Privacy Policy
- Introductions
- Who are we?
- Companies and websites within the scope
- Collection of personal data
- Legal basis for processing personal data
- Do we share your personal information?
- International transfers
- How long do we keep your personal information?
- Security measures
- Your rights as a data subject
- Do you need to provide your personal information to us?
- Do we use automated decision making?
- Do we use your personal information for marketing?
- Cookies
- Contact
- Complaints
- Changes to this policy
1. Introduction
We appreciate the trust you give us in sharing your personal data. The security of that data is very important to us.
This policy explains how we collect and use your personal data and with whom we share it, and also explains what rights you have with respect to your personal data and how to exercise those rights.
2. Who we are
Coolpack,
For the purposes of the General Data Protection Regulation, Coolpack is the data controller. This means that Coolpack determines what data is collected, how this data is used and how this data is protected.
The address of our registered headquarters is:
De Ridder BV
Industrieweg 11b
1566 JN Assendelft
Netherlands
If you have any questions about how we process personal data, or if you wish to exercise your rights as a data subject, please send an email to in**@co**********.nl or contact us in writing at the above address.
3. Companies and websites within the scope
The following companies and websites are within the scope for this privacy policy:
Coolpack www.coolpack.nl
This includes personal data collected through our websites, over the phone, via LiveChat and through related social media applications.
4. Collection of personal data
We collect personal data from you for one or more of the following purposes:
- To fulfill a contract we have entered into with you or the entity (or organization) you represent. In these circumstances, it may be your entity (or organization), and not yourself, that has provided us with your personal data
- For initiating and completing commercial transactions with you or the entity (or organization) you represent for the purchase of products and/or services
- To deliver a product that you purchased directly or indirectly from us
- For communicating with suppliers of goods and services
- For maintaining accounts and other business records
- To conduct marketing, electronically or otherwise
- For complying with legal requirements or regulations
- To manage existing and former employees
- To manage applicants
- For handling inquiries from our current employees, former employees and job applicants
- For handling complaints or inquiries from our customers and our suppliers
- For dealing with inquiries from our shareholders and other stakeholders.
- To generate data analysis to monitor and improve the performance of our website.
- To ensure the security and safe operation of our websites and underlying business structure.
Technical Information
In addition, we also collect the following to ensure that each visitor to one of our Web sites can use the site effectively:
- Technical information, including the IP (Internet Protocol) address used to connect your device to the Internet.
- Your login information, browser type and version, time zone setting, browser plug-in types and versions
- Operating system and platform
- Information about your visit, including the URL (Uniform Resource Locators) clickstream to, through and from our site.
In section 10 below we identify your rights regarding the personal data we collect and describe how you can exercise those rights.
5. Legal basis for processing personal data
We believe it is in our legitimate interest, or necessary for the performance of a contract, to collect and use personal information to conduct our business and provide a service you have requested. In some cases, we may be required by law to use or disclose personal information, such as to comply with a request from an official agency.
When we process information based on legitimate interest, we apply the following test to determine whether such processing is appropriate:
The test of usefulness – is there a legitimate interest behind the processing?
Necessity test – is the processing necessary for that purpose?
Balancing test – is the legitimate interest overridden, or not, by the interests, rights or freedoms of the individual?
6. Sharing your personal information.
We may share your personal information, but this will be done on a “need to know” basis and only where necessary or where we need to share information. Such as our professional advisors and service providers, including:
- Accountants
- Legal advisors
- Consultants
- Payment providers
- Salary providers
- Pension administrator
- Insurers
- Providers of information technology and communications services.
- Suppliers
- Logistics and transportation services.
We may also potentially share personal information:
- With any authorized law enforcement or supervisor as required by law
- When we buy or sell businesses or assets.
We strive to take the necessary precautions to ensure that personal information for which the Company is legally responsible is properly protected and used appropriately when in the hands of a third party.
7. International transfer
We are a global organization and use third parties based in other countries to help us run our business. This includes countries outside the European Union (“EU”) and countries that do not have laws providing specific protections for personal data. We have taken steps to ensure that all personal data is adequately protected and that all transfers of personal data outside the EU are lawful. When we transfer personal data outside the EU to a country that has not been determined by the European Commission to provide an adequate level of protection for personal data, the transfers are made under an agreement that covers EU requirements for the transfer of personal data outside the EU.
8. How long do we keep your personal information?
We take steps to retain your information only as long as necessary for our business needs and in accordance with any legal or regulatory obligations to retain personal information for a specified period of time. Regardless of how long we retain personal information, we ensure that it is subject to appropriate security.
9. Security measures
We believe we have appropriate security measures in place to protect personal data. Risk analysis, including analyzing risks to the rights and freedoms of data subjects, is at the core of our Information Security Management System. However, we have no control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate measures to protect your own information. We accept no liability with respect to breaches beyond our control.
