PRIVACY AND COOKIE POLICY

1. Introduction
2. Personal data we collect
3. Why we collect your personal data: purposes
4. Legal bases for processing
5. Cookies
6. Meta-pixel
7. Google analytics
8. How long we store your data
9. How we secure your data
10. Where your personal data are processed
11. Who has access to your data
12. Changes to our policy
13. How can you exercise your rights?
14. Objection and right of complaint
15. Contact

1. INTRODUCTION

Your privacy is important to us. This Privacy and Cookie Policy (“Policy”) describes how we handle your personal data. We comply with the applicable laws and regulations, including the General Data Protection Regulation (GDPR). Your personal data will be used solely for the purposes stated in this Policy unless the further processing of your data is compatible with the purposes for which the data were originally processed.

2. PERSONAL DATA WE COLLECT

We collect personal data via our website.

Personal data are any information (data) that relate to an identified or identifiable individual. We collect the following information:
• When placing an order on our website, we ask you for your name, address, contact and invoicing details in order to process and deliver your order.
• If you create an account on our website, we ask for your name, e-mail address and password so that you can log in and use our services. We request your billing information and delivery address for practical reasons as well; you do not have to re-enter these when placing your next order.
• If you write a review expressing your dissatisfaction, we will ask for your details (address, e-mail address and/or telephone number) so we can contact you.
• If you contact our customer service by using the chat function, the web form, via phone or by sending an e-mail, we ask for your name, telephone number and/or e-mail address in order to be able to answer your question.
• If you wish to receive our newsletter, we ask you for your e-mail address.
• When you visit our website, we may ask you to fill in a survey. The main purpose of this inquiry is to improve our services in general. It is not mandatory to fill in a survey in order to be able to order products from our web shop.
• When you visit our website, we collect information about your activity on our website in order to personalise your website visits. This information concerns the IP address of your computer, your username, the time of retrieval, and any other data your browser sends to us. We anonymise these data as much as possible. We collect visitor data via the use of cookies. Please refer to the cookie section below (section 5) for more information on the use of cookies.
• We collect technical data from our website visitors in order to analyse and improve our services. This includes the measurement and analysis of statistical data and the generation of user statistics. We anonymise these data as much as possible. We collect technical data via the use of cookies. Please refer to the cookie section below (section 5) for more information on the use of cookies.

3. WHY WE COLLECT YOUR PERSONAL DATA: PURPOSES

We only process your personal data for the purposes described above.
We shall ask for your consent before using your personal data for other purposes, unless the further processing of the personal data is compatible with the purposes for which these data were originally processed. If we wish to process your personal data for other purposes, we shall inform you in advance.
We shall not use your personal data to take a decision based on automated processing only, including profiling.

4. LEGAL BASES FOR PROCESSING

Contract
When you place an order, you enter into a contract with us. In order to provide you with our services, we require certain information, such as your name, delivery address, e-mail address and billing information.

Legitimate interests
We may process your data if we have certain legitimate interests in processing your personal data, except if your interest in not having the data processed, is greater.

Optimising our marketing campaigns, personalising our website, and answering your questions are part of our regular business activities. In addition, we would like to keep you informed of our products via a newsletter. We also have an interest in a website with good functionalities tailored to the wishes of the visitors thereof.
The first time you place an order via our website, we ask you to create a user account. We have a legitimate interest to do so, because this will speed up the order process and delivery.

You have the right to object to these processing operations. If so, please contact us.

You can reach us by using the online contact form or via phone +31 (0) 70 319 99 00.

In case of an objection, we shall cease processing your personal data unless there are compelling, justifiable reasons because of which our interest in this processing is greater than your interest in stopping the processing. Please note that you may not be able to make the best use of our services if you request us to cease processing.

Consent
In some cases, we ask your consent for processing your data namely
• before you write a review or contact our customer service
• before we send you a newsletter
You have the right to withdraw your consent at any time. In that case, we will stop processing your data for that purpose. Your personal data shall be deleted unless there are compelling reasons requiring us to retain these data.
You can unsubscribe and/or delete your data by the following means:
• Each newsletter contains a link that allows you to unsubscribe with one click.
• Contacting us through the contact form
• Contact us via phone: 31 (0) 70 319 99 00.
Please also refer to section 13 below.

Legal obligation
We process personal data by virtue of the law. For example, the storage of personal data in our financial records is required by reason of tax legislation.

5. COOKIES

We use so-called cookies. Cookies are small text files that are stored on a computer or other device such as a tablet or telephone when a visitor views or uses our website.
The purpose of the use of cookies is:
• to allow the website to function properly or better by, for example, recognising the visitor and thus providing a better service.
• Traffic analysis on a website with the aim of identifying potential improvements.
• Recording visitor surfing behaviour in order to provide our visitors with targeted offers.
You can choose either to accept or to refuse marketing cookies. Your settings can be managed via our cookie banner.
Some internet browsers are set to accept cookies by default. You can change the settings of your browser to prevent this. The “Help” function of your browser shows how to block cookies. When you choose this option, it is possible that certain parts of our website do not function optimally or are not accessible anymore. Please note that you can also adjust the settings before saving a cookie.
The data collected by means of cookies will be treated confidentially.

6. META-PIXEL

We use Meta pixels for gathering information that allows us to identify specific target groups.
For more information please refer to the Meta privacy policy: www.facebook.com/privacy/policy.

7. GOOGLE ANALYTICS

We use Google analytics for gathering statistical information about our website use with the purpose of creating targeted marketing campaigns.

8. HOW LONG WE STORE YOUR DATA

We store your personal data no longer than necessary for the purpose of data processing.
• Newsletter: your name and contact details will be kept for as long as you are interested in receiving our newsletter.
• Answering your question(s): your name and contact details are kept for as long as necessary to answer your question(s). Details are stored for a maximum period of 1 year, unless there are other (legal) reasons for retaining the data.
• Delivery of our products: we store your data no longer than necessary to deliver the product, to collect the invoice and other administrative purposes. The data for collecting the invoice shall be stored no longer than 2 years, unless there are other (legal) reasons for retaining the data.
• Technical reasons, such as website optimisation: if possible, technical data are stored in an anonymous form. The data are used for as long as necessary to optimise the website, but no longer than 6 months.
• Surveys: we keep this information – for monitoring the quality of our services – no longer than necessary.

9. HOW WE SECURE YOUR DATA

We have taken technical and organisational measures to protect your personal data against unlawful processing or loss.
These include, inter alia, the following measures:
• All persons working with us are bound by confidentiality with regard to your personal data.
• We ensure that third parties who have access to your personal data, comply with our security requirements. For this purpose we have entered into contracts with these parties.
• Where possible, we pseudonymise your data and encrypt your personal data.
• We have created a secure backup environment in order to restore personal data in the event of physical or technical incidents.
• We test and evaluate the measures regularly.
Although we cannot prevent third parties from accessing your data or prevent a loss of your data through a breach of our security measures, we shall take all appropriate measures to ensure your personal data are not accessible to unauthorised persons.

10. WHERE YOUR PERSONAL DATA ARE PROCESSED

We process your personal data in the European Union. Any transfer of personal data to countries outside the European Union, will be done in accordance with the provisions of the GDPR. We will take appropriate measures to ensure that the data are protected properly.

11. WHO HAS ACCESS TO YOUR DATA

We shall not provide your personal data to third parties, unless we are required to do so by law or if you have given permission for this.
We use ICT and marketing service suppliers with whom we will conclude a data processing agreement, including confidentially clauses. These parties process personal data upon our explicit instructions only.

12. CHANGES TO OUR POLICY

This Policy may be amended in the event of changes of our products and/or services and/or changes of the law. Any amendment will be published on this website.

In case of substantial amendments that apply to you directly, we shall inform you personally, for example by e-mail. In case of substantial changes of the purposes of our processing and if the processing is subject to your consent, we will ask your consent for these new purposes.

13. HOW CAN YOU EXERCISE YOUR RIGHTS?

You have the following rights under GDPR (articles 15 – 21) and other relevant data protection laws:
• Right to request access to your personal data
• Right to request the correction of your personal data if these are incorrect (rectification)
• Right to request removal of your personal data
• Right to request restriction of the processing of your personal data
• If we have processed your personal data on basis of our legitimate interests: the right to object to the (further) processing of your personal data (opposition)
• If we have processed your data on basis of your consent or the performance of our contract with you: the right to receive data in machine-readable form so that you can transmit those data to another processing controller (data portability)
• If you want to receive more information or if you want to exercise one or more of these rights, you can contact us through the contact form or contact us via phone: 31 (0) 70 319 99 00.

14. OBJECTION AND RIGHT OF COMPLAINT

We process certain personal data based on our legitimate interests (section 4). You have the right to object to the processing of your personal data on this basis at all times. In that case, we shall cease processing your personal data unless there are compelling, justified reasons because of which our processing interest is greater than your interest to stop the processing.

What should you do if you disagree with a decision by us, for example, when we decide not to delete your personal data? In that case you can use one or more of the following options:
• Contact us: we shall do our utmost to find a joint solution. You can find our contact information at the bottom of this Policy.
• Lodge a complaint: you have the right to lodge a complaint with the Dutch Data Protection Authority: www.autoriteitpersoonsgegevens.nl or, if you are located in another EU member state, the Data Protection Authority in your country.
• Litigate: you have the right to apply to the competent court.

15. CONTACT

The responsibility for processing personal data lies with:
XD Connects B.V.
Lange Kleiweg 6-28
2288 GK Rijswijk, the Netherlands
Telephone: +31 (0) 70 319 99 00
E-mail : [email protected]

February 2023

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