Privacy Policy

This privacy policy explains the ways in which we process your personal data. ‘Personal data’ is defined as all information about an identified or identifiable natural person. In addition, this policy contains information about your privacy rights and our obligations. The privacy policy is divided into the following sections: 

1. Introduction
2. What personal data do we process, for what purposes and on what basis do we do this?
3. With whom can we share your personal data?
4. How long do we store your personal data?
5. How do we protect your personal data?
6. What are your privacy rights and how can you exercise them?
7. Where can you go if you have a complaint or question about the processing of your personal data?

We reserve the right to change this privacy policy. The most recent version of this privacy policy is available on our website. If there are substantial changes that could significantly affect one or more data subjects, we strive to inform these data subjects directly.

In the performance of our activities we may process personal data. On the basis of applicable data protection legislation – in particular the General Data Protection Regulation (GDPR) – we qualify as controller.

Depending on the relationship you have with us, we may process certain personal data. 

• If you are a business client, please refer to section 2.1 of this privacy policy.
• If you have ordered a product in our webshop, please refer to section 2.2 of this privacy policy.
• If you have purchased a product in one of our physical stores, please refer to section 2.3 of this privacy policy.
• If you want to apply for a job or have applied for a job with us, please refer to section 2.4 of this privacy policy.
• If you attend one of our events, please refer to section 2.5 of this privacy policy.
• If you visit one of our locations, please refer to section 2.6 of this privacy policy.
• If you visit our website, please refer to section 2.7 of this privacy policy.
• If you email or otherwise contact us, please refer to section 2.8 of this privacy policy.

In these sections we also always indicate why we process these personal data (“purposes”) and on what legal basis we base this. We process your personal data on the basis of one or more of the following legal bases: 

1. when this is necessary for the performance of an agreement to which you are a party or to perform pre-contractual steps at your request;
2. when this is necessary to comply with a legal obligation;
3. when this is necessary to protect our legitimate interests or the interests of a third party;
4. with your consent. 

When we process your personal data on the basis of your consent, we will request it separately. You can always withdraw your consent (see also below in section 6. “What are your privacy rights and how can you exercise them?”). We would like to point out that withdrawing your consent does not affect the lawfulness of the processing of your personal data before the withdrawal of your consent. 

When processing is based on the basis of ‘legitimate interest’, this interest is briefly explained. If you have specific questions about this, you can always contact us.

In the context of starting a business relationship and entering into an agreement, we may process the following personal data that we collect directly from you or from public sources (such as the Trade Register and the Chamber of Commerce): 

• initials, first and last name, title, gender, signature, address details;
• other contact details, such as telephone number, email address and fax number;
• payment details (including the bank account number), company details, details of the legal representative, details of the Ultimate Beneficial Owner, certain details regarding an identity document, position, extracts from registers (public or not), VAT registration, order information.

Below we indicate for which purposes we process these personal data, with the associated legal bases (a to d as described above):

• to be able to register you, to identify you and to check whether you are authorized to represent our customer (a, b, c: the importance of being able to offer and provide or purchase services);
• to be able to draw up and conclude agreements with you (a, b, c: the importance of being able to offer and provide or purchase services);
• to be able to provide or purchase the agreed services to you (a, b, c: the importance of being able to offer and provide or purchase services);
• to be able to keep a correct administration (a, b, c: the importance of keeping correct administration);
• for billing and payment purposes, including the collection of claims; (a, b, c: the importance of being able to keep correct administration and to make / collect payments);
• for the performance of audits and internal controls (a, b, c: the importance of keeping a correct administration);
• to keep in touch and communicate with you (a, b, c: the importance of bringing our services to the attention of existing customers, d);
• to send you our newsletters and to keep you informed about offers (a, b, c: the importance of bringing our services to the attention of existing customers, d);
• to deal with any complaints and disputes, including assessing our legal position, defending it and exercising our rights (a, b and c: to defend rights, to maintain and improve existing relationships through proper complaints handling, to improve the quality of the service);
• to comply with our legal obligations (b, c: the importance of being able to comply with these legal obligations).

When you order a product in our webshop, we may process the following personal data that you provide to us:

• initials, first and last name, title, gender, address details;
• other contact details, such as telephone number, e-mail address and fax number;
• payment details (including bank account number), order information.

Below we indicate for which purposes we process this personal data, with the associated legal bases (a to d as described above):

• to be able to offer and provide the agreed services to you, including creating an account with the option to log in and place an order (a, b, c: the importance of being able to offer services and to provide);
• to be able to draw up and conclude agreements with you (a, b, c: the importance of being able to offer or purchase services);
• to be able to keep correct administration (a, b, c: the importance of keeping correct administration);
• to optimize and personalize your shopping experience (c: the importance of being able to offer you the best possible and personal shopping experience and d);
• to keep in touch and communicate with you (a, b, c: the importance of bringing our services to the attention of existing customers);
• to send you newsletters and to keep you informed of offers (c: the importance of bringing our services to the attention of existing customers, d); 
• handle any complaints and disputes, including assessing our legal position, defending it and exercising our rights (a, b and c: to defend rights, to maintain and improve existing relationships through proper complaints handling, to improve the quality of the service);
• to comply with our legal obligations (b, c: the importance of being able to comply with these legal obligations).

When you buy, return or request a repair from a product in one of our stores, we may process the following personal data that you provide to us:

• initials, first and last name, title, gender, signature, address details;
• other contact details, such as telephone number and email address;
• payment details, order information.

Below we indicate for which purposes we process this personal data, with the associated legal bases (a to d as described above):

• to be able to offer and provide the agreed services to you (a, b, c: the importance of being able to offer and provide services);
• to be able to keep correct administration (a, b, c: the importance of keeping correct administration);
• to keep in touch and communicate with you (a, b, c: the importance of bringing our services to the attention of existing customers);
• handle any complaints and disputes, including assessing our legal position, defending it and exercising our rights (a, b, c: to defend rights, to maintain and improve existing relationships through proper complaints handling, to improve the quality of the service).
• to comply with our legal obligations (b, c: the importance of being able to comply with these legal obligations).

When you apply for a job with us, we may process the following personal data provided to us by you or through third parties (such as an employment or recruitment agency) or obtained by us from other public sources (such as social media):

• initials, first and last name, title, gender, address details; 
• other contact details, such as telephone number and email address;
• nationality, date and place of birth;
• availability, CV (possibly with photo) and employment history, training history (copies of diplomas, certificates, certificates), motivation letter;
• notes on interviews and written communication with the applicant;
• where relevant for the vacancy: (written) references, screening results, certificate of conduct, certificate of no objection.

Below we indicate for which purposes we process this personal data, with the associated legal bases (a to d as described above):

• recruitment and selection (a, b, c: our interest in assessing whether you are suitable for the vacancy and d: permission if you wish to remain in the portfolio longer, see: “How long do we keep your personal data?”);
• to keep in touch and communicate with you (a, b, c: the importance of handling the procedure in a correct manner);
• to comply with the agreements we have with employment and secondment agencies (a, b, c: our interest in keeping our agreements);
• internal control and company security (c: our interest to process correct information and to create a safe environment for our employees and visitors);
• improvement of the application procedure (c: our interest in improving our application procedure);
• handling questions, comments and complaints (a, b: to maintain and improve contact with applicants through proper complaints handling, improving our application procedure and resolving complaints);
• to comply with our legal obligations (b, c: the importance of being able to comply with these legal obligations).

Depending on the type of event, we may process the following personal data provided by you or created by us: 

• initials, first and last name, title, gender, address;
• other contact details, such as telephone number and email address;
• date and place of birth;
• CV (possibly with photo) and employment history, motivation letter;
• photo and video footage of the event.