10. Your rights as a data subject
As a data subject whose personal information we hold, you have certain rights. If you wish to exercise these rights, please email in**@co**********.nl.
You can also use the information provided in the Contact section below. To process your request, we will ask you for valid proof of identity for verification purposes. Your rights are as follows:
- The right to be informed
As a data controller, we are required to provide clear and transparent information about our data processing activities. We deliver this to you with this Privacy Policy and any related notices we may send you.
- Right of Access
You may request a copy of the personal data we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of an external requestor, we will grant access to the personal data we hold about you, as well as the following information:
(a) Knowing whether we hold personal data about you as a data controller
(b) Receiving a description of the personal data held and, if permitted and practical, a copy of the personal data
c) Be informed of the purpose(s) for which such personal data are processed, and where they were obtained
d) Be informed whether the personal data will be disclosed to anyone other than the original recipient of the personal data and, if so, the identity of those recipients
e) Request that your personal data be transferred to you or a third party in a machine-readable format (Word, PDF, etc.) (Although such requests can only be granted if the personal data in question is
- provided by the individual to the company
- be processed automatically
f) If personal data is used to make automated decisions about you as a data subject (e.g., profiling), be told what logic the system uses to make those decisions and to request human intervention to override such automated decisions.
g) When your personal data are transferred to a third country or to an international organization, you have the right to be informed of the appropriate safeguards in accordance with Article 46 of the AVG regarding the transfer
- If there are exceptional circumstances that allow us to refuse to provide the information, we will explain them. If requests are frivolous or frustrating, we have the right to refuse them. If responding to requests is likely to involve additional time or unreasonable costs (which you may have to meet), we will notify you.
- Right to rectification
If you believe that we have inaccurate or incomplete personal information about you, you may exercise your right to correct or supplement that information. This can be used with the right to restrict processing to ensure that inaccurate/incomplete information is not processed until corrected.
- The right to erasure (the “right to be forgotten”)
If there remains no compelling legal basis or legitimate reason for processing personal data, you may ask us to delete personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable measures to ensure erasure.
- Right to restrict processing
You can ask us to stop processing your personal data. We will then still keep the data, but will not process it further. This right is an alternative to the right to erasure. If one of the following conditions applies, you can exercise the right to restrict processing:
a) The accuracy of the personal data is disputed
b) The processing of the personal data is unlawful
c) We no longer need the personal data for processing, but the personal data is required as part of legal proceedings
d) The right to object has been exercised and the processing is restricted pending a decision on the status of the processing.
- The right to data portability
You may request that your set of personal data be transferred to another data controller or processor, provided that it is delivered in a commonly used and machine-readable format. This right is only available if the original processing was based on consent, the processing is automated and if the processing is based on the fulfillment of a contractual obligation.
- The right to object
You have the right to object to the processing of your data where
a) The processing is based on legitimate interest
b) The processing is for marketing purposes
c) The processing is for the purpose of scientific or historical research; or
d) The processing involves automated decision making and profiling.
11. Do you need to provide your personal information to us?
You are never required to provide personal information to us, but you may be required to do so when you enter into a contract to provide our services or products. We cannot provide our services or products unless you provide us with the personal information we need.
In addition, you must provide certain personal information when you contact us to exercise your rights under the AVG, as set forth in Section 10.
12. Automated decision-making
We perform automated decision-making when you use our website. This includes providing content to you based on your online behavior. This allows us to show you content that is relevant to you.
13. Do we use your personal information for marketing?
Yes, we may use your personal data for marketing purposes, but we strive to contact only people who register to do so. If you object to marketing – electronic or otherwise – let us know and we will no longer contact you.
14. Cookies
We use cookies, which are small text files placed on your computer by websites you visit, to make our website work properly, to monitor its use and to display content that we think is relevant to you. If you register with us or continue to use our site, you will be asked to agree to our use of cookies. More details about cookies and your rights can be found [hier] in our Cookie Policy.
15. Contacting us
Any comments, questions or suggestions about this privacy policy or our handling of your personal information should be emailed to in**@co**********.nl.
Alternatively, you can contact us at the following mailing address:
De Ridder BV
Industrieweg 11b
1566 JN Assendelft
Netherlands
16. Complaints
Should you wish to discuss a complaint, please feel free to contact us using the details above. All complaints are handled in a confidential manner.
Should you feel dissatisfied with our handling of your data, or with a complaint you have made to us about our handling of your data, you have the right to escalate your complaint to a supervisory authority within the European Union. For the Netherlands, this is https://www.autoriteitpersoonsgegevens.nl, which is also our lead regulator. Contact details can be found at https://autoriteitpersoonsgegevens.nl/nl/contact-met-de-autoriteit-persoonsgegevens/contactgegevens-algemeen
17. Changes to this policy.
This policy was last updated on [28 september 2020]
