Privacy Policy

Dazzle Platform B.V. (the “Company,” “we,” or “us”) wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect through: 

• Websites operated by us from which you are accessing this Privacy Policy (the “Websites”); 

• Our social media pages and apps located at the following URLs (collectively, our “Social Media Pages”): 

• Linkedin 

• Youtube 

• HTML-formatted email messages that we send to you that link to this Privacy Policy or other communications with you; and

• Offline business interactions you have with us.

 

Collectively, we refer to the Websites, Social Media Pages, emails, and offline business interactions as the “Services.” 

 

PERSONAL INFORMATION

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The Services collect Personal Information, including:

• Name and Contact Details: Such as first and last name, title, prefix, email address, telephone number, postal address, date of birth, gender, country of residence.

• Business Contact Details: Such as company name, business email address, business telephone number, business postal address, country of business.

• Account Information.

• Billing Information: Such as debit or credit card details, bank account details, billing address.

• User Content: Such as reviews about our services, and other content you may create or share on our Services, including posts on our Social Media Pages, blogs, and comment sections.

• Preferences: Such as language, interests, and other customer feedback/preferences that you might express during your use of our Services.

• Marketing Data: Such as your choices regarding our newsletters, surveys, and other marketing/advertising displayed or provided to you, and preferred methods of such promotional communication.

• Relationship History: Such as details of your communications with us, and details of your claims, complaints and queries in general.

• Transaction Information: Such as details of Services you have purchased from us.

• Device Information: Such as information about your devices and your use of our Services. This includes data obtained through cookies and similar technologies, such as the IP address.

• Social Media Information: Such as profile pictures, social media account ID, and other social media profile information, including lists of friends/followers on social media.

 

COLLECTION AND PROCESSING OF PERSONAL INFORMATION

How we collect Personal Information‍

We and our service providers collect Personal Information in a variety of ways, including: 

• Through the Services.
  ○ We collect Personal Information through the Services, for example, when you sign up for a newsletter, register an account to access the Services, request a software demo, attend one of our events or webinars, contact customer service, download or access Dazzle content (such as a Whitepaper), participate in a survey, or make a purchase. 

• From Other Sources.
  ○ We receive your Personal Information from other sources, for example:
  - publicly available databases;
  - joint marketing partners, when they share the information with us;
  ‍
  ○ If you connect your social media account to your Services account, you will share certain Personal Information from your social media account with us, for example, your name, email address, photo, list of social media contacts, and any other information that may be or you make accessible to us when you connect your social media account to your Services account.

 

We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Processing of Personal Information‍

 

We and our service providers use Personal Information for the following purposes: 

• Providing the functionality of the Services.
  ○ Examples of Processing Activities

• ‍To provide the Services’ functionality to you, such as arranging access to your registered account, and providing you with related benefits, special promotions, or customer service.To complete your transactions, verify your information, and provide you with related benefits, special promotions, or customer service.

• To send administrative information to you, such as changes to our terms, conditions, and policies. 

• To allow you to send messages to another person through the Services if you choose to do so.
  
  ○ Personal Information Categories

• Name & Contact Details;  Business Contact Details; Account Information; Billing Information; Preferences; Relationship History; Transaction Information; Device Information.
  
  ○ Legal Basis

• Performance of contract, including the General Terms and Conditions or any other agreement we enter into with you to provide the Services.
  ‍

• Customer service/ Fulfilling your requests
  ○ Examples of Processing Activities‍

• To respond to your inquiries and fulfil your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about our Services.
  
  ○ Personal Information Categories

• Name & Contact Details; Business Contact Details; Account Information; Billing Information; Relationship History; Transaction Information; Device Information;  and Preferences.
  ‍
  ○ Legal Basis

• Performance of contract, including the General Terms and Conditions or any other agreement we enter into with you to provide the Services. 

• Legitimate interests, such as responding to inquiries or complaints.   

• Legal obligations, such as when you submit a request to access your Personal Information.
  ‍

• Providing you with our newsletter and/or other marketing materials and facilitating social sharing.
  ○ Examples of Processing Activities

• To send you marketing related emails, with information about our Services, new products and other news about our company. 

• To facilitate social sharing functionality that you choose to use.
  ‍
  ○ Personal Information Categories

• Name & Contact Details; Business Contact Details; Account Information; Relationship History; Transaction Information; Preferences; Marketing Data; Device Information; and Social Media Information.
  
