CHANGING YOUR COOKIE SETTINGS
Do you want to view your current cookie settings? Click on the button below to view, change or save the choices you’ve made before with regards to accepting cookies on the website you are currently visiting or one of the other Sanoma websites.
With your use of our products and services we, Sanoma Media Netherlands B.V. , publisher of Flowmagazine.com can process information, including personal data, from and about you. For example, among other things, data that you provide us with when subscribing to one of our magazines or information that we collect when using our (mobile) websites, apps, web shops and other services, such as online promotions, events and promotions, contests and loyalty programs.
We do this in order to make our products and services increasingly better based on the insights we obtain from them, for example by better attuning them to your needs. We also do this for commercial reasons, namely to gain a better understanding of the products and services you are interested in as a user and to sell the advertising space that we offer to advertisers as well as possible; the majority of our (digital) products and services are fully financed with the revenues generated by the sale of advertising space.
You can read here, among other things, how we handle your information, how and what information we (can) collect and for what purposes we (can) use it. In addition, you will find information in this document about how you can access your data, change, correct or delete your data, and who the (possible) recipients of this data are.
PROCESSING BY SANOMA
Extensive details of (the group companies of) Sanoma through which your personal data can be processed:
Sanoma B.V., Capellalaan 65, 2132 JL Hoofddorp, registered in the Commercial Register of the Chamber of Commerce Amsterdam under number 34159491;
- Sanoma Media Netherlands B.V., Capellalaan 65, 2132 JL Hoofddorp, registered in the Commercial Register of the Chamber of Commerce Amsterdam under number 33133064;
- Subsidiaries Sanoma: Head Office Netherlands B.V. (CoC 30128420); magazine.nl/Mediakiosk B.V. (CoC 32058600); LINDA./Mood for Magazines B.V. (CoC 33277855); Sanoma Digital Group The Netherlands B.V. (CoC 17111115); Sanoma Digital The Netherlands B.V. (CoC 17111121); Sanoma Media Customer Services B.V. (CoC 34051078); SB Commerce B.V. (CoC 28104469); Scoupy B.V. (CoC 53322185); and, Veronica Uitgeverij B.V. (CoC 32064149)
Would you prefer to contact us by post or e-mail, click here for our address details.
Questions can be directed at:
Sanoma Media Netherlands B.V.
T.a.v. “Customer service Privacy”
2132 JL Hoofddorp
If you do not use the abovementioned web forms for your request, remember to clearly state your (full) name, address and place of residence and send a copy of an identification document. This is necessary for us to establish with some certainty whether the data that your request relates to, actually are about you.
For security purposes, please note on the copy of your identification document that you send it to us and make your citizen service number and any photo unrecognizable. The copy of your ID will only be processed for your identification in the context of your request and will then be deleted.
The company that Sanoma is part of has appointed a data protection officer. An independent and competent person who performs supervisory and advisory tasks within the organization, including when necessary with regard to data subjects requests.
THE SUPPLY OF PERSONAL DATA IS NOT REQUIRED
You are not obliged to disclose your personal data when you purchase a product or service from us. You always have the choice whether you want to enter your personal data or not. However, in order to use some of our products and services, entering personal data is necessary.
When is the provision of data necessary?
If, for example, you subscribe to one of our journals, we will need your data to have the magazine delivered to you and to invoice you for it. If you want to receive a newsletter or create an account to post on a forum, then we need at least a working e-mail address (via e-mail is asked to confirm the request to create an account).
If you are asked to enter your details, then it is indicated which data are necessary to be able to use the service (and therefore have to be filled in), the other data are therefore optional. If you fill this in, we will use this information to optimally adapt our services and marketing to your interests and needs.
LEGAL BASES FOR THE PROCESSING OF PERSONAL DATA BY SANOMA
Personal data may only be processed if there is a legal basis for processing. Legal grounds on which Sanoma can process your personal data are the following:
- Consent: legally valid consent is given when you express in a free, informed and unambiguous way that you agree to specific processing by Sanoma, such as when you register for an e-mail newsletter.
