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Hunkemöller Privacy Statement
Date: 17/12/2024
Hunkemöller B.V. and its subsidiaries (hereinafter also referred to as Hunkemöller, or we, us, our) are committed to protecting your personal data. It is important for us to use your personal data carefully and securely in a transparent manner in accordance with the applicable privacy laws (including the General Data Protection Regulation).
What information you can find in this Privacy Statement
In this Privacy Statement we explain:
- What personal data we collect.
- When we collect your personal data.
- How we use such personal data.
- How long do we keep your personal data in relation to our stores, webshop and app.
- Who we share your data with.
- Your data subject rights and how we respect them.
This privacy statement may be updated in the event of new developments, such as changes to our use of your personal data or to reflect changes in regulatory requirements. When there is an update, we will notify you in this Privacy Statement. We will notify you separately of any significant changes to our Privacy Statement via email.
INDEX
1. WHO IS THE DATA CONTROLLER FOR THE PROCESSING OF YOUR PERSONAL DATA??
Hunkemöller B.V. is the main data controller responsible for the processing of your personal data. If you have any questions about our Privacy Statement or want to exercise your rights as explained in our Privacy Statement, please let us know.
2. WHEN DO WE COLLECT YOUR PERSONAL DATA??
2.1 When you become a member (in-store and online)?
- Tailoring marketing communications to your interests: As a member, if you have provided consent to receiving marketing communications from us, you will receive regular mail or, depending on your cookie choice, online personalised advertisements (for more details please see Section 3 of this Privacy Policy), offers, information on our promotions and events, product suggestions and recommendations you may be interested.
- Personalization and targeting with cookies: If you are logged-in on your My Hunkemöller account as a member and provided your consent to the use of cookies via the cookie banner on our webshop or app, we will collect the products or content you viewed, products you added to your shopping basket but did not yet purchase, to track your shopping habits, advertisements you viewed or interacted with, and your potential interests gleaned from such browsing behaviour. Picking-up online orders or returning products ordered online in one of our stores:
- Picking-up online orders or returning products ordered online in one of our stores: When picking up an order in one of our stores, we ask you to show an e-mail/text message (e.g., confirmation email) where the name of the original purchaser and order number is stated as a proof of purchase. If someone else picks up your parcel, we ask this person to show an identification document with his/her name and signature on it (e.g. ID, drivers’ license or credit card). The collector is also asked to show an email/text message where the name of the original buyer and the order number is stated. We will only record your name, the date when the order arrived and when it was collected, the details of your order and payment and any feedback you have on the pick-up form. You need to sign when picking up a product in one of our stores. The signed collection forms are kept for 6 months.
- (Full) Name
- Date of birth
- Full (home) address (billing)
- Mail address (shipping)
- E-mail address
- Membercard number
- Phone number(s)
- Gender
- Outstanding and redeemed Passion Points
- Credit balance and redeemed credit
- Your in-store and online purchased products, and their size, color, price and other product details
- Where you have purchased products, such as which store
- Time and date of your purchases
- Returned products, date on which you have indicated that you want to return products, date of return of products.
- Sizes (bra size, brief size, fashion size)
- Whether you provided consent to receiving marketing communications, via which channel (online, in-store, app) and date and time.
- Payment details: bank account number, bank or credit card number, time and date of payment. We do not store bank account or credit card numbers (unless you have given your consent, we store this encrypted so that you do not have to fill in these details for your next purchase) once the transaction has been successfully completed. We share your personal information with credit card companies and other payment providers only for the payment of your transaction.
- Categories of products purchased.
- If you have visited our webshop or app: IP address and time and date of your visit.
- Billing address
- Personal note (optional when purchasing a gift)
- Track & trace number
- If you choose to pick up your order in one of our stores, your pick-up location.
- If you have accepted cookies in our webshop or app and are logged in to your My Hunkemöller account, information collected via cookies in our webshop to which you have consented, such as viewed web pages, products in which you have shown interest by clicking on or viewing the product or adding it to your shopping basket or by clicking on an advertisement.
- The customer audience segment that matches your online and in-store shopping habits, your demographic, preferences, products you've viewed or expressed interest in, and your size data.
- Any questions, requests, feedback or complaints.
- Reviews that you post on the website.
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2.1.2 For what purpose do we process your personal data?
When you become a member, we use your personal data for the following purposes:
- To give you Passion Points, based on your purchases and likes on social media, to manage your Passion Points, and to allow you to redeem Passion Points and credits.
