Privacy Policy

This Privacy Policy explains how Kugler Publications (“Kugler”, “we”, “us”) collects, uses, and shares personal data when you use the website pgi-publication.com (the “Site”) and register for free access to the digital edition of The PAUL^® Glaucoma Implant (the “Publication”).

We take your privacy seriously and comply with the General Data Protection Regulation (GDPR, EU 2016/679) and applicable Dutch data-protection law. If you have any questions about this policy, please contact info@kuglerpublications.com.

1. Who is the data controller?

2. What data we collect

We collect personal data in the following ways:

2.1 When you register

To create an account you provide:

• First name and last name
• Email address
• Academic title (e.g. Dr, Prof)
• Profession (e.g. ophthalmologist, resident, researcher)
• Country
• Institution/hospital
• Fields of interest
• Password (stored as a one-way cryptographic hash — we never see or store it in readable form)
• Your consent choices (Terms of Use, data sharing, marketing opt-in)
• Timestamp of registration and IP address at time of registration (for security and consent-audit purposes)

2.2 When you download content

Every download of a chapter PDF or the full-book PDF is logged with:

• Your user ID (linked to the registration data above)
• The chapter or the full book downloaded
• Timestamp
• Your IP address and browser user-agent

This is used to enforce a per-user download rate limit (protecting the Publication from bulk scraping), to notify you when a chapter you previously downloaded is updated (errata), and for aggregated download statistics.

The name and email address on your account are embedded on the licence page of every PDF you download. This is a technical measure to help enforce the personal-use terms of your licence.

2.3 When you browse the Site

We use privacy-respecting cookies and analytics tools as described in our Cookie Policy. This may include Google Analytics (via Google Site Kit), which is only enabled after you give consent through the cookie banner.

2.4 When you contact us

If you email us, we retain the correspondence to answer your questions and — where applicable — as a record of consent, complaint, or data-subject request.

3. Why we process your data (legal basis)

4. Who we share your data with

We share your registration data with the following recipients. You are told about this sharing at registration and asked to consent explicitly.

4.1 Kugler Publications

As the publisher of the Publication, Kugler receives your registration data for editorial, distribution audit, and relationship-management purposes. Kugler is the data controller for this policy.

4.2 Advanced Ophthalmic Innovations (AOI)

AOI (based in Singapore) is the manufacturer of the PAUL^® Glaucoma Implant and supports production of this digital edition. Your registration data is shared with AOI for the purpose of understanding readership of the Publication in the clinical community.

Transfer outside the EEA: AOI is based in Singapore, which is outside the European Economic Area. Singapore is not currently the subject of an EU adequacy decision. Data transfer is safeguarded under Standard Contractual Clauses (SCCs) as approved by the European Commission (Decision 2021/914), which we and AOI have executed. A copy of the SCCs is available on request.

4.3 Service providers (processors)

We use the following processors to run the Site:

• TransIP B.V. (Netherlands) — hosting and outbound email
• Google LLC — analytics (via Google Site Kit / GA4), only if you consent via the cookie banner
• Automattic Inc. — WordPress software components

Processors act only on our instructions and are contractually bound to protect your data. Where processing involves transfer outside the EEA, appropriate safeguards (SCCs or equivalents) are in place.

4.4 Legal disclosures

We may disclose personal data if required by law, court order, or to protect the rights, property, or safety of Kugler, our users, or others.

5. How long we keep your data

• Account data: for as long as your account is active, plus up to 12 months after you delete your account (for security and audit purposes)
• Download logs: up to 24 months from the date of download, then aggregated (personal identifiers removed) for long-term statistics
• Consent records: for the duration of your account plus 3 years after account deletion (evidence of GDPR compliance)
• Correspondence: up to 24 months from the last message

6. Your rights

Under the GDPR you have the right to:

• Access: request a copy of the data we hold about you
• Rectification: correct inaccurate or incomplete data (you can also do this yourself in your account settings)
• Erasure (“right to be forgotten”): request deletion of your data, subject to any overriding legal or legitimate interest we may have to retain some of it
• Restriction of processing: request that we stop processing some of your data while another concern is resolved
• Data portability: receive your data in a structured, machine-readable format
• Objection: object to processing based on legitimate interest
• Withdraw consent: where processing is based on consent, withdraw it at any time (this does not affect the lawfulness of processing before withdrawal)
• Lodge a complaint: with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, autoriteitpersoonsgegevens.nl) or the supervisory authority in your country of residence

To exercise any of these rights, email info@kuglerpublications.com. We aim to respond within one month.

7. Security

We use technical and organisational measures to protect your data, including HTTPS encryption for all site traffic, one-way password hashing, protected file storage for PDF content, rate-limiting to prevent abuse, and access controls for administrative interfaces. However, no online service can guarantee absolute security. Please use a strong, unique password and keep your credentials confidential.

8. Cookies

We use a limited set of cookies described in our Cookie Policy. You can manage your preferences at any time via the “Manage cookie preferences” link in the site footer.

9. Children

The Site is intended for healthcare professionals and is not directed at children under 16. We do not knowingly collect data from children. If you become aware that a child has provided us with personal data, please contact us and we will delete it.

10. Changes to this Policy

We may update this Policy from time to time. When we do, we will update the “Last updated” date at the top of this page. Material changes will be brought to registered users’ attention via email or an on-site notice.

11. Contact and complaints

For any question about this Privacy Policy, to exercise your rights, or to lodge a complaint: