Privacy Policy

1. Introduction & Data Controller Identity

Digital Markups ("we," "us," "our," or the "Company") operates enterprise revenue infrastructure, operational diagnostic evaluations, and sales automation systems. This Privacy Policy sets forth our policies and practices regarding the collection, processing, storage, disclosure, and protection of Personal Data collected from enterprise representatives, prospective clients, users, and visitors who interact with our digital web properties, diagnostic evaluation modules, and intake services.

For the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679) ("GDPR") and applicable European Union member state data protection legislation, the Data Controller responsible for your personal data is Digital Markups. Any inquiries, requests, or notices regarding data protection must be directed to our designated data contact at contact@digitalmarkups.com.

2. Legal Bases for Processing Personal Data

In accordance with Article 6 of the GDPR, we only collect and process Personal Data where a lawful basis exists. Specifically, our processing activities are grounded in the following legal bases:

• Contractual Necessity (Art. 6(1)(b) GDPR): Processing is necessary for the performance of a contract to which you or your enterprise is a party, or to take preparatory steps at your request prior to entering into a contract, such as evaluating operational compatibility, compiling architecture audit scopes, or scheduling calendar deployments.
• Legitimate Interests (Art. 6(1)(f) GDPR): Processing is necessary for the purposes of legitimate business interests pursued by Digital Markups, including securing infrastructure against unauthorized intrusion, improving technical server response latency, analyzing platform performance, and maintaining business-to-business (B2B) communications, provided these interests do not override your fundamental rights and freedoms.
• Explicit Consent (Art. 6(1)(a) GDPR): Where required by applicable law, processing is performed on the basis of your affirmative, freely given, specific, and unambiguous consent, such as opting into diagnostic data capture or automated dispatch communications.
• Compliance with Legal Obligations (Art. 6(1)(c) GDPR): Processing is necessary to comply with binding statutory obligations, taxation rules, regulatory reporting directives, or lawful court orders under European Union or Member State law.

3. Categories of Personal Data Collected

We collect information strictly necessary to diagnose enterprise revenue architecture and administer client engagements. The categories of data collected include:

4. Purpose and Scope of Data Processing

Digital Markups utilizes collected Personal Data strictly for defined corporate objectives:

• To compile, analyze, and deliver forensic enterprise diagnostic assessments.
• To evaluate enterprise infrastructure compatibility and schedule architecture consultations.
• To transmit relevant administrative notices, engagement agreements, and audit documentation.
• To harden our server environment, mitigate malicious penetration attempts, and safeguard platform integrity.
• To comply with regulatory recordkeeping, taxation, and statutory accounting requirements.

We do not engage in automated individual decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you within the meaning of Article 22 of the GDPR.

5. Third-Party Sub-Processors & Data Transfers

We do not sell, rent, monetize, or lease your Personal Data to third parties. We share data only with verified sub-processors who assist us in maintaining operational infrastructure, subject to rigorous Data Processing Agreements (DPAs) incorporating standard contractual clauses:

• Automation & Webhook Infrastructure: Make.com (Celonis SE), utilized for secure transmission and orchestration of intake diagnostics.
• Hosting & Cloud Infrastructure: Enterprise-grade hosting providers operating secure server environments located within the European Economic Area (EEA) or in jurisdictions offering an adequate level of data protection recognized by the European Commission.
• Calendar & Scheduling Infrastructure: Secure calendar scheduling integrations utilized to coordinate architecture consultations.

Where data is transferred outside the European Economic Area (EEA), we enforce Standard Contractual Clauses (SCCs) adopted by the European Commission pursuant to Article 46(2)(c) GDPR to guarantee equivalent levels of protection.

6. Data Retention Policy

We retain Personal Data only for the duration strictly necessary to fulfill the purposes outlined in this Policy, or as mandated by applicable legal, fiscal, and regulatory retention periods. Diagnostic intake data associated with prospects that do not proceed to an active engagement is retained for a maximum of 24 months before being permanently purged or aggregated into non-reversible, anonymized benchmarks. Client engagement documentation is maintained for seven (7) years to satisfy statutory accounting and tax compliance regulations.

7. Your Data Subject Rights Under GDPR

Under Articles 15 through 22 of the GDPR, European Union residents and data subjects possess enforceable rights regarding their Personal Data:

• Right of Access (Art. 15 GDPR): You have the right to request confirmation as to whether your data is being processed and obtain a copy of the specific data held.
• Right to Rectification (Art. 16 GDPR): You have the right to obtain without undue delay the rectification of inaccurate or incomplete personal records.
• Right to Erasure / "Right to be Forgotten" (Art. 17 GDPR): You have the right to request the permanent deletion of your Personal Data when it is no longer necessary for the original collection purpose or where consent has been withdrawn.
• Right to Restriction of Processing (Art. 18 GDPR): You have the right to restrict our processing under specific statutory circumstances, such as during the verification of data accuracy.
• Right to Data Portability (Art. 20 GDPR): You have the right to receive your data in a structured, commonly used, and machine-readable format and transmit it to another controller.
• Right to Object (Art. 21 GDPR): You have the right to object at any time to processing based on legitimate interests.
• Right to Withdraw Consent (Art. 7(3) GDPR): Where processing relies on consent, you may withdraw your consent at any time without affecting the lawfulness of processing prior to withdrawal.
• Right to Lodge a Complaint (Art. 77 GDPR): You have the right to lodge a complaint with an authorized Data Protection Authority (DPA) within the EU member state of your habitual residence, place of work, or place of the alleged infringement.

To exercise any of these statutory rights, submit your formal request via email to contact@digitalmarkups.com. We will respond within thirty (30) calendar days as prescribed by law.

8. Technical & Organizational Security Measures

We implement state-of-the-art technical, physical, and administrative measures pursuant to Article 32 GDPR to safeguard Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. All data transmission across public networks is secured using TLS 1.3 cryptographic protocols. Server infrastructure operates under least-privilege access governance, continuous audit logging, and isolated network virtualization.

9. Tracking, Cookies & Server-Side Telemetry

Our web platform avoids invasive advertising trackers. We utilize essential technical cookies strictly required for core routing, session integrity, and security verification. Where analytics or conversion measurements are executed, they operate primarily via hardened server-side telemetry protocols designed to respect user browser privacy configurations and minimize personal data footprint.

10. Policy Amendments

Digital Markups reserves the right to modify or update this Privacy Policy periodically to reflect technological adjustments, changes in operational practice, or evolving statutory requirements under European Union law. The updated policy will be published on this page with an amended Effective Date. Continued engagement with our services following such revisions constitutes acknowledgement of the updated terms.