1. Introduction
This privacy notice provides you with details of how we collect and process your personal data through your use of our site cyclinghollandandbeyond.com and its subdomains. We also explain the legal grounds on which we process your personal data.
By providing us with your data, you warrant to us that you are over 16 years of age.
Cycling Holland and Beyond is represented by Social Now Consulting and referred to as “we”, “us” or “our” in this privacy policy.
If you have any questions about this privacy policy, please contact Social Now Consulting by using the details set out below.
Based on the constant goal of service improvement, we reserve the right to modify, without prior announcement, the Privacy Policy.
2. What data do we collect about you, for what reason, and on what legal ground we process it
Personal data means any information capable of identifying an individual.
We commit to only collect personal data that is necessary for optimal delivery of the service and retaining this data for the minimum period needed (as per Section 8 below).
We may process the following categories of personal data about you:
- Communication Data
Communication Data includes any communication that you send to us whether that be through the contact forms on our website, through email, text, social media messaging, social media posting, blog comments, or any other communication that you send us. We process this data for the purposes of communicating with you, for record-keeping, and for the establishment, pursuance, or defence of legal claims. Our lawful ground for this processing is our legitimate interests (Article 6, (1) f), GDPR) which in this case are to reply to communications sent to us, to improve our service, to guarantee good customer service, to keep records, and to establish, pursue, or defend legal claims. - User Data
User Data includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases, and to enable publication and administration of our website, other online services, and business.
Our lawful ground for this processing is our legitimate interests (Article 6, (1) f), GDPR) which in this case are to enable us to properly administer our website and our business and to meet todays’ standards regarding user experience. - Technical Data
Technical Data that includes IP address. We process this data to administer and protect our business and website and to understand how frequently our service is being used. Our lawful ground for this processing is our legitimate interests (Article 6, (1) f), GDPR) which in this case are to enable us to properly administer and improve our website and marketing strategy. - Marketing Data
Marketing Data that includes data about your communication preferences and email behavior tracking (Mailchimp Privacy Policy). We process this data to enable you to partake in our occasional promotions such as competitions, prize draws or free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising and email communication. Our lawful ground for this processing is either consent (Article 6, (1) a) GDPR) or our legitimate interests (Article 6, (1) f) GDPR) which in this case are to study how customers use our product and service, to develop and improve them, to grow our business and to decide our marketing strategy. - We may use User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interest which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent (Article 6, (1) a) GDPR), performance of a contract (Article 6, (1) b) GDPR) or legitimate interests (Article 6, (1) f) GDPR) (namely to grow our business and to monetize our website to be able to continue delivering the information service).
We will only use your personal data for the purpose it was collected for or a reasonably compatible purpose if necessary. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We do not carry out automated decision making or any type of automated profiling that may result in any legal or other significant effects for you (as defined in Article 22, 1, GDPR).
Sensitive Data
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offenses.
3. How we collect your personal data
We may collect data about you by you providing the data directly to us (for example by commenting on a post or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our Cookie Policy for more details about this.
We only place cookies after your explicit consent.
We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as FacebookTM based outside the EU, Social Networks such as FacebookTM, Instagram, Pinterest or Twitter, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators. This data may also include anonymised demographic, interest, or behaviour data that is made available to us for marketing purposes.
4. Marketing Communications
Our lawful ground of processing your personal data to send you marketing communications is either your consent (Article 6, (1) a) GDPR) or our legitimate interests (Article 6, (1) f) GDPR) (namely to grow our business).
We may send you marketing communications if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted-out of receiving such communications since. If you are a limited company, we may send you marketing emails without your consent. However, you can still opt-out of receiving marketing emails from us at any time.
You can change the status of your consent to marketing emails by following the opt-out links on any marketing message sent to you OR by emailing us at cyclinghollandandbeyond@gmail.com at any time.
Please note, if you opt-out of receiving marketing communications this opt-out does not result in the deletion of personal data provided as a result of other transactions, such as commenting, etc..
5. Disclosure of your Personal Data
We may have to share your personal data with the parties set out below:
- Service providers who provide IT and system administration services.
- Service providers, as payment providers and email marketing service provider.
- Professional advisers including lawyers, bankers, auditors and insurers.
- Government bodies that require us to report processing activities.
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law.
6. International Transfers
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:
- We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- If we use US-based providers that are part of EU-U.S. Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
7. Data Security
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
8. Data Retention
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they stop being customers.
In some circumstances, we may anonymize your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your Legal Rights
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ [please note, that we explicitly added the information of the UK national data protection authority, as our working language is English, note, that we are based in the Netherlands]
If you wish to exercise any of the rights set out above, please email us at cyclinghollandandbeyond@gmail.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within four weeks, which is the legally allowed timeframe. Occasionally it may take us longer than four weeks if your request is particularly complex or you have made a number of requests. In this case, an extension up to three month is allowed by law. If we need to extend beyond the four weeks, we will notify you.