- Necessary for the execution of an agreement: your personal data can also be processed by Sanoma because this processing is necessary for the performance of an agreement that you have or enter into with Sanoma, or in order to take steps at your request prior to entering into a contract . For example, Sanoma needs to process your address in order to deliver a paper version of a magazine when you have a magazine subscription with Sanoma.
- Legal obligation: in some cases Sanoma must process your personal data in order to comply with a legal obligation that applies to Sanoma. An example is the storage of certain data on the basis of tax legislation.
- Legitimate interest: Sanoma can also process your data when this is necessary for the purposes of the legitimate interest pursued by Sanoma or a third party, unless your interests, fundamental rights or fundamental freedoms weigh more heavily. When determining whether processing can take place on this legal basis, the interests of Sanoma (or a third party) and the interests of data subjects will be balanced. For example, processing for the purpose of fraud prevention (if and in case a prior and careful weighing of interests rules in favor of the company’s interests) can occur on this legal basis.
Processing of personal data is also justified when this is necessary to protect the vital interests of a person (eg medical data in the event of an accident) or when this is necessary for the fulfillment of a general interest task or a task within the framework of the public authority entrusted to a controller. Although it is conceivable that in very exceptional cases Sanoma would process personal data on one of the latter legal grounds, this is not likely to occur.
TYPES OF DATA
When offering products and services we can process (personal) data of subscribers to our magazines, customers and visitors / users of our (mobile) websites, apps, web shops and other services, such as online promotions, events and promotions, contests and loyalty programs. It differs per product / service whether, and if so, which (personal) data we can process.
Roughly there are five ways in which we can collect personal data:
- Ordering / delivery of products (for example a subscription to a magazine or an online purchase): the personal data you have provided to us are processed; such as name, address and place of residence (for the purpose of delivery), financial details such as your bank account number (for the purpose of payment), and the knowledge that you have made use of that specific product / service (and therefore apparently expresses your interest) );
- Creating a (Sanoma) account on a (mobile) website or in an app: we process the personal data you provide to us when you create the account / where you have given us access to (when using a social login) such as your e-mail address and (user) name;
- Requesting products / services through our (mobile) websites and apps (for example requesting an e-mail newsletter): this process processes information that you have provided to us via the website, such as your e-mail address;
- Use of our (mobile) websites and apps: this includes information about your use of those (mobile) websites and apps, such as the visited pages and websites within our network, the advertisements that have been shown and the advertisements you clicked on . From that information we can derive your possible interests;
- Use of our apps: this involves processing (personal) data that you have filled actively provided via the app, or information that you have actively given us access to (such as location data).
Are all these data collected for all products and services that I receive from Sanoma?
No. Above is a summary of the data that we can collect. This does not mean, however, that we actually request and store them under all circumstances. For example, it may be that one service needs your e-mail address, while another does not use your e-mail address, but your location. For example, if you subscribe to an e-mail newsletter, we generally do not need much more than your e-mail address, your name and possibly your gender (to personalize the e-mails).
This also applies to the collection of information about your actual use of our (mobile) websites and apps. For example, some of our apps only use data about your use of the app to improve the app, while others also use information about using the app to show you personalised ads. You will be informed about this when installing the specific app.
With regard to a number of types of data, a more extensive explanation is given below, namely data collected on the basis of cookies, Sanoma account and location data.
Sanoma can exchange your personal data with its subsidiaries as mentioned above under the heading ‘Processing by Sanoma’.
When will my data be exchanged within Sanoma’s subsidiaries?
All data relating to subscriptions is stored by us in one system, which includes the data of both Libelle subscribers (Sanoma Media Netherlands BV), LINDA subscribers (Mood for Magazines BV) and Veronica Magazine subscribers (Veronica Uitgeverij BV). If you have subscriptions to several of our magazines, we can place these different subscriptions under one customer number (instead of registering you as different subscribers).
We keep your use of our online services online by means of (a) cookie (s). Here too, we apply the same system everywhere so that no distinction is made whether you visit a website of Sanoma Media Netherlands B.V. (such as vtwonen.nl) or from Mood for Magazines B.V. (such as LINDA.tv).
