Mondriaan Digital Consulting Privacy Statement
Effective as of January 01, 2019.
Mondriaan Digital Consulting and its operating divisions, subsidiaries, affiliates and branches (collectively, “Mondriaan DC”,
“MDC”, the “Company,” “we” or “us”) are committed to protecting the privacy of information you provide. Accordingly, Mondriaan DC provides this privacy and information practices statement to inform you about its online information practices, the kinds of information MDC may collect, how MDC intends to use and share that information, and how you can correct or change such information (“Privacy Statement”).
Except as where otherwise indicated, this Privacy Statement applies to individuals who visit Mondriaan DC’s websites (the “Sites”), individuals who register to attend the Mondriaan DC’s online or offline events, use the Sanoma Push Notification System (“SPNS”), Mondriaan DC’s mobile applications, or other programs, services or offerings of Mondriaan DC (together with the Sites and any and all future online and offline offerings operated by or on behalf of Mondriaan DC, the “Services”).
What Personal Information We Collect and How We Use It
The types of Personal Information MDC may collect (directly from you or from Third Party-sources) and MDC’s privacy practices depend on the nature of the relationship you have with Mondriaan DC and the requirements of applicable law. Below are some of the ways MDC collects information and how it uses it.
INFORMATION MONDRIAAN DC COLLECTS
In general, Mondriaan DC collects information from you based upon the business relationship, your use of our Sites and Services, and includes information that may be deemed Personal Information, such as title, name, address, phone number, email address, user name, Internet Protocol address, and billing and payment information related to payments for Services or programs.
HOW MONDRIAAN DC COLLECTS PERSONAL INFORMATION
Some of the ways that Mondriaan DC may collect your Personal Information include:
- Mondriaan DC may collect Personal Information from you through various channels, including the Services, in surveys, during business or marketing events, and when delivering programs and Services to you.
- When you use the Services, Mondriaan DC may provide you with opportunities to sign up to receive specific information and may ask for your contact information (e.g. name, company name, company address, phone number or email address), so that MDC can send you specific information about products, Services, with your consent.
- As you navigate the Sites and use the Services, certain passive information may also be collected, including Internet Protocol addresses, cookies, navigational data, advertisements clicked, the name of the domain and host from which you access the Internet, the browser software you use and your operating system, your browser settings, your mobile device type, the date and time you access our Services and other device identifiers. This type of information is used for the purposes of gathering data to provide improved administration of our Services, and to improve the quality of your experience when interacting with MDC’s Services.
INFORMATION FROM THIRD-PARTY SOURCES
Mondriaan DC may collect information about you from Third-Party sources to supplement information provided by you, including Internet Protocol addresses, cookies, navigational data and advertisements clicked. This supplemental information allows MDC to verify information that you have provided to Mondriaan DC and to enhance our ability to provide you with information about products and Services. Mondriaan DC’s agreements with these Third Party-sources typically limit how the Company may use this supplemental information.
From time to time, Mondriaan DC may perform research (online and offline) via surveys. MDC may engage Third Party-service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help better serve Individuals by learning more about their needs and the quality of the products and Services MDC provides. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. MDC may share anonymous individual and aggregate data for research and analysis purposes.
HOW MONDRIAAN DC USES YOUR PERSONAL INFORMATION
Depending on how you interact with Mondriaan DC, MDC and its Third Party-service providers may also use Personal Information in a variety of ways, including:
- Providing Information and Services You Requested. Mondriaan DC may use the Personal Information about you to fulfil requests for programs, Services, or information that you may request, including information about potential or future Services, including to: (a) generally manage your information and accounts; (b) respond to questions, comments and requests; (c) provide access to certain areas and features of the Services; and (d) allow you to register for events or participate in webinars.
- Marketing Products and Services. Mondriaan DC may use the Personal Information about you to provide you with materials about offers, products and services, including new content or information about future services on Mondriaan DC sites. Mondriaan DC may provide you with these materials by phone, postal mail, facsimile or email, as permitted by applicable law. Such uses include: (a) to tailor content, advertisements, and offers; (b) to notify you about offers, products, and services that may be of interest to you; (c) to provide Services to you; (d) for other purposes disclosed at the time that you provide Personal Information; or (e) otherwise with your consent. If you do not wish us to use your Personal Information for marketing purposes, you may contact us at any time to opt out of the use of your Personal Information for such purposes, as further described below.
- Research and Development. Mondriaan DC may use your Personal Information to create non-identifiable information that MDC may use alone or in the aggregate with information obtained from other sources, in order to help MDC to optimally deliver existing products and Services or develop new products, processes and services.
- Anonymous and Aggregated Data. Mondriaan DC may use and share your anonymized or aggregated information for research, analytics and any other legally permissible purposes.
- Other Uses. Mondriaan DC may use your Personal Information for other purposes disclosed to you at the time you provide Personal Information or with your consent.
