In accordance with our data processing operations we have checked if your consent is the most appropriate basis for processing. We ask our customers and respondents to positively opt-in prior to any start of the processing. The request for consent to you is made prominent and separate from any conditions that may apply to the promotions you have participated. Your consent is (also) used to administer the campaigns you are interested in. If you withdraw consent you contact data is blocked until you have given your consent again. Any given consent is never made on a default mode. We keep a record of when and how we received your consent on an individual identifiable basis. We also keep a record of exactly what you were shown or told at the time of participating to the campaign.
Should you have questions about the campaign to which you participated in, then please contact our privacy officer at [email protected] who can reply to you directly for any question or concern you may have.
We would like to specify to you why we process data and what we’re going to do with it, for which purposes data are going to be used and further processed.
We give individual options to consent or positively opt-in to different purposes and types of processing. We name our organisation and any third party controllers who will be relying on the consent at the moment of collecting your data. We inform our customers and respondents that they can withdraw or refuse their consent without detriment. We perform on withdrawals of consent as soon as we can and direct our customers and respondents how to do so. In offering online communication directly to our customers and respondents we seek consent in accordance with and necessary for the purposes of our data processing operations and our relation with you. We have age-verification measures (and parental-consent measures for younger children) in place to avoid that children (below 12) and youngsters (12-18) can participate to our services.
If you would like to find out how our Sponsors protect your personal data, please see these companies’ privacy policies.
Our Sponsors regularly ask us for consent to offer you new promotions. For example, discounts to e-learning books, retail goods and vouchers. Because we do not wish to prevent our customers and respondents from getting the best discounts, we let you know about such offers ourselves or directly from the Sponsors that are named in the promotion.
The categories of personal data which are necessary to provide the services are:
These categories of personal data are processed for purposes which are based on legitimate interests in accordance with the laws and regulations. The legitimate interests are our own interests and the (commercial) interests of third parties to provide you with the offers you would like to receive (common interests). The promotions contain not only offers which benefit our customers’ and respondents’ contact preferences (see above) but also apply to educate you about discount offers and for that purpose sending the correct email and sms on the right moment. In order to balance the commercial interests with your privacy preferences we never collect or ask for more data than is necessary for a proper operational performance of our online communication.
We process data data when such is necessary for:
Information is not automatically used for all these objectives simultaneously.
Data required for online (direct) communication are processed in accordance with the following requirements.
The processing is intended for communication with data subjects, sending information about the products and services of Mobivity and Sponsors, keeping an overview of the information sent and maintaining the contact with the data subjects.
No other personal data will be processed than:
No special categories of data as referred to in the General Data Protection Regulation 2016/679 will result from the processing.
The personal data are only provided to those Sponsors, who are in charge of or direct communication with the data subject or who are thereby necessarily involved.
The personal data will be deleted at the request of the data subject or no later than two years after the relationship with the data subject has terminated, unless the personal data are necessary for compliance with a legal obligation to retain data.
Data required for security reasons are processed in accordance with the following requirements.
The processing is intended for the control and security of the systems or programs, the support of the proper functioning of the systems or programs, sorting and recovering files, creating backup copies of files, the management of the systems or programs.
No other personal data will be processed than: a. data relating to the use of the software,
b. technical and control data,
c. data to promote proper functioning,
d. historical data,
e. user data.
The personal data are only provided to those, including third parties, who are in charge of or direct the system, data management or application management or who are necessarily involved and others, as the case may be, to the (further) performance of another legal obligation.
The personal data will be deleted at the latest 6 months after they have been obtained, unless the personal data are necessary to comply with a legal data retention obligation.
Data required for processing operations concerning prize winners are processed in accordance with the following requirements.
Processing is only for company purposes to inform who were the prize winners.
No other personal data will be processed than
a. initials and surname of the prize winner.
b. photos and video images with or without sound.
The personal data will be deleted after termination of the website or will be immediately deleted at the request of the data subject (prize winner).
As controller of the data Phonify B.V. does not intend to transfer personal data to a third country (country outside the European Union). Should data be transferred to a country outside the European Union then (in that event):
We also make use of the IP-address of your computer. This IP-address is a number which automatically assigned to your computer when you have a browsing session on the internet, such as when you visit one of our sites or landing pages. They can be used to see which use has been made of the website and for drafting analyses and reports with non-identifiable information.
‘Analytical’ cookies are used to analyse your visit to our websites. We analyse the number of visitors to our websites, the duration of the visits, the order of pages visited and whether any changes need to be made to the website. Using the information collected, we can make our websites even more user-friendly. These cookies are also used to solve possible technical problems on the websites.
We will only use tracking cookies for commercial purposes with your prior consent. These cookies, which are often posted by third parties, help us to tailor promotional offers to you personally. Third parties can use tracking cookies.
You are also invited to send a letter to:
Dutch representative Mobivity
Cornelis Dirkszstraat 27-2
1056 TP Amsterdam
Amsterdam, August 2018