PRIVACY STATEMENT

GENERAL

The protection of your privacy and the security of your personal data is important to Albron. We handle your personal data responsibly and will process your personal data in accordance with the General Data Protection Regulation. We want to inform you about the way in which we treat and protect your personal data.


APPLICABILITY

This privacy statement applies to our companies in the Netherlands and Belgium and provides an overview of the collection and processing of personal data by our Dutch services, such as of (potential) visitors to (the website of) Albron and users of apps that Albron offers to businesses and consumers (hereafter: "guests").

When you visit Albron's website, order, use or purchase products or services (such as apps) from Albron, or when you come into contact with Albron, Albron collects personal data from you. Albron does this in the manner and for the purposes as described below.


WHO IS RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA?

Albron BV is responsible for the processing of personal data of its guests and employees. Albron is located at Rijnzathe 11, 3454 PV, De Meern.


WHY DO WE COLLECT YOUR DATA?

Albron collects your personal data to the extent necessary for a predetermined purpose, such as:

  • to offer you the website of Albron
  • to offer you Albron's products, apps and services
  • to facilitate your access to and stay in Albron's branch locations
  • to implement an effective safety policy in the Albron sites
  • to send you our general e-mail newsletter (if you have given permission for this) or to keep you informed about general promotions and offers from Albron
  • to inform you (if you have given permission for this) about specific products and services of Albron based on preferences known to Albron
  • to comply with legal obligations resting on Albron
  • to be able to process your requests and questions
  • to invite you to participate in research related to Albron
  • if in the future there would be a takeover of (part of) the shares or assets in (part of) Albron BV, to share the personal data with the purchasing party (after the takeover)

WHAT PERSONAL DATA DO WE COLLECT FROM YOU?

Albron can process the following personal data of our guests, service providers or clients:

  • Name, date of birth, gender, country of residence and contact details (such as address, place of residence, telephone number and e-mail address)
  • Photo, camera images and audio
  • Date and location of your visit
  • Transaction data for bank transfers, including the account number
  • Preferences and lifestyle characteristics that you make known to us, such as family composition, living situation, interests or demographic characteristics
  • Device information
  • User preferences and information about previous purchases

HOW DO WE COLLECT PERSONAL DATA FROM YOU?

You can disclose personal data to us in various ways, for example when you:

  • visit Albron's website or get in touch with Albron
  • directly or indirectly purchases products, apps or services from Albron
  • participate in promotions, promotions, or competitions held by Albron
  • visit an Albron branch location
  • register for an event
  • apply for a job or internship

WHY DO WE COLLECT PERSONAL DATA FROM YOU?

  • When you provide such information, we will only use it for the purpose for which you provided it. In addition, we may also use such information for notification purposes, to troubleshoot services provided to you, to process orders and other matters submitted by you, to verify or fulfil our obligations with regard to any arrangement you have with us. Also to be able to answer questions or comments you have made
  • When using apps, we can create marketing profiles of guests. The purpose of this is to be able to provide you with better and targeted offers, to provide better service and to optimize our business operations
  • When using apps, we may collect device information related to your interactions with us, such as geo-location, browser type and operating system, Internet Protocol (IP) address (a unique number that identifies your internet access), cookie information, pages viewed and visited (including those viewed before and after interacting with our websites), how long you visited our websites and other technology in a given session, and the date and time of access
  • When using apps, we may collect user preferences, such as food preferences, dietary restrictions and related information, purchase preferences, sizes, favourite Albron locations. In addition, we may track preferred hours, when you receive services, when you make purchases through us, when you interact with our websites and other technology. We may also collect preferences when you choose to make them known to us, for example by participating in surveys or other interactions or communications with us
  • When using apps, we may collec information about guests' past purchases and use it to improve our services, respond to guest requests, and provide a more customized guest experience. For example, we may use this information to make sure we are offering the right products at the right time, and to understand order trends, which products are the most popular, and generally how our business is doing. We also use information about past purchases to provide our guests with more tailored offers for marketing purposes. When we use this information, it is generally aggregated and pseudonymised
  • When using apps, we may process payment information, such as payment method (e.g. credit card, or iDeal) and payment information (such as account number, account holder, payment amount, time of transactions, applicable taxes, etc.) so that we can process the payments and include them in our financial administration to comply with regulations of the tax authorities. We are allowed to process this data because we need it to perform our contract with you and to comply with the rules of the tax authorities
  • Albron does not make significant decisions based on automated decision-making. This means that when we draw up a profile, the way we draw up a profile does not have any legal consequences with a significant impact on you
    Affiliate Programs: At times, Albron may partner with a third party to provide offers, promotions, or run a rewards program. These affiliate programs may be offered on our websites, apps, or at one of our physical locations. When you provide information in connection with these affiliate programs, you may be providing it directly to one or more third-party affiliates and its use is subject to that third party's privacy statement. While the way we process your personal data is governed by this privacy statement, you can refer to the privacy statement of the third party affiliates for information about how they process your data

