This Privacy Policy describes how Prompt Access Downloads, a service operated by FRST Media Europe B.V. (KvK 80008798), processes personal data collected through the promptaccessdownloads.com website and subscription service. We are committed to handling your information transparently and in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection legislation.
The data controller responsible for personal data processed in connection with this service is FRST Media Europe B.V., Keizersgracht 268, 1016EV Amsterdam, Netherlands. You can reach us at info@promptaccessdownloads.com for any privacy-related enquiries.
1. Information We Collect
Prompt Access Downloads is a carrier-billed subscription service. No account registration is required, and we do not collect or store passwords, email addresses, or credit card details. Depending on how you interact with the service, we may process the following categories of personal data:
- Mobile phone number (MSISDN) — your mobile number is passed to us by your carrier at the point of subscription activation. It is the primary identifier used to manage your subscription, process billing, and handle cancellation requests.
- Subscription status and history — records of your subscription start date, current status (active, suspended, or cancelled), and billing events are maintained to administer your account and resolve any disputes.
- Content access logs — records of which educational guides, self-improvement resources, and downloadable materials you access through the service. These are used to maintain service quality, curate relevant content, and troubleshoot technical issues.
- IP address and device data — your IP address, device type, operating system, and browser version are collected automatically when you visit the website. This technical data is used for security monitoring, compatibility, and aggregated analytics.
- Cookie and session data — functional data stored locally in your browser to maintain session continuity and basic site functionality. See Section 6 for full details.
We do not collect sensitive personal data (such as health records, financial account details, or biometric data). We do not require users to create accounts or provide names or email addresses to access the service.
2. How We Use Your Data
We use the personal data described above for the following purposes:
- Providing and administering the subscription — activating your access to Prompt Access Downloads content, processing monthly carrier billing through SMS shortcodes 19001 and 19000, and handling cancellation or suspension requests.
- Service communications — sending you SMS confirmations of subscription activation, renewal charges, and cancellation confirmations via your carrier. We do not send unsolicited promotional SMS messages.
- Content delivery and personalisation — using content access logs to ensure you can access the educational materials included in your subscription and to identify which content categories are most valuable to subscribers.
- Security and fraud prevention — monitoring access patterns and IP data to detect and prevent unauthorised use, subscription fraud, or abuse of the service.
- Service improvement and analytics — analysing aggregated, anonymised usage data to understand how the service is used, improve the content catalogue, and optimise the website experience for mobile users.
- Legal compliance — retaining billing and subscription records to meet Dutch accounting and telecommunications regulations, and responding to lawful requests from regulatory authorities.
We do not use your personal data for unsolicited direct marketing, and we do not sell or rent your data to third-party advertisers.
3. Legal Basis for Processing
We process your personal data only where a valid legal basis under Article 6 of the GDPR applies. The bases we rely on are:
- Performance of a contract (Article 6(1)(b)) — processing your mobile number, subscription status, and billing records is necessary to deliver the subscription service you have signed up for. Without this processing, we cannot activate or manage your subscription.
- Legitimate interests (Article 6(1)(f)) — we process content access logs, IP addresses, and device data on the basis of our legitimate interests in operating a secure, functional, and continuously improving service. We have assessed that these interests are not overridden by your rights and freedoms, given the limited nature and scope of the data involved.
- Compliance with a legal obligation (Article 6(1)(c)) — we retain billing and subscription records for the period required by Dutch accounting law (Boekhoudbesluit) and applicable telecommunications regulations.
- Consent (Article 6(1)(a)) — where we rely on consent for any specific processing activity (for example, optional analytics), we will notify you clearly at the point of collection and provide a mechanism to withdraw consent at any time.
Where processing is based on legitimate interests, you have the right to object. Please see Section 5 for details of how to exercise that right.
Data Retention
We retain personal data only for as long as necessary to fulfil the purposes described in this policy or to meet our legal obligations:
- Subscription and billing records — retained for a minimum of seven years following the end of your subscription, in accordance with Dutch statutory accounting requirements (Article 2:10 of the Dutch Civil Code).
- Content access logs — retained for up to 24 months from the date of the access event, after which they are anonymised or deleted. Anonymised aggregate data may be retained indefinitely for analytics purposes.
- IP address and device data — server logs containing IP addresses are retained for up to 90 days for security and debugging purposes, then deleted.
- Erasure requests — if you request deletion of your personal data, we will action this within 30 days, except where a statutory retention obligation requires us to retain specific records for a defined period.
When data is no longer required, it is securely deleted or irreversibly anonymised.
Your Rights
Under the GDPR and applicable Dutch data protection law, you have the following rights with respect to your personal data:
- Right of access — you may request a copy of the personal data we hold about you, along with information about how it is processed.
