Hunkemöller Privacy Statement

Version: June 2026

Hunkemöller B.V. and its subsidiaries (hereinafter “Hunkemöller”, “we”, “us”, or “our”) are committed to protecting your personal data. We use your personal data carefully, securely and in a transparent manner in accordance with applicable privacy laws (including the General Data Protection Regulation).

We regularly update this Privacy Statement to reflect changes to how we process personal data.

Hunkemöller may provide additional privacy notices that apply to certain personal information collected and processed by us. For example, we may provide additional privacy information if you choose to participate in an event or take advantage of a particular promotion.

1. Scope, Data Controller and Data Protection Officer

What is the scope of this Privacy Statement?

This Privacy Statement applies to the personal information Hunkemöller collects and processes when you interact with us as a customer, including when you visit our websites, apps, stores, and online or offline events. This Privacy Statement also applies to the personal information that Hunkemöller processes when you subscribe to receive marketing communications from us, communicate with us or engage with us via our website or via social media, or participate in contests and surveys.

If you are a model, ambassador, or influencer that collaborates with us, you can refer to our dedicated Talent Privacy Policy.

Who is the controller of your data?

Hunkemöller acts as the controller of your personal data. This means that we determine the purposes for which and the means by which your personal data is processed. If you have any questions about how we process your personal data, you can contact us at DPO@hunkemoller.com or by post to our office:

Hunkemöller B.V.

Koos Postemalaan 8

1217 ZC Hilversum

P.O. Box 386, 1200 AJ Hilversum, The Netherlands

2. How, when, where and why do we collect or process your data?

 

When you visit our stores

For what purpose do we process your data?	What is our lawful basis to process your data?	What data do we collect or process?	How long do we keep it?
Process your purchase and allow you to make returns	-Necessary for a contract -Legal obligation of offering return services -Legal obligation to issue a receipt and keep transaction records	-Order details -Order number -Member number (if applicable)	7 years
To pick up a click and collect order	-Necessary for a contract	-Name -Order details -Order number	Until you collect your order or the order is deemed ‘not collected’
Provide you with a digital receipt	- Consent -Legal obligation to issue a receipt and keep transaction records	-Email Adress -Payment method -Order number -Purchase details	We keep a record of having provided a digital receipt to your email address for 7 years.
Maintaining safe and secure stores with CCTV cameras	-Legitimate interest in ensuring the safety of employees and customers; and prevent, limit or deal with incidents. Legitimate interest means we process your data because it is necessary for our business purposes, while carefully balancing this against your privacy and fundamental rights.	-Instore recordings where you might be identifiable	-72 hours in the DACH region -10 days in Belgium -28 days in the Netherlands - If an incident is recorded, the footage will be deleted once the issue is resolved

 

When you use our web shop or app

For what purpose do we process your data?	What is our lawful basis to process your data?	What data do we collect or process?	How long do we keep it?
Fulfil your online purchase, deliver your order, and allow you to make returns	- Necessary for a contract - Legal obligation to issue a receipt and keep transaction records	- Name - Order number - Member number (if applicable) - Phone Number - Email - Billing and delivery address  - Purchase details	7 years
Improving products and services by receiving and publishing reviews	-Legitimate interest in improving our products and being transparent with customers	-Email -Name (only first name and initial) -Order number -Your product review, including date, size, comments	As long as the product you reviewed is on our website
Identify stores near you	-Legitimate interest in informing customers where to find our stores	-Approximate location based on your device settings (only where you have enabled location services -Post code (if provided by you)	Deleted after use
Provide customer service through our AI chatbot	-Legitimate interest in maintaining brand reputation and providing efficient customer support	-Name -Email -Purchase details (if applicable) -Member number (if applicable)	2 years
Provide direct customer support (phone & webchat)	-Legal obligations of providing costumer support -Legitimate interest in maintaining brand reputation	-Name -Order number (if applicable) -Membership number (if applicable) - Any personal data you voluntarily provide during the interaction	-Phone recordings: 90 days -All other customer service records: 2 years
Send push notifications to customers through the app	-Consent - Legitimate interest when, for example, the push notification is regarding items in your cart or wishlist that may be on sale, vouchers that are expiring, Member benefits	-Name -Browsing habits (such as clicks and interactions, pages you visit)	Until you withdraw consent

 

You are a Hunkemöller member

For what purpose do we process your data?	What is our lawful basis to process your data?	What data do we collect or process?	How long do we keep it?
Providing members with member benefits (such as vouchers, communications, event invites, early discounts)	-Legitimate interest in connecting with our members and showcasing the brand, and marketing our products	-Purchase history -Member number -Name -Email -Postal Adress -Address	For the duration of your membership
Connecting your purchases to your account	-Legitimate interest in knowing what a member has bought and including it in their account	-Member number -Purchase details -Method of payment	For the duration of your membership
Contact you if your account has been inactive	-Legal obligation to not keep your personal data for longer than necessary - Legitimate interest to remind you about member benefits	-Email -Name -Member number	For the duration of your membership
Sending marketing material or communication via post	-Legitimate interest in connecting with our members, showcasing the brand, and marketing our products that we think are relevant to you -Consent for newsletter or other mass mails	-Name -Address -Member number	For the duration of your membership
Conduct our customer satisfaction survey	-Consent	-Name -Email -Purchase details -Your feedback -Any additional data you submit with the survey	1 year and 3 months after you submit the survey

 

3. What happens when I buy through marketplaces?

If you buy Hunkemöller products through a marketplace (e.g. Zalando, Amazon, etc.), the marketplace will provide us with the necessary data to process your purchase and deliver the product. Depending on the circumstances, the marketplace and Hunkemöller may act as independent controllers. We will retain this data for 2 years and we may share your data with a logistics service provider to complete the delivery.

