privacy and terms conditions

For over 25 years, EDM has been working with databases from renowned partners and customers. Working with and exchanging data and personal information obviously requires monitoring and compliance with all current legal rules and codes of conduct regarding privacy and security.

Privacy and security have been important to EDM for years. EDM works strictly in accordance with the Dutch and European legislation on the protection of personal data. The processing of personal data has been reported to the Dutch Data Protection Authority under number 1285521. EDM holds the ‘Gold’ DDMA privacy guarantee.

EDM only makes data available to customers who are active in the EU and must comply with the local (Dutch) and European legislation. This ensures that personal data is protected by the Local (Dutch) and European rules and regulations.

The rights of consumers are guaranteed in the organization of EDM. EDM will always honor requests for the removal of personal data or access to the origin of data. EDM’s Privacy Officer always answers such questions as quickly as possible.

EDM’s Privacy Officer can be contacted by e-mail at: privacyvraag@edm.nl

Secure environment

In the context of Privacy and Security, EDM does not send or receive any data by e-mail. EDM always uses a secure online transfer environment.

EDM employees can create an account for you immediately, after which a username and password are provided to you via various channels. Thank you for your co-operation in maintaining the privacy of you and our data.

GENERAL TERMS AND CONDITIONS

Click here to download our general terms and conditions.

Security

As part of The Data Agency, EDM is ISO 27001-certified by Brand Compliance and operates an up-to-date information security policy in accordance with the ISO 27001 security standard.

The Data Agency’s security measures include:

  • Access control and authorisation of employees. All employees must make a code of conduct declaration and are obliged to maintain confidentiality
  • Own secure server centre in the Netherlands
  • Use of processor agreements
  • In-house Privacy Officer for questions from consumers and structural consultation with and advice from the in-house Data Protection Officer
  • Use of a secure environment for secure exchange of files

Specific terms and conditions EDM online advertisement services

  • Processing Data for Google

Methods of processing

EDM takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to EDM, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (Operations and Support department, IT system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by EDM. The updated list of these parties may be requested from EDM at any time.

Legal basis of processing

EDM may process Personal Data relating to Users of Clients if one of the following applies:

  • Users have given their consent for one or more specific purposes.;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which EDM is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in EDM;
  • processing is necessary for the purposes of the legitimate interests pursued by EDM or by a third party.

In any case, EDM will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at EDM's secure datacenter and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

If broader protection standards are applicable, Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by EDM to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with EDM using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between EDM and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of Client’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by Client within the relevant sections of this document or by contacting EDM.

EDM may be allowed to retain User’s Personal Data for a longer period whenever the User has given Client consent to such processing, as long as such consent is not withdrawn. Furthermore, EDM may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow EDM and Google to provide their Service to Client, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

  • Analytics

The services contained in this section enable EDM and Google to draft and present aggregated reports on attribution of Google Advertising to offline conversions by Client.

First Party Data

Google DV-360

  • What can an advertiser do with Google DV-360?
    In order to be able to use Google DV-360 with audiences, personal data is necessary. EDM offers an advertiser the opportunity to provide this data to a trusted third party – EDM in this case – so that the advertiser builds in maximum assurance that minimal data is shared with Google. EDM needs personal data such as name, address, email and/or telephone number to facilitate the process. EDM processes the data to an anonymized and aggregated level.
  • Is personal data shared with Google?
    EDM ensures that the data is uploaded to the advertiser's account on the Google platform. Only hashed information is shared with Google. EDM ensures that all other information remains safe in the data centre and is removed within the agreed period.
  • What data is it exactly?
    Step1
    In order to be able to link the PII information to online advertisements, the PII data is necessary. EDM offers an advertiser the opportunity to provide this data to a trusted third party – EDM in this case – so that the advertiser builds in maximum assurance that minimal data is shared with Google. EDM needs personal data (name and address, email and/or telephone number) to facilitate the process. EDM processes the data to an anonymized and aggregated level.

    Step2
    EDM ensures that the data is uploaded to the advertiser's account on the Google platform. Only the hashed ID and the aggregated sales information is shared with Google. EDM ensures that all other information remains safe in the data center and is removed within the agreed retention period.
    Step3
    Google shows reports of audiences and the associated media spending on the Google platforms in its Google Ads, Analytics and/or YouTube dashboards. An individual consumer is not recognizable. The resulting insight into the online advertisements and campaigns information is exclusively at an aggregated level and only visible to the advertiser in his own Google dashboard.

  • Why don't I need to get additional prior permission from my customers to share this offline sales information with EDM and Google?
    Use of Google DV-360 generally takes place within the advertiser's existing services; additional permission is therefore not necessary provided that the privacy conditions of the existing service are in order. So the advertiser has an agreement with Google. EDM is the data processor in this process.

    In general, an advertiser may have a legitimate interest in processing the personal data for marketing analysis and thus for the use of the services of Google DV-360. To test whether there is a legitimate interest on the part of the advertiser, he can use the 'Legitimate Interests Assessment' (LIA) template of the ICO (Appendix 1). EDM can help the advertiser with this.

    • What agreement with Google does DV-360 cover?
      The use of DV-360 falls under the agreement(s) that an advertiser has to use Google Ads, YouTube and Google Analytics. Google must accredit an advertiser in advance. This is done through your own Google account manager.
    • What do I put in the Privacy Statement on my website?
      Normally no adjustments necessary - see also answer to question 4. If the advertiser already is makingmarketing analyses and also uses Google Analytics, and has stated this in the privacy statement, DV-360 is covered in the advertiser's existing privacy policy. Purposes of use: processing of personal data for analysis purposes is usually stated.
    • How long will my conversion data/PII be kept by EDM? And by Google?
      EDM stores the supplied conversion online services and files for a standard retention period of 90 days after processing. Google deletes the provided, aggregated and encrypted data by EDM 90 days after processing. This has been agreed by the advertiser itself in its advertising agreement with Google. Checking the agreements between Google and the advertiser is the responsibility of the advertiser itself.
  • What guarantees do I have for the security of the data and the privacy of my customers?
    EDM is ISO 27001
    EDM is ISO 27001 certified for all data processing and processes.

  • Which legal documents are relevant?
    Privacy statement of the advertiser DV-360 falls under the purpose of analysis and creating insights, a fairly standard part of a privacy statement.

    Processing agreement between the advertiser and EDM. If an advertiser is used to working with partners in the field of data. If an advertiser does not have a processing agreement, then EDM can provide a template.

    Advertising agreement between Google and the advertiser. In this agreement, an advertiser makes agreements with Google regarding costs, responsibilities and data. The Legitimate Interests Assessment (LIA) statement.

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