Article 1.                Definitions

 1.1.            In this privacy policy, the following terms are defined as stated below:

a.        Internet Politie: the user of this privacy policy: the private limited company Internet Politie B.V., with its registered office at Jagerserf 7 (3851 SM) in Ermelo, registered with the Chamber of Commerce under Chamber of Commerce number 82700133;

b.        data subject: the natural person who (on behalf of a company) has entered into an agreement with Internet Politie, or the natural person who has contacted Internet Politie (on behalf of a company) in connection with the conclusion and/or performance of the agreement or the natural person who (on behalf of a company) visits the website;

c.        agreement: the agreement between Internet Politie and the data subject, under which the data subject makes use of the service offered by Internet Politie;

d.        website: the websites www.internetpolitie.nl and www.internetpolice.com, as administered by Internet Politie;

e.        profiling: the processing of personal data during which certain personal aspects of the data subject are evaluated on the basis of said data with the aim of analysing or predicting his personal preferences, interests, online search behaviour, location;

f.         personal data: data that can be used to identify a natural person.

 

Article 2.                Personal data

 2.1.            Internet Politie considers due care in handling personal details of paramount importance. With regard to the processing of personal data, Internet Politie acts in accordance with the applicable laws and regulations.

 2.2.            Internet Politie handles personal data with care and treats it in confidence.

 2.3.            Internet Politie collects personal data from the data subject when the data subject has provided this personal data to Internet Politie (via the website) or when the data subject visits the website or has contacted Internet Politie by telephone or e-mail.

 2.4.            Internet Politie collects and processes the following personal data:

a.        first name and surname;

b.        address;

c.        postcode and locality;

d.        bank account number;

e.        telephone number;

f.         e-mail address;

g.        IP address;

h.        surfing behaviour;

i.          location details.

 2.5.            Internet Politie does not process special personal data of data subjects.

 2.6.            Internet Politie does not intend to collect data about data subjects under the age of 16, unless they have permission from a parent or legal representative. However, Internet Politie cannot check whether a data subject is 16 or older. Internet Politie therefore advises parents and legal representatives to be involved in the online activities of their children, to prevent data about children from being collected without parental consent. If a parent or legal representative is convinced that Internet Politie has collected personal information about a minor without such permission, the parent or legal representative should contact Internet Politie using the contact details provided in Article 12.1, after which Internet Politie will terminate the processing and delete the personal data.

 

Article 3.                Principle and purposes of data processing

 3.1.            The principle of processing personal data is the performance of the agreement or, at the request of the data subject, the taking of pre-contractual measures. In the case of profiling, this concerns the consent of the data subject.

 3.2.            Internet Politie collects and processes the personal data for the following purposes:

a.        dealing with questions and/or comments from the data subject;

b.        issuing a quotation and/or offer to the data subject;

c.        concluding the agreement;

d.        being able to contact the data subject regarding the performance of the agreement;

e.        informing the data subject about changes to the products and services of Internet Politie;

f.         maintaining a customer relationship with the data subject;

g.        building and maintaining a customer base;

h.        sending an invoice;

i.          fulfilling administrative duties;

j.          offering the data subject personalised advertisements and content (profiling), see also Article 4;

k.        sending the data subject newsletters, if he subscribed to this, see also Article 5;

l.          improving the website and the services of Internet Politie;

m.      generating general statistics about the use of the website.

 3.3.            The data subject providing his name, residential address, telephone number, e-mail address and age is a contractual obligation. No agreement can be concluded without name, country of origin and e-mail address.

 3.4.            Internet Politie will not retain the personal data for longer than is strictly necessary for the purposes for which the personal data is collected, as set out in Article 3.2.

 3.5.            Internet Politie only processes the minimum personal data required for the existing purposes. Internet Politie aims to process as little personal data as possible.

 3.6.            Internet Politie will not process personal data for purposes other than described above.

 

Article 4.                Profiling

 4.1.            Profiling is only performed if the data subject has given Internet Politie permission to do so. This consent can be withdrawn by the data subject at any time.

 4.2.            The object of profiling is:

a.        to show the data subject advertisements or other content on the website of which Internet Politie believes that the content of the advertisement or content is in accordance with the interests of the data subject;

b.        marketing analyses;

c.        sending personalised newsletters.

