1. Data Controller
    Preliminary Information: The Data Controller is Lean ADV, a project by R&R Media Compass Rose B.V, registered at Fellenoord 39, 5612 AA, Eindhoven, Netherlands – VAT: NL856133358B01 – KVK: 65490266.The Controller provides the data subject with the information required by Articles 13 and 14 of Regulation (EU) 2016/679, describing the characteristics of the processing performed on the personal data provided, the purposes of collection, the measures adopted to secure such data, and the rights of the data subject.Contact Details: For any privacy-related inquiries, please use the dedicated email address provided by the Data Controller:
    privacy@leanadv.com.
  2. Data Protection Officer
    Pursuant to Article 37, letter b) of the GDPR, the Controller has appointed Ms. Anne Maren Fun as the Data Protection Officer (“DPO”).E-mail: dpo@leanadv.com
    Phone/Mobile: +31 621 320 897
  3. Nature of Data Provision (Mandatory or Optional)
    The provision of the data (described below in paragraph 5) required for profiling purposes (see paragraph 4) is optional and will occur only upon the explicit and informed consent given by the data subject. Refusal to provide consent will result in the Controller’s inability to send personalized communications to the data subject regarding the services offered by the platform and/or by authorized third parties.
  4. Purposes of Processing
    Subject to specific consent, the purpose of the processing is profiling through automated tools for direct and indirect marketing activities. By cross-referencing the information provided, the Controller may create a commercial and behavioral profile of the data subject to:
    • record, verify, analyze, and segment data subjects into homogeneous categories (e.g., interests, browsing habits, purchasing preferences);
    • send targeted or personalized communications and improve the effectiveness of marketing campaigns;
    • monitor online behavior and confirm interest in specific categories of services and/or offers through direct contact;
    • process information derived from interactions with emails, websites, blogs, and social media channels managed or used by R&R Media Compass Rose B.V.
      The use of email tracking pixels is subject to the data subject being appropriately informed and, where necessary, providing valid consent. Data subjects may withdraw their consent or object to email tracking in accordance with applicable data protection legislation, and records of such choices may be retained to demonstrate compliance.
  5. Categories of Data Collected
    Below is an outline by which the data collected by the Controller have been subdivided into homogeneous categories:
    Data CategoryType
    Name, surname, company name, title, tax identification number, address, email, city, telephone number, postal code, IP address, opt-in date, opt-in country, category of interestCommon Data
    Attribution Data (IP, Browser, User Agent, Device, OS, Country, Time Zone)Common Data
    GDPR Data (privacy policy [T/F], privacy policy date, profiling [T/F], profiling date, transfer [T/F], transfer date, collection URL, IP)Common Data
    Email Tracking Data (information collected through email tracking pixels, including email open events, deliverability information, technical delivery diagnostics and aggregated campaign performance metrics).Data Category
  6. Purposes of Profiling
    • Segment data subjects into homogeneous categories to optimize promotional outcomes;
    • Verify the data provided by data subjects;
    • Send targeted or personalized communications;
    • Analyze user engagement based on the behavior of the data subject.
  7. Categories of Data Subjects
    Data subjects for profiling purposes are users of the websites, blogs, and online portals owned by the Controller, identified by the following domain: urbanpulse.blog.
  8. Categories of Recipients
    The indicated data will be disclosed to the following categories of recipients: internal personnel properly trained and authorized to access the data (Art. 29, Regulation (EU) 2016/679), IT service providers, mailing platforms, marketing and lead-generation service providers, clients and contractors, professionals or consulting firms, and public authorities or supervisory bodies.
  9. Data Retention Terms
    The Data Controller will use the collected data for the purposes set out in paragraph 5 for a period not exceeding three (3) years from the date the specific consent for processing is provided.
  10. Overall Technical and Organizational Measures
    Pursuant to Article 32 of Regulation (EU) 2016/679, the following measures are implemented:
    • A. Technical Assistance: Mitigates risks arising from software malfunctions affecting telematic infrastructures.
    • B. Training: Prevents and mitigates risks of improper management and/or misuse of personal data through internal procedures and personnel training on data-protection principles and rules.
    • C. Access Logging: Prevents unauthorized access by maintaining access logs, viewable only via personal identification devices.
    • D. Periodic Equipment Maintenance: Prevents hardware malfunctions via regular maintenance by qualified professionals.
  11. Place of Data Processing
    All personal data are processed by R&R Media Compass Rose B.V (LEAN ADV) registered in Fellenoord 39, 5612 AA, Eindhoven, Netherlands – VAT: NL856133358B01 – KVK: 65490266  and hosted by SiteGround Spain S.L. in Eemshaven, The Netherlands with ASN AS19527 – Google LLC. The data will not be disseminated. If a processor is appointed for storage, data may be stored outside the European Union by leading companies operating in data processing and technological innovation.
  12. Rights of the Data Subjects
    • Right of Access: Obtain a copy of the personal data subject to processing.
    • Right to Rectification: Correct personal data that are not up to date or accurate.
    • Right to Object to Processing for Commercial Purposes: Request at any time that the Controller cease sending commercial communications.
    • Right to Object to Decisions Based Solely on Automated Processing: Request not to be subject to decisions based solely on automated processes, including profiling.
    • Right to Withdraw Consent: Withdraw consent for a specific processing activity at any time, without affecting the lawfulness of processing prior to withdrawal.

    In such cases, and in full compliance with Regulation (EU) 2016/679, the company will promptly execute the requests through which the rights provided by the Regulation have been exercised.