Customers that use our website and services (Customers) can upload, collect and further process personal data of their contacts (you, your) when using our Contacts feature.
Customers are responsible for and act as data controllers in relation to their processing of personal data in their use of Contacts. You may at any time contact us at firstname.lastname@example.org to receive information about which Customers that are currently processing your personal data in Contacts, including their contact information and (if applicable) contact information to their respective data protection officers.
We are however also responsible for and act as data controller in relation to the processing of your personal data insofar as our capacity as provider of the Contacts feature on our platform gives us the opportunity to enable certain processing activities (subject to our terms and conditions) as further described below.
2. How is your personal data processed in Contacts?
In this section, you can read about Contacts and the processing of personal data in the Contacts feature, including the purpose of the processing. We explain how your personal data is collected, the categories of personal data concerned, the processing activities involved, why we process your personal data as platform provider, with whom we share your personal data , including information regarding transfers of personal data outside the EU/EEA and the time period during which your personal data is stored in the Contacts platform.
2.1. About Contacts
Contacts is a service and feature on our platform where our Customers may collect contact information and other information about their contacts in order to efficiently manage and distribute Content. Customers may collect such information by themselves uploading it and importing it into Contacts, or by using functions in the platform allowing them to collect information imported into Contacts by us, ourselves or via our third party suppliers, such as contact information to new contacts and further information about their contacts. Contacts allows Customers to create their own address lists for send-outs based on their collected information and to use functions to generate and further analyze information regarding their contacts’ interests and how their contacts interact with and respond to their messages.
The purpose of Contacts is to facilitate and enable the procedure of managing and distributing commercial and non-commercial content (including marketing messages) based on the legitimate interest for our Customers to do so in accordance with applicable data protection law. For more information about Contacts, please visit https://help.mynewsdesk.com/en/how-to/introduction-to-contacts/.
2.2. How is your personal data collected in Contacts?
Your personal data is imported into Contacts by:
- Customers uploading your contact information and other information about you to Contacts (such information is only accessed via their user accounts); or
- us providing your contact information and other information about you to Contacts, ourselves or via our third party suppliers, such information having been published by you or others in publicly accessible sources such as social media and other media channels online, and researched and collected by us or our third party suppliers.
2.3. Which personal data is processed in Contacts?
The categories of personal data processed in Contacts are the following:
- Name and contact details such as your address, email address, telephone number and fax number;
- Nationality, country and other location information;
- Professional title and company name;
- Information regarding you and your interests as published by you or others on publicly accessible sources, such as social media and other media channels online, for example on your profile on LinkedIn, Twitter, Facebook or other information platforms; and
- Information about your interaction with emails sent to you via the email function in Contacts.
2.4. How is your personal data processed in Contacts?Your personal data will only be processed for the following activities in Contacts.
- Search function: Making articles and other items that have been published online and which contain information about you easy to find;
- Address lists function: Adding your contact information and other information about you to address lists in Contacts in order to manage and distribute content to you;
- Email function: Distributing content to you;
- Following-up on and analyzing your personal interests with digital analyzing tools in order to choose relevant content based on your personal interests, including data generated from your interaction with emails sent to you via the email function in Contacts.
2.5. Why we process your personal data as provider of the Contacts feature
In this subsection, we describe when and why we process your personal data. Your personal data will not be used by us in any manner that is incompatible with the purposes for which they were collected.
2.5.1. Provide our services
We process your personal data to provide the Contacts service and feature on our platform. Our processing for the purpose of providing our services is based on our legitimate interest to do so in order to facilitate and enable our Customers’ procedure of managing and distributing commercial and non-commercial content as described in section 2.1 above.
2.5.2. Improve our services
We process your personal data to improve our services and make them more user friendly (e.g. by testing and troubleshooting, fixing bugs and amending our interfaces). This includes producing statistics on and analyzing how our services are used. For these purposes, we also use your personal data based on your activity associated with messages sent to you by our Customers.To the extent possible, we use your personal data in an aggregated or anonymized form in this processing. Our processing for the purpose of improving our services is based on our legitimate interest to do so.
2.6. How we share your personal data as provider of the Contacts feature
These are the types of third parties with whom we share your personal data:
- Service providers: We use third party service providers to manage some aspects of our business operations, including the processing or handling of personal data related to Contacts. We share personal data related to Contacts with such third parties with regard to IT infrastructure, operating and hosting services and other IT services such as IT support, maintenance and development.
- Sale or transfer of business or assets: Your personal data may, to the extent allowed and in accordance with applicable data protection law, be transferred or disclosed to a purchaser or prospective purchaser in the event of a sale, assignment, or other transfer of all or a portion of our business or assets.
- For security reasons: We may share your personal data when this is required by law, to protect you or our Customers or for the security of our services.