 4.3.            Profiling can be achieved through a combination of data provided by the data subject when creating the account and data originating from various cookies.

 4.4.            The following data may be processed by Internet Politie for profiling purposes:

a.        gender;

b.        age;

c.        location details;

d.        search arguments entered on the website;

e.        surfing behaviour.

 

Article 5.                Newsletters

 5.1.            Newsletters will only be sent to the data subject if the data subject has given explicit unambiguous consent to Internet Politie to do so. The data subject can unsubscribe from newsletters at any time, see Article 6.

 5.2.            Internet Politie will not approach the data subject for direct marketing purposes if the data subject has not given permission to do so.

 

Article 6.                Unsubscribing from newsletters

 6.1.            The data subject can unsubscribe from newsletters in the following ways:

a.        by clicking on the link in the e-mail containing the newsletter, which link allows the data subject to unsubscribe from such newsletters;

b.        By contacting Internet Politie, see Article 12.1 for contact details.

 6.2.            Every newsletter that is sent to the data subject contains a link to unsubscribe from the newsletters.

 

Article 7.                Deletion of personal data

 7.1.            Internet Politie will delete personal data from its systems without unreasonable delay if, for instance:

a.        the personal data is no longer required for the purposes for which it was processed;

b.        the data subject objects to his personal data being processed and this objection is justified;

c.        the personal data is incorrect or superseded.

 7.2.            Internet Politie is not obliged to delete personal data if it concerns one of the situations described in the law in which the “right to be forgotten” does not apply.

 

Article 8.                Disclosure of personal data to third parties

 8.1.            Internet Politie will not disclose the personal data of the data subject to third parties, unless:

a.        Internet Politie has received explicit prior consent of the data subject to do so;

b.        one of the statutory principles applies under which the disclosure of personal data to third parties is permitted;

c.        required for the performance of the agreement;

d.        forwarding is effected to a processor engaged by Internet Politie for the purposes listed in this privacy policy, with whom Internet Politie has entered into an agreement which ensures that the processor provides sufficient guarantees with regard to the technical and organisational security measures in respect of the processing to be performed.

 8.2.            The data subject can withdraw his consent for his personal data to be disclosed to third parties at any time.

 

Article 9.                Right of inspection, right to data portability, rectification and deletion

 9.1.            On request, Internet Politie will grant the data subject access to all his personal data held on record by Internet Politie and Internet Politie will give the data subject a copy of this data in an adequate format, free of charge, so that the data subject himself can provide the personal data to a third party.

 9.2.            Internet Politie offers the data subject the opportunity to rectify or delete any of his data held on record by Internet Politie that appears to be incorrect.

 9.3.            The request to access, change or delete data can be submitted to Internet Politie in writing or by e-mail. See Article 12.1 for the contact details of Internet Politie. Internet Politie will respond to such a request as soon as possible and in any case within 4 weeks.

 

Article 10.             Objection

10.1.            The data subject can object to Internet Politie about the processing of his personal data if he has a good reason to do so given his specific situation. After Internet Politie has received the objection from the data subject, Internet Politie will stop processing the data subject’s personal data, unless Internet Politie has justified interests that outweigh those of the data subject when it comes to processing personal data.

 

Article 11.             Right to restriction

11.1.            If the data subject has submitted a request for the adjustment, supplementation or deletion of his personal data or if he has submitted an objection against the processing of his personal data and the handling, processing and completion of this request or objection take some time, the data subject may ask Internet Politie to restrict the processing of his personal data.

 

Article 12.             Contact

12.1.            If the data subject has any questions about the way in which Internet Politie processes personal data, about withdrawing his consent in connection with the processing of personal data, inspection of the data subject’s personal data processed by Internet Politie, a request for a copy of his personal data, a request to change or delete his personal data, the request to restrict the processing of his personal data or submitting an objection to the processing of his personal data, he can contact Internet Politie on the details given below.

 

Contact details:

Internet Politie B.V.

address:                     Jagerserf 7

postcode/locality:        3851 SM Ermelo

e-mail address:           [email protected]

telephone number:      085 40 14 383

 

12.2.            If at the request of the data subject, Internet Politie corrects, supplements or deletes personal data of the data subject or ends or restricts the processing of personal data or has processed the withdrawal of consent, Internet Politie will notify the data subject accordingly.