  ○ Legal Basis

• Consent, for example, where we would like to send you direct SMS and email marketing communications, but do not have an existing relationship with you, we will ask for and rely on your prior opt-in consent.

• Legitimate interests, such as to promote our Services.
  ‍

• Analysing Personal Information for business reporting and providing personalised services and for developing new products and services.
  ○ Examples of Processing Activities

• To analyse or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.

• To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.

• To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.

• For developing new products and services.

• For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.

• For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures.

• For identifying usage trends, for example, understanding which parts of our Services are of most interest to users.

• For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.
  
  ○ Personal Information Categories

• Name & Contact Details; Business Contact Details; Account Information; Marketing Data; Social Media Information; User Content; Relationship History; Transaction Information; Device Information; and Preferences.
  
  ○ Legal Basis

• Legitimate interests, such as improving our Services.

• Consent, such as when we use cookies and similar technologies and the data collected by means of such technologies qualify as Personal Information.
  ‍

• Allowing you to participate in sweepstakes, contests or other promotions.
  ○ Examples of Processing Activities

• We may offer you the opportunity to participate in a sweepstakes, contest or other promotion. If you participate, we will use your information to administer such promotions.  

• Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information. Please read those additional rules before choosing to participate.
  ‍
  ○ Personal Information Categories

• Name & Contact Details; Business Contact Details; Account Information; Relationship History; Transaction Information; Preferences; Marketing Data; Device Information; User Content; User Photographs and Videos; Event Photographs and Videos; and Social Media Information.
  
  ○ Legal Basis

• Legitimate interests, such as to promote our Services.     

• Performance of contract, such as fulfilling obligations associated with a contest.
  ‍

• Aggregating and/or anonymising Personal Information.
  ○ Examples of Processing Activities

• We may aggregate and/or anonymise Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.
  
  ○ Personal Information Categories

• Personal Information as relevant for the specific business purpose.
  
  ○ Legal Basis

• Legitimate interests, such as to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.
  ‍

• Fraud prevention and security.
  ○ Examples of Processing Activities

• For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements; 

• For fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.
  
  ○ Personal Information Categories

• Name & Contact Details; Business Contact Details; Account Information; Billing Information; Device Information; Relationship History; site security information; and Transaction Information.
  
  ○ Legal Basis

• Legal obligations, such as to detect and prevent cyberattacks.

• Legitimate interests, such as identifying and/or preventing fraudulent transactions.‍‍

DISCLOSURE OF PERSONAL INFORMATION

We disclose Personal Information: 

• To our third party service providers, to facilitate services they provide to us.
  ⁃ These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, fraud prevention, information technology and related infrastructure provision, customer relationship management, customer service or related benefits (including special promotions), email delivery, auditing, and other services.

• To third party sponsors of sweepstakes, contests, and similar promotions. 

• By using the Services, you may elect to disclose Personal Information.
  ⁃ On message boards, chat, profile pages, blogs, and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
  ⁃ Through your social sharing activity. When you connect your Services account to your social media account, you will share information with your friends associated with your social media account, with other users, and with your social media account provider. By doing so, you authorise us to facilitate this sharing of information, and you understand that the use of shared information will be governed by the social media provider’s privacy policy.

 

OTHER USES AND DISCLOSURES

We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:

• To comply with applicable law and regulations.
  ⁃ This may include laws outside your country of residence. 

• To cooperate with public and government authorities.
  ⁃ To respond to a request or to provide information we believe is necessary or appropriate.
  ⁃ These can include authorities outside your country of residence.

• To cooperate with law enforcement.
  ⁃ For example, when we respond to law enforcement requests and orders or provide information we believe is important.

• For other legal reasons.
  ⁃ To enforce our terms and conditions; and
  ⁃ To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others. 

• In connection with a sale or business transaction.
  ⁃ We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). 

OTHER INFORMATION

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:

• Browser and device information

• Information collected through cookies, pixel tags and other technologies

• Demographic information and other information provided by you that does not reveal your specific identity 

• Information that has been aggregated in a manner such that it no longer reveals your specific identity

Collection of Other Information 

We and our service providers may collect Other Information in a variety of ways, including: 

• Your browser or device.
  ⁃ Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly. 

