DiverTown’s Privacy Policy

Personal Data Management and Cookie Policy

European Studios as Guardian of Your Personal Data

Central to the mission of European Studios is the empowerment of individuals through our diverse assortment of sites, products, and services. To this end, we operate under the watchful governance of specific European Studios controllers in various countries, ensuring the secure management of personal data in line with our users’ trust and expectation. The preservation of this trust through stringent data handling practices is crucial to our operations.

We place significant value on our users’ privacy, while acknowledging that personal data utilization is integral to delivering our offerings. Our commitment is to maintain absolute transparency in our personal data processes, consistently striving to achieve an equilibrium between privacy and commercial interests. For any enquiries, our privacy team remains at your disposal.

This policy provides a broad outline of our data collection practices, the reasons behind them, potential sharing entities, and the means by which you can exercise your rights over your personal data. For a more comprehensive understanding of how personal data is processed in each European Studios country, we direct you to the country-specific privacy and cookie policies referred to throughout this document.

Should you have concerns or queries pertaining to European Studios’s handling of your personal data, the European Studios privacy team is readily accessible via this contact form. Rest assured, we are committed to addressing all queries within a 30-day period.

Objectives of European Studios in Utilizing Your Personal Data

At the heart of our services, European Studios primarily employs your personal data to fulfill the following purposes:

• The provision of quality news and journalistic content, along with corresponding product features, accessible through our digital services or physical delivery. Personal data guides the management of these customer relationships.
• The facilitation of consumer-to-consumer and business-to-consumer transactions, marketing, and communication via our online marketplaces. We also accommodate professional job postings and job seeker applications.
• The offering of product and price comparison services, allowing users to assess products and online stores and navigate to different online stores through provided links.
• The execution of product distribution, delivery, and associated services, which include, but are not limited to, newspapers, packages, magazines, bread, and juice, either delivered to a user’s home address or a local pick-up point.
• The safeguarding of access to our services through European Studios accounts, or other site-specific log-ins, where you can manage your privacy preferences, verify your contact details, and establish a trusted identity for interactions with other service users.
• The provision of customer service via telephone, email, our brands’ social media pages, and chat.
• The administration of payments, invoicing, and additional responsibilities and documentation necessitated by book-keeping regulations.
• The improvement of our services through the analysis of user behavior data, surveys, and user research.
• The maintenance of site and service security, employing data to protect our users and ourselves from fraudulent activities, policy breaches, and abusive behavior.
• The display of targeted advertising to users and the measurement of its effectiveness.
• The delivery of personalized content to users, including a selection of personalized content on some news service front pages, newsletters dispatched to our service users, and recommendations of classified ads on our marketplaces.
• The exposure of users to marketing messages for services within European Studios via email, in-product sales offers, and other channels such as social media platforms, including retargeting on third-party sites.
• The provision of data insights and analytics to our business, detailing the usage of the European Studios ecosystem of services, to inspire, inform, and enable our team to enhance our products and services, and uncover opportunities for new product and service development.
• The processing of data pertaining to professional partners and their employees within our business-to-business sales and services.

Classification and Processing of Personal Data by European Studios

The breadth of personal data that European Studios typically amasses encompasses:

• Fundamental Profile Data (e.g., name, address, email address, date of birth, gender, and other profile data necessary for the provision of specific services.)
• Account Information (e.g., account activity, service subscriptions, privacy settings, support queries, account security data like passwords.)
• Third-Party Data (e.g., suggestions, petitions, notices, and other feedback obtained from other users or third parties related to our marketplace services.)
• Financial Transaction Details (e.g., purchase history and specifics, due and received payments, payment methodologies.)
• User-Supplied Content (e.g., comments on articles, feedback via user surveys and user ratings/reviews, classified ads and correspondence between sellers and buyers in the marketplace.)
• Technical and Behavioural Data (e.g., device and cookie identifiers, network address identifiers such as IP addresses, user browsing history and actions, email opening and reading data.)
• Geographical Data (e.g., GPS data and location data associated with IP addresses.)
• Predictive User Data (e.g., presumed interests, probable locations, likely demographics.)
• Advertisement Efficacy Data (e.g., ad views, duration and frequency of views, and user interactions with the ads.)
• B2B Client Information (for our corporate clients and contacts within their businesses, including business roles, contract specifics, and contact details.)