Generally, online social media resources are interactive tools that enable individuals to collaborate and share information with others. Social media resources include, but are not limited to, social networks, discussion boards, bulletin boards, blogs, wikis, and referral functions to share web site content and tools with a friend or colleague.
Mondriaan DC may collect Personal Information to enable individuals to use online social media resources offered either by Mondriaan DC or a Third Party. MDC may also enable you to use these social media resources to post or share Personal Information with others. When using social media resources, you should take into careful consideration what Personal Information you share with others.
If you use on online social media resource offered by a Third Party (“Third Party SMR”) through the Services, you acknowledge that Mondriaan DC may be able to access any information you make public through such Third Party SMR (such as your username, comments, posts and contacts) and other information your privacy settings on such Third Party SMR permit Mondriaan DC to access. Mondriaan DC will comply with the terms of this Privacy Statement and the privacy policies applicable to the social media resources it uses.
DIRECT MAIL AND EMAIL MARKETING
Individuals who provide MDC with Personal Information, or whose Personal Information MDC obtains from Third Parties, may receive periodic emails, newsletters or mailings with information on Mondriaan DC or its business partners’ products and Services or upcoming special offers/events MDC believes may be of interest. MDC offers the option to decline these communications at no cost.
ALL INTERNET USERS – ANALYTICS INFORMATION
MDC may use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of MDC Sites, and to develop website content. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/ . You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout .
Mondriaan DC may provide websites, applications and online resources that are specifically designed to be compatible and used on mobile devices. Mondriaan DC will collect certain information that your mobile device sends when you use such websites, applications or online resources, like a device identifier, location, user settings and the operating system of your device.
Mondriaan DC may enable Individuals to download an application, widget or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to Mondriaan DC to enable you to access user accounts and to enable Mondriaan DC to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. Mondriaan DC may use personal or non-identifiable information transmitted to the Company to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Statement or in other notices Mondriaan DC provides.
ANONYMOUS AND AGGREGATED INFORMATION
Mondriaan DC may use your Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the Sites or other online Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Mondriaan DC may use such information in a number of ways, including research, internal analysis, analytics and any other legally permissible purposes. MDC may share this information within Mondriaan DC and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
CHOICE/MODALITIES TO OPT OUT
You have the right to opt out of certain uses and disclosures of your Personal Information, as set out in this Privacy Statement.
Where you have consented to Mondriaan DC’s processing of your Personal Information, you may withdraw that consent at any time and opt out by sending an e-mail to firstname.lastname@example.org. Additionally, before MDC uses Personal Information for any new purpose not originally authorized by you, MDC will provide information regarding the new purpose and give you the opportunity to opt out. Note that, due to the nature of the Services, you may have to provide the email or other identifying value that is associated with your Personal Information in order for Mondriaan DC to segregate out the use and retention of such Personal Information.
Prior to disclosing Sensitive Data to a Third Party or Processing Sensitive Data for a purpose other than its original purpose or the purpose authorized subsequently by the individual, Mondriaan DC will endeavor to obtain each individual’s explicit consent (opt-in). Where consent of the individual for the Processing of Personal Information is otherwise required by law or contract, Mondriaan DC will comply with the law or contract.
An “Unsubscribe” button will be provided at the top or bottom of each email communications sent by Mondriaan DC so that you can opt-out.
INFORMATION WE SHARE
Mondriaan DC does not sell or otherwise disclose Personal Information about you, except as described in this Privacy Statement or as you explicitly consent. Mondriaan DC endeavors to require third parties to which it discloses Personal Information to protect Personal Information using substantially-similar standards to those required by Mondriaan DC (and at least the same level of privacy protection as is required by the Privacy Shield Principles and this Privacy Statement).
Mondriaan DC may share Personal Information with service providers to perform Services on MDC’s behalf including (i) provision of IT and related Services; (ii) provision of information and Services you have requested; (iii) payment processing; and (iv) customer service activities. Payment information will be used and shared only to effectuate your order and may be stored by a service provider for purposes of future orders.
Mondriaan DC has executed appropriate contracts with service providers that prohibit service providers from using or sharing your personal information except as necessary to perform the contracted services on MDC’s behalf or to comply with applicable legal requirements.
INFORMATION DISCLOSED FOR OUR PROTECTION AND THE PROTECTION OF OTHERS
MDC may disclose information about you: (i) if we are required to do so by law, court order or legal process; (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (iii) under the discovery process in litigation; (iv) to enforce Mondriaan DC policies or contracts; (v) to collect amounts owed to Mondriaan DC; (vi) when MDC believes disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if MDC, in good faith, believes that disclosure is otherwise necessary or advisable.
