Please take a moment to read the following policy statement to learn more about our information practices, including what types of information are gathered, how information is used and for what purposes, to whom we disclose the information, and how we safeguard your personal information.
The information we collect
Through the Frame Publishers websites you can, amongst other things, order products and services, enter competitions, subscribe to our publications, complete surveys and post comments.
In order to process your requests and orders, it may be necessary to collect personal information about you. This includes, but is not limited to, your name, mailing address, email address, telephone number, and credit/debit card information. Frame Publishers also collects other profile data including, but not limited to, your personal interests, gender, education, and occupation in order to provide you with more relevant products and services.
In addition, we collect technical device information such as your unique device ID, as well as information about your visits to and your activity on our websites including the content (and any advertisements) that you view and interact with, the address of the website from which you arrived and other clickstream behavior (such as the pages you view, the links you click, the items you add to your shopping cart, the length of your browsing session, your IP address and the approximate location at the time of browsing). IP addresses are not linked to personally identifiable information.
We will not collect any sensitive personal information such as race, political beliefs, religion, membership with labor unions, sexual preference, or genetic information.
How we collect information
We collect information about you when you register an account on our websites, place an order, subscribe to a newsletter, fill out a form, enter information on our website, call us, or contact us via a different channel.
We request user information in our order forms, where you must provide your contact and financial information. This information is used for billing purposes and to fulfill customer orders. Should we have issues when processing an order, this contact information is used to get in touch with you.
To optimize our website content, products, and user experience design in response to individual preferences, we analyze and compare information of different users. This includes analyzing the purchasing habits of users with similar profiles to suggest content, offers, and products to you that you might be interested in.
How we store information
We do not store personal information longer than necessary for the objective as agreed in the terms of service contract by law. The retention period depends upon the purpose for which we have received or collected the data and upon any legal obligations to retain the data.
What we do with the information
We may use the information we collect from you in one of the following objectives:
• register your account on our websites and manage our website services (including the processing of search queries or requests for information relating to our company, products or services) in order to conclude the agreement that you have with us and to provide you with the requested services;
• assess and analyze our market, customers, products and services (including asking for your products and services and conducting customer research), based on legitimate interests;
• evaluate, review and improve our products and services, based on legitimate interests;
• for internal archiving, based on legitimate interests;
• for marketing purposes, based on your consent;
• target content, products, messages and offers to better match your preferences through evaluating some of your personal data against other user data, based on your consent;
• organize competitions where you can win prizes, to execute the agreement you have made with us and to provide you with the requested services; and
• hire you, if applicable, such as if you have provided information in the context of an application for a job in our company, in order to take certain measures including contacting you in the run-up to the conclusion of an agreement with you.
We do not collect personal information irrelevant to the objective as agreed in the terms of service contract by law.
How we share your information
We will not provide any of your personal information to third parties without your permission, except:
• when we are of the opinion that it is necessary for other companies, financial institutions or institutions to enforce the law in the context of fraud prevention or detection;
• in the form of statistical aggregated information, including information relating to sales and web-usage, for advertisers and our business partners to monitor the efficacy of our business partnerships and to sell advertising. We may also pass such information onto reputable third parties for onward sale;
• in the event that Frame Publishers is, or its assets are substantially, acquired by one or more third parties as a result of a merger, sale, consolidation or liquidation, then customer information may be one of the transferred assets;
• when necessary to pursue Frame Publishers’ legitimate interests; or
• when required or permitted by law.
Any distribution of your personal data by us to a carefully selected third party or to one of the third parties mentioned in the above list is in accordance with the provisions of the General Data Protection Regulation. You are assured that contractual provisions are provided to ensure that third parties:
• do not use your personal data for purposes other than those we have recorded, in accordance with the purposes described in this policy document; and
• have taken the security measures necessary for the protection of the personal data against unauthorized processing and against unintentional loss, destruction or damage to your personal data.
How we protect your information
• Frame Publishers servers and devices are equipped with up-to-date security software, including an anti-virus program and a firewall.
