Table of Contents
- Data Controller
- Minors
- Types of Data
- Source of Data
- Purposes for Data Processing
- Legal Grounds for Data Processing
- Data Sharing
- Cookies
- Retention
- Security
- Rights of the Data Subject
- Changes
- Questions
1. Data Controller
PALM RADIO is our trade name. Through our services, we process privacy-sensitive data (hereinafter: “personal data” or “data”). Processing refers to any use of your personal data, such as storing, modifying, forwarding, or (partially) deleting this data. We process personal data when you use our website(s), app(s), or when you participate as a participant or attend one of our (Radio) productions as an audience member. The data controller is PALM RADIO, located at Kaya Corosolweg 30 Willemstad, Curaçao.
2. Minors
If you are under the age of 16, you may only provide personal data to PALM RADIO if your parents or legal representatives have read this policy and given their consent. This applies only if consent is the legal basis for processing (see ‘6. Legal Grounds for Data Processing’). Considering available technology, we make reasonable efforts to check if your parents or legal representatives have truly granted consent.
3. Types of Data
We use the following data for the purposes outlined in this policy:
Basic Data:
- Name, address, and residence
- Contact information such as (mobile) phone number and email address
- Date of birth and age
- Gender
- Participation history
- Participant agreements and other contracts
Additional Specific (Radio) Production Data:
- Marital status and relationship status
- Information about partner and/or children
- Work-related information such as employer, position, and income data
- Payment data such as billing address, bank account number, and possibly credit card details
- Data from your social media accounts
- Media (photo, video, and audio fragments)
- Biographical data (your ‘bio’ prepared by us) and other data relevant for selection or participation in our programs
Technical Data:
- Detailed (technical) data about your use of our website(s) or app(s), such as device type and properties, browser type and language, date and time of interaction, and IP address
- Search terms used on our website(s) or app(s)
The data we use depends on the purpose for which we process the data (see also ‘5. Purposes for Data Processing’). We do not use all of the above-mentioned ‘additional specific (Radio) production data’ for every (Radio) production. It depends on the specific (Radio) production.
Biographical and other data that is relevant for the selection or participation in our programs may also include sensitive personal data such as race, ethnicity, political opinions, religious beliefs, union membership, sexual orientation, health, or criminal data. We are aware of the sensitivity of this data and the possible impact it may have on your privacy. Therefore, we process this data only based on your explicit consent (see ‘6. Legal Grounds for Data Processing’) and handle this data with extra care. Additionally, we will delete this data immediately after the last broadcast date of a production.
4. Source of Data
The main way we collect data is by asking you directly. You can choose whether to provide us with this data or not. For example, data that you can fill in on (one of) our website(s) or app(s) such as when filling out a registration form. However, if you choose not to provide certain data, you may not be able to use our services or participate as a participant or audience member. For example, because we are also obligated to collect certain data from you in this context. When entering personal data, we indicate which data is necessary and which can be optionally provided.
Additionally, there is data we automatically collect, such as (technical) data about the devices you use. This data is collected through cookies and similar technologies. See also ‘8. Cookies’.
5. Purposes for Data Processing
We will use your data for the following purposes:
- To offer you our services, products, and/or information or to allow you to participate in them. For example, if you participate as a participant or audience member in one of our (Radio) productions
- To select suitable participants and/or audience members for our (Radio) productions
- Because you want us to store your data. For example, when you register to be included in our DJ database to be selected as a Radio host, participant, or audience member for future (Radio) productions
- To approach you for participation in a PALM RADIO program or production, such as a Radio host, participant, or audience member
- To allow you to post and exchange information via our services, such as on our website(s) or app(s). If this website and/or app allows, also to contact other users of the service
- To analyze, collect statistics, maintain, secure, and optimize our website(s) and/or app(s) and related technologies
- To send you (electronic) commercial communications from PALM RADIO and third parties who advertise, sponsor, or offer prizes via our services
- To comply with applicable laws and regulations
We will not use your data for purposes other than those outlined above.
6. Legal Grounds for Data Processing
We process data because it is necessary for the performance of a contract. For example, when processing is required to deliver our services.
Additionally, we process data because it is required by law. For example, there is legislation that obligates us to retain data for a specific period, such as payment data, which the General Tax Act requires us to retain for 7 years for the Tax Authorities.
We also process data because we or a third party have a legitimate interest, such as business interests. In that case, we always make a thorough assessment of whether this interest outweighs your privacy interests.
Lastly, we process data based on your consent, for example, when processing sensitive personal data or when we wish to retain data for a long period, such as in the DJ database. We also inform and ask for your consent before placing and reading cookies or sending you (electronic) commercial communications.
7. Data Sharing
Your data may be exchanged and combined within PALM RADIO. See also ‘1. Data Controller’.
For processing your personal data, we make use of third parties who may have access to your data. Where possible, we require these third parties to act as processors. This means that we determine the purpose and means of processing, and the processor may only handle your data according to our instructions and our (security) standards. We document these arrangements with each processor in a so-called processor agreement.
8. Cookies
On our website(s) and/or app(s), we use cookies and other similar technologies (hereinafter: “cookies”). Would you like more information about what cookies are, what specific types of cookies we use, why we use them, and how you can control them? Then please refer to our Cookie Policy.
9. Retention
We try to retain personal data as long as necessary. We have made a conscious distinction between the types of data we collect (see ‘3. Types of Data’). The ‘basic data’ must be retained as long as necessary for the operation of our (Radio) productions. The ‘production-specific data’ will be deleted immediately after the last broadcast date of a production.
An exception to this is if the law requires us to retain certain data for a longer period. For example, payment data must be retained for 7 years for the Tax Authorities as required by the General Tax Act.
10. Security
We do our utmost to secure personal data as effectively as possible. We do this by taking organizational and technical security measures that, given the state of the art, try to prevent unauthorized access to the data, alteration, disclosure, or loss of the data.
If we engage processors, we require them to handle your data according to our instructions and security standards. See also ‘7. Data Sharing’.
11. Rights of the Data Subject
You have the right to access, correct, delete, or transfer your personal data. You also have the right to limit or object to the processing. Finally, we would like to inform you about your right to file a complaint with the Dutch Data Protection Authority.
You can always send us a request to exercise your rights. You can do this by sending an email to [email protected]. Please specify as much as possible in your request which personal data your request pertains to, which right you wish to exercise, and provide proof that it is indeed your personal data. We will aim to respond to your request within a month.
12. Changes
We may unilaterally change this Privacy Policy. We recommend that you regularly check this policy for any changes. If we make significant changes, we will notify you, for example, by placing a notice on our website(s) and/or app(s), by email, or by asking for your consent again.
13. Questions
Questions or complaints regarding privacy can be sent to [email protected].