- To give you Passion Points or other surprises on your birthday.
- To give you Passion Points when you tell us more about yourself, shop in different categories or shop in multiple channels (stores and webshop).
- If you have consented to receive marketing communications such as newsletters and push notifications via the app, we will use your contact details to send you marketing communications.
- To provide you with personalized and more relevant offers, discounts, invitations, online and in-store suggestions and recommendations tailored to you based on your personal data collected in our stores or online in our webshop or app
- If you provided consent, to show you relevant advertisements on social media, such as Facebook and Instagram or on third-party websites, such as search engines or third-party advertisements that may appear on other third-party websites that you visit.
- To contact you with important information regarding your membercard, Passion Points and credits, or purchases, including confirming your order.
- To process purchases, orders, payments, returns and debt collections.
- To manage your My Hunkemöller account that you use as a member.
- To provide customer support and properly handle and respond to your questions, requests, feedback, or complaint.
- To secure your My Hunkemöller account and our systems.
- To analyse the use of membercards, purchased products, services used and abandoned shopping baskets in our webshop on an aggregate basis to improve and optimise our products and services, including in-store and online offerings, on a general basis.
- To prevent, investigate, handle or report fraud or theft.
- To comply with a legal obligation, a court order, or to exercise or defend legal claims.
- We will use your contact details to send you marketing communications or show relevant advertisements on social media platforms you are using, such as Facebook, Instagram, Snapchat and Pinterest.
- If you consent to our use of cookies, we will also collect information about your browsing behavior and shopping habits to determine your interests and things you may like and link such collected information to your My Hunkemöller account when you are logged in. For further information about cookies, please read our Cookie Policy.
- You can withdraw your consent to receiving marketing communications at any time at the bottom of every newsletter you receive, by contacting us, or if you have a My Hunkemöller account under your profile details. Withdrawing your consent will not affect the lawfulness of our use of your personal data prior to your withdrawal.
- We are obliged to process your data to comply with accounting requirements.
- We are also required to retain receipts and refunds to comply with minimum tax retention obligations.
- We may also be required to process or disclose your personal data based on a court order or order from a competent governmental authority.
- Sending you an email within 1 hour if you are logged in on whether you wish to complete your order for the products added and left in your shopping basket on our webshop after you closed our webshop or app for managing inventory, increase customer satisfaction by reminding you on (sale) products you still wish to purchase, and improve our business;
- Reduce business risk by detecting and reducing credit and fraud risks and verifying your identity;
- Evaluating and improving the quality of our products and services, including developing new products and services, to improve our business;
- To protect our business against unlawful activities by implementing security measures.
2.1.3 Legal grounds for processing your personal data
We rely on one of the following legal grounds for the processing of your membership data:
Consent
Performance of a contract with you
If you are a member, we also process your personal data for the performance of a contract with you, namely to carry out the membership program and to offer you the benefits thereof. We need your personal information to run the membership program and handle your purchases and returns. Please refer to our terms and conditions for our member card for more information.
Legal obligation We process your personal data if this is necessary to comply with one of our legal obligations.
Legitimate interests
We process your personal data if this is necessary to achieve our legitimate interests. At Hunkemöller, we like to get to know our valued members, their preferences, interests and things they may like, and segment them into specific customer audience groups based on the information obtained or analyzed from your personal data, including purchasing and browsing behavior, shopping habits, demographic data and other personal data as described under "what personal data do we collect". This allows us to improve our business by finding new ways to provide you with a more personalized, a better shopping experience and increase customer satisfaction, such as by recommending products that would be a better fit for you to help you pick the right products and make your shopping efficient, like:
2.1.4 How did we obtain your personal data?
We may obtain your personal data directly from you, such as when you register or activate your membercard, create a My Hunkemöller account, visit our webshop, use our app, place orders, make in-store purchases, ask questions or give feedback. We may also receive your personal data from third parties, such as the cookie providers listed in our Cookie Policy, loyalty services we use to make sure that you can save and redeem Passion Points and credits, logistic services we use to handle online orders and returns, the package delivery company we use to send your package, and payment service providers.