Finally, your data may in some cases be combined by us with data collected in the context of your purchase or use of various of our products or services (and / or products or services of our group companies) or with information from external sources (such as demographic and geographical segments of Cendris). On the basis of all this information, we draw up a profile so that we can provide you with a better service and that you can better tailor the content of these products and services (including websites and magazine offerings) to your interests.
How are data combined, and what data?
Data collected in the context of, for example, the use of Scoupy can be linked to your online profile and / or subscription data, so that we can better tailor our own products and services to your needs, but also use your interests and preferences to sell advertising space on our websites in a more useful and valuable way. Through the settings page of your Scoupy account you can express your preferences regarding the use of this combined data for marketing and advertising purposes.
When you complete a registration form at one of our websites, we can add the information you have entered to the cookie with which we measure your use of our online services. We do not combine all the information you enter with the online user information. We use data such as your age, gender and (the digits of your) zip code. This data is used for building an online profile. In addition, we can combine subscription data with information about the use of our websites if you have a subscription to one of our magazines and also receive an e-mail newsletter. The way this works is: via the e-mail newsletter your customer number (in our system) is linked to the unique number of the cookie. We can add your gender, age category and postal code (for example: male, 30-35 years, 1234AB) to your cookie profile, and add the interests derived from your website usage to your subscription data. For example, if you regularly visit the website of vtwonen, then you are probably interested in this magazine and / or information about living and interior.
We can only make this link when i) you both are a subscriber to one of our magazines and visit our websites (and you haven’t disabled cookies) and ii) you use the same e-mail address for both services (e-mail newsletter and subscriber data) and iii) you open this newsletter in the same browser with which you also visit websites (webmail). If one of the conditions mentioned does not apply (for example because you open your e-mail in an e-mail app on your smartphone), then it is not possible for us to combine your data.
With the enrichment of the subscription data we aim to offer our own (magazine) products in a more targeted way to you as reader / subscriber; the enrichment of the online information serves the purpose of optimising the selling of advertising space on our websites (all our online services are fully financed by the income generated from the sale of advertising space to advertisers).
Finally, information from external sources can be added to the data we process from you. For example, Cendris provides demographic data such as general information about postal code areas (average age in certain postal codes, average family composition, average income).
We only use the profiles that we draw up to better tailor our offers and advertisements to your interests, so that this profiling does not have any legal consequences for you. If you object to the exchange and combining of your personal data within Sanoma Media Netherlands B.V. and its subsidiaries and / or the creation of an online profile as mentioned under the heading ‘Processing by Sanoma’, you can make this known by using the aforementioned web form that you can find on our privacy page.
Is an objection to the exchange or combining of my data within Sanoma always honored?
In principle yes, with a few exceptions.
When it comes to data that are necessary to, for example, deliver a subscription to you, or that we have to keep for fiscal reasons, we do not have a separate system for storing this information per company. We only have one system and therefore cannot make a distinction between these data. As a result, this data is also exchanged with group companies.
If it concerns online data (such as information stored in a cookie), you can choose not to accept cookies that are used to keep track of your ‘interests’. If you disable those cookies on our websites, no information about your use of our online products and services is processed and therefore no information can be exchanged between group companies. Your cookie settings for all our websites can be reached via the blue button ‘Customize cookie settings’ [at the top of this page], or by clicking on the following link: https://privacy.sanoma.nl.
PURPOSES OF PROCESSING
We collect and process personal data for the following purposes, including via the (mobile) websites operated by us:
- for the formation and execution of an agreement concluded with you;
- to provide you with the agreed services, products and / or information, and to adapt these to your needs and wishes;
- to give you the opportunity to post and exchange information on one of the websites or, if the website offers the possibility to contact other users;
- if it concerns a paid service / product, to invoice. We never publish financial information on a website, nor are they made available to third parties for purposes other than the execution of the agreement. When payment is not made for our products or services, we hand the claim over to a third party, such as a debt collection agency;
- to make targeted offers, eg via e-mail. It is also possible, for example, to display an advertisement of a product on a website or in an app of which we suspect your interest on the basis of data processed by us. In the context of the optimization of making offers we can draw up a profile of you;
- to send you a newsletter, offer, user information, service message or other electronic message;
- we may rent (name and address) data to third parties that can offer you products, services or information (see further under ‘Sharing and publishing personal data’);
- to analyze, maintain, optimize and secure our (mobile) websites, apps and associated technologies and to prevent fraud;
in order to comply with the laws and regulations that apply to us, and to handle disputes and have auditors (audit) carried out;
- to carry out market research and to prepare management information for product and service development and for determining the (general) strategy;
Here, not all data is always processed for the same purposes. For example, some data is only stored for billing purposes or for the provision of the requested service, while other data can be used, for analyzing as well as improving the use of our websites and for making a specific offer.
