AED360 B.V., Vlierberg 4-5b, 3755 BS EEMNES, the Netherlands or its affiliates or subsidiaries (”AED360”, “our”, “we” or “us”) wants you to be familiar with how we collect, use and disclose Personal Data. This Privacy Notice is meant to help you understand our privacy practices, including what Personal Data we collect, why we collect it, what we do with it, and how we protect it, as well as your individual rights.
AED360 appreciates the interest you have shown in our company, products and services by visiting our websites (www.AED360.com) or related communication channels, including, but not limited to, our social media pages and/or channels and blogs (together “AED360 Pages”). This Privacy Notice applies to the Personal Data that we collect or process when you interact with AED360 Pages. You can interact with AED360 through AED360 Pages, through the purchase and use of our products/services, through marketing communications, as well as through our customer support. These interactions can be made by visitors, customers, business customers, suppliers and/or business partners.
AED360 also processes Personal Data beyond our AED360 Pages, which will require a different privacy notice (e.g. AED360 Apps, or AED360 research projects, or other specific Websites or Portals). Whenever and wherever that is the case, AED360 will make it clear that the privacy notice concerned is different from this privacy notice.
Last but not least, your privacy is of sincere importance to us. You have shown your trust in us by interacting with our AED360 Pages and we value that trust. This means that we are committed to protecting your privacy at all times.
What we collect
When using the term “Personal Data” in our Privacy Notice, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold.
Online Feedback Data
You can choose to give your feedback, comments, questions, ratings and reviews in online evaluations (Online Feedback).
Where you make use of this opportunity, we will process the following Personal Data:
- Your cookie ID;
- Your feedback/comments/questions/your rating review;
- Your contact details in case you provide them to us (name, email, telephone number).
We use this Personal Data to provide AED360 with valuable insights to improve our AED360 Pages or products/services range.
We consider the processing of your Online Feedback Data to be based on legitimate interest of AED360 to improve our AED360 pages and our range of products and services and to be lawful under article 6(f) Regulation (EC) 5419/16.
Social listening Data
When you interact or communicate on social media channels/pages/promotions and blogs (e.g. when you click on ‘like’ or ‘share’, when you post and share comments and when you submit ratings and reviews) your Personal Data is processed by a third party that provides social listening services to AED360. This means that the third party that provides social listening services will retain a copy of your online publicly available interactions to which the third party has provided us access.
The Personal Data we collect includes publically available data provided in the social media context by you from the relevant social media provider via a third party that provides social listening services such as: name, gender, birthday or age, homepage, profile photo, time zone, mail address, country, interests, and comments and content you have posted/shared.
We use this Personal Data to gain a general view of the opinion of people about us and our brands and to get an idea of relevant online influencers and to resolve issues and/or improve AED360 products and services and/or start a promotional conversation with you (based on questions/requests that you addressed to us or our competitors).
We consider the processing of Social Listening Data in the above context to be based on a legitimate interest of AED360 to be lawful under article 6(f) Regulation (EC) 5419/16
In the course of providing services to you, we may collect information that could reveal your racial or ethnic origin, physical or mental health, religious beliefs or alleged commission or conviction of criminal offences. Such information is considered “sensitive personal data” under article 9 Regulation (EC) 5419/16.
We only collect Sensitive Data where you have given your explicit consent, it is necessary, or you have deliberately made it public.
Sharing Personal Data
Affiliates and service providers
We may disclose your Personal Data:
- To our affiliates or subsidiaries for the purposes described in this Privacy Notice;
- To our third party service providers who provide services such as website hosting, data analysis, payment/billing processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, CRM, identity management, event management, marketing intelligence, auditing, fraud detection and other services;
- To third parties, to permit them to send you marketing communications, consistent with your choices if you have opted into such sharing;
- To third-party sponsors of sweepstakes, contests and similar promotions;
- When you interact with AED360 as a business customer, supplier or business partner, AED360 may disclose Personal Data available in reports and other materials provided by you and/or your company pursuant to an engagement with another business partner and/or a supplier.
Other uses and disclosures
We may also use and disclose your Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable law, which may include laws outside your country of residence, to respond to requests from public and government authorities, which may include authorities outside your country of residence, to cooperate with law enforcement or for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety or property, and/or that of our affiliates or subsidiaries, you or others.
In addition, we may use, disclose or transfer your information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
This Privacy Notice does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the AED360 Pages link. The inclusion of a link on the AED360 Pages does not imply endorsement of the linked site or service by us or by our affiliates or subsidiaries.
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Data you disclose to other organizations through or in connection with the AED360 Pages. These other organizations may have their own privacy notices, statements or policies. We strongly suggest that you review them to understand how your Personal Data may be processed by those other organizations.
Third-party cookies or other tracking technologies
The data collected is used to:
- Ensure that the digital channel functions properly;
- Analyze digital channel usage so we can measure and improve performance of our digital channels;
- Connect to your social media networks and read reviews;
- Help better tailor advertising to your interests, both within and beyond AED360 digital channels;
You can delete cookies if you wish; while certain cookies are necessary for viewing and navigating on our website or app, most of the features will be still accessible without cookies.
Protecting your Personal Data
How do we secure your Personal Data?
We seek to use reasonable organizational, technical and administrative measures to protect Personal Data within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “How can you contact us?” section below.
How long will the Personal Data be kept?
We will retain your Personal Data for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you to participate in the AED360 pages; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Jurisdiction and cross-border transfer
Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the AED360 Pages you consent to the transfer of information to countries outside of your country of residence, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data.
Your rights and choices available to you
If you would like to submit a request to access, rectify, erase, restrict or object to the processing of Personal Data that you have previously provided to us, or if you would like to submit a request to receive an electronic copy of your Personal Data for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us via our contact form. We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Data you would like to have changed, whether you would like to have your Personal Data suppressed from our database, or otherwise let us know what limitations you would like to put on our use of your Personal Data. For your protection, we may only implement requests with respect to the Personal Data associated with your account, your email address or other account information, that you use to send us your request, and we may need to verify your identity before implementing your request.
You may also opt-out from receiving electronic communications from AED360. If you no longer want to receive marketing-related emails on a going-forward basis, you may opt-out by clicking the unsubscribe button at the bottom of each promotional email you receive from us.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g. when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Data provided until after the completing of such a purchase or promotion). There may also be residual information that will remain within our databases and other records, which will not be removed.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
If you make use of (some of) your choices and rights, you may not be able to use, in whole or in part, certain AED360 Services.
Special information for parents
The AED360 Pages are not directed to children, as defined under applicable law, and we do not knowingly collect Personal Data from children. It is, however, AED360 policy to comply with the law when it requires parent or guardian permission before collecting, using or disclosing Personal Data of children. We are committed to protecting the privacy needs of children and we strongly encourage parents and guardians to take an active role in their children’s online activities and interests.
If a parent or guardian becomes aware that his or her child has provided us with his or her Personal Data without their consent, please contact us via our contact form. If we become aware that a child has provided us with Personal Data, we will delete his/her data from our files.
How can you contact us?
If you have any questions about this Privacy Notice or about the way AED360 uses your Personal Data, please contact our Data Protection Officer via our contact form. Alternatively, you have the right to lodge a complaint with a supervisory authority competent for your country or region.