• Cookies.
  ⁃ Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services. We may also use cookies or other technologies in online advertising to track responses to our ads. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. You also may not receive advertising or other offers from us that are relevant to your interests and needs.

• Pixel tags and other similar technologies.
  ⁃ Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates. 

 

Uses and Disclosures of Other Information 

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

 

CHOICES AND INDIVIDUALS’ RIGHTS

Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from: 

1. Receiving marketing-related emails from us. If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt out by sending an email to info@dazzle-platform.com  stating “I would like to opt out from marketing-related emails”. At the footer of the newsletter, there is also an unsubscribe link.

2. Our sharing of your Personal Information with affiliates for their direct marketing purposes. If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with our affiliates for their direct marketing purposes, you may opt out of this sharing by sending an email to info@dazzle-platform.com and stating “Please discontinue sharing my Personal Information with any affiliates of Dazzle. 

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.

How you can exercise your rights

If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, withdraw your consent (which will not affect the lawfulness of processing prior to the withdrawal), or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below. We will respond to your request consistent with applicable law.

In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion). 

Your principal rights under data protection law are:

 

The right to information: You have the right to confirmation as to whether we process your personal data and, where we do, access to the personal data;

 

The right to inspect: You have the right to inspect at any time. We will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee;.

 

The right to correct: You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

 

The right to object to: You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

 

The right to data portability: You have the right to transfer the information that you have given to us in the framework of the agreement that you have entered into with us. You have the right to receive a machine-readable format, so you can save this data in a database of yours or another party. This includes your name, address and residence information. To obtain this information, please send an email to our customer service.

 

The right to restrict processing: In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

 

The right to be forgotten/request for account delete: In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

 

The right to complain to a supervisory authority: If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. When you have a complaint, please contact us. You also have the right to complain directly to our data protection officer. You can do this by emailing: info@dazzle-platform.com. Finally, you have the right to file your complaint to the authorities. We process requests within 7 days.

 

Lodge a complaint with an authority

You may also lodge a complaint with an EU/EEA data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

RETENTION PERIODS

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law, for example, for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. 

The criteria used to determine our retention periods include: 

• The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services); 

• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or 

• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations). 

Where a legal obligation arises or retention is advisable in light of our legal position, in some circumstances, we will retain certain Personal Information, even after your account has been deleted and/or we no longer provide the Services to you; for example:

• To cooperate with law enforcement or public, regulatory and government authorities: If we receive a preservation order or search warrant, related to your Services account, we will preserve Personal Information subject to such order or warrant after you delete your Services account.

• To comply with legal provisions on tax and accounting: We may retain your Personal Information, such as Billing Information, Relationship History, and/or Transaction Information for up to 10 years after you delete your Services account, as required by tax law and to comply with bookkeeping requirements. 

• To pursue or defend a legal action: We may retain relevant Personal Information in the event of a legal claim or complaint, including regulatory investigations or legal proceedings about a claim related to your Personal Information, or if we reasonably believe there is a prospect of litigation (whether in respect of our relationship with you or otherwise) for up to 10 years after the dispute has been settled or decided by a court or tribunal from which there is no further right of appeal.
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THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates. 

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.

 

USE OF SERVICES BY MINORS

The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18. 

JURISDICTION AND CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. 

Some countries outside the European Economic Area (EEA) are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by contacting us in accordance with the “Contact Us” section below.

 

SENSITIVE INFORMATION

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.

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THIRD PARTY PAYMENT SERVICES

The Services may provide functionality allowing you to make payments to the Company using third-party payment services with which you have created your own account. When you use such a service to make a payment to us, your Personal Information will be collected by such third party and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your Personal Information.

 

UPDATES TO THIS PRIVACY POLICY

The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services. 

 

CONTACTING US

Dazzle Platform B.V., located at Gedempte Zalmhaven 893, 3011 BT Rotterdam, the Netherlands, is the company responsible for collection, use, and disclosure of your Personal Information under this Privacy Policy.

 

If you have any questions about this Privacy Policy, please contact us at info@dazzle-platform.com 

 

or:

Dazzle Platform B.V. 

Gedempte Zalmhaven 893

3011 BT Rotterdam, the Netherlands

 

Dazzle’s co-founders can be contacted at info@dazzle-platform.com  for matters relating to this Privacy Policy, data collection and data processing.

 

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.