Privacy Policy

Last updated: May 31, 2022

This Privacy Policy describes how We collect, use and disclose Your information when You use the Webshop and tells You about Your privacy rights and how the law protects You.

Please read this Privacy Policy carefully. If You have any questions, please feel free to contact Us.

1. Scope

The scope of this Privacy Policy is limited to processing activities to which the General Data Protection Regulation (“GDPR”) and its national implementation acts apply.

Our Webshop may contain links to websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the privacy policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

2. Definitions

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

For the purposes of this Privacy Policy, the below definitions apply:

Account	A unique account created for You to access our Webshop or parts of our Webshop.
Affiliate	An entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
Application	The software program provided by the Company downloaded by You on any electronic device, named Veloretti
Company	Veloretti BV, Moermanskkade 401, 1013 BC, Amsterdam, also referred to as either "the Company", "We", "Us" or "Our" in this Privacy Policy. For the purpose of the GDPR, the Company is the Data Controller
Country	The Netherlands.
Data Controller	The legal person who alone or jointly with others determines the purposes and means of the processing of Personal Data. The Company is a Data Controller.
Data Processor	Any natural or legal person who processes the Personal Data on behalf of the Company.
Device	Any device that can access the Webshop such as a computer, a cell phone or a digital tablet.
Facebook Fan Pag	A public profile named Veloretti specifically created by the Company on the Facebook social network, accessible from https://www.facebook.com/Veloretti/.
GDPR	The General Data Protection Regulation, also referred to as the applicable privacy legislation.
Personal Data	Any information that relates to an identified or identifiable individual, also referred to as personal information. For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
Service Provider	any natural or legal person who processes the data on behalf of the Company. It refers to tThird-party companies or individuals employed by the Company to facilitate the Webshop, to provide the Webshop on behalf of the Company, to perform services related to the Webshop or to assist the Company in analyzing how the Webshop is used. For the purpose of the GDPR,If individual Service Providers are considered Data Processors, the Company will conclude a data processing agreement with the relevant Service Providers.
Third-party Social Media Service	Any website or any social network website through which a User can log in or create an account to use the Webshop.
Usage Data	Data collected automatically, either generated by the use of the Webshop or from the Webshop infrastructure itself (for example, the duration of a page visit).
You	The individual accessing or using the Webshop, or the company, or other legal entity on behalf of which such individual is accessing or using the Webshop, as applicable. Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Webshop.

Other terms that are defined in the applicable privacy legislation, such as data subject and processing will have the meaning in this Privacy Policy as described in the applicable privacy legislation.

3. Details of Processing

It depends on the processing activity, which Personal Data We process about You, for which purposes We do that and based on which legal ground. Please find an overview below.

Activity	Categories of Personal Data processed	Legal ground(s) for processing and purposes for processing
To provide and maintain our Webshop, including to monitor the usage of our Webshop.To provide and maintain our Webshop, including to monitor the usage of our Webshop.	◾️ IP address ◾️ Browser type and version ◾️ Browsing history ◾️ Cookie preferences ◾️ Movements on our Application(s) or websites of third parties gathered through tracking cookies ◾️ The type of mobile device You use ◾️ Your mobile device unique ID ◾️ Your mobile operating system ◾️ Location data Jointly referred to as “cookie information” or “usage data”. For detailed information about Our use of cookies, We refer to Our Cookie Policy.	We collect these Personal Data on the basis of Your consent or, in case We are not legally required to obtain consent, on the basis of Our legitimate interests, namely improving Our Webshop. We process Your Personal Data for purposes of (i) improving Our Webshop, (ii) being able to show You the products and services that fit Your preferences, (iii) being able to provide You with a consistent Webshop across all your devices, (iv) enhancing Our security and protecting your information and (v) enhancing Your (shopping) experiences
To manage Your Account and to manage Your registration as a user of the Webshop. The Personal Data You provide can give You access to different functionalities of the Webshop that are available to You as a registered user.	◾️ Email address First name and last name Bank account information in order to pay for products and/or services within the WebshopUsage Data Jointly referred to as “account data”.	We collect these Personal Data on the basis of Our legitimate interests, namely providing Our Webshop to You as a registered user. We process Your Personal Data for purposes of (i) registering You as a user, (ii) enabling You to store Your information in our Webshop and (iii) improving Our Webshop.
For the performance of a contract, the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Webshop.	◾️ Your account data ◾️ Date of birth ◾️ Passport or National ID card ◾️ Bank card statement ◾️ Other information linking You to an address to which Your order is delivered	We collect these Personal Data as this is necessary for the performance of a contract We have concluded with You, namely the purchase agreement that applies to Your order(s).
To contact You, via email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation, To manage Your requests to Us.	◾️ Your name, e-mail address and telephone number ◾️ Content of Your message, for instance a complaint or pictures of a damaged product ◾️ Details with regard to the follow-up	We collect these Personal Data as this is necessary for the performance of a contract or on the basis of Our legitimate interests, namely verifying Your identity for reasons of security, improving Our services and providing customer service. We process Your Personal Data for the purposes of (i) following up on Your questions, complaints and claims, (ii) providing information with regard to products or services that are relevant to You, (iii) verifying Your identity to make sure You are who You say You are, and (iv) enhancing Our security and protecting Your information. (v)Being able to ship the order and order confirmation to you.
To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information,	◾️ Your name and email address ◾️ Preferences for receiving information, such as frequency and categories of information	We collect these Personal Data on the basis of Your consent or, in case We are not legally required to obtain consent, on the basis of Our legitimate interests, namely Our commercial activities and informing You of products or services that You might like.
To deliver targeted advertising to You, to develop and display content and advertising (and work with third-party vendors who do so) tailored to Your interests and/or location and to measure its effectiveness.		Consent: We send You Our newsletters and marketing e-mails (other than for marketing regarding similar products or services), always on the basis of Your prior consent. You always have the option to unsubscribe from Our mailings, e.g. via the unsubscribe link in Our newsletter and marketing e-mails. Legitimate interest: We send offers about similar products or services that You have previously ordered with Us on the basis of Our legitimate interest. You always have the option to unsubscribe from Our mailings, e.g. via the unsubscribe link in Our marketing e-mails. We process Your Personal Data for the purposes of (i) providing information with regard to products or services that You might like, and (ii) providing offers.
For business transfers, to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Webshop users is among the assets transferred.	All the information as referred to above.	We collect these Personal Data on the basis of Our legitimate interests, namely providing Our Webshop to You as a registered user. We process Your Personal Data for purposes of (i) exploring the options to carry out a reorganization or a restructure or the like.
For other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Webshop, products, services, marketing and your experience.	◾️ Any information We possibly have of You that is necessary for the relevant purpose of processing.	We collect this Personal Data as this might be necessary for compliance with a legal obligation that is applicable to Us as a data controller or for purposes of Our legitimate interests, namely carrying out Our regular business activities and protecting Our interests in case of conflicts. We may process Your Personal Data for purposes of (i) following requests of public authorities, (ii) conducting criminal investigations, prosecutions, trails and the execution of judgments, (iii) protecting rights of third parties, (iv) conducting statistical or academic researches, or (v) other circumstances as stipulated by relevant laws and regulations.