2.1.5 How long do we retain your personal data?
We do not store your personal data longer than is necessary regarding the purposes for which the data are processed. If you are a member, we will retain your data for as long as you remain an active member. If you are inactive as a member due to not using your member card for six (6) years, we will send you an e-mail asking whether you still wish to be a member. If you remain inactive thereafter, we will cancel your membership and delete your personal data related to your membership. We are required to retain receipts and refunds to comply with minimum tax retention obligations. In some circumstances, such as to comply with our legal or regulatory (accounting and tax) minimum retention periods, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions, we may retain your personal data after we cancel your membership or finished providing products and services to you.
2.1.1 What type of personal data do we collect?
To provide you all benefits of your membercard and allow you to benefit from a more personal shopping experience tailored to your interest, and preferences, we collect and use the following personal data of you, depending on whether you have activated your membercard (if you have not yet activated your My Hunkemöller account, we will only process the member registration details you provided in-store and your in-store purchases to provide and administer Passion Points), completed your My Hunkemöller account registration details, and your interactions with us:
2.2 If you use our webshop and place orders without an account
You can also visit and shop in our webshop without an account. We will then process your personal data in relation to your visit to our webshop or app. If you place orders, we will also process your personal data to ensure that your order is handled correctly.
- · If you provided your consent to the use of cookies via the cookie banner on our webshop, the third-party advertising cookies that we use allow these third parties and us to recognise your device and track your browsing behaviour on our webshop and on third-party websites, which results in online personalised advertisements.
2.2.1 What personal data do we collect?
If you use our webshop and order products without an account, we use the following personal data of you:
- If you visit our webshop:
- If you accepted cookies on our webshop, information collected through the third-party advertising cookies that we use on our webshop, such as viewed webpages, products that you have shown interest in by clicking or viewing the product or adding it to your shopping basket or by clicking on an advertisement in our webshop or third-party websites.
- IP address, time and date of your visit.
- Any questions, requests, feedback, or complaints.
- Whether you subscribed to receive our marketing communications via email or other contact details you provided.
- If you allow browser push notifications on our website, we will send you marketing communications via your web browser. We will collect your Membercard number, first and last name and your device ID.
- If you write a product review on our website: email address, your name and your order ID.
- In addition, we also use the following personal data of you if you place an order:
- Name
- Address
- Delivery and billing address: your delivery address is shared with our external delivery/transport partners who take care of the delivery of your purchases to your delivery address
- Email address
- Personal note (optional when you buy a gift)
- Track&trace number
- Details of your order: time of your purchases, purchased products, details of the purchased products, including their size, color, and price.
- Payment details: bank account number, bank or credit card number, time of payment, payment method, even if you have chosen to pay for your order after delivery. We do not store payment account or card numbers once the transaction is completed. We share your personal data with credit card companies and other payment providers for the payment of your transaction.
- If you choose to pick-up your order in one of our stores, your pick-up location.
- Information on returns and reimbursements.
2.2.2 Why do we collect this personal data?
When you visit our webshop, or place orders, we use your personal data for the following purposes:
- To process purchases, orders, payments, and debt collections.
- To provide you with the functionalities of our webshop such as required to remain logged in while shopping and save your current language selection.
- If you provided consent to receive marketing communications such as newsletters, push notifications in your browser, to send you such marketing communications.
- To provide customer support and properly handle and respond to products you wish to return, refund your payments, and your questions, requests, feedback or complaints.
- If you provided your consent to receiving marketing communications from us, such communications will also be tailored to you.
- If you write a product review on our website: to collect and display the reviews on our website, to analyze on an aggregate basis to improve our products, authenticity and fraud detection and hosted authentication.
- To contact you with important information regarding your purchases, including confirming your order.
- To provide customer support and appropriately handle and respond to products you wish to return, reimbursement of your payments, and your questions, requests, feedback, or complaints.
- To secure your use of our webshop, placement of an order and our systems.
- To analyze the use of our webshop, such as purchased products, used services and abandoned shopping baskets, on an aggregate basis to improve and optimize our products and services, including our webshop, on a general basis.
- To prevent, investigate, handle or report fraud or theft.
- To comply with a legal obligation, a court order, or to exercise or defend legal claims.
2.2.3 Legal processing grounds for using your personal data
We rely on one of the following legal grounds for the processing of your personal data in relation to your use of our webshop and online orders:
- Consent
- If you provide your consent, we will use your contact details to send you marketing communications or show relevant advertisements on social media platforms you are using, such as Facebook and Instagram.
- Should you consent to our use of cookies, we will also collect information on your browsing behavior and shopping habits to determine your interests and things you may love. For further information about cookies, the information collected via cookies, and how we use such information, please read our Cookie Policy.
