SDP

Privacy Policy

Effective date: January 2026

At Spaaij Digital Publishing (SDP), we are committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, share, and protect your information in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws.

By using our Platform, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with this policy, please do not use our services.

1. Data Controller

Company Name: Spaaij Digital Publishing (SDP)

Country: The Netherlands

Chamber of Commerce (KvK): 89337557

VAT Number: NL004719278B58

For privacy-related inquiries, please contact us through our Contact page.

2. Information We Collect

2.1 Personal Data You Provide

When you use our Platform, we may collect the following personal information:

  • Account Information: Name, email address, username, password (encrypted)
  • Profile Information: Display name, profile picture, bio, website, social media links (for authors)
  • Payment Information: PayPal email address (for authors receiving royalties), bank account details (if you opt for bank transfers)
  • Content Information: Books you publish, including metadata, cover images, and file uploads (for authors/publishers)
  • Communication Data: Messages sent through our messaging system, reviews, and other user-generated content

2.2 Automatically Collected Information

  • Usage Data: Pages visited, books viewed, reading progress, purchase history, bookmarks, wishlist items
  • Device Information: Browser type, device type, IP address, operating system
  • Cookies and Similar Technologies: Essential cookies for session management and user preferences

2.3 Information from Third Parties

  • Payment Processors: Transaction confirmation and payment status from PayPal or Stripe

3. Legal Basis for Processing (GDPR)

Under GDPR, we process your personal data based on the following legal grounds:

3.1 Contractual Necessity

Processing is necessary to fulfill our contract with you (Terms and Conditions, Publishing Terms), including account creation, content delivery, payment processing, and service provision.

3.2 Legitimate Interest

We process data based on our legitimate interests in operating and improving our Platform, preventing fraud, ensuring security, and providing customer support, provided these interests do not override your fundamental rights and freedoms.

3.3 Legal Obligation

Processing is necessary to comply with legal obligations, including tax reporting, anti-money laundering requirements, and responding to lawful requests from authorities.

3.4 Consent

For certain optional features (e.g., marketing communications, analytics), we obtain your explicit consent, which you may withdraw at any time.

4. How We Use Your Information

We use your personal data for the following purposes:

  • Service Provision: To create and manage your account, process purchases, deliver digital content, and enable platform features
  • Payment Processing: To process transactions and distribute royalties to authors
  • Communication: To send transactional emails (purchase confirmations, account notifications), respond to inquiries, and provide customer support
  • Personalization: To provide personalized book recommendations and save your reading preferences
  • Platform Improvement: To analyze usage patterns, improve features, and enhance user experience
  • Security and Fraud Prevention: To detect and prevent fraud, abuse, unauthorized access, and violations of our terms
  • Legal Compliance: To comply with legal obligations, including tax reporting and responding to lawful requests
  • Notifications: To notify authors of sales, reviews, and messages; to notify readers of new releases from followed authors

5. Data Sharing and Third Parties

Your Privacy is Protected

  • • We do not sell your personal data to third parties for marketing purposes
  • • Your email address is never shared publicly
  • • You control your public profile information

5.1 When We Share Your Information

We may share your personal data only in the following limited circumstances:

Payment Processors

We share necessary payment information with PayPal and Stripe to process transactions securely. These processors have their own privacy policies governing their use of your information.

Authors/Publishers (Limited)

We share your email address with authors/publishers only for royalty distribution purposes when you purchase their books. Your username (not email) is shown when you send messages or leave reviews.

Service Providers

We may use trusted third-party service providers to help us operate our Platform (e.g., hosting, email delivery, analytics). These providers are bound by confidentiality agreements and may only use your data to perform services on our behalf.

Legal Requirements

We may disclose your information when required by law, legal process, or valid governmental request, or to protect our rights, property, safety, or that of our users.

Business Transfers

If SDP is involved in a merger, acquisition, or sale of assets, your personal data may be transferred as part of that transaction. You will be notified of any such change.

6. Your Rights Under GDPR

As a data subject in the European Union, you have the following rights:

6.1 Right of Access

You have the right to request a copy of the personal data we hold about you.

6.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal data.

6.3 Right to Erasure ("Right to be Forgotten")

You have the right to request deletion of your personal data, subject to legal retention requirements (e.g., tax records, transaction history for legal compliance).

6.4 Right to Restriction of Processing

You have the right to request that we limit how we use your data in certain circumstances.

6.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller.

