Effective date: July 07, 2017
Personal data: Information that allows, in any form whatsoever, directly or indirectly, the identification of the natural persons to whom it applies.
User: Any natural person connecting via Internet to this website.
1. Data collection
- To ensure a smooth connection setup and a comfortable use of the website;
- To ensure navigation on our Website and the management and traceability of the services;
- To prevent and fight against computer fraud;
- To evaluate system security and stability as well as for further administrative purposes
- To improve user experience on our Website;
- To conduct communication campaigns;
- To conduct optional surveys;
- Other administrative needs to manage user relationships.
2. Use of data
We do not use the collected Personal data for the purpose of individual profiling of our users. We do not publish, exchange, transfer, assign or sell Personal data in any medium to third parties without User's knowledge and explicit permission. We do not process, host or transfer Personal data to a country outside the European Union or recognized as "unsuitable" by the European Commission. We destroy any unnecessary data, unless their storage is required for legal compliance (conservation or archiving of documents) or evidentiary purposes. We also automatically destroy any Personal data if the purpose of the data collection was found to be illegitimate or the data processing was unlawful.
3. Non-disclosure of Personal data
We undertake all necessary precautions to preserve the security of Personal data to prevent it from being transferred to unauthorized persons or entities. If an incident affecting the integrity or confidentiality of User’s Personal data is brought to our attention we will take the corrective measures available and inform affected users as soon as possible. A transfer of your data to third parties for purposes, except for those listed below, does not take place:
- You gave your express consent for data transfer;
- Transfer is necessary to manage a user relationship;
- There is a legal obligation to transfer data;
- Disclosure is required to assert, exercise or defend legal claims and there is no reason to assume that you have an overriding interest in not disclosing your data.
In exceptional cases of data transfer, the amount of data is limited to the minimum required for achieving the objective of such transfer.
We take all necessary technical and organizational security measures to store your personal data so that it is not accessible to third parties or the public. To ensure the security and confidentiality of Personal Data we use all reasonable state-of-the-art technologies and measures to protect it from loss, misuse, unauthorized access, disclosure, alteration or destruction. Insofar as any data transfers are made to third party recipients an appropriate level of data protection is ensured by means of suitable security measures.
5. Data processing
Direct Initiative Foundation is responsible for processing Personal Data collected through our Website or subsidiaries. Persons likely to have access to Users' Personal data are mainly our Support team members within the limits of their respective authorizations and for the purposes outlined in this Policy. The User's Personal data may be processed by our subsidiaries and subcontractors exclusively for the purposes of this Policy.
6. Duration of data storage
The data collected will be stored by us as long as necessary to manage User relationship, or as long as User has not exercised his/her rights to cancellation or transfer of data.
7. Depersonalized data
Every time a User accesses our website, the Internet browser used for access automatically sends information to our Website’s server. This information is temporarily stored in a log file for statistical, analytical, and security purposes. The following data will be collected without any manual human action and stored until automated deletion:
- IP address of the requesting computer, as well as device ID or individual device identifier and device type;
- Name of the retrieved file and amount of data transferred, as well as date and time of retrieval;
- Message about successful call;
- Requested domain;
- Description of the type of internet browser used and, if applicable, the operating system of your device used and the name of your access provider;
- Your browsing history and standard weblog information;
- Location information. Please note that you can control or disable the use of location services in the settings menu of your browser or mobile device.
8. Identifiable personal data
We might collect and process identifiable personal data for User’s authentication, identification or verification of the data we collect. For example, we will ask you for providing us with data that personally identifies you, such as name, occupation, country, or email address, to verify your identity for the purpose of signing our initiatives. Such data will be stored and processed to manage user relationship. The retention period is limited to the purpose of such relationship, and, if applicable, any statutory retention requirements.
9. User rights
In accordance with current national and international regulations, Users have the following rights:
- Right of access and rectification, updating, completeness of Users' data;
- Right to block or delete Users' personal data, when they are inaccurate, incomplete, ambiguous, outdated, or whose collection, use, disclosure or storage is prohibited;
- Right to withdraw consent at any time;
- Right to limit the processing of Users' data;
- Right to object to the processing of Users' data;
- Right to the portability of the data provided by Users, when such data are processed automatically;
- Right to define the fate of Users' data after their death and to choose to whom their data must be communicated in such event.
Your personal data will be automatically deleted by us if the purpose of the data collection has been omitted or the data processing has been unlawful.
10. User requests
If User wishes to know how we use his/her Personal Data, requests to rectify them or objects to their processing, the User may contact us in writing by e-mail at [email protected]. On such request, we will provide information regarding Personal data stored by us, in particular the processing purposes, the category of personal data, the categories of recipients to whom your data has been disclosed, the planned retention period, the right of rectification, cancellation, limitation of processing or objection, the existence of a right of appeal, the source your data, if not collected by us, and the application of any automated decision-making regarding Personal data. Any requests for correcting, updating or erasing of Personal data must expressly specify the relevant data and identify User with a copy of an identity document. In case of violations of the data protection regulations Users have a right to file a complaint with a supervisory authority.
11. Validity and updating
12. Data controller
This Data Protection Policy applies to data processing by Direct Initiative Foundation (Foundation), Trade registry: 65278488, Tax number: 856048690, headquartered in Utrecht, the Netherlands. As the controller of the data we collect, the Foundation undertakes to comply with the legal requirements in force. We are responsible for establishing the purpose of our data processing, to respond to Users of our website with full information on the processing of their Personal data and to maintain an up to date register of data processing. We take all reasonable measures to ensure the accuracy and relevance of the Personal Data for the purposes for which we process it.