- If you write a product review on our website, we will only place such review if you provide your consent.
You can withdraw your consent to receiving marketing communications at any time at the bottom of every newsletter you receive or by contacting us. Please read our Cookie Policy for how you can withdraw your consent for cookies at any time. Withdrawing your consent will not affect the lawfulness of our use of your personal data before your withdrawal.
- Performance of a contract with you
- We also process your personal data for entering into and performance of a contract with you, namely to provide you the functionalities of our webshop and handling your online purchases.
- Legal obligation
We process your personal data if necessary for complying with one of our legal obligations.
- We are required to process your information to comply with accounting requirements.
- We are also required to retain receipts and refunds to comply with fiscal minimum retention obligations.
- We may also be required to process or disclose your personal data based on a court order or order of a competent governmental authority.
- Legitimate interests
We process your personal data as necessary for achieving our legitimate interests:
- At Hunkemöller we like to get to know our customers, their preferences, interests, and things they may love obtained or analyzed from your personal data, including purchasing and browsing behavior, shopping habits, demographics, and other personal data as described under "what personal data do we collect". This allows us to improve our business by finding new ways to provide you with a more personal and seamless shopping experience and increasing customer satisfaction, such as by recommending products that would be a better fit for you to help you pick the right products that you will love to wear and make your shopping more user friendly and efficient.
- Reduce business risks by detecting and reducing credit and fraud risks.
- Evaluating and improving the quality of our products and services, including developing new products and services, to improve our business.
- To protect our business against unlawful activities by implementing security measures.
2.2.4 How did we obtain your personal data?
We obtain your personal data directly from you when you provide your information when placing an order or visit our web shop, allow push notifications in your browser, write a product review, ask questions or make requests. We may also receive your personal data from third parties, namely cookie providers listed in our Cookie Policy, logistic services we use to handle online orders and returns, the package delivery company we use to send your package, and payment service providers we use to process your payment, namely Adyen N.V.
2.2.5 How long do we retain your personal data?
We will not retain your personal data longer than necessary in relation to the purposes for which the data are processed. If you place and order without being a member or without having a My Hunkemöller account, we will hold on to your information for as long as is needed for us to be able to provide the relevant products or services to you. After handling your order, we are required to keep your personal data, including purchased products, to retain this information to comply with fiscal retention obligations.
If you allow to receive push notifications in your browser we will store your personal data for a period of 2 years.
If you write a product review on our website, we retain your personal data for a period of 18 months, unless you request us to remove your review any sooner.
Please read our Cookie Policy for more information on how long cookies remain valid.
In some circumstances, such as to meet our legal or regulatory (fiscal) minimum retention term obligations, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions, we may hold on to your personal data after finishing providing products and services to you.
2.3 When you use our app and place orders through our app
You can choose to download and use our app, also without a My Hunkemöller account. Our app provides various features which you can also use without registering, such as the possibility to view our products, to scan product information in our stores and to look for a store which is closest to you. We will only process your geolocation for this purpose if you provided your consent to this in our app. You will only be able to place orders via the app if you have or create a My Hunkemöller account and become a member. If you do not want to become a member, you can place an order via our mobile website as a guest. To download and use our app, we will require details of your smartphone or tablet: your IP address and your MAC address, model and operating system of your devices.
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Targeting you using cookies: If you provided your consent to the use of cookies through the app, we track how you use our app, meaning the content you viewed, products you added to your shopping basket that have not yet been purchased, your shopping behavior, in-app promotions that you viewed or interacted with, and your potential interests collected from such app usage and shopping behavior. Based on the information, we will make your use of our app and shopping from the app more efficient and tailored to you by showing you products in our app you might also like based on products bought by other customers, the closest store near you where products are still on stock, where you can choose to pick-up your order, to offer you coupons in the app, and showing you more relevant advertisements in the app.
2.3.1 What personal data do we collect?
When you use our app, we use the following personal data about you:
- Your IP-address
- Your device's MAC-address
- Your device's model and operating system
- If you accepted cookies on our app, information collected through third-party cookies, such as products you have shown interest in by viewing the product or adding it to your shopping.
- Whether you would like to receive push notifications regarding your order, news, events, promotions and other marketing communications.
- App inbox messages we sent to you as push notifications.
- Whether you subscribed to receive our marketing communications via email.
