The Max Media attaches importance to the protection of your personal data. Therefore, when processing your personal data, we always comply with the applicable legislation, specifically the Law of 8 December 1992 on the protection of privacy with regard to the processing of personal data and its implementing decrees, replaced as of 25 May 2018 by the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (“General Data Protection Regulation”) (hereinafter referred to as ” the Privacy Act”).
In this privacy statement, we explain which personal data we collect and how we process them. By communicating your personal data to us (via our website, via our mobile app or in any other way), you agree to the provisions of this privacy statement. When you provide us with someone else’s personal data, you must first discuss the content of our privacy statement with this person and obtain their consent.
We invite you to read this privacy statement carefully, together with our general terms and conditions and/or any other conditions that may apply to our products and services.
We can adapt this privacy declaration, for example in the context of adjustments to our products or services or to the applicable legislation. It is therefore advisable to read this privacy declaration at regular intervals.
Last update: January 2022
To whom does this privacy declaration apply?
This privacy statement concerns the processing of personal data of visitors to our website, our webshop, our customers and prospects who show an interest in our products and services, as well as personal data of former customers whose details are still stored in our database.
This privacy statement also concerns the processing of personal data of our suppliers and business contacts.
What data do we process?
Depending on the specific products or services you purchase from us or the business relationship we have with you as a supplier or other business contact, the following categories of data may be stored in our database:
General information: information that allows us to identify or contact you
Private individuals: name, first name, sex, address, telephone (landline and/or mobile), e-mail, fax, date of birth, etc.
Companies: company name, legal form, address, company phone number, VAT number, company number, contact person name, function or job title, contact person phone number (landline and/or mobile), e-mail, etc.
Information related to the execution of the specific agreement or transaction by The Max Media bv or to the specific products and services you provide to The Max Media bv as a supplier.
This may include: customer or file number, order/transaction history, webshop account login, delivery address, credit score information (only for VAT obligations), payment information (e.g. IBAN/BIC bank account number, direct debit number), and any other information required for the execution of the agreement.
We may also storeyour responses or feedbacks about products purchased that we receive from you as part of satisfaction or market surveys, or any complaints you may have about products or services provided to us.
Where possible, we also record the date on which these data were communicated to us or on which certain adjustments were made to these data.
Information collected by automated means
When you visit our website/webshop or use our mobile app, in addition to the personal data you voluntarily share with us, we may automatically collect and process certain information using cookies and similar technologies placed by us.
This concerns: IP address, time of your visit to the website or use of the mobile app, the web address from which you clicked through, pages viewed, links clicked through…
Location data may be used for some applications if enabled by you.
If you are active on our social network pages or “like” them, we may also include this information in our database.
We may also receive information relating to you from third parties.
The Max Media bv can use information acquired through external partners or specialized data suppliers to contact you for prospecting purposes. If you have been contacted by us in the context of a commercial action and have not provided us with your personal data yourself, you can always contact us to find out from which source we have received your personal data.
We may also acquire data from external partners or specialised data suppliers in order to supplement, correct or update your personal data or to create a marketing profile.
This information may also include information from publicly available sources.
What do we use your personal data for and what is the legal basis for these processes?
With your permission (legal basis: art. 6a. of the privacy law)
- To be able to answer your question or to contact you at your request, e.g. via our reply forms.
- To be able to follow up and process your participation in one of our competitions or actions.
- To provide you with the services of our Mobile App.
- To send you our digital newsletters or personalised marketing via email or other channels to which you have subscribed.
- In accordance with E-Privacy legislation, we may, based on your implicit consent, send you commercial e-mails (newsletter and commercial offers) regarding our products and services if you are already a customer and have provided us with your e-mail address.
You have the opportunity at any time, free of charge, to object to this use of your e-mail address (you can easily unsubscribe using the link provided at the bottom of each e-mail).
You may withdraw your consent at any time (see “exercising your rights” below).
For the execution of the agreement (legal basis: art. 6b. of the privacy law)
- To prepare, execute and follow up the order or agreement.
- For general customer management, including accounting processing, debt collection or assignment, dispute management and legal proceedings.
- For processing and follow-up of complaints, after-sales service.
- For general supplier contract management, including order tracking, supplier payment, supplier prospecting.