2.7. Transfer of your personal data outside the EU/EEAWhen another company in the Mynewsdesk group, our service providers, other suppliers or any potential purchaser of our business or assets are located in or have business activities in a country outside the EU/EEA, we may transfer your personal data to such countries. In the event of such transfer it will be made in accordance with applicable data protection law, for example by ensuring that the country in which the recipient is located ensures an adequate level of data protection according to the European Commission or by use of standard contractual clauses that the European Commission has issued ensuring suitable measures to safeguard your rights and freedoms.
You may access a list of the countries that the European Commission has decided provide an adequate level of data protection at http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm.
You may access the European Commission’s standard contractual clauses at http://eur-lex.europa.eu/eli/dec/2010/87/oj.
We have routines in place to remove personal data that is no longer necessary or allowed to store, including of due to termination of the agreements between us and our Customers or where you have opted-out from processing in Contacts. See section 4.5 below to learn more about your right to opt-out.
3. Security measures
We have taken a number of security measures to ensure that the personal data we keep in Contacts is secure. For example, access to areas where personal data is stored is limited to our employees and service providers who require it in the course of their duties and who are informed of the importance of maintaining the security and confidentiality of the personal data we keep. We maintain appropriate safeguards and security standards to protect your personal data against unauthorized access, disclosure or misuse. We also monitor our systems to discover vulnerabilities in order to protect your personal data.
4. Your rights
In this section, we describe your rights under applicable data protection law as well as how you exercise these rights.
As described in section 1, our Customers are responsible for and act as data controllers in relation to their processing of personal data in their use of Contacts. We are responsible for and act as data controllers insofar as our capacity as provider of the Contacts feature on our platform gives us the opportunity to enable certain processing activities (subject to our terms and conditions), but otherwise only act as data processor on behalf of our Customers with regard to their processing of personal data within Contacts. You may exercise your rights in relation to the processing of personal data within Contacts regardless of whether your right concerns the processing of our Customers or our processing.
According to our customer agreements both we and our Customers shall ensure compliance with applicable data protection law and thereby respect your rights as a data subject in relation to the processing activities in Contacts.
4.2. Right of access and rectificationYou have the right to information regarding which of your personal data that is processed in Contacts and to access and rectify such personal data.
4.3. Right to erasure
You may request that your personal data is erased from Contacts without undue delay in the following circumstances:
- the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- you withdraw your consent on which the processing is based (if applicable) and there is no other legal ground for the processing;
- you object to the processing of personal data and we or our Customers do not have any overriding legitimate grounds for the processing;
- the processed personal data is unlawfully processed; or
- the processed personal data has to be erased for compliance with legal obligations.
4.4. Right to restrictionYour request may be denied if erasing your personal data is prevented by requirements set out in applicable laws and regulations or if they are needed for the establishment, exercise or defence of legal claims. If your request cannot be met with reference to such circumstances, we will, unless prevented in relation to our agreements with our Customers, restrict the processing of your personal data to the purpose that prevents the erasure.
You have the right to restrict the processing of your personal data in Contacts under the following circumstances:
- you contest the accuracy of the personal data during a period enabling us or our Customers to verify the accuracy of such data;
- the processing is unlawful and you oppose erasure of the personal data and request restriction instead;
- the personal data is no longer needed for the purposes of the processing, but are necessary for you for the establishment, exercise or defence of legal claims;
- you have objected to the processing of the personal datain accordance with section 4.5 below, pending the verification whether legitimate grounds for the processing override your interests, rights and freedoms.
If your personal data has been restricted in accordance with this section they may, with exception of storage, only be processed for the establishment, exercise or defence of legal claims, or for the protection of the rights of a third party or for reasons of important public interest according to EU or EU member state legislation.
4.5. Right to object to further processing
You may at any time exercise your right to opt-out from any further processing of your personal data in Contacts by one or more of our specific Customers by using the dashboard for privacy settings available at http://www.mynewsdesk.com/contact_subscriptions. If you opt-out using the dashboard you will not receive any further send-outs via Contacts from the Customers that you have chosen to opt-out in relation to, and your personal data will not be further processed in Contacts by these Customers.
You may also at any time exercise your right to generally opt-out from the processing of your personal data in Contacts by contacting us at email@example.com. If you exercise your right to generally opt-out from such processing you will not receive any further send-outs via Contacts from any of our Customers and your personal data will not be further processed in Contacts, except forthe purpose of ensuring that your choice to opt-out is respected (by registering your email address in order to identify you as blocked from being subject to further processing – please note that further processing of your personal data may still occur if you use more than one email address).
4.6. Right to data portability
If your personal data in Contacts has been provided by you and the processing of your personal data is based on your consent or on the performance of a contract with you, you have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format in order to transmit these to another service provider where it would be technically feasible and can be carried out by automated means.
4.7. Right to withdraw consent
When the processing of your personal data in Contacts is based on your consent, you have the right to withdraw your consent at any time. Please note that the lawfulness of processing based on consent before its withdrawal is not affected.
4.8. Right to file a complaint
You may at any time lodge a complaint with the supervisory authority if you believe that the processing of your personal data in Contacts is performed in breach of applicable data protection law. Please note that you are also always welcome to contact us in such event.