If you are not happy with any aspect of how we collect and use your data, based on our feedback to your request, you have the right to complain to the Dutch Autoriteit Persoonsgegevens, which is the Dutch Supervisory Authority (Dutch DPA) for the Data Protection Regulation (https://autoriteitpersoonsgegevens.nl).
10. Third-Parties we use that may collect and process personal details and on what legal ground we use these services
To guarantee the best user experience, make our site functioning, enhance our services, monetize our website, and grow our business, we make use of third-party links and services on the lawful ground of legitimate interests (Article 6, (1) f) GDPR).
Third parties may collect or process data about you when clicking on those links or enabling those connections. Where possible, we chose for anonymised data collection. But we do not control these third-party websites and are not responsible for their privacy statements. We therefore recommend to read the Privacy Policies of the respective websites and/or use the Cookie settings in our Cookie Policy to adjust your preference.
- User Data
Third-Party Links and Social Networks
We use social share options and social network links to enhance the user experience. For social share we use a safeguarded process to ensure no data is delivered to the respective social networks before clicking on a share button. Upon the affirmative action of sharing or liking, the social networks, like Twitter or FacebookTM may receive and use your personal data in accordance to their privacy policy. Clicking on social profile links of other users or mundolore social links, enables social networks to gather personal data who may use it in accordance with their data privacy policy.
By visiting, following, liking, or any other interaction with our social profiles on the respective networks, these networks will collect and process data about you according to their privacy policies. Without requesting it, anonymised analytical data of visitors interacting with our profiles and content is made available to us, e.g. age groups, groups of interests, etc., to analyse the performance of our content and to use for our marketing strategy.
Google Web Fonts
Google Web Fonts are used to optimise the user experience of our service by displaying coherent and user friendly reading/design experience. Requests are made to font-specific domains only, meaning displaying Google Web Fonts is separate from and do not contain any credentials you send to to Google while using other services, such as Gmail. A CSS cache cookie is set for 1 day. Google Privacy Policy - Technical Data
Google Analytics
We use Google Analytics to track our website performance and to improve our services with the use of anonymised IP addresses and cookie placement. We receive generic technical data that includes details about browsers used, length of page visits on our website, page views, referral pages, navigation path, or approximate geolocation. We use this data to deliver relevant website content to you and to understand the effectiveness of our content, design and advertising. Our lawful ground for this processing is our legitimate interests (Article 6, (1) f), GDPR) which in this case are to enable us to improve our website, service and to grow our business. To improve privacy protection we took the following measures: beside marking the IP address, we do not allow Google to pass your data to another service within Google and we do not use Google Analytics for remarking purposes. All tracking data will be deleted after 14 months. If you want to opt-out of the anonymised tracking use the link given in our Cookie Policy.
Hotjar
We use Hotjar to see how people navigate through our website to improve our service according to the needs of our users. We receive information about the pages you visited, session duration, the operating system you use (e.g. Windows), which browser you used (e.g. Chrome), the device you used (Desktop, tablet or mobile), the country you were located in when visiting our website, and an User ID which we cannot correlate to any IP address or other personal identifiable information, and thus is classified as anonymised data. We use this data to deliver relevant website content to you and to understand the effectiveness of our content, design and advertising. Our lawful ground for this processing is our legitimate interests (Article 6, (1) f), GDPR) which in this case are to enable us to improve our website, service and to grow our business. Hotjar may receive and use your personal data in accordance with their Privacy Policy. If you want to opt-out of the tracking use the link given in our Cookie Policy. - Marketing Data
Facebook Pixel
The Facebook Pixel is a tracking code to measure the effectiveness of our Facebook Advertisements and decide on marketing strategies on the lawful ground of legitimate interests, namely to grow our business. It also allows us to perform retargeting based on interest, demographics and website behaviour to grow our business. All data is collected by FacebookTM and processed according to their Privacy Policy. We do not control any of this data. To change the settings regarding advertisement, see our Cookie Policy. Performing specific retargeting (=Custom Audience based on Lists) for which an uploading of email addresses by us is necessary, and therefore personal data is being processed, is done on affirmative consent only, as specified under point 2 above.
We only use third party links and tools that are either located within the EU and claim to be GDPR compliant or located in the US operating under the EU-U.S. Privacy Shield.
11. Cookies
We do not place Cookies (with the exclusion of Strictly Necessary Cookies) without your explicit consent.
For more information about the cookies we use, please see our Cookie Policy.
Last updated: 31 January 2022