• If necessary to share your personal data internally or with third parties, we only do so via secure Internet connections (TLS, previous SSL). You can identify this through the ‘https’ in the website address and the green lock in the address bar.
• Our websites are scanned on a regular basis for security holes and known vulnerabilities in order to make your browsing experience as secure as possible. When our registration/order form asks users to enter sensitive information (such as credit card numbers), that information is encrypted and is protected with the best encryption software in the industry – SSL.
• Your personal information is stored behind secured networks, and is only accessible to a limited number of persons who have special access rights to such systems, and are required to keep the information confidential.
• All transactions including payments are processed through a gateway provider and are not stored or processed on our servers.
Information with regards to minors
We encourage all parents and guardians to educate children in their care to share personal information in a safe and responsible manner when using our products and services. We do not intentionally collect (via our website or otherwise) information that relates to or originates from a minor, unless we have received the permission of the minor’s parent or guardian. If we are informed that a user of the products or services on our websites is a minor who does so without the consent of a parent or guardian, we will take reasonable and necessary measures to ensure that all information provided by the minor is expunged as soon as possible to ensure that this information is neither communicated to third parties nor used by us for direct marketing purposes or otherwise.
View, edit or delete your personal information
You have the right to view, edit or delete the personal data we have collected about you. Furthermore, you have the right to withdraw consent or to object to the processing of your personal data. And you have the right to data portability: this means that you can request that we send you, or another organization named by you, the personal data that we have about you in a computer file.
Requests to view, edit, delete or port your personal data, and withdrawals of consent can be sent to [email protected]
• To ensure that the request for access to your stored data has been made by you, we will ask that you provide some personal details (such as your postcode, or the last four numbers of your credit card) to verify your identity. We aim to respond to your request as quickly as possible, and no later than four weeks.
We advise that you have the right to file a complaint with the national supervisory authority, the Dutch Data Protection Authority.
Frame Publishers makes no decisions based on automated processing which can have adverse consequences for you.
We will use your information to provide you with personalized content, services and communications as well as targeted advertising on our websites and selected partner websites (for example, you might see an advertisement on a partner site such as Facebook for a product that you have recently viewed on our websites). We may do this by matching, combining or linking different sources of information we have about you (e.g. linking your contact or subscriber information with your activity across our websites, or linking your activity on our websites across all your devices using your email or social media accounts) or by creating segments based on various factors such as your age and gender, inferred interests or your device details. We work with data management platform providers to assist with this process.
Where we have the appropriate permissions, we will use your information to market and advertise products and services from Frame Publishers, and occasionally third-party products and services that may be of interest to you including sales and discounts, competitions, and commercial communications via telephone (mobile or landline), post, email, online or mobile applications.
You can always let us know that you wish to stop receiving direct marketing communications from us. We always try to give you relevant content, products and services based on the information you share with us, so we will no longer be able to get in touch to let you know about valuable and exciting offers. If you would prefer to stop receiving direct marketing communications from us at any time, let us know by writing to the Privacy Officer at Frame Publishers, Luchtvaartstraat 4, 1059 CA Amsterdam, The Netherlands; to [email protected]; or by following the opt-out instructions in the relevant communication. Please note that this will not stop you from receiving service messages from us regarding your account or use of our products and services.
Third party links
Occasionally, at our discretion, we may include or offer third party products or services on our websites. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, Frame Publishers seeks to protect the integrity of our websites and channels, and we welcome any feedback about third party sites.
Frame Publishers will take reasonable steps to protect the security and integrity of all personal information provided to the Frame Publishers websites. However, due to the inherent nature of the internet as an open global communications vehicle, Frame Publishers cannot guarantee that this information will be absolutely safe from malicious actions or intrusions by others, such as hackers. If you are requested to send us any sensitive personal information such as your credit card number or password, in an email or on a webpage or otherwise, and you are uncertain whether such a request is authorized by us, please do not hesitate to ask us by sending an email to our Privacy Officer at [email protected]
Last Edit: May 2018