 

Article 13.             Security measures

13.1.            In order to prevent unauthorised access to personal data, loss, theft and unlawful use of personal data, Internet Politie has taken various security measures, including measures against unauthorised access, use, changes, unlawful and unintended destruction and unintended loss of personal data.

13.2.            Internet Politie takes the following security measures:

a.        the use of systems with strong passwords to prevent unauthorised access to information systems;

b.        the use of secure network connections;

c.        data provided to Internet Politie is stored in a secure cloud environment;

d.        this environment is located in a data centre within the EU and complies with ISO security requirements (ISO 27017, ISO 27701, ISO 27018)

e.        encrypted storage of data in the database;

f.         periodic checks of the security measures taken;

g.        timely software updates and backups;

h.        e-mail messages and/or other documents that contain personal data of the data subject are, as a rule, not printed. If something is printed nonetheless, the document will be kept in a locked cabinet or the document will be destroyed immediately after use;

i.          physical protection of its IT facilities and equipment against unauthorised access and damage and malfunction.

 

Article 14.             Third-party privacy policy

14.1.            This privacy policy does not apply to third-party websites or applications, such as social media websites, linking to this website. Internet Politie does not accept any responsibility or liability with regard to the way in which these websites handle personal data. For more information about the way in which these third parties handle personal data, etc., reference is made to the privacy policy of the relevant website or application.

 

Article 15.             Changes

15.1.            Internet Politie reserves the right to unilaterally make changes to this privacy policy. The latest version of Internet Politie’s privacy policy can be found on its website.

 

Article 16.             Data breach

16.1.            If a security incident has occurred at Internet Politie in the course of which personal data of a sensitive nature has been leaked or which for any other reason has a serious adverse effect on the protection of the personal data that has been processed, Internet Politie will, if possible, report it to the Dutch Data Protection Authority within 72 hours of detecting the data breach and act in accordance with the Policy Rules on the obligation to report data breaches of the Dutch Data Protection Authority.

16.2.            In the event of a data breach at Internet Politie resulting in an adverse effect on the privacy of the data subject, Internet Politie will immediately notify the data subject thereof.

 

Article 17.             Cookies

17.1.            Internet Politie uses functional, analytical and tracking cookies.

17.2.            A cookie is a small text file that is stored in the browser of the device of the data subject when he first visits the website.

17.3.            Internet Politie only places tracking cookies if the data subject concerned has given permission for tracking cookies to be placed, prior to visiting the website. Before the data subject has given permission for tracking cookies, only functional and analytical cookies will be placed that have no consequences for the privacy of the data subject.

17.4.            The data subject can opt out of cookies by setting his Internet browser in such a way that it no longer stores cookies. In addition, the data subject can also delete all previously saved information through his browser settings. More information about enabling, disabling and deleting cookies can be found in the instructions and/or the Help feature of the browser of the data subject. Functional cookies are necessary for the correct functioning of a website. When the data subject deletes functional cookies, it may affect the correct functioning of the website, as a result of which Internet Politie may not be able to provide its service or not properly.

17.5.            Types of cookies and purposes:

 

The party placing the cookie	The type of cookie	The purpose for which the cookie is placed
Internet Politie	Functional cookie	Functional cookies ensure that the website functions properly. These cookies are used, for example, so that the data subject can log in to the website. Functional cookies help the website to recognise the data subject when he returns to visit the website. This is convenient as it means the data subject does not have to log into the website every time he visits.
Internet Politie for the use of Google Analytics	Analytical cookie	By using analytical cookies, Internet Politie can see how the website is used by the data subject and Internet Politie can improve the website on the basis of that information. Analytical cookies are not shared with or used by third parties, nor are they linked to the name or the e-mail address of the data subject. Internet Politie has set Google Analytics in such a way that visitors of the website remain anonymous.
Internet Politie	Tracking cookie	Conducting marketing analyses and personalised marketing.

 

17.6.            Internet Politie can adjust its policy with regard to cookies from time to time, for example due to a change in legislation. Changes or additions to the policy of Internet Politie with regard to cookies will be published here. Internet Politie advises the visitor to regularly check this policy.

 

Article 18.             Submitting a complaint

18.1.            If the data subject is of the opinion that the processing of personal data by Internet Politie is not in line with this privacy policy and/or the applicable legislation, the data subject can submit a complaint to the Dutch Data Protection Authority.