OTINPLUS What Personal information do we process?
1.1 OTINPLUS is a data controller under the GDPR. This means that with regard to any Personal information referred to in this Policy, we are responsible for determining the purpose for which we process this data, and determine the means necessary for the processing of this data. As a data controller, we process the data set out in this section.
Information that is processed automatically
1.2 When you access our Websites, we may collect automatically generated information about you and/or your device. We do not have the intent of identifying you with this information, but as it may be possible to identify you directly or indirectly on the basis of this information, we are required to mention it in this Policy. Automatically generated information may include:
- Your IP address;
- Your (mobile) device identifier;
- Information about your settings, such as screen ratio, screen resolution, language settings, browser information (user agent) and/or operating system;
- Your Website preferences
- Your location and time zone;
Information voluntarily provided by you
1.3 Access to the Websites, their content and any web search results generated by using the Websites in general do not require you to submit personal details to us. We do not require you to create an account, nor do we need your email address or other contact details in order to provide our services.
1.4 We do understand that under certain circumstances, you may want to provide us with more information about yourself, for example in relation to any enquiry you may want to make with us. When you are reaching out to us, we may process the following information about you, in addition to the information that is processed automatically:
- Your name;
- Your company name;
- Your email address;
- Your website;
- Any other Personal information you provide us with;
1.5 If you choose to voluntarily provide us with any personal details, we recommend that you limit the provision of such data to the absolute minimum, and to not provide us with any sensitive Personal information, such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data or data about your sex life or sexual orientation.
Information that is processed by our partners
1.6 Third parties may be able to process data related to you through our websites in order to provide us with certain products and services. Such third parties may use technologies such as cookies, ad tags or ad beacons to collect information about your interaction with any products and services (such as advertisements) they offer through the Website. Data that is processed by such partners may include:
Our advertisement partners may process data on advertisements shown on our Websites and on third party websites, including on their relevance and effectiveness;
- Loyalty program
2 For what purposes do we process Personal information?
2.1 Primary purposes for which we process your Personal information are to offer you the best services possible, to optimize our Websites and services and to ensure continuity thereof. More specifically, your personal details can be used for the following purposes:
- To provide our services: this may seem rather obvious, but we may need certain information about you in order to be able to provide our services. However, as set out above, identifying you as a user is not our main intention. It is however unavoidable that we process certain data such as IP-address, device identifier and other automatically collected Personal information as set out above.
- To customize our services: you have the option to customize the Website experience to your needs. In order to be able to remember your customizations, we may process Personal information about you, such as a unique ID and your IP address.
- To improve our services: our Websites and services are constantly involving, and we are constantly working on improving your user experience and adding new functionality to our Websites. Processing among others analytics data (in an aggregated form) is essential to this.
- To secure our services: in order to be able to provide your with the best user experience possible, it is necessary to keep out ‘the bad guys’, such as hackers, automated bots or other threats. We are therefore constantly monitoring our services and the use of our services. When we identify a possible threat, we may take immediate action in order to avoid disruption or wrongful or fraudulent use of our services.
- To communicate with you: when you contact us, we process your contact details such as name and email address and any other Personal information you may provide to us in order to be able adequately revert to you on your enquiry.
- For marketing purposes: data on your visit to our Websites may be used by our advertisement partners in order to serve you with advertisements about our services elsewhere. As indicated, we do not use any behavioural targeting or profiling techniques.
- To exercise and safeguard our rights: though we trust you will use our Websites and services in accordance with the law and our terms of service, we may need to exercise our legal rights among others in case you infringe our intellectual property, engage in fraudulent acts or act in violation of this Policy or our terms of service.
- Compensation of our partners: as we show and run advertisements certain Personal information may be needed in order to calculate the compensation to be paid to or received by or from our partners.
- To comply with a legal obligation: we may be required by law or by a court order to process (and/or transfer) certain Personal information.
2.2 We have multiple legal grounds for the processing of your Personal information. Applicable legal grounds are listed below:
- Execution of a contract with you: most processing activities are carried out in order to provide you with our services. We provide our services on the basis of our terms of service, a contract entered into with you when using our services.
- Your consent: should certain processing activities not be related to our contract with you, we may process your Personal information on the basis of your consent.
- Compliance with a legal obligation: we may under certain circumstances be legally required to process your Personal information.
- Our legitimate interests: your Personal information may be processed by us for purposes of our legitimate interests, such as our commercial interests. This may be the case with among others (re)marketing and compensation of our partners.