LEGAL GROUND FOR PROCESSING PERSONAL DATA

The legal grounds for processing your personal data by Albron are:

  • the performance of an agreement
  • your consent
  • a legal obligation
  • a legitimate interest

These principles are explained below.

  • The performance of an agreement with you, such as participating in a loyalty program or using one of our apps, when we have concluded an agreement with you. We ask for your preferences and, for example, name, address, place of residence, date of birth and e-mail address
  • Your consent mainly concerns the commercial e-mail messages and mail that we send to you. You can easily withdraw this permission by clicking on the 'unsubscribe' link in the email or by contacting privacy@albron.nl
  • The legal obligation concerns exceptional cases in which we are obliged to share data to comply with laws and regulations or in the context of a court order or other writ of execution from, for example, the police or judicial authorities
  • In other cases, the legal basis for processing the personal data is the legitimate interest. For example, we use our apps to make trend analyses within different groups of people and identify needs within our target group. We use this to improve our services to you. Invoking the legitimate interest requires a balancing of interests between Albron's legitimate interest and your interests, rights and freedoms. In that context, it is relevant that we pseudonymise and aggregate where possible. In addition, Albron continuously performs quality assessments. Only a limited number of employees have access to your personal data and Albron has secured your personal data

NEWSLETTERS AND OTHER COMMERCIAL COMMUNICATIONS FROM ALBRON

Albron would like to get in touch with you about its products and services, for example by e-mail, post, telephone or other communication channels. You always have the option to unsubscribe and stop receiving further commercial communications from us by using one of the following options:

  • by clicking on the 'unsubscribe' link at the bottom of e-mails that Albron sends
  • by indicating via the contact form on the Albron website that you no longer wish to receive commercial communications from Albron
  • By sending an email to privacy@albron.nl stating ‘request to unsubscribe from newsletter’

If you unsubscribe from receiving commercial communications, we will remove you from the mailing list as soon as possible.


CAMERA SURVEILLANCE

Albron can use camera surveillance in its locations to guarantee the safety of its guests and employees and to be able to comply with its legal obligation.

These images are automatically deleted after 14 days, unless there is an incident, in which case the term is extended under strict conditions.

Only a limited number of employees have access to the images and recordings and this data is well protected.


COOKIE POLICY

When you visit the Albron website, Albron uses so-called "cookies" to facilitate your visit. Cookies are small text files that are stored on your computer's hard drive or memory. Albron uses cookies, among other things, to record the preferences you have set for a certain service or web page, so that you do not have to enter them again on a subsequent visit to our site. Albron currently uses the following cookies on its website:

  • Facebook - to show you personalized messages and ads
  • Google Ad Services and Doubleclick – to share and display relevant products on Google platforms
  • Google Analytics - to collect and display detailed statistics from our Website(s). The purpose of this service is to give us a clear overview of visitor flows, traffic sources and page views. Based on this information, we can improve our Website(s) and improve your shopping experience on our Website(s) and App(s)
  • Google tag manager to measure events on our website and add tags to our website. Each tag represents a piece of code from other programs that measure events on our website. For example, the Facebook pixel

HOW DO WE PROTECT YOUR PERSONAL DATA?

Albron has taken appropriate technical and organizational measures to protect your personal data against loss and against unlawful processing. We protect your personal data in several ways, including secure storage.

Our information security policy is based on the standards of ISO 27001 and contains provisions about the organization of the security of personal data, such as assigning responsibilities to functions, physical security, access management, authorizations of employees, maintenance and development of systems, calamities, monitoring and periodic testing of systems for security (penetration testing) by an external party.


DO WE SHARE YOUR PERSONAL DATA?