In principle, we keep your personal data only as long as necessary for the aforementioned purposes, or to comply with statutory (storage) obligations.
Explanation of the retention period of data.
In principle, we use a period of two years after the end of the customer relationship as a retention period of the data we process. For example, if you receive e-mails with promotions and offers of Sanoma products and services because you are (or have been) a customer of Sanoma, you will receive them no later than two years after the termination of the subscription. If you receive e-mails with promotions and offers of Sanoma products and services because you have registered for this, you will continue to receive them until you opt out.
Transaction data (data related to the purchase / sale of a product) must in many cases be retained for tax reasons.
However, there are also data that we retain and use for a shorter period in view of their relevance or sensitivity (such as online data).
More generally, we do not store data longer than necessary for the purposes for which they were obtained.
SHARING AND DISCLOSING PERSONAL DATA
We may exchange personal data processed by us with the subsidiaries mentioned above under the heading ‘Processing by Sanoma’ and combine these with data processed by these (subsidiary) companies. For a more detailed explanation, see ‘Data types’. If you object to this, you can make this known by using the aforementioned web form that you can find on our privacy page.
Your address details (name, street, house number, postal code and / or telephone number) can also be provided to carefully selected third parties for sending information and offers by telephone and / or by mail (eg ‘list rental’). We can select these third parties based on the information we have collected about your product use, internet behavior and / or subscriptions. These third parties will then use your information to make you offers that they expect to suit your interests. If you do not appreciate this information or these offers, we will block your details on your request. Please contact Sanoma by using the aforementioned web form that you can find on our privacy page.
Examples of ‘list rental’ are, for example, car brands that want to reach readers of Autoweek with an offer, or a producer of a baby products that wants to approach readers of Ouders van Nu with an offer relevant to them. If the advertiser is allowed to approach you as a user directly, then it is contractually stipulated that advertiser may approach the file only once and must thereby observe the relevant marketing regulations (such as taking into account the “Bel-Me-Niet-Register” and / or Postfilter). We check whether advertisers comply with these conditions.
In addition, we have a collaboration with Cendris (https://www.cendris.nl). Cendris provides companies with information about postal codes, among other things. We use this information, among other things, for verifying address data on the basis of the postal code. Cendris manages a large database with name and address data (‘Name, address, place of residence’). Like many advertisers, we use that file to send promotions and offers to former subscribers. We in turn supply Cendris name and address data from subscribers to keep Cendris’s name and address details up-to-date.
You will only receive information and offers from third parties about their products and services via e-mail if you have given us legal permission to do so. Such information and offers will always be sent from Sanoma.
More information about e-mails with promotions and offers from third parties.
If when entering into a subscription to one of our magazines, for example the Libelle, you have indicated that you wish to receive promotions and offers from third parties by e-mail, you will receive an e-mail from Libelle with the offer of the advertiser. The e-mail in question will always be reviewed by us in advance. Consent previously granted for this can always be withdrawn. If it concerns an e-mail, you can unsubscribe from such a title for such mailings via the unsubscribe link at the bottom of each e-mail. The advertiser does not receive your e-mail address.
For the targeted purchase of online advertising space we can offer third parties (advertisers) the possibility to use the segments in which we have classified visitors (based on the personal data collected by us). For example, an advertiser can indicate that his shampoo advertisement should only be shown to women in the 20-35 age group. The advertiser can – without actually receiving the data himself – advertise specifically. In any case, the advertiser is also contractually prohibited from collecting the data (in-)directly. Advertisers can use this on our websites, but also outside of it.