- Your geolocation to show you which stores are closest to you and send you push notifications with marketing communications when you are near (within approximately 100 meters of) one of our stores.
- When you write a product review on our app: email address, name and order ID.
- Any questions, requests, feedback, or complaints.
2.3.2 Why do we collect this personal data?
When you use our app, we use your personal data for the following purposes:
- To provide you the functionalities our app: creating an account, updating your account, placing an order, save your sizes, Sexy Shapes and Favourite Fits.
- If you provided consent to receiving push notifications for marketing communications, to send you such marketing communications to your inbox in our app via push notifications.
- To provide customer support and appropriately handle and respond to products you wish to return, reimbursement of your payments, and your questions, requests, feedback, or complaints.
- If you provided consent to allow us to access your device's location, to send you push notifications based on when you are near (within about 100 meters) a Hunkemöller store and to show you the nearest store. We also process how often you were near one of our stores to measure the effectiveness of our advertising campaigns and promotions on an aggregate level. Depending on the type and version of your device's operating system, you can choose whether and when we have access to your location.
- To secure your use of our app and your data stored in the app, and our systems.
- To analyze the use of our app, such as used functionalities, products and content viewed, and abandoned shopping baskets, on an aggregate basis to improve and optimize our products and services, including our webshop, on a general basis.
- If you write a product review on our app: to collect the reviews and display them on our website, to analyze on an aggregate basis to improve our products, authenticity and fraud detection and hosted authentication.
- To prevent, investigate, handle or report fraud or theft.
- To comply with a legal obligation, a court order, or to exercise or defend legal claims.
2.3.3 Legal processing grounds for using your personal data
We process your personal data only if this is allowed under one of the legal processing grounds. We rely on one of the following legal grounds for the processing of your personal data in relation to your use of our app:
- Consent
- If you provide your consent, we will use your contact details to send you marketing communications.
- Sending you push notifications, including our marketing related notifications, if you consented to receiving such notifications.
- Using your geolocation to show nearest shops and send you push notifications based on your geolocation when you are near (within approximately 100 meters of) one of our stores.
- If you consent to our use of cookies, we also collect information about your app usage behavior and shopping habits to determine your interests and things you may like.
You can withdraw your consent to receive marketing communications at the bottom of each newsletter you receive from us or by contacting us, or if you have a My Hunkemöller account under your profile details. Please read our Cookie Policy for how you can withdraw your consent for cookies at any time. Withdrawing your consent will not affect the lawfulness of our use of your personal data prior to your withdrawal.
- • Performance of a contract with you
- We also process your personal data for the performance of a contract with you, namely to provide you the functionalities of our app.
- Legal obligation
We process your personal data if necessary for complying with one of our legal obligations.
- We may also be required to process or disclose your personal data based on a court order or order of a competent governmental authority.
- Legitimate interests
We process your personal data as necessary for achieving our legitimate interests:
- At Hunkemöller, we like to get to know our valued members, their preferences, interests and things they may like, and segment them into specific customer audience groups based on the information obtained or analyzed from your personal data, including purchasing and browsing behavior, shopping habits, demographic data and other personal data as described under "what personal data do we collect". This allows us to improve our business by finding new ways to provide you with a more personalized and seamless shopping experience and increase customer satisfaction, such as by recommending products that would be a better fit for you to help you pick the right products and make your shopping efficient.
- Reduce business risks by detecting and reducing credit and fraud risks and verifying your identity.
- Evaluate and improve the quality of our products, including developing new products and services, to improve our business.
- To protect our business against unlawful activities by implementing security measures.
2.3.4 How did we obtain your personal data?
We obtain your personal data directly from you through your use of our app and information you enter in the app, if you give us access to your location, or when you ask questions or make requests.
2.3.5 How long do we keep your personal data?
The app itself does not store any of your personal data. The app has only access to your personal data stored in our supplier's systems. We do not store your personal data longer than is necessary with regard to the purposes for which the data are processed. Your personal data obtained by the app will be stored for 2 years. If you write a product review on our app, we will delete your data upon your request.
2.4 When you visit our stores
Security camera: There is CCTV surveillance in our stores to protect us and our valued customers against theft and ensure the safety of our customers and colleagues. If you visit our stores, you will be informed of the presence of CCTV cameras via visible signs. When there is a serious incident, such as theft, we will provide relevant CCTV recordings to the competent authorities, such as the police.