3 Who may receive your Personal information?
3.1 OTINPLUS may transfer your personal inform to third parties, being:
- Suppliers: when such is necessary to enable the use Websites and services, we may transfer your Personal information to suppliers, subcontractors and business partners, such as but not limited to our hosting partner company that host the Websites.
- Group companies: we may provide Personal information to other companies within the OTINPLUS group of companies, if this is necessary for compliance, internal reporting, auditing or security purposes.
- Advertisement partners: Information on your Website visit may be provided to advertisement partners in order to serve you with (relevant) advertisements on our Websites and elsewhere, and to measure effectiveness of advertisements.
- Law enforcement agencies: we may be under an obligation to provide your information to law enforcement, regulators, courts or other public authorities in relation to an official (court) order. In addition we may provide your data to law enforcement agencies, regulators, courts or otherwise in order to exercise our rights.
- Fraud prevention: we may engage third parties in order to investigate or prevent any fraudulent acts or to protect our assets and/or rights.
- Third parties: we may transfer data to third parties acquiring or merging with DISHOPPI, or purchasing part or all of our assets, or in case of a corporate restructuring.
Parties we transfer your Personal information to may be situated outside the European Economic Area. We have implemented appropriate safeguards to protect Personal information from unlawful processing. Where we are the data controller and engage a third party as a data processor, such third parties shall always act and process the Personal information on behalf of DISHOPPI and the instructions we provide them with.
4 How long do we store your Personal information?
4.1 We retain your Personal information for as long as necessary in order to fulfil the associated purpose as set out above. After that, we may retain your Personal information if this is required or necessary in order to comply with applicable law or in order to be able satisfy any legal, reporting or audit requirements. Where possible we anonymize or pseudo-anonymize your Personal information or retain it in an aggregated form only.
5 How do we secure your Personal information?
5.1 We highly value the security of your Personal information. Therefore we have implemented technical and organizational measures to protect your Personal information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. To keep your Personal information safe, the following measures are implemented:
- Encrypt the transfers of data via the Websites;
- Protect the servers on which your Personal information is stored with passwords and appropriate security measures;
6 What are your rights?
6.1 Applicable data protection laws and regulations guarantee you certain rights:
- Objection: Depending on the situation, you have the right to consent or object to the processing of your Personal information and the conditions under which this processing takes place.
- Access: You have the right to request from us, without constraint, at reasonable intervals and without excessive delay or expense, i) a confirmation as to whether or not Personal information regarding you is being processed, ii) information on the purposes for which Personal information is processed, iii) the categories of Personal information concerned, and iv) the recipients or categories of recipients to whom the Personal information is disclosed. You have the right to receive, in an intelligible form, a communication of the Personal information being processed and of any available information as to the source(s). Furthermore, you have the right to knowledge of the underlying logic of the automated processing of Personal information relating to you.
- Rectification, erasure, blocking or deletion: You, where appropriate, have the right to rectification, erasure, blocking or deletion of your Personal information that is not processed in compliance with data protection laws and regulations, in particular when the nature of the data is incomplete or inaccurate.
- Notification: You have the right to a notification to third parties to whom your Personal information has been disclosed, when you have been granted any rectification, erasure, blocking or deletion as stated above, unless such notification proves to be impossible or requires a disproportionate effort from us.
- Withdraw consent: where we are processing Personal information relating to you on the basis of your prior consent to that processing, you may withdraw your consent at any time.
- Complaint with relevant authority. You have the right to file a complaint with the relevant data protection authorities, e.g. the Autoriteit Persoonsgegevens in the Netherlands.
6.2 In order to fulfil your possible requests pursuant to the rights as stated above, we may request specific additional information from you to identify you with or we may ask you for information to identify you with. We only collect and process such specific data with the purpose of executing your above stated rights insofar this is requested by you.
7 What are your choices?
7.1 As indicated, you may choose to withhold your consent to certain processing activities, such as the processing of your personal information by our advertisement partners. The easiest way to do so is by opting out through among others these sites:
7.2 As an alternative to the above, you may set your web browser or mobile device settings in such a way that certain technologies, such as third party cookies, are blocked as a general rule. For more information on how to do this, we refer to the help-section of your web browser or mobile device.
8 What else is there to know?
8.1 This Policy is effective until terminated by OTINPLUS. If you no longer agree to be bound by this Policy, you must cease your use of the Websites and can no longer use the Websites.
8.2 The laws of the Netherlands exclusively apply to this Policy and all agreements and legal relationships between you and OTINPLUS. Any disputes relating to or arising from this Policy and the use of Websites will only be submitted to the competent court in the district of Overijssel, location Almelo, the Netherlands, unless there is another competent court on the basis of mandatory law.