To protect our legitimate interests (legal basis: art. 6f. of the privacy law).
In such a case we always strive to find a balance between that interest and respecting the privacy of the person concerned.
- To keep you informed about our offer and new products, services or promotions that might interest you, including by using files of specialised companies, data suppliers, that we acquire for prospection purposes, possibly on the basis of an analysis of your marketing profile. If you do not want any advertising at all, you can exercise your right to object to direct marketing (see below “exercising your rights”).
- To centralize, combine and enrich customer data with useful data.
- To create customer profiles to make information about our products and services and offers more relevant and tailored to your interests or personal needs.
- To conduct research and testing for the purpose of evaluating and improving our products and services, our internal processes and our services in general.
- To compile statistics and analyses for financial, management, marketing and reporting purposes.
- To detect and combat abuse and fraud, for the management of disputes and legal proceedings and to protect our rights in general.
To comply with the legal obligations to which we are subject (legal basis: article 6c. of the privacy legislation):
In certain cases, we are legally obliged to process your personal data and/or to communicate them to the authorities or bodies determined by law.
To whom are your personal data passed on ?
Your personal data may be passed on to third parties in the following cases:
- To the service providers whom we engage to perform certain services on our behalf and who process personal data in the process (e.g., e-mail marketing service provider, service provider involved in the execution of payment transactions, etc.)
These processors can only use your data within the strict limits of the instructions they receive from us, in accordance with this privacy notice. They are subject to strict confidentiality and security obligations and do not become owners of your data.
- To third parties to whom we need to transfer your information in view of the specific services we provide for you.
- To other companies in our corporate group for the same purposes as mentioned in this privacy statement.
- To our possible legal successors (e.g. in case of sale, reorganisation, merger, liquidation of (part of) our company).
- If (i) certain laws, legal proceedings or a government agency require us to do so, (ii) there is a legitimate interest in doing so or the disclosure of such information is necessary and appropriate to prevent financial or other loss or protect our rights (e.g., disclosure to our credit insurer with whom we purchase insurance against unpaid invoices or to legal service providers) , or (iii) in connection with an investigation of (suspected) fraudulent or illegal activities.
- To other third parties, if you have given specific permission.
Transfer of personal data outside the European Union
By submitting your personal data to us, you agree that it may be transferred to countries outside the European Economic Area. For example, we may use cloud service providers located in countries outside the European Economic Area to host and process your personal data.
In the event of such a transfer, we will ensure that the processing of your personal data is always appropriately protected in accordance with the obligations of the privacy legislation and of this privacy statement.
How long do we keep personal data?
Your personal data will be kept for the period necessary to achieve the purpose for which we are processing them. The retention period may therefore differ for each purpose.
Personal data of customers are kept for a period of ten years after the last purchase.
Personal data of prospects will be kept for a period of five years after the last contact.
In case of subscription to the newsletter, your data will be stored as long as you do not unsubscribe.
Personal data of business contacts and suppliers will be kept in our database as long as you represent the respective supplier and their retention is necessary for the management of the supplier relationship.
Location data is only used to provide the service in question and is not stored.
Retention period for compliance with legal obligations and evidence purposes. For other purposes, personal data may need to be retained for a longer period, for example, to comply with our legal obligations and (e.g. accounting and tax obligations) or to be able to present certain data as legal evidence in disputes.
During this period of passive management, access to the data is limited.
How do we secure your personal data?
The Max Media bv is committed to secure your personal data and protect your privacy as much as possible. We take all the necessary technical and organizational measures. Our network, our infrastructure and our computer systems are strictly secured. Only our employees who need to have this access in order to perform their tasks are granted access to your personal data.
What rights do you have ? How can you exercise them ?
Your right of access and correction
You have the right to access your data included in our file. You also have the right to ask us to correct incorrect information about you or to complete incomplete information.
Your right to withdraw your consent
If you have given The Max Media bv permission for the processing, you can withdraw it at any time.
Your right to object
You can always object, without giving any reason, to the use of your personal data for direct marketing purposes (i.e. to send you promotional offers), as well as to their use for marketing profiling (i.e. to send you the promotional offers we consider most interesting for you, based on your marketing profile).
You also have the right to object to the processing of your personal data based on your specific circumstances in all cases where we process your personal data based on our legitimate interest (see above).