 

4. Does Hunkemöller share my personal data?

Our subsidiaries

We may share your personal data with our subsidiaries in relation to local events, promotions, communications, costumer services, fulfill your purchases, and compliance with local laws and regulations. We have appropriate internal policies and procedures to ensure the protection of your personal data. Your data is only processed by people working on our behalf on a need-to-know basis and only for the purposes stated in this Privacy Statement.

 

Processors and third parties

We may share your data with the following categories of processors and third parties. These parties act either as processors on our behalf or as independent controllers, depending on the service provided.

• Payment service providers
• IT hosting providers, such as cloud storage
• Communications service providers, such as to send emails to customers
• Logistics Service Providers, such as Post NL to deliver an online order
• Marketing and publicity, such as Google Ads, or Marketing Agencies
• Customer service providers, such as to address costumer requests
• Costumer management platforms, such as Salesforce and SAP
• Other customers, such as for online product reviews (we may publish your review, name and initials if applicable)

We might also share your data with public authorities when we are legally obliged to do so and only after a direct request from the relevant authorities.

 

Transfer of Data outside the EEA

We may share your data with third parties outside the European Economic Area (EEA) to fulfill some of the purposes stated in this Privacy Statement. We only do this under an adequacy decision of the European Commission, by implementing appropriate safeguards or by relying on the European Commission’s Standard Contractual Clauses (SCCs).

Where necessary, we also carry out Transfer Impact Assessments (TIAs) and apply additional technical, organizational, or contractual measures to address local legal risks in the destination country.

We only transfer your data outside the EEA to fulfil the purposes stated in this Privacy Statement.

5. How does Hunkemöller protect my data?

We make every effort to secure and protect your personal data. We implement appropriate technical, organizational and physical measures to prevent loss, misuse, unauthorized access, disclosure, alteration, or destruction of the personal data we collect and process, taking into account the state of the art, implementation costs, and the nature, scope, context and risks of the processing. These measures include:

• Access control and strict role-based permissions
• Asset and device management
• Encryption and secure network protocols
• Information security management policies
• Regular monitoring, testing, and evaluation of the effectiveness of our security controls, mandatory security training and awareness programs for all employees

 

6. Does Hunkemöller process Children’s Data?

We process personal data from data subjects in accordance with applicable national laws regarding the age of consent when they buy in store. We only process their personal data for the purpose of completing their purchase. We do not know with certainty the ages of people who interact with our social media accounts. We do not actively target customers under 16 years of age.

We process data from 16 years and older when they want to become a member. We do this with the consent of a parent or legal guardian as per our Member Programme Terms & Conditions until the member is 18 years of age.

 

7. Does Hunkemöller do automated decision-making and targeted advertising?

Hunkemöller does not rely on automated decision-making that produces legal or similarly significant effects for customers or members. We do, however, use automated tools, including profiling and segmentation techniques, to better understand customer preferences and tailor our communications and marketing activities. This may involve the use of algorithms or data analysis tools that assess your interactions, preferences, and purchase history. These activities are carried out under our legitimate interest in providing relevant and personalized communications, where permitted by law, or based on your consent where required (for example, for cookies and targeted advertising).

This processing does not result in decisions that significantly affect you, and you remain in control of your communication preferences by opting in to our newsletter, or changing communication preferences in the member portal, You can find more information about automated decision making for our website and app appearance  in our Cookie Policy. You can manage your cookie preferences at any time via our cookie settings.

 

8. What are my rights as a data subject?

As a data subject, you have the following rights regarding the processing of your data:

• Right of access: You can ask us to confirm whether we process your personal data and, if so, receive a copy of that data.
• Right to correct your personal data: You can ask us to correct inaccurate or incomplete personal data. You can also update certain details in your My Hunkemöller account or our app.
• Right to erase your personal data: You can ask us to delete your personal data in specific situations, for example when you object to the processing or believe the data is inaccurate.
• Right to restrict our processing of your personal data: You can request that we limit our use of your personal data in certain circumstances (such as when its accuracy is disputed). Restriction does not stop us from storing the data.
• Right to data portability: You can request the personal data you provided to us in a structured, commonly used, machine-readable format, or ask us to transfer it to another organization where technically feasible.
• Right to object: You can ask us to stop processing your personal data. We will comply unless we have compelling legitimate grounds, or the processing is necessary for legal claims.
• Right to withdraw consent:  When our processing is based on your consent, you can withdraw that consent at any time. This does not affect the lawfulness of processing carried out before the withdrawal but does stop future use.
• Right to object to direct marketing: You have the right to object at any time to the processing of your personal data for direct marketing purposes, including profiling related to such marketing. If you object, we will stop using your personal data for direct marketing activities. You can exercise this right, for example, by using the unsubscribe link in our marketing communications or by contacting us directly
• Right to lodge a complaint with the supervisory authority: You can file a complaint with your local supervisory authority if you have concerns about how we handle your personal data.

We will respond to your request within one month, in accordance with applicable law.

You can exercise these rights at any time by using the Privacy Request Form, to be found online on our website, or contacting DPO@hunkemoller.com. We will handle your requests carefully and in accordance with the applicable regulations.