informational notices regarding the Services used by you (e.g., reminders, login information, links to access the Services, and similar), the Website, your privacy and security, and other important matters are sent to you on an “if-needed” basis and they do not fall within the scope of marketing communication that requires your consent.
Marketing communication from third parties. If you provide your consent to receive marketing communication from us and/or third parties (e.g., when ordering the Services), we will share your contact details with our clients, sponsors of the Services, marketing agencies, and other third-party service providers (collectively, the “Sponsors”) as a part of our agreement with them. The Sponsors may contact you to offer their services, information, sessions, or other materials that may be of interest to you. To ensure your privacy, no such communication is carried out by the Sponsors without your prior consent. Also, you can withdraw your consent at any time (e.g., by clicking on the “unsubscribe” link). The third parties that may receive your personal data include:
6. Security measures
We put reasonable efforts to ensure the security of your personal data. We implement organisational and technical information security tools to protect your personal data, such as secured networks, encryption, strong passwords, and limited access to your personal data by our staff. However, due to the inherent risks of the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data caused by circumstances beyond our reasonable control.
In order to ensure the security of your personal data, we kindly ask you to keep your registration details in a secure and confidential manner and use the Website and the Services only through a secure network.
Security breaches. In case a personal data breach occurs, we will inform the relevant data protection authorities without undue delay and immediately take reasonable measures to mitigate the breach, as stipulated in the applicable law.
7. Retention period
8. Disclosure and transfer of your personal data
8.1 Purposes of disclosure
In certain situations, on a case-by-case basis, we may disclose your personal data to third parties that act as our data processors. Such a disclosure is limited to the situations when the personal data is required for the following purposes:
8.2 List of our data processors
Your personal data may be disclosed to third parties that provide professional legal, technical, marketing, and other types of support to us, including:
8.3 Sharing personal data with the Sponsors
We strive to process your personal data in full transparency. From time to time, the Services may be affiliated with the Sponsors that would like to deliver you their own marketing communication. We will share your personal data with such Sponsors only if you provide your opt-in consent to receive third-party information and marketing materials. We do not transfer or sell your personal data to third parties if you do not allow us to do so. Therefore, before subscribing to certain Services, you may be requested to provide your freely given, specific, informed and unambiguous consent to receive third-party marketing materials. Where reasonably possible, we will specify the third parties that will receive your personal data. You will be able to opt out from such marketing materials at any time. The third parties that receive your personal data may become (joint) data controllers responsible for the processing of your personal data. For the categories of the Sponsors that may receive your personal data, please refer to section 4.
8.4 Sharing of non-personal data
We may disclose or use non-personal data and de-identified data for any purpose. For example, we may share it with prospects or partners for business or research purposes, for improving the Website and the Services, responding to lawful requests from public authorities, or developing new products and services.
8.5 Transfer of personal data outside EEA
Please note that some third parties listed in this section 8 may be located outside the EEA and we may need to transfer your personal data to the jurisdictions located outside the EEA. In case it is necessary to make such a transfer, we will make sure that the jurisdiction in which the recipient third party is located ensures an adequate level of protection of your personal data or we conclude an agreement with the respective third party that ensures such protection (e.g., the country in which the recipient is located is white-listed by the European Commission or the recipient is a Privacy-Shield certified entity) or we conclude an agreement with the respective third party that ensures such protection (e.g., a data processing agreement based on the Standard Contractual Clauses provided by the European Commission).
8.6 Other third parties
9. Your rights regarding your personal data
We provide you with the possibility to exercise the following rights regarding your personal data:
How to exercise your rights. If you would like to exercise your rights listed above, please contact us by email at firstname.lastname@example.org. We will answer your request within a reasonable timeframe but no later than two weeks.
10. Third-party applications and links
11.1 What are cookies?
11.2 What types of cookies do we use?
We use several types of cookies on the Website that are listed in the table below, including:
11.3 Purposes of cookies.
11.4 Cookie consent
11.6 Google Analytics
We use Google Analytics to analyse your use of the Website and the Services. Google Analytics generates statistical and other information by means of cookies and we use its services to create reports about the use of the Website and the Services and to collect data via advertising cookies and identifiers. We use the following Google Analytics features: (1) Remarketing with Google Analytics; (2) Google Display Network Impression Reporting; (3) Google Analytics Demographics and Interest Reporting; and (4) Integrated services that require Google Analytics.
If you would like to opt out from Google Analytics features, you can do so through Ad Settings, Ad Settings for mobile apps, or any other available means (for example, the NAI’s consumer opt-out). You can also install a Google Analytics opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout?hl=en.
14. Contact information
You can contact us by using the following contact details: