Because of all the personal details that Tommies collects from its website www.tommies.nl, Tommies is considered to be a controller of data. Tommies’ contact details are as follows:
130 Middel Broekweg
2675 KJ Honselersdijk, the Netherlands
#31(0)174 61 25 20
2. Processing objectives
a) Using information for the technical operation of the website. This concerns information that you (voluntarily) provide when you visit and includes your IP address, the device you are using, your browser type, and the device operating system. We save this information for the duration of your visit, but do not sell it on to third parties.
b) Collecting information about the duration, scope, and frequency of your visits for analysis purposes. We use the results of this analysis to improve the technical operation, the ease of use, and the attractiveness of the website. Insofar as it is possible, we keep the collected information separate from other details and, whenever possible, anonymous.
c) Examining your wishes, behaviours, and preferences (in addition to those of all the other satisfied users and visitors) regarding our products. This is done mainly via specific promotions and social media and to a very limited extent via the website. We do not sell this information to third parties. We also keep the collected information separate from other details and, whenever possible, anonymous. For example, we note whether or not you want to receive the Tommies newsletter.
d) Examining the effectiveness of (online) campaigns that have been carried out. We use the results of the analysis to increase our connections with you and to seek out and reach other people who are interested in our products. In doing so we aim at groups of consumers, and not at individuals. For example, Tommies does not examine ‘the behaviour of Mrs A de Vries’, but instead examines the behaviour of a group, for example, the behaviour and responses from ‘caring “jacks of all trades” and women with an average age of 36’ regarding a campaign that Tommies is running via various channels. However, assuming you have already agreed, we can approach target groups of users of which you may also be a part, with information about products. We do not sell this information to third parties.
3. Legal basis for processing
We only process your personal details on the following legal basis: (i) processing is necessary for the execution of an agreement with you, or at your request to take measures for the conclusion of an agreement; (ii) processing is necessary to comply with a statutory obligation that rests with Tommies; and/or (iii) processing is necessary for the defence of the legitimate interests of Tommies, when these interests outweigh your fundamental rights and freedoms. The legitimate interests that Tommies represents in this context include improving performance, accessibility, and content of its websites and improving its services.
4. Categories of recipients
In principle, we keep collected data for a limited period of time and share it with no one, unless we believe there is a good reason for doing so. When processing its data Tommies sometimes allows marketing, technical, and other business activities to be carried out by third parties. Insofar as these third parties have access to your personal details while they are carrying out service and operational activities, Tommies has implemented technical and organisational measures to ensure that they treat your personal details with the utmost care.
Tommies only complies with this when it is forced to provide personal details to third parties, such as government bodies and when there is either a court order or a statutory obligation to do so. Your personal details can also be passed on to recipients in countries outside the European Union within the context of Article 10. In such cases, Tommies takes appropriate measures that are reasonably necessary to ensure your data is protected as far as possible, such as applying the Standard Contractual Clauses. A copy of the Standard Contractual Clauses can be requested via firstname.lastname@example.org.
5. Period of retention
Tommies only stores and processes your personal details for as long as is necessary and for the purpose they were collected, such as the execution of a mutual agreement, unless Tommies has the statutory right or obligation to keep the details for a longer period, or the information is required for instituting legal proceedings, or for exercising or substantiating such proceedings.
6. Individual’s rights
In order to keep the level of our services as high as possible, Tommies considers it essential that the personal details that we retain are up to date and complete. Therefore you can ask us at any time to inspect the personal details we have collected about you and you can request to make changes if your situation has altered in the meantime. Moreover, according to the GDPR [AVG in the Netherlands], you have the following rights concerning Tommies’ processing of your personal details:
- The right to access your personal details This allows you to receive a copy of the personal details we hold about you and to check whether we have processed it lawfully.
- The right to rectification, deletion or addition of your personal details This allows you to rectify or add to incomplete or incorrect details about you.
- The right of transferability (the right to obtain personal details already provided by you in a machine-readable form) insofar as this provision is relevant within the context of your relationship with Tommies.
- The right to deletion of your personal details You can ask us to delete or remove your personal details if there is no good reason for us to continue processing them. You also have the right to ask us to delete or remove personal details if you have exercised your right to object to processing (see below).
- The right to limited processing of your personal details You can ask us to suspend the processing of your personal details, for example if you want to check whether the personal details are correct or you want to check the aims of the processing.
- The right to object to the processing of your personal details in certain circumstances This right may apply if the processing of your personal details is based on the representation of the legitimate interests of Tommies.
If you wish to exercise one or more of the above rights, please contact us via email@example.com. You also have the right to file a complaint with the Dutch Data Protection Authority if you are not satisfied with how Tommies processes your personal details and we were unable to deal with your request satisfactorily.
7. Miscellaneous information concerning your personal details
Tommies does not process your personal details for automated decision-making (including profiling). Furthermore, there are no statutory or contractual obligations whereby you must provide Tommies with your personal details. In some cases, providing your personal details may be a condition for entering into an agreement, as otherwise Tommies would not be able to proceed with the implementation thereof. Tommies also retains the right to refrain from entering into an agreement with you or to terminate or modify an existing agreement with you if the personal details in question are necessary for Tommies’ administration and/or for complying with statutory requirements.
If you would like to receive further information, or find out which information we already have about you, or you want to change your details or permission, please contact us in writing at the following address:
130 Middel Broekweg
2675 KJ Honselersdijk, the Netherlands
Our staff are happy to receive your telephone calls at: #31(0)174 61 25 20
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