The exact categories of data processed may vary depending on the particular European Studios services you utilize. For a comprehensive description of these data types, refer to the specific privacy and cookie policy for your country.

Disclosure of Personal Data to External Entities

In the course of processing personal data, European Studios occasionally disseminates this data to other entities. These entities may either be:

1. Data Processors: Companies operating under a legally binding agreement with European Studios, with processing restricted to the specific purposes defined by European Studios and utilizing third-party services only as permitted by European Studios. Notable examples include Amazon Web Services, Zuora, Braze, among others.
2. Data Controllers: Entities utilizing the data independently and assuming full responsibility for the use of user’s personal data for the explicit purposes that data is shared. They also bear responsibility for any third-party involvement in the processing of user’s personal data. European Studios shares data with such entities only when essential for product or service delivery.

Additionally, we may disclose personal data to public authorities upon request or at our discretion if legally mandated. Occasionally, we assist in disputes by sharing relevant information with our marketplace users if deemed helpful in resolving issues related to fraudulent ads.

In our commitment to fostering scientific research and development, we provide anonymised data sets and insights from our services, safeguarding the individual privacy of our users in the process.

Data Transfer Beyond EU/EEA Boundaries

• European Studios, acting in its capacity as the data controller, reserves the right to engage data processors located outside the EU/EEA, strictly in instances where • such a transfer location and the recipient have been deemed suitable in accordance with the standards established under GDPR, or
• transfers occur within the framework of the standard contractual clauses delineated by the EU Commission to govern such transfers under GDPR, and essential supplementary safeguards have been put in place.

Data Retention Policy

European Studios abides by the overarching principle that personal data of users is retained only for a duration necessary to fulfil the intent of its collection. We also retain data to comply with legal obligations, such as book-keeping and accounting. Specific retention periods may vary according to the country.

User Rights in the Capacity of a Data Subject

Users possess legally mandated rights in relation to their personal data. European Studios is resolutely committed to enabling users to exercise these rights. We strive to respond to rights-related requests promptly, but always within 30 calendar days. The rights you possess, and how to exercise them, are explained below in general terms. For more details, please consult the country-specific privacy and cookie policies.

The Right to Access and Data Portability

Primarily, data access is facilitated through the European Studios or other digital account management interfaces. In certain instances, users may need to contact customer support to request data access.

Right to Rectification

Users may correct their profile details via their digital account at any time.

Right to Erasure

Users can request the deletion of their personal data held by European Studios at any time through the European Studios or other digital account administration interface. In some cases, it may be necessary to contact customer support to request data deletion.

The Right to Restrict and Object to Processing

European Studios offers users options and controls to manage the processing of their personal data, including the right to restrict and object to processing, and to withdraw consents connected to personal data processing. These controls are typically located in the footer of our websites and mobile application settings. Some controls can also be found in your European Studios or other digital account administration interface. For more about the controls offered in each country, refer to the country-specific privacy and cookie policies.

Right to Prevent Automated Decisions with Legal or Similar Effects

European Studios does not engage in automated decision-making concerning our users that could result in legal or similarly significant effects.

Data Usage for Journalistic Purposes

Personal data may also be processed by European Studios’s brands for journalistic purposes. As freedom of speech and access to information are of paramount concern, significant portions of the regulations for personal data do not apply to processing of personal data for such purposes. Nevertheless, European Studios’s brands place high importance on information security, ensuring full compliance with legal business obligations, as well as obligations related to their editorial operations.”