In special cases we may, without your permission, provide personal information to third parties. Special cases include, for example, legitimate requests by authorities, subpoenas or court orders, actions to detect or prevent damage or fraud, or actions to ensure the security of our network and our services.
How does that work?
Unfortunately, our services are sometimes misused. For example, by using a forum to seriously insult someone else or to wrongly accuse someone of criminal offenses. If on the basis of the user name or the circumstances it is not clear who is responsible for these statements, it sometimes happens that we are asked for further information in the context of a criminal investigation, such as the e-mail address or IP address used when creating the account that was used to make the statements. If such a request complies with article 126n et seq. of the Dutch Code of Criminal Procedure, we are obliged to (and will) cooperate with that.
We can also provide personal data to so-called processors who act on our behalf. Your personal data will only be used by processors to perform that specific assignment. These processors are not entitled to use this data for their own purposes.
For example, we do not execute the delivery of our magazines ourselves, we have outsourced is. For this third party to be able to deliver the magazines, we provide them with the address details of our subscribers.
Finally, we can share certain anonymized data with third parties, such as the number of users who searched for a particular search term, or how many users clicked on a particular ad. You cannot be identified on the basis of these data.
Where we offer functionalities on our websites for which the use of an account / login is necessary, we use one uniform login: the Sanoma account. With this Sanoma account(s) we try to make logging in to our digital services even easier. This way you can log in to all our digital services with one login and password, so you no longer have to think up and remember a new login name and password for each service. We aim to further facilitate the use of our services. In addition, it is also much clearer for you as a user which data is shared and used between our various services. It is not mandatory to use the same account everywhere though, you can also create a separate account per service if you prefer to for any reason.
The use of one account makes it possible for us to better tailor our products and services to your needs and interests. If you have the same account for all of our services, it gives us the opportunity to (better) keep track of your use of our products and services. Both about different services and different devices. We will record data about your interests and preferences (profile) linked to your account. In the My Account environment of your Sanoma account you can set whether we can use this data for commercial purposes or not.
The Sanoma account also gives us the opportunity (when you log in on your mobile and / or tablet as well as on your computer with the same account) to assign your mobile / tablet and desktop to one user. In that case we can link the cookie that we use on your mobile to the cookie that we use on your desktop to keep track of your use of our website(s). This makes it possible to apply preferences set on your computer to your mobile phone and, for example, to prevent you from seeing an advertisement that you have already seen on your computer several times, on your mobile as well. If you do not want this, you can disable (profiling) cookies on your desktop or on your mobile / tablet (go to: privacy.sanoma.nl/settings). In principle, it is sufficient to disable these cookies on one of the two devices, since there is no data to connect to anymore on one of the two devices. You can also adjust these (and other) privacy settings directly in your account.
- keep track of the products you have in your shopping cart or to record the preferences you have set for a certain service or web page;
- for statistical purposes. In order to be able to see how often a website is visited, through which website(s) visitors end up on our website (s) and which pages are visited on a website;
- (if you have given permission for this) to better tailor advertisements on the websites you visit to your needs and interests, to prevent you from seeing a certain advertisement too often and to register how often an advertisement is shown.
Technical explanation of the cookies used for this purpose.
We make use of session cookies, and unique-id cookies (short and long life).
Session cookies: these are automatically deleted when you close your internet browser. Based on this we can, for example, keep track of which advertisements you have seen on our websites within one session and thus prevent you from seeing certain advertisements several times within one session.
Unique-id cookies (long life): these are used to recognize an internet user as a unique visitor. This cookie has a lifetime of one year on most of our websites, which means that it automatically disappears if you have not visited any of our websites for more than one year. This is particularly important for statistical purposes: for example, we can see over a longer period of time how many individual visitors have visited a website.
Unique-id cookies (temporary): these temporary cookies record your surfing behavior on our websites for a maximum of ninety days. When you contact one of our websites for the ninety-first day, the data from day one disappears from the cookie. The information obtained through these cookies is automatically deleted 180 days after your last visit.
If you have disabled cookies through your browser settings, there is a chance that certain functions will not work or that you will not be able to use certain services. In any case, you will see the cookie information bar on every page since our websites cannot save (in a cookie) that you have visited the website before and possibly even made a choice between accepting cookies or not.