In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing Personal Information may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
INFORMATION DISCLOSED IN CONNECTION WITH BUSINESS TRANSACTIONS
MDC reserves the right to disclose or transfer any information about you in the event of a proposed or actual purchase, any reorganization, sale, lease, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing of all or any portion of our business or of any of the business assets or shares (including in connection with any bankruptcy or similar proceeding). Should such an event occur, Mondriaan DC will endeavor to direct the transferee to use Personal Information in a manner that is consistent with this Privacy Statement.
Mondriaan DC primarily stores Personal Information sent or collected via or by Mondriaan DC in Hungary and in the United States, in the cloud, our servers, the servers of our affiliates or the servers of our service providers. To facilitate the Company’s global operations, the Company may transfer, store and access such information from around the world. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Mondriaan DC, you consent to the storage of your Personal Information in these locations.
RIGHTS OF ACCESS, RECTIFICATION ERASURE AND RESTRICTION
YOUR PERSONAL INFORMATION
You may seek confirmation regarding whether Mondriaan DC is processing Personal Information about you, request access to Personal Information, and ask that MDC corrects, amends or deletes your Personal Information where it is inaccurate or has been Processed in violation of applicable data protection laws. Where otherwise permitted by applicable law, you may use the email address set forth in this Privacy Statement to request access to, receive (port), restrict processing, seek rectification or request erasure of Personal Information held about you by Mondriaan DC. Such requests will be Processed in accordance with local laws. Although Mondriaan DC makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Mondriaan DC is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Mondriaan DC determines that access should be restricted in any particular instance, MDC will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Mondriaan DC will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
As a data processor for our Customers, Mondriaan DC processes data that may include Personal Information of Users (“Customer Data”). Mondriaan DC will not review, share, distribute or reference any such Customer Data except as provided in the agreements between us and our Customers, or as may be required by law. If Personal Information pertaining to you as an individual has been submitted to us by a Customer as Customer Data and you wish to exercise any rights you may have to access, correct, amend or delete such data, please inquire with the relevant Customer directly. Because Mondriaan DC personnel have limited ability to access Customer Data, if you wish to make your request directly to Mondriaan DC, please provide the name of the relevant Mondriaan DC customer. MDC will refer your request to that Customer, and will support them as needed in responding to your request within a reasonable timeframe.
Mondriaan DC retains the Personal Information received as described in this Privacy Statement for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide products and Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce agreements and comply with applicable laws.
The security of all Personal Information provided to Mondriaan DC is important, and Mondriaan DC takes reasonable steps designed to protect your Personal Information. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure. As a result, while Mondriaan DC strives to protect your Personal Information, it cannot ensure or warrant the security of information you transmit to Mondriaan DC. You are responsible for maintaining the secrecy of your own passwords. If you have reason to believe that your passwords or Personal Information is no longer secure, please promptly notify Company at email@example.com.
REDRESS/COMPLIANCE AND ACCOUNTABILITY
If after reviewing this Privacy Statement, you would like to submit a request or you have any questions or privacy concerns, please contact:
Mondriaan DC will address your concerns and attempt to resolve any privacy issues in a timely manner.
OTHER RIGHTS AND IMPORTANT INFORMATION
INFORMATION REGARDING CHILDREN
Due to the nature of Mondriaan DC’s business, Services are not marketed to minors. Mondriaan DC does not knowingly solicit or collect Personal Information from children under the age of 13 (and in certain jurisdictions under the age of 16). This applies to any Personal Information directly collected by us, but does not apply to the Personal Information provided to us by Third Party services and organizations or from our Customers regarding Users (please refer to the terms of their respective Privacy Policies). If MDC learns that it has collected Personal Information from a child under the age of 13 (and in certain jurisdictions under the age of 16) in relation to the Services, MDC will promptly delete that information.
LINKS TO THIRD-PARTY DIGITAL PROPERTIES
CHANGES TO THE PRIVACY STATEMENT
Mondriaan DC may update this Privacy Statement from time to time as it deems necessary in its sole discretion. Mondriaan DC will provide notification of any material changes to this Privacy Statement through the Company’s Sites or as otherwise required by applicable law. Mondriaan DC encourages you to review this Privacy Statement periodically to be informed regarding how Mondriaan DC is using and protecting your information and to be aware of any policy changes. Your continued relationship with Mondriaan DC after the posting or notice of any amended Privacy Statement shall constitute your agreement to be bound by any such changes. Any changes to this Privacy Statement take effect immediately after being posted or otherwise provided by Mondriaan DC.
This Privacy Statement shall be implemented by Mondriaan DC and all its operating divisions, subsidiaries and affiliates. Mondriaan DC has put in place mechanisms to verify ongoing compliance with this Privacy Statement. Any Employee that violates these privacy principles will be subject to disciplinary procedures.
“Personal Information” is any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU-residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the individual’s sex life; or (8) information relating to the commission of a criminal offense.
“Third Party” is any natural or legal person, public authority, agency or body other than the Individual, Mondriaan DC or Mondriaan DC’s agents.