Privacy Statement
1. Introduction
This Privacy Statement applies to the products and services of FD Mediagroep B.V. and its affiliated companies or subsidiaries. These subsidiaries are: Het Financieele Dagblad B.V., Business Nieuws Holding B.V. and FD Business B.V., all located at Prins Bernhardplein 173, 1097 BL Amsterdam. Hereafter to be referred to as “FDMG”, “we”, “us” or “our”. FD Mediagroep B.V., Prins Bernhardplein 173, 1097 BL Amsterdam is the controller with regards to the processing of personal data, also on behalf of its affiliated companies or subsidiaries for the purposes stated in this Privacy Statement. Internal regulations have been drawn up for this purpose.
Subsidiary Company.Info B.V. has its own Privacy Statement. Pensioen Pro uses an additional Privacy Statement, alongside this Privacy Statement, for Pensioen Pro Insights.
We understand “processing” to include everything that can be done with your personal data, such as collecting, but also storing, using and deleting. Personal data includes all data that directly or indirectly provide information about you, such as your name, address, bank account number or email address, but also the IP address of your computer, for example.
In this Privacy Statement we describe for which purposes we process your personal data, which personal information we process, on what legal grounds we do so, how we protect your privacy and how you can exercise your privacy rights. If, after reading this Privacy Statement, you have any questions about our use of your personal data, you are always welcome to contact us at privacy@fdmediagroep.nl. You can also reach the Data Protection Officer of FDMG via privacy@fdmediagroep.nl.
This Privacy Statement may change from time to time. The most recent version of the Privacy Statement will be published on this page. This current version is effective as of February 13, 2024 and was last modified on that day.
2. When is this Privacy Statement applicable?
This Privacy Statement applies to the processing of the data of all of the people who read our newspaper(s) and magazines, who use our websites, apps and social media-outlets, who contact the service desk or visit one of our events and who disclose their personal data to us there. This Privacy Statement is therefore not only applicable to our use of your personal data in relation to the paper publications of FD Mediagroep, but it this also concerns the processing of personal data upon visiting the websites: www.fd.nl, www.fdmg.nl, www.bnr.nl, www.energeia.nl, www.pensioenpro.nl, www.impact-investor.com, www.propertynl.com and sub-sites of these websites, related programme and event sites and all associated apps.
Privacy Statement FD Mediagroep
3. Who is responsible for the processing of your personal data?
FD Mediagroep B.V. is responsible for the processing of all personal data that falls within the scope of this Privacy Statement (as described in the introduction). This Privacy Statement lists which personal data are collected and used by FDMG, for what purpose, and to which persons or entities the data are or can be disclosed.
4. For what purposes do we process your personal data and which data does this comprise?
4.1. When you engage in business with us
a) For the conclusion and performance of a contract
When you as a customer purchase a product or service from us, for example when you take out a subscription, online or by telephone, we process your personal data for administrative purposes, e.g., sending invoices, or providing assistance to you by our customer service. We also use your personal data to deliver or administer our products or services, e.g., delivering the newspaper to your address or allowing you to log in to our sites. For this purpose, we process your contact details, such as your address and email address, and other personal data, such as name and payment information.
We are carrying out these processing operations in order to be able to execute an agreement between you and FDMG.
In some cases, we process your data to comply with laws and regulations, for example of tax authorities. In those incidents, we may need to disclose your personal data to government agencies or supervisory authorities. We do this on the ground of a legal obligation that lies with FDMG.
b) For relationship management and marketing
As a customer of FDMG, you will regularly receive newsletters about products and services similar to those you already purchased from FDMG. If you do not want this, you can unsubscribe at any moment, and we will always respect your choice.
Furthermore, we use the information stored in our subscription and sales databases to make you suitable offers and to be able to send you (personalised) mailings. We also use your personal data for the development, execution and analysis of market research and marketing strategies.
In addition, if you have agreed to this prior to use, we build a personal profile of you and your interests with the information we have that pertains to you, in addition to information which we get from other sources, in order to be able to display personalised, relevant articles, advertisements and promotion of FD Mediagroup products and services on our websites or through other channels. We also sell available advertising space to advertisers. These third (advertising) parties use personalised target groups to show you appropriate advertisements guided by the target groups. For these purposes (relationship management and marketing) we process your contact details, such as your address and email address, and personal information, such as your name, and technical data, such as the IP address, MAC address and other information about the equipment with which you are receiving FDMG communications.
If we approach you with personalised marketing, this will always only be done after you were clearly informed about this in advance and have clearly given your consent to do so. You can revoke your consent at any time. You can manage your consent by adjusting your settings in your FDMG account or by changing your settings in the Consent Management Platform.
For the processing of personal data for non-personalised administration and marketing we base our conduct on the principle of legitimate interests. We send newsletters and other communications to existing customers to inform them about similar, FDMG products and services. In doing so, we have taken various measures to prevent infringement upon the privacy of our readers and users as much as possible, and where there is no other option, to limit the impact as much as possible as described in this Privacy Statement. On the same basis, we also process your personal data when you call or email our customer service. In this case, the “performance of a contract” principle also applies, because our customer service is aimed at ensuring that you receive the content and services you have ordered.
4.2. When you visit our websites or use our apps (also as a non-customer)
In addition to the processes described above, we also process personal data to monitor the use of our services and for security purposes. For example, we can register which content on our sites is shared or read a lot. Partly, we do this to use this information to make our website(s) and app(s) function even better, but also because in the case of business subscriptions, companies would like to know how and how often our content is consulted.
Provided the employer informs his employees in advance, FDMG provides aggregated usage data of services upon request, whereby FDMG expressly ensures that the employer can never trace the specific use back to an individual employee or a small group of employees.