2.4.1 What personal data do we collect?
When you visit or shop in our stores, we use the following personal data about you:
- If you purchase products: your encrypted bank account or credit card number, debit card number and time and date of payment, products purchased, and your receipt.
- If you pick up products ordered online: name, date or arrival of your order, details of your order and payment details.
- E-mail address, if you want to receive receipts via e-mail or indicate to our colleague that you want to receive marketing communications from us via e-mail.
- If you return products: our colleagues have access to your order details if you ordered the products online, to be able to process your return. We also process your return information, namely the date and time of your return, refunds you receive, items you have returned, and items you keep (if any).
- Any questions, requests, feedback or complaints you may have.
- CCTV recordings.
2.4.2 Why do we collect this personal data?
When you visit and shop in our stores, we use your personal data for the following purposes:
- To provide customer support and appropriately handle and respond to products you wish to pick-up, return, reimbursement of your payments, and your questions, requests, feedback, or complaint.
- To secure our store, ensure the safety of our colleagues and customers and prevent, limit or deal with incidents.
- If you provided consent to receive marketing communications via email to send you such marketing communications.
- To analyze visits, pick-ups, purchases and returns in our stores on an aggregate basis to improve and optimize our products, services and marketing on a general basis.
- To prevent, investigate, handle or report theft.
- To comply with a legal obligation, a court order, or to exercise or defend legal claims.
2.4.3 Legal grounds for processing your personal data
We rely on one of the following legal grounds for the processing of your personal data in relation to your visit to our shops::
- Consent
- If you provide your consent, we will use your contact details to send you marketing communications or display relevant advertisements on social media platforms you are using, such as Facebook and Instagram.
You can withdraw your consent to receive marketing communications at the bottom of each newsletter you receive from us or by contacting us, or if you have a My Hunkemöller account under your profile details. Withdrawing your consent will not affect the lawfulness of our use of your personal data prior to your withdrawal.
- Performance of a contract with you
- We also process your personal data for the performance of a contract with you, namely when handling your purchases, including in-store pick-ups, or returns.
- Legal obligation
We process your personal data if this is necessary to comply with one of our legal obligations.
- We are required to process your data to comply with accounting requirements.
- If you want to reclaim the VAT payed on your purchase, we need to process your personal data for this purpose.
- We are also required to retain receipts and refunds to comply with minimum tax retention obligations.
- We may also be required to process or disclose your personal data based on a court order or order of a competent governmental authority.
- Legitimate interests
We process your personal data as necessary for achieving our legitimate interests:
- At Hunkemöller, we like to get to know our customers, their preferences, interests and things they may like. This allows our colleagues to make you more relevant suggestions, which increases customer satisfaction.
- Evaluate and improve the quality of our products, including developing new products and services, to improve our business.
- To protect our business, our colleagues and customers against unlawful activities and to ensure their safety by implementing security measures.
2.4.4 How did we obtain your personal data?
We obtain your personal data directly from you when you visit our store, purchase, pick up or return products, redeem Passion Points or credits as a member, or when you ask questions or make requests.
2.4.5 How long do we retain your personal data?
We do not store your personal data longer than is necessary with regard to the purposes for which the data are processed.
Transaction data is stored for up to 7 years for in the event of tax audit queries. For pick-up (click & collect) online orders and returns: only our store employees have access to your personal data within the return period or pick-up period of your order. After this period, the order will no longer be visible to our store employees. Signed pick-up forms are kept for 6 months.
CCTV footage is stored at a maximum of 30 days and deleted afterwards. Note: depending on the country this period might be less. If you want to learn more about CCTV retention period, please contact us via DPO@hunkemoller.com.
2.5 When you participate in events or competitions
When you participate in an event, or competition that we organize for our customers, we find it important to protect your privacy and only collect the information necessary.
2.5.1 What personal data do we collect?
If you participate in our events, prize draws or competitions, we process the following personal data:
- (full) Name
- Email address
- Home address
- Membercard number (if applicable)
2.5.2 Why do we collect this personal data?
If you participate in our events, prize draws or competitions, we use your personal data for the following purposes:
- To allow you to participate and check whether you are eligible to participate in an event, or competition.
- To communicate with you about your participation in our events, and competitions.
- To provide your prize, if you win.
- To analyse and evaluate on a general aggregated basis the participation in events, and competitions and improve them, so our customers enjoy such events, and competitions even more.