Your right to be forgotten
You have the right to request that your data be completely removed from our database in the cases provided for by law.
Your right to restriction of processing
In the event of a dispute regarding the processing of your personal data, you may request that we restrict the processing. In this case, we will no longer use your personal data until the dispute is resolved.
Your right to data portability
Finally, you have the right to the portability of your personal data that you yourself have communicated to us.
Exercising your rights
You must exercise your rights in writing. To exercise your rights, please provide us with proof of your identity (in order to prevent any unauthorised disclosure or processing of your personal data). For this purpose, we ask that you preferably attach a copy of the front of your identity card to your request.
You can send your request to the following address:
By letter: The Max Media bv : Kocasinan Merkez Mah. Malazgirt Cad, Mevsim Sk. No:3, 34192 Bahçelievler/İstanbul
By email: firstname.lastname@example.org
In accordance with the provisions of the privacy legislation, The Max Media bv will process your request within a period of 30 days from the moment we are in possession of all the elements necessary to process it.
You can also contact the Data Protection Authority at any time, rue du Mail 35, 1000 Brussels or by e-mail at email@example.com.
If you visit our website/webshop or make use of our mobile app, the following personal data will be processed by us automatically, on the basis of cookies and similar technologies placed by us:
Ip-address, type and language of browser, software, type and brand of equipment used during connection to website/webshop and app, duration of website visit or use of the app, web address from which the website/webshop or app was reached, pages viewed, links clicked and other actions taken on website/webshop or app.
What are cookies ?
What do we use the information collected through cookies for?
Personal data collected through the cookies on our websites are used:
- For technical and functional purposes: to allow our website/webshop or mobile app to function technically, to optimize and to remember technical choices (e.g. language selection, newsletter, ….).
- For analytical and static purposes: to learn more about our users and how they use our website/webshop, mobile app and to show more relevant services and offers ( Google Analytics, see below).
- For marketing purposes: to display relevant offers that match user preferences (google AdWords) and are based on the user’s browsing behaviour.
On our website we use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics sets a cookie to evaluate the use of our site and enables us to compile reports on website activity. This helps us to understand how visitors use our website. More information on the data processing by Google Analytics can be found via this link: https://marketingplatform.google.com/about/analytics/terms/us/
Social Media buttons
Our website uses a number of social media tools in the form of “share” buttons that make it easy for users to share information with their friends on certain social networks. As a result, by visiting a page that incorporates such a social media plugin, you may encounter cookies from these websites. These websites are not under our control. If you use these links, you also accept the privacy policies of these sites.
How to manage your cookies ?
Here we inform you about the processing of your personal data on our social media company pages.
The Max Media bv uses social media to keep you up to date with advertising messages, sponsored messages, campaigns and customer service messages and to communicate with our customers. You can follow us on the following social media platforms:
When you visit our company pages and post a comment, your data will be processed. The Max Media bv and the social media platform are individually or jointly responsible for this in accordance with applicable laws and regulations.
The social media platform manages the IT infrastructure of the platform, has its own data protection policy and maintains its own user relationship with you (as far as you are a registered user of the social media platform). On the data that social media platforms collect from you, The Max Media bv has no influence. The social media platform is responsible for the processing of such data.
Purpose of our data processing on/social media
On our company page, we share certain information with our customers. When you post a comment, video, photo or like, your data is public. The processing of this (personal) data takes place for the purpose of providing information, obtaining customer feedback and assessing any complaints.
The legal basis for processing your data is our legitimate interest to communicate with our customers and advertise our company through the social media platform.
Recipients / categories of recipients:
If you submit a question to us on our company page, in some cases we may direct you to another communication channel such as Facebook Messenger, Twitter DM or e-mail. You may submit confidential questions to us at any time by sending a message to the address listed in this Privacy Statement. Data submitted to us in confidence (e.g. by private message, letter or e-mail) will not be passed on to organisations outside The Max Media bv. This excludes companies that process data on our behalf and according to our instructions, such as social media agencies. We have good agreements with these companies about the processing of personal data.
Storage period / criteria for determining the storage period
Public posts will remain on the timeline as long as they are not deleted by you (or by us in case of inappropriateness). Data submitted to us in confidence will be deleted or stripped of its identifying characteristics (anonymized) by us no later than seven days after the last response.