As mentioned earlier, we may exchange personal data processed by us with group companies and combine your personal data with data collected in the context of your purchase or use of our products or services (or products or services of group companies). This also concerns surf data collected via cookies.
In order to be able to offer advertisements as focused as possible, part of the information we collect about you and your surfing behavior on our websites, including personal data (gender, age category and surfing behaviour), is combined with information about you and your surfing behavior on the websites of other publishers participating in NLProfiel, being De Persgroep and Telegraaf Media Groep, to draw up joint segments. In this context, we share the aforementioned information that we have collected (gender, age category and surfing behaviour) with Buymedia, that draws up NLProfiel segments on the instructions of the participating publishers (as a processor) using this information of all participating publishers. More detailed information about this can be found here.
If you object to this, you can make this known by using the aforementioned web form that you can find on our privacy page.
The advertisements on our websites are placed on it (in our assignment) by AppNexus. They also place cookies on your computer. Again, this applies to our websites only if you have given permission for this. This permission only applies to our websites and a number of third-party websites where Sanoma performs the sale of advertising space. For an overview of these partner websites, see below. The cookies placed by AppNexus are placed in our order. AppNexus acts as processor in the sense of the General Data Protection Regulation, Sanoma is the controller.
Overview of partners for whom Sanoma sells (a part of the) advertising space on the websites of these partners:
SBS Broadcasting Students
With a limited number of parties, we have different agreements with respect to the above.
Sanoma has a cooperation with Zalando, under which Sanoma uses data collected by Zalando. Zalando shares data at a group level, such as ‘interested in fashion’ or ‘interested in furniture’. Zalando does not share your e-mail, telephone number or address. The purpose of sharing the data is to make the advertisements on the Sanoma websites more relevant (the data is therefore not used outside of Sanoma).
For the sharing of Zalando data, technology (a cookie) from nugg.ad is used. Nugg.ad collects information about the topics of the pages you visit (and frequency of them). More information about nugg.ad, such as the storage period of 26 weeks, can be found here: https://nugg.ad/en/privacy/general-information.html. If you do not want nugg.ad to store this information about your internet use, click opt-out.
In certain apps, we may use your location data, such as in the NU.nl app, to provide you with news and local weather forecast based on your location. In that case, your location will also be used to tailor advertisements based on your (previous) location(s). When an app has this functionality, you are always asked in advance for your free, explicit, unambiguous and informed consent. If you have given your consent, but you no longer wish to use information and receive advertisements tailored to your location, you can switch it off at any time via the settings of your telephone.
How are ads tailored to my location?
We can use your location in two ways to present ads in a targeted manner.
First of all, by setting in our advertising system that a particular advertisement must be shown on every mobile phone that is located in a certain area and on which the NU.nl app is opened. Our advertising system then looks – at the moment the (open) app asks to show an advertisement – if the location that is sent with that request meets that condition. If so, the relevant advertisement will be shown. If not (you are not in the area or you have disabled your location), you will see another advertisement.
If you have enabled the use of your location, our advertising system informs the parties that want to show an advertisement at that moment about your location. The advertiser can then tailor the ad to your location.
TRANSFER THIRD COUNTRIES
When we pass on personal data to third parties through which the personal data are processed in countries outside the European Economic Area, we ensure that the data are transmitted and processed in a manner that is permitted under applicable privacy legislation.
To display advertisements on our websites, we use an AppNexus Adserver. The servers that AppNexus uses to present advertisements on our websites are located outside the European Union. In order to present the right, Dutch-language advertisements, we provide location data to AppNexus. An appropriate level of protection is guaranteed as AppNexus has committed itself to the EU-US Privacy Shield Framework (https://www.privacyshield.gov/welcome). AppNexus will only use this information for the implementation of the agreement with us (and therefore not for its own purposes). Regarding the tracking of the online profiles, we use the services of Krux Digital Inc., which, like AppNexus, is based in the United States. Krux Digital Inc. is linked to the EU-US Privacy Shield Framework (https://www.privacyshield.gov/welcome) as well.
