Privacyverklaring Dialog
4 February 2025 – Version 1.14
This Privacy Policy applies to the processing of personal data by Dialog B.V. (“Dialog”). Dialog processes personal data in accordance with the General Data Protection Regulation (GDPR) and applicable Dutch data protection laws.
1. Roles and responsibilities
Depending on the services provided, Dialog acts as:
- Controller for its own marketing and communications activities; and
- Processor when processing personal data on behalf of its customers within the Online Platform.
Where Dialog acts as a processor, the customer (controller) determines the purposes and means of processing.
2. Categories of personal data
Dialog may process the following categories of personal data:
- Identification data (e.g., name, job title, organisation)
- Contact data (e.g., email address, phone number)
- Usage and interaction data (e.g., login moments, click behaviour, email open rates)
- Technical data (e.g., IP address, browser information)
- Communications data
Dialog does not intentionally process special categories of personal data, unless explicitly agreed and legally permitted.
3. Purposes and legal bases
| Purpose | Legal basis |
|---|---|
| Performance of agreements | Necessary for contract performance |
| Use and administration of the platform | Necessary for contract performance |
| Customer service and support | Legitimate interests |
| Marketing communications | Consent |
| Analytics and service improvement | Legitimate interests |
| Legal obligations | Legal obligation |
4. Use of HubSpot
Dialog uses HubSpot, a CRM and marketing automation platform, for marketing and communications activities. HubSpot processes personal data on Dialog’s behalf as a processor.
As HubSpot is located in the United States, personal data may be transferred outside the European Economic Area (EEA). Such transfers take place on the basis of Standard Contractual Clauses (SCCs) and additional appropriate safeguards, including technical and organisational measures.
For more information on how HubSpot processes your data, please refer to HubSpot’s Privacy Policy.
5. Marketing and consent
Dialog uses personal data for marketing purposes (such as newsletters and invitations) only where explicit consent has been obtained. Consent can be withdrawn at any time, and every marketing email includes an unsubscribe option.
6. Profiling and automated processing
Dialog may use limited profiling for marketing optimisation, such as segmentation based on interactions. Dialog does not carry out automated decision-making that produces legal effects or similarly significant effects for individuals.
7. Access to data
Access and visibility within the Online Platform are determined by the controller through authorisation settings. Questions? End users/managers can contact their internal contact (often HR). Administrators can email support@dialog.nl or call +31 30 7600 290.
8. Retention
Dialog retains personal data no longer than necessary for the purposes for which it was collected, unless a statutory retention obligation applies. Retention periods are determined based on the type of data, the purpose of processing, and legal requirements.
9. Sharing and sub-processors
Dialog shares personal data only with sub-processors where necessary to deliver its services. Dialog has entered into GDPR-compliant processing agreements with its sub-processors. An up-to-date overview of sub-processors is available upon request via support@dialog.nl.
10. Security
Dialog implements appropriate technical and organisational measures to protect personal data against loss, misuse, and unauthorised access. Further details are described in our Security Policy (available upon request via support@dialog.nl).
11. Your rights
Individuals have the right to request access, rectification, erasure, restriction, to object to processing, data portability, and to withdraw consent at any time. Requests can be submitted via support@dialog.nl.
Privacy-related requests (such as access, correction, deletion, or data portability) may also be submitted directly via HubSpot’s data privacy request form: https://eu1.hs-data-privacy.com/request/CpLJXSoCMFgp8Gays2gxCA. Dialog will handle requests in accordance with the GDPR within the applicable statutory time limits.
You also have the right to lodge a complaint with the Dutch supervisory authority: the Autoriteit Persoonsgegevens.
12. Changes
Dialog may update this Privacy Policy from time to time. Updates are published on this page. These terms are governed by Dutch law.