2.5.3 Legal grounds for processing your personal data
We rely on one of the following legal grounds for the processing of your personal data:
- Performance of a contract with you
- If you participate in an event, or competition, we process your personal data for the performance of a contract with you, namely to allow you to participate in the event, or competition and providing you an opportunity to win, determining whether you have won, and giving the prize you have won.
- Legitimate interests
- We process your personal data if this is necessary to achieve our legitimate interests:
- We analyze the success of our events, and competitions by looking at the number, type and demographics of participants and their engagement. This allows us to improve our events, and competitions and increase customer satisfaction.
2.5.4 How did we obtain your personal data?
We obtain your personal data directly from you when you participate in an event, or a competition.
2.5.5 How long do we keep your personal data?
We will not store your personal data for longer than is necessary in relation to the purposes for which the data are processed, with a maximum of 2 months after the end of the event, or competition you participated in.
2.6 When you contact our customer service
You can contact our customer services via various channels, including via a phone call, email or chat (e.g., Facebook Messenger or other social media). If you contact our customer services via email, you may be invited to complete a survey about your experience with our customer services. Your answers will only be used to improve our customer services.
2.6.1 What personal data do we collect?
We process the following personal data:
- Voice recording of contact
- Copy of correspondence
- Date of correspondence
- Origin of correspondence
- Reason of correspondence
- Resolution of correspondence
- Name and contact details
- Survey feedback about your experience with customer services
2.6.2 Why do we collect this personal data?
We use your personal data for the following purposes:
· To provide you with customer support
· To process your request/question
· To train our customer service agents
· To improve our services
· To send you a survey about your experience with our customer services
2.6.3 Legal grounds for processing your personal data
We rely on one of the following legal grounds for the processing of your personal data:
Performance of a contract with you: we process your personal data to provide you with customer service and answer your questions as you requested.
Legitimate interests: at Hunkemöller we want to get to know our customers, their preferences, interests and things they may like. This allows our colleagues to make more relevant suggestions to you, which increase customer satisfaction. Evaluating and improving the quality of our products and services, including developing new products and services, to improve our business.
2.6.4 How did we obtain your personal data?
We obtain your personal data directly from you, when contacting our customer service through various channels, such as a phone call, via email or chat (e.g., via social media), or when completing the survey about your experience with our customer services.
2.6.5 How long do we keep your personal data?
We do not store your personal data longer than is necessary regarding the purposes for which the data are processed. If you contact our customer services via a phone call, the voice recording of this call may be stored for 12 months for training and service improvement purposes. If you contact our customer services via email or chat (e.g., via social media), a copy of this correspondence may be stored for 24 months for training and service improvement purposes and to be of service to you in the event of complaints. Please note that certain social media platforms are located outside the EU and may store copies of correspondence locally. If you complete the survey about your customer services experience, your answers to the survey will be stored for 12 months. After the expiry of the retention periods, information about the customer service case will be anonymised.
3. WHO HAS ACCESS TO YOUR PERSONAL DATA?
Your personal data may be collected by, shared with and processed by any member of the Hunkemöller group, specifically also with our local subsidiary located in your country in relation to local events, promotions, and communications, your shopping in our webshop, the handling of any of your questions or requests, and compliance with applicable local laws and regulations. We have implemented appropriate agreements and internal policies within our group to ensure the protection of your personal data. Your information will be processed by persons working for or on behalf of us on a need-to-know basis only for the purposes specified in this Privacy Statement.
We use other third-party service providers to perform Customer Relationship Management (CRM), email marketing campaigns, online advertising, customer analytics (e.g. Selligent), customer satisfaction surveys (e.g. The Choice), uploading and sharing of your social media posts or other content (e.g. Flowbox), fulfilment of orders, delivery, returns, refunds, payment providers handling your payment (e.g. Adyen N.V.), and IT services. In providing the services, your personal data will, where applicable, be processed by the third-party service provider on our behalf. When we use the services of such third-party service provider that processes your personal data on our behalf, acting as a data processor, we have written data processor agreements in line with applicable data protection laws in place to safeguard the proper and secure processing of your personal data and ensure compliance with international data transfer restrictions.
Advertisements and offers
To be more efficient in our online marketing communications, we work with various social media providers, search engines and advertising networks ("Advertising Partners"). Depending on your cookie choices, your personal data may be shared with social media providers such as Facebook and Google for online advertising networks.