We maintain at all times a security level in the processing of personal data which, in view of the state of the art, is appropriate to prevent unauthorized access to, adaptation, disclosure or loss of personal data. The measures are both technical and organizational (such as encryption of data, access control to our locations, preset conditions for access to data by employees, pseudonymisation of data, anonymisation of data, and so on).
CHILDREN UNDER 16 YEARS
Want to know more about specific conditions relating to minors?
Sanoma does not intend to collect data about website visitors younger than 16 years old. However, it is not possible for Sanoma to determine with certainty whether a visitor is actually older than 16 if the visitor says so. If, in your opinion, Sanoma has collected personal information about a minor without parental consent, please contact us via the web form or the contact details on our privacy page so that this information can be deleted.
OBJECTION, ACCESS, CHANGE, TRANSFERABILITY, REMOVAL AND LIMITATION OF THE PROCESSING OF PERSONAL DATA
Under the General Data Protection Regulation, you as a data subject have certain rights vis-à-vis Sanoma as controller. You can exercise your rights easily by using the Sanoma web forms referred to above, which you can find on the customer service page. Before we can process you request, we will ask you to identify yourself by means of a valid identity document or by logging into your account, to ensure that the request is actually made by you. We will only use a copy of your ID to identify you in the context of your request.
You have the following rights:
- Right of access: you have the right to inspect, free of charge, whether and what personal data we process about you.
- Right to rectification: If the personal data we hold about you is incorrect or incomplete, you can ask us to add or correct your personal data.
- Right to erasure: you have the right to have your personal data erased when (i) the data is no longer required for the purpose for which it was collected, (ii) you withdraw your consent to the processing (and there is no other legal ground for processing the data), (iii) you (validly) object to the processing, (iv) the personal data are processed unlawfully, (v) this is required by a legal provision or (vi) the personal data has been collected within the framework of a so-called information society service. In some cases it is not possible to delete your personal data, for example when there is a legal obligation for Sanoma to keep the data, when the data are necessary to perform an agreement with you (for example, the delivery of a magazine ) or when the right to freedom of expression and information should weigh more heavily in a specific case.
- The right to restriction of the processing: you have the right to request a restriction on the processing of your personal data (for example, while checking the accuracy of your personal data).
- The right to transfer data (“dataportability”): under certain conditions you have the right to receive your personal data that you have provided to us in a structured, commonly used and machine readable format and to pass on your personal data to a third party of your choice.
- Objection against processing: you have the right to object to the processing of your personal data due to your specific situation. In that case, a weighing of interests will take place in consideration of your specific situation.
- You also have the right to file a complaint with Sanoma at the Dutch authority in charge of the protection of personal data, being the Dutch Data Protection Authority (“Autoriteit Persoonsgegevens”).
You can also state that you no longer appreciate the provision of your personal data to group companies or to third parties, the combination of your personal data into a profile, the use of your data for making you targeted offers or receiving (e-)mail containing information and offers.
Which information to send with questions about your data?
If you do not wish to make use of the aforementioned web form and wish to send us your request by post, please mention your full name, address and place of residence in the message and include a copy of a valid identity document so that we can be sure that the information you request or the request you make actually relates to you and is therefore sent to the right person or, for example, removed or corrected at the request of the person concerned. For safety reasons, please write on the copy of your identity document that you are sending it to us and make your citizen service number and any photo unrecognizable. If we cannot (fully) determine which personal data your request relates to, we can ask you to specify your request (further). We suspend the execution of your request until you have provided us with the (further) specification. We will always send you a confirmation message after completing your request.
As soon as possible after receiving your request, we will inform you if and how, and if not why not, we grant your request.
We will make all reasonable and practical efforts in handling your request, in accordance with applicable laws and professional standards.
Why is a request denied?
Not every request will be honored. A request that relates to personal data that does not (only) relate to you will be refused. A request to amend data that does not show ore prove that the data are factually incorrect, or that does not show or prove that the requested change actually makes the data accurate, will not be honored. We will not fully honor every request for deletion of data. In some cases, we are required by law to retain certain data (for example, on the basis of tax legislation).
On many of our websites you have the possibility to view or change your own personal data yourself, and to delete the personal data that you have entered on such a website by means of the options provided.