FDMG also processes personal data in order to detect abuse, for example the sharing of personal login codes in violation of our general terms and conditions, and to be able to enforce these terms.
For this purpose, in addition to the aforementioned personal data and data that you may have provided yourself, we also use data that are automatically generated by the functionalities you have accessed on our website(s) or app(s) and the technical data of your device, such as the IP address, the internet browser you use, the pages you have visited on our website(s) or app(s), your clicking and surfing behaviour and the length of your (audio) sessions. We collect and process these data for this purpose on the basis of ‘consent’, if given, or on the basis of ‘legitimate interest’.
4.3. If you have created a personal account
On several FDMG websites you can create a personal account (FDMG account). You can also choose that you wish to receive push notifications, for example. Then you are also sharing personal data with us, for example your telephone number, and we process these data. We do this processing on the basis of the consent you have given, in advance and informed, when you created an account. You can of course always change or delete the information provided, as well as withdraw your consent.
4.4. When you enter information in a profile
On some of the FDMG websites (like Pensioen Pro), companies or entrepreneurs can create and/or enhance profiles in order to display their company data to visitors. These data also may sometimes be personal data. The relevant FDMG subsidiary or entity has contractually agreed with the users of those profiles that in those situations FDMG is not responsible for the legitimacy of the use of that personal data and the possible infringement of the privacy of the data subject. The user has provided the relevant subsidiary or entity with a guarantee that it has obtained consent for the processing of these data. If this is not the case, please report this to privacy@fdmediagroep.nl and we will have the data deleted immediately.
4.5. When you participate in our surveys, etc.
We regularly ask our users to participate in surveys, via email or social media, to assess, analyse and where necessary improve new products and services in response to user experiences. Upon participation in such a survey you are sometimes asked to enter your personal data and you thereby also are giving consent to process these data for the stated purpose. We will not use that information for any other purpose.
A telephone conversation between you and a FDMG employee may sometimes be recorded for training purposes, but only after you have given your explicit consent for this in advance. These audio recordings will be deleted within a week at the latest.
5. Cookies
We collect some of the personal data mentioned above by means of “cookies”. These are small data files that store and retrieve data about your visit to our website(s) – for example, how you arrived at our site, how you navigated the site, and what information was of interest to you. More information about cookies and related technologies and their use can be found on the respective website or app.
6. Who has access to your personal data?
6.1 Within the FDMG organisation
The personal data obtained by FDMG can be exchanged with the subsidiaries of the FDMG group. We share your user account data internally for administrative purposes and in order to have a comprehensive overview of your contacts and contracts with FDMG. We may also share your data internally in order to offer you a complete package of services and products. To this end, FDMG stores the personal data in a single, central data warehouse. That data warehouse is located within the European Union.
Our employees only have access to that personal data to the extent necessary to perform their work.
6.2. Outside the FDMG organisation
In some occasions we are legally obliged to share data with third parties, such as the tax authorities. Except if legal obligations apply, we will only provide personal data to third parties after we have sought your consent and when this is really necessary for providing our service, whereby we will comply with all the requirements of the General Data Protection Regulation (GDPR).
The following categories have access to your personal data, when appropriate, for the delivery of their products and services to us: banks, insurance companies, IT service providers, advertising agencies, product support, payment partners, trade information agencies, call centres, debt collection agencies, market research agencies and other service providers.
The parties who gain access to your data from us may only use it in their capacity as processors for FDMG, see below, unless they themselves take up responsibility for obtaining and protecting your data. FDMG has taken the necessary measures to guarantee that the data are only processed by processing parties when this is necessary and only at the explicit instruction of FDMG and that this processing is protected by the required privacy guarantees.
6.3. Use of your personal data by processors
When a third party processes your personal data at our request and according to our instructions, this party is acting as a processor as defined in the GDPR. We have a contract with each processor for the processing of personal data. This contract contains obligations to ensure that your personal data are processed exclusively by the processor or possibly contracted third parties (sub-processors), exclusively for the services they provide to us and that they will meet all requirements set by laws and regulations, as stated by the General Data Protection Regulation for example.
7. How is the protection of your personal data guaranteed?
FDMG has established safeguards to guarantee the confidentiality and security of your personal data. We have implemented appropriate technical, physical and organisational measures to protect personal data from accidental or unlawful destruction or loss, damage, modification, unauthorised disclosure or access, as well as all other forms of unlawful processing (including, but not limited to, unnecessary collection) or further processing. Examples are an ISO 27001 certified IT security policy, training of personnel, secure servers and a protocol against possible data leaks. If your data are shared outside of the EEA, we have put in place appropriate safeguards for such data transfers.
8. How long will your personal data be stored?
Your personal data will be deleted or anonymised when your personal data are no longer required for the purposes for which these personal data were being processed.
9. How can you exercise your privacy rights?
You have the right of access to an overview of your personal data and, under certain conditions, you can rectify and/or delete your personal data such as being used by us. In addition, in certain cases you also have the right to restrict the processing of your personal data, the right to object to the processing, and the right to data portability.
To invoke your right of access, rectification, deletion, restriction, objection or data portability, please contact us at privacy@fdmediagroep.nl. We may require additional information to verify your identity when invoking these rights. If you have given consent for the processing of your personal data for a specific purpose, you can withdraw this consent at any time. Withdrawing your consent is not retroactively effective. You can always contact us about this at privacy@fdmediagroep.nl.
10. Can you file a complaint?
If you are unhappy with the use of your personal data by FDMG, you can contact our Data Protection Officer at any time via privacy@fdmediagroep.nl or submit a complaint to the Dutch Data Protection Authority.