Below we indicate for which purposes we process this personal data, with the associated legal bases (a to d as described above):

• to be able to provide you with access to our locations and, where necessary, to identify you and to be able to maintain a correct access administration (a, b, c: our interest to guarantee a safe environment for employees and visitors and to be able to keep correct administration);
• to make payments possible (a, b, c: our interest to be able to keep a correct administration);
• to keep in touch and communicate with you (a, b, c: the importance of optimally providing our services to you);
• recruitment and selection (a, b, c: our interest in assessing whether you are suitable for the open vacancy and d: permission if you wish to stay longer in the portfolio, see: “How long do we keep your personal data?”);
• internal control and company security (c: our interest to process correct information and to create a safe environment for our employees and visitors);
• for marketing and promotional purposes (c: for existing customers: our interest in being able to draw attention to our events, products and services, d);
• handling questions, comments and complaints, including assessing our legal position, defending it and exercising our rights (a, b, to maintain and improve contact with applicants through proper complaint handling, improve of our application process and complaint resolution and rights defense);
• to comply with our legal obligations (b, c: the importance of being able to comply with these legal obligations).

When you visit one of our locations, we may process the following personal data, which we obtain directly from you or through third parties (such as security services):

• initials, first and last name, name of organization, contact person;
• email address, telephone number;
• identity document number, signature;
• date, arrival and departure time;
• CCTV-footage;
• license Plate.

Below we indicate for which purposes we process this personal data, with the associated legal bases (a to d as described above):

• to be able to provide you with access to our locations and, where necessary, to identify you and to be able to maintain a correct access administration (a, b, c: our interest to guarantee a safe environment for employees and visitors and to be able to keep correct administration);
• the security of our locations, properties and our employees (b, c: our interest to process correct information and to create a safe environment for our employees and visitors);
• to be able to investigate and handle incidents and irregularities (b, c: our interest to be able to adequately investigate and address incidents);
• handle any complaints and disputes, including assessing our legal position, defending it and exercising our rights (a, b and c: to defend rights, to maintain and improve existing relationships through proper complaints handling, to improve the quality of the service);
• to comply with our legal obligations (b, c: the importance of being able to comply with these legal obligations).

When you visit our website, we may process the following personal data: 

• data related to the operating system, the browser used, IP address,
• data relating to the unique identifiers associated with the device used,
• data relating to the web pages consulted,
• data relating to products viewed online (including information on products searched or viewed, purchased or added to an online shopping cart),
• data relating to the time spent on certain parts of the site or an interface site or application, including the date and time of the visit.

Below we indicate for which purposes we process this personal data, with the associated legal bases (a to d as described above):

• to optimize and personalize your shopping experience (c: the importance of being able to offer you the best possible and personal shopping experience and d);
• to personalize your shopping experience based on your account information and search, browsing and purchase history (c: the importance of providing you with the best possible and personalized shopping experience and d);
• to send you personalized advertisements (c: the importance of providing you with the best possible and personalized shopping experience and d); 
• to be able to perform generic analyses relating to visitor’s behavior on our website(s) (c: the importance of being able to set up our website in the best possible way);
• to send you newsletters and keep you informed about offers (c: the importance of bringing our services to the attention of existing customers, d);
• to handle any complaints and disputes, including assessing our legal position, defending it and exercising our rights (a, b and c: to defend rights, to maintain and improve existing relationships through proper complaints handling, to improve the quality of the service);
• to comply with our legal obligations (b, c: the importance of being able to comply with these legal obligations).

We may process this personal data through the use of cookies and similar techniques. Cookies are small text files that are placed in your browser when a website is visited. Cookies can process personal data. For more information about the use of cookies, please read our cookie policy.

When you email or otherwise contact us, we may process the following personal data which you provide to us:

• first and last name, e-mail address, telephone number and / or the content of your e-mail.

Below we indicate for which purposes we process this personal data, with the associated bases (a to d as described above):

• to answer your questions and provide you with information (b, c: our and your interest in answering your questions, providing you with information and optimizing our services);
• handle any complaints and disputes, including assessing our legal position, defending it and exercising our rights (a, b and c: to defend rights, to maintain and improve existing relationships through proper complaint handling, to improve the quality of the service);
• to comply with our legal obligations (b, c: the importance of being able to comply with these legal obligations).

We do not provide your personal data to third parties (“recipients” within the meaning of the privacy legislation), unless this is necessary for the proper implementation of the purposes described in this privacy policy, when this is legally required or when you have given permission for this. The third parties to whom the personal data are made available are obliged to treat your personal data confidentially. If these parties are regarded as “processors” within the meaning of the privacy legislation, we will ensure that a processor agreement is concluded with these parties that meets the applicable requirements.

We may share your data with:

• our employees (on a need-to-know basis);
• entities affiliated with us;
• suppliers (e.g. software suppliers, bailiffs, collection agencies, parcel deliverers and other courier services, accountants, law and notary offices, etc.);
• courts and government institutions;
• other parties, such as regulators and other authorities if required by law or with your consent.

Finally, we note that if we go bankrupt, your data can be shared with the trustee appointed in the bankruptcy.

We may transfer your personal data to a recipient in a country outside the European Union that offers a lower level of protection of personal data than European law. In that case, we ensure that such a transfer of personal data is in accordance with applicable laws and regulations, for example by entering into a model contract drawn up and approved by the European Commission for that purpose and we check whether additional measures are required to ensure an adequate level of protection for your personal data.

We do not store your personal data in an identifiable form for longer than is necessary to achieve the purposes stated in this privacy policy. More specifically, we use the following retention periods:

• the personal data you provide to us for your job application will be kept for up to four weeks after the end of the application procedure. If you give permission for this, we will keep your personal data in portfolio for one year after the application procedure has ended. This gives us the opportunity to contact you for any future vacancies. When you enter into employment with us, the personal data that you have provided in the context of your application will become part of your personnel file;
• personal data that must be administered on the basis of (national) tax legislation, will be stored in connection with our fiscal retention obligations;
• camera images taken at our locations are automatically overwritten after 30 days.

The specific retention periods mentioned above can be extended if legal retention obligations apply. We can also keep the personal data longer if this is necessary for the settlement of incidents and/or legal disputes.

We have taken technical, organizational and administrative measures to protect your personal data. These measures include the use of firewalls, authentication passwords and limited access. Above that, we have implemented a security policy. For questions about the security of your personal data, or if you suspect or have indications of misuse, please contact:

info@legal-privacy.com

When we process your personal data, you as a data subject have certain privacy rights. You have:

• the right to clear information about what we do with your personal data;
• the right to request whether we process your personal data and if this is the case, the right to access your personal data and the right to receive certain information about the processing of your personal data;
• the right to rectification and supplementation of your personal data if they are incorrect or incomplete;
• the right to have your personal data erased (the “right to be forgotten”);
• the right to limit the processing of your personal data;
• the right to receive or hand over your personal data to a third party designated by you in a structured, commonly used and machine-readable form (the “right to data portability”);
• the right to object to the processing of your personal data;
• the right to withdraw your consent to the processing of your personal data, where the processing is based on your consent;

We do not use automated decision-making within the meaning of Art. 22 GDPR. 

To exercise your rights, please contact us at info@legal-privacy.com

To prevent us from providing information to the wrong person, we may ask for additional information to verify your identity. In principle, we will inform you within one month of receiving your request whether we can comply with your request. This period can be extended by two months in specific cases, for example when there is a complex request. We will inform you of such an extension within one month of receipt of your request. Under privacy legislation, we can refuse your request under certain circumstances. If so, we will explain why. More information about your privacy rights can be found on the website of the Dutch Data Protection Authority or your national Data Protection Authority.

If you have a complaint about the processing of your personal data by us, we will be happy to try to resolve this together with you. If this does not lead to the desired result, you have the right to file a complaint with the competent supervisory authority. In the Netherlands, this is the Dutch Data Protection Authority. If you live or work in another country in the European Union, you can file a complaint with the supervisory authority in that country. 

If you have questions about your privacy rights, this privacy policy, or the processing of your personal data, please feel free to contact us at: 

info@legal-privacy.com