Advertising partners use information provided by us and collected through cookies and other technologies to predict your preferences and interests and take this into account when choosing advertisements in the advertising spaces offered through their online advertising networks. This is a practice known as "retargeting". Advertising partners use cookies and similar technologies to track your use of our websites and services by using data stored on your device or in apps. Please read more about cookies and other tracking technologies in our Cookie Policy.
To choose the content that suits your interests, we may use information we obtained from you when you signed up for our newsletter or an account or made a purchase from us. We may share this information, such as an encrypted email address, with third parties such as Facebook and Google, for the purpose of showing you relevant ads on third-party websites and apps. To be able to do this, your data is compared with the database of that third party. When a match is found, you'll see promotional and relevant content in your feed or search engine. If no match is found, your data will be safely deleted.
If you do not want us to share your data with third parties for this purpose, you can withdraw your consent to marketing at any time. This can be done via the Cookie Settings under "About us", at the bottom of the page.
Hunkemöller has no control over the privacy practices of these advertising partners and social media providers. Please read their privacy statements carefully for information on how they handle your personal data. When you share social media content that gets featured by us with your consent, your content will be available publicly and third parties could share or use your content without our knowledge and approval. Hunkemöller is not able, nor responsible for the processing of or removing content that has been obtained or shared by such third parties. You can contact these third parties directly to request them to remove your content.
4. HOW DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE THE EEA?
The processing of your personal data may entail the transfer of your personal data within the Hunkemöller group, or a third-party service provider located outside of the European Economic Area (EEA). Where applicable, we have taken appropriate safeguards to transfer your personal data to a country located outside the EEA, if that country does not provide an adequate level of protection according to the applicable data protection laws, including by concluding standard contractual clauses approved by the European Commission to protect your personal data.
5. HOW DO WE PROTECT YOUR PERSONAL DATA?
We make every effort to ensure that your personal data is kept secure. To prevent loss or unauthorized access, disclosure or alteration, we have taken appropriate physical, technical and organizational measures to protect the personal data we collect and process. All our employees and third-party service providers acting as our data processor (i.e., those who process your personal data on our behalf) who have access to and are involved in the processing of personal data are obliged to respect the confidentiality of your personal data.
6. WHAT ARE YOUR PRIVACY RIGHTS AS A DATA SUBJECT?
If you have any customer service related questions or requests, for example in relation to your order on our webshop, please contact our customer service using the contact details available here.
As a data subject, you have the following rights with regard to our processing of your personal data:
- Right of access: You have the right to request confirmation if we process personal data about you, and if this is the case, we provide you with a copy of that personal data.
- Right to correct your personal data: You have the right to request to correct your personal data if you believe that we have inaccurate or incomplete personal data about you. You can also update your personal data via your My Hunkemöller account or via our app.
- Right to erase your personal data: You have the right to request deletion of your personal data in certain cases such as when you object to the processing, or you contest the accuracy of that personal data.
- Right to restrict our processing of your personal data: You have the right to restrict our use of your personal data in certain circumstances such as when you object to the processing, or you contest the accuracy of that personal data. It does not prevent us from storing your personal data.
- Right to data portability: You have the right, in certain circumstances, to obtain personal data that you have provided to us (in a structured, commonly used and machine-readable format) and reuse it elsewhere or to ask us to transfer this to a third party of your choice where this is technically feasible.
- Right to object: You have the right to ask us to stop processing your personal data, and we will do so, except if we can demonstrate compelling legal grounds for the processing or when necessary for the exercise of legal claims.
- Right to withdraw consent: You have the right to withdraw your consent at any time if we rely on your consent as our legal basis for processing your personal data. This will not affect the lawfulness of our use of your personal data prior to your withdrawal.
- Right to lodge a complaint with the supervisory authority: You have the right to lodge a complaint with your local supervisory authority, if you are concerned about how we have processed your personal data.
You may send us your privacy request(s) using the Privacy Request Form. We will handle your questions and requests carefully and in accordance with the applicable data protection rules. If you request information about your account or request to be deleted, we will store these requests to ensure that they are followed up in a timely manner. This information will be deleted 6 months after completing the request.
7. OUR CONTACT DETAILS?
Please contact our head office:
Hunkemöller B.V.
Koos Postemalaan 8
1217 ZC Hilversum
P.O. Box 386, 1200 AJ Hilversum, The Netherlands
If you have any questions about this privacy statement, or if you believe that your data subject right has not been handled properly, please send an email to DPO@hunkemoller.com