4. Sharing with Third Parties

We may share Your personal information in the following situations:

With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Webshop, to show advertisements to You to help support and maintain Our Webshop, to advertise on third party websites to You after You visited our Webshop, for payment processing, to contact You. For instance payment providers such as Mollie and PayPal and marketing companies or services such as Google, Facebook and Klaviyo. Other categories of Service Providers we engage are hosting providers, cloud providers and IT service providers.
For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
With Your consent: We may disclose Your personal information for any other purpose with Your consent.

We do not involve parties that are located outside the European Economic Area (“EEA”) for the processing of Your Personal Data. If this will be the case in the future, We will duly inform You of that matter and the procedure as explained below will apply.

Transfers of Your Personal Data to a country outside the EEA may in the first place be legitimized on the basis of a so-called adequacy decision. This is a decision in which the European Commission states that e.g. a certain country offers a level of data protection similar to the GDPR. See this link for the current list of adequacy decisions. If and insofar as We transfer Personal Data with parties in countries outside the EEA to which no adequacy decision applies, We will agree with these parties to data protection provisions set by the European Commission, so called standard contractual clauses. A copy of the agreed standard contractual clauses can be requested by You.

5. Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Webshop
Protect the personal safety of Users of the Webshop or the public
Protect against legal liability

6. Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with Our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies. Please see an overview below.

Activity	Retention term
To provide and maintain our Webshop
To manage Your Account
To let you sign in through social media
For the performance of a contract
To contact You
To manage Your requests
To provide You
To deliver targeted advertising to You
For business transfers
For other purposes

7. Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Examples of technical security measures taken by us are:

logical and physical security (e.g. safe, doorman, firewall, network segmentation);
technical control of the authorizations (as limited as possible) and keeping log files;
management of the technical vulnerabilities (patch management);
keeping software up-to-date (e.g. browsers, virus scanners and operating systems);
making back-ups to safeguard availability and accessibility of the Personal Data;
automatic erasure of outdated Personal Data;
encryption of Personal Data;
applying hashing or (other) pseudonymization methods to Personal Data; and
provide secure storage facilities for end-users (e.g. file server storage).

Examples of organizational security measures taken by us are:

assign responsibilities for information security;
promote privacy and security awareness among new and existing employees;
establish procedures to test, assess and evaluate security measures periodically;
check logfiles regularly;
using a protocol for handling data breaches and other security incidents;
conclude confidentiality, data processing and data protection agreements;
assess whether the same objectives can be achieved with less Personal Data;
provide access to Personal Data to as few people within the organization as possible; and
define the decision-making and underlying considerations per processing.

8. Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If You are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to Our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Webshop.
Automated decision-making. You have the right not to be subject to a decision based solely on automated processing, which significantly impacts You (“which produces legal effects concerning You or similarly significantly affects You”). In this respect, please be informed that when processing Your personal data, We do not make use of automated decision-making.

9. Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that We may ask You to verify Your identity before responding to such requests. We will provide You with information about the follow-up to the request without undue delay and in principle within one month of receipt of the request. Depending on the complexity of the request and on the number of requests, this period can be extended by another two months.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. Our lead Data Protection Authority is the Dutch Autoriteit Persoonsgegevens.

10. Data Controller for the Facebook Fan Page

The Company is the Data Controller of Your Personal Data collected while using the Webshop. As operator of the Facebook Fan Page https://www.facebook.com/Veloretti/, the Company and the operator of the social network Facebook are Joint Controllers.

The Company has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms of Service: https://www.facebook.com/terms.php

Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more information about how Facebook manages Personal data or contact Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.

11. Children's Privacy

Our Webshop does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 16 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

12. Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Webshop, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

13. Contact Us

If you have any questions about this Privacy Policy, You can contact us:

By email: privacy@veloretti.com

By visiting this page on our website: www.veloretti.com

14. Cookie Policy

Read here