6.6 Right to Object

You have the right to object to processing of your personal data based on legitimate interests or for direct marketing purposes.

6.7 Right to Withdraw Consent

Where processing is based on consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing before withdrawal.

6.8 Right to Lodge a Complaint

You have the right to lodge a complaint with your local data protection authority if you believe your rights have been violated.

To exercise any of these rights, please contact us through our Contact page. We will respond to your request within 30 days as required by GDPR.

7. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy:

  • Account Data: Retained while your account is active, plus a reasonable period after account closure for legal compliance
  • Purchase Records: Retained for 7 years as required by tax, accounting, and legal regulations
  • Published Content: Retained while published, or as needed for legal/contractual obligations
  • Communications: Retained for customer support and dispute resolution purposes, typically 2-3 years
  • Usage Data: Anonymized or deleted after a reasonable period, typically 12-24 months

After the retention period expires, we will securely delete or anonymize your personal data, unless longer retention is required by law.

7.1 Transferring Purchases Between Email Addresses

If you have made purchases under a different email address and wish to transfer them to your current account, you may request this within the 7-year retention period. To do so:

  • Provide proof of ownership of the original email address (e.g., verification email, purchase confirmation)
  • Send your request to: publishing@spaaijdigital.com
  • Include both email addresses (old and new) in your request

We will verify your identity and ownership before processing any transfer of purchase records.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data:

  • Encryption: Passwords are encrypted; sensitive data transmitted over HTTPS/TLS
  • Access Controls: Strict access controls limit who can view personal data internally
  • Secure Payment Processing: Payment data is handled by PCI-DSS-compliant processors (PayPal, Stripe)
  • Regular Security Audits: We regularly review and update our security practices
  • Account Security: You are responsible for keeping your login credentials confidential

While we strive to protect your personal data, no method of transmission or storage is 100% secure. If you suspect unauthorized access to your account, please notify us immediately.

9. Cookies and Tracking Technologies

9.1 What Are Cookies?

Cookies are small text files stored on your device that help us provide and improve our services.

9.2 Types of Cookies We Use

Essential Cookies (Required)

These cookies are necessary for the Platform to function properly. They enable core features like authentication, session management, and security. You cannot opt out of essential cookies.

Preference Cookies

These cookies remember your preferences (e.g., reading theme, font size, language) to enhance your user experience. You can manage these through your browser settings.

9.3 What We Don't Use

  • We do not use third-party advertising or tracking cookies
  • We do not sell cookie data to third parties
  • We do not use cookies for cross-site tracking

9.4 Managing Cookies

You can control and delete cookies through your browser settings. Note that disabling essential cookies may affect the functionality of the Platform.

10. International Data Transfers

SDP is based in the Netherlands (EU). If you access our Platform from outside the EU, your data may be transferred to and processed in the EU or other countries where our service providers operate.

When we transfer personal data outside the EU, we ensure appropriate safeguards are in place, such as:

  • EU Commission approved Standard Contractual Clauses (SCCs)
  • Adequacy decisions confirming the destination country provides adequate data protection
  • Other legally recognized transfer mechanisms under GDPR

11. Children's Privacy

Our Platform is not intended for users under the age of 18. We do not knowingly collect personal data from children under 18. If you are a parent or guardian and believe your child has provided us with personal data, please contact us, and we will delete such information.

12. Privacy in Community Features

Privacy-First Design

  • • Your email address is never displayed publicly
  • • You can choose to use a username instead of your real name in reviews and messages
  • • You control whether your purchase history is visible to others
  • • All community interactions use pseudonyms to protect your identity

12.1 Messaging System

When you send messages to authors, your username is displayed, but your email address remains private. Authors cannot see your email address unless you explicitly include it in your message content.

12.2 Reviews

Reviews display your username or display name, but not your email address. You can control what name is shown in your profile settings.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or service features.

We will notify you of any material changes by:

  • Posting a notice on the Platform
  • Sending an email to the address associated with your account
  • Updating the "Effective date" at the top of this policy

Your continued use of the Platform after the effective date of the updated Privacy Policy constitutes your acceptance of the changes. If you do not agree, please stop using the Platform.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

  • Through our Contact page
  • For data protection inquiries specifically, you may also reach out through the contact information provided in the footer

Acknowledgment

By using Spaaij Digital Publishing (SDP), you acknowledge that you have read, understood, and agree to this Privacy Policy and consent to the collection, use, and sharing of your information as described herein.