Our basic principle is that we do not share your personal data with third parties.

Sometimes it is necessary to pass on your data to third parties, for example in the context of the execution of an agreement or sending marketing messages. This usually concerns external service providers, such as marketing or IT and development companies. We agree on a data processing agreement with these parties that meets all requirements of the General Data Protection Regulation.

We may also provide your personal data to third parties to comply with laws and regulations or in the context of legal proceedings, a court order or other writ of execution.


DATA RETENTION

Albron does not store your personal data for longer than is necessary for the purpose of the processing. For example:

  • Order information: When you place an order for our products, we keep that information for a minimum period of seven years after the end of the financial year in which you placed your order. This is in accordance with our legal obligation to keep records for tax purposes
  • Correspondence and questions: When you ask a question or contact us by e-mail or via our contact form, we will keep your data for 24 months after the complete resolution of your question
  • Mailing List: We keep the information you used to sign up for our newsletter until you unsubscribe or we decide to cancel our newsletter service, whichever comes first

In all other circumstances, we will not keep your data for longer than is necessary, taking into account the following:

  • The purposes and use of your data, now and in the future (such as whether it is necessary to keep that data in order to fulfil our obligations under a contract with you or to contact you in the future)
  • Whether we have a legal obligation to continue processing your information (such as any record keeping obligations imposed by relevant law or regulation)
  • Whether we have a legal basis to continue processing your information (such as your consent)
  • All relevant practices regarding how long information should be kept

YOUR PRIVACY RIGHTS, COMPLAINTS AND CONTACT

You can request Albron at any time to inspect the personal data that Albron processes about you. You have the right to correct, supplement or have it removed. Albron will comply with those requests if the law allows us to. You must make a request for inspection and/or correction in writing. You must also enclose a copy of your proof of identity. This is allowed via the secure CopyID app of the Dutch government.

You can preferably make your request by e-mail to privacy@albron.nl.

If you do not have an e-mail address or do not wish to make the request by e-mail, you can send a letter, signed and with a copy of your proof of identity, to the postal address:

Albron BV, attn. Legal Department, Rijnzathe 11, 3454 PV De Meern.

For questions or comments about this privacy statement, please contact us at the above address. You can also use our contact form on the website or contact our privacy department via privacy@albron.nl.

If you are not satisfied with the handling of your request or if you have a complaint about the processing of your personal data by Albron, you can contact the supervisory authority, the Dutch Data Protection Authority (https://autoriteitpersoonsgegevens.nl/nl). We would appreciate it if you complain to us first so that we have the opportunity to resolve the issue.


SOCIAL MEDIA AND OTHER WEBSITES

Albron cannot be held responsible for the privacy policy or privacy actions of other websites or social media, such as Facebook, Instagram, LinkedIn or Twitter, even if:

  • You reached this external website by following links on our website
  • You reached our website by following a link from an external website

We recommend that you consult the privacy policy of any site or social media you visit and contact the owner of that website with any questions or comments.


INFORMATION ABOUT MINORS PROVIDING PERSONAL DATA

Albron generally does not target its websites or services or products to children and does not knowingly collect personal information from children under the age of thirteen (13). If Albron learns that a child under the age of thirteen (13) has posted personal information on Albron's websites without parental consent, Albron will take all reasonable steps to remove such information from our databases and not use such information for any purpose (except as necessary to protect the safety of the child or others, as required or permitted by law). If you become aware of any personal information we have collected from children under the age of thirteen, please contact us at privacy@albron.nl.

Minors under the age of eighteen can email us at privacy@albron.nl to have the personal information they have provided to us deleted, subject to applicable law.

Insofar as Albron offers apps that are aimed at children, Albron ensures that these apps are built in such a way that no personal data from children is collected, because children deserve specific protection with regard to their personal data. Such specific protection should in particular apply to the use of children's personal data for marketing purposes or for the creation of personality or user profiles and for the collection of personal data relating to children when using services offered directly to a child.


MODIFICATION OF THIS PRIVACY STATEMENT

Albron may amend this privacy statement from time to time. You can always view the latest version of this privacy statement via www.albron.nl/privacy. We advise you to regularly check whether you have the most recent version of the privacy statement, and in any case when you provide personal data to Albron.

This privacy statement was last amended on 7 December 2021.