- Right to rectification — if any personal data we hold about you is inaccurate or incomplete, you may ask us to correct or complete it.
- Right to erasure — you may request that we delete your personal data. We will comply unless we are required to retain it for legal reasons, in which case we will explain the applicable obligation.
- Right to restriction of processing — in certain circumstances (for example, if you contest the accuracy of your data or object to our processing), you may ask us to restrict how we use your data while the matter is resolved.
- Right to data portability — where processing is based on your consent or performance of a contract and is carried out by automated means, you may request a copy of your data in a structured, machine-readable format.
- Right to object — you may object at any time to processing based on legitimate interests. We will stop processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
- Right to withdraw consent — where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing that took place before withdrawal.
To exercise any of these rights, contact us at info@promptaccessdownloads.com with a description of your request. We will respond within 30 days. You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at autoriteitpersoonsgegevens.nl.
Cookies
Prompt Access Downloads uses a limited number of cookies strictly necessary to operate the website. We do not use advertising cookies, cross-site tracking cookies, or third-party profiling technologies.
The cookies we use are:
- Session cookies — temporary cookies that expire when you close your browser. They maintain your session state as you navigate between pages and are essential for the subscription flow to function correctly.
- Analytics cookies — if Google Analytics is active on this site, it may set cookies to collect anonymised data about page visits, session duration, and device type. This data is used in aggregate form only and does not identify individual users. You can opt out of Google Analytics tracking by installing the Google Analytics opt-out browser add-on.
Most web browsers allow you to control cookies through their settings. You can typically refuse or delete cookies by adjusting your browser preferences. Disabling session cookies may prevent the subscription flow from working correctly. For full details on cookies set by this site, please refer to our Cookie Policy.
Third-Party Services
To deliver the Prompt Access Downloads service, we work with a small number of trusted third-party providers who act as data processors on our behalf. These providers may access limited personal data only to the extent necessary to perform their services:
- Mobile carriers and SMS billing partners — your mobile number and subscription events are shared with the carrier or SMS aggregator responsible for processing your monthly billing charge and delivering cancellation confirmations.
- Hosting and infrastructure providers — our website and service infrastructure is hosted on cloud platforms. These providers process technical data (including IP addresses and logs) solely for the purpose of hosting and securing the service.
- Analytics providers — if Google Analytics is used, anonymised usage data is processed by Google LLC in accordance with their privacy terms. No personally identifiable information is shared with Google for analytics purposes.
All third-party processors are selected carefully and are contractually bound to process personal data only for the purposes we specify, to maintain appropriate security measures, and to comply with applicable data protection law. We do not sell your data to any third party.
Data Transfers
FRST Media Europe B.V. is established in the Netherlands and primarily processes personal data within the European Economic Area (EEA), where GDPR protections apply in full.
Some of our third-party service providers may process data outside the EEA. Where such transfers occur, we ensure that appropriate safeguards are in place, including:
- Standard Contractual Clauses (SCCs) — approved by the European Commission for transfers to third countries, ensuring equivalent data protection standards apply.
- Adequacy decisions — transfers to countries recognised by the European Commission as providing an adequate level of data protection.
If you have questions about international data transfers or wish to obtain a copy of the safeguards we rely on, contact us at info@promptaccessdownloads.com.
Children’s Privacy
Prompt Access Downloads is an educational and self-improvement content service intended for adults aged 18 and over. The subscription is charged via carrier billing, which requires a mobile phone contract — a mechanism that is generally not available to minors.
We do not knowingly collect personal data from individuals under the age of 16. If we become aware that we have inadvertently processed personal data belonging to a child under 16, we will delete that data promptly.
If you believe that a child has subscribed to the service without parental consent, please contact us immediately at info@promptaccessdownloads.com so that we can investigate and take appropriate action, including cancellation of the subscription and deletion of any associated data.
Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or the services we offer. When we make material changes, we will post the revised policy on this page with an updated effective date at the top.
We encourage you to review this page periodically to stay informed about how we protect your personal data. Continued use of the Prompt Access Downloads service after a revised policy is published constitutes your acceptance of the changes to the extent permitted by applicable law.
Where changes are significant and affect your rights in a meaningful way, we will take reasonable steps to bring them to your attention, such as including a notice on the website.
Contact
If you have any questions, concerns, or requests relating to this Privacy Policy or the way we handle your personal data, please contact us:
Prompt Access Downloads
Operated by FRST Media Europe B.V.
Keizersgracht 268
1016EV Amsterdam
Netherlands
KvK: 80008798
Email: info@promptaccessdownloads.com
We aim to respond to all privacy-related enquiries within 30 days of receipt. If you are not satisfied with our response, you have the right to escalate your concern to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at autoriteitpersoonsgegevens.nl.