KUBUS SPORTS B.V.

PRIVACY STATEMENT

1. INTRODUCTION
Kubus Sports B.V. (hereafter referred to as “Kubus Sports“), want to give you the best experience possible and are very committed to your privacy and keeping your personal data safe. We are bound by the General Data Protection Act (GDPR) and will protect your personal information in accordance with the principles set out therein.

This privacy statement aims to give you a clear view of what personal data we collect and how we use it, our dedication to protecting it and your rights and options to control your personal information and protect your privacy.

2. WHEN DOES THIS PRIVACY STATEMENT APPLY?
This Privacy Statement is applicable to the processing by Kubus Sports of all personal data of its customers, suppliers and business partners and other individuals. This Privacy Statement does not address the processing of personal data of employees in the context of their employment relationship with Kubus Sports.

2.1 What is personal data?
Within Kubus Sports, we consider all information that relates to you and identifies you personally, either alone or in combination with other information available to us as personal data.

2.2 What categories of personal data do we collect?
We collect your personal data through a variety of sources, such as when you buy a ticket with us, sign up for our newsletter or simply browse our websites.

We also collect personal data through cookies and similar technologies. Cookies are small files of information stored on your equipment which save and retrieve information about your visit to this website – for example, how you entered our site, date and time of visit, location information, IP addresses, how you navigated through the site, and what information was of interest to you. Read more about how we use cookies in our Cookie Statement.

– Personal identification information
When you contact us, we may record any or all of the following: your name & contact details. Your contact details may include your address, telephone number, social media account or email address.

– Information about your visits to our websites or other digital media
When you visit our websites, we may register your IP address, browser type, operating system and referring website web-browsing behaviour.

– Your communication with us
When you send us an email or chat with us via social media, we might register your communication with us. When you call us, our customer support may register your questions, queries or complaints in our database. We don’t record telephone calls.

– Information in relation to social media
Depending on your social network settings we may receive information from your social network provider. For example, when you sign in for our services using a social network account, we may receive your social network profile including your contact details, interests and contacts. For more information on the personal data that we receive from your social network provider and how to change your settings, please check the website and privacy policy of your social network provider.

– Information you choose to share with us
You may choose to share information with us, for example when you leave a comment for us on social media, fill out a customer survey or submit an entry for a contest.

2.3 When was this privacy statement last amended? 
This Privacy Statement was lastly amended on 20-04-2020.

3. WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA?

Kubus Sports is responsible for the processing of all personal data that fall within the scope of this Privacy Statement.  Kubus Sports may share your personal data with third parties, but if it does so, it will remain responsible for your personal data, unless your personal data have been summoned as part of a court order or another legal obligation to share these data rests on Kubus Sports.

4. FOR WHAT PURPOSES DO WE USE YOUR PERSONAL DATA AND HOW DO WE COLLECT THESE PERSONAL DATA?

We may use your data for various purposes, all of which have been set-out below. This may be data that you provided to use explicitly, but also data that we collected ourselves (for example, data relating to your visits of our websites). Some information that we collect is mandated by law or otherwise necessary for the delivery of our products or services. Some information we collect based on your consent. If you do not allow us to collect all the information we request, we may not be able to deliver all our services or products effectively.

4.1 To send you our newsletter
When you sign up for our newsletter we will send you regular updates on the products of Kubus Sports which may be relevant for you. We can update you via e-mail, regular mail or on our social media cannels. You have the right to unsubscribe at any time from our newsletter by using the “unsubscribe” button at the bottom of the newsletter.

On what grounds do we process your personal data when we send you our newsletter?

We process this personal information based on your consent if you have subscribed to our newsletter.

4.2 To send you personalized marketing messages
When you have visited our website, signed up for our newsletter, engaged in sweepstakes or shared your contact details with us via one or our representatives, we may send direct marketing communications to you, such as email, phone, or social media. We ask for your consent, where required by applicable law to send our personalised marketing communications.

The messages you receive will be personalised and tailored to your individual preferences and interests. We use analytics to generate such personalised messages. These analytics will process your personal information and place you in marketing segments, which determine the content of the messages and the offers you will receive from us.

We also undertake opinion research (such as to ask if you would like to participate in a survey) to learn about your experience and improve your experience with Kubus Sports, including by sending you personalised messages.

On what grounds do we process your personal data when we send you personalised marketing messages? 

We process this personal information for legitimate business purposes, to send you relevant information about our products and services, events, prize giveaways or promotions and Kubus Sports news that might be of interest to you.

4.3  To combine and analyse your data
We will use your personal information to create a profile based on the information we hold about you, which is stored and processed in a central marketing database. This is necessary to ensure that we have all accurate information about you in one place. We create your profile in accordance with your preferences to provide you with the best personalised experience, to send you personalised marketing messages and newsletters and for opinion research purposes. Below you can find a more detailed description of the ways in which we will use your personal information for these purposes.

The way you and other customers interact with our brand across all the different channels described above (e.g. our website, social media channels and marketing messages we send you) and the information we collect in that regard from each of these channels provides us valuable information about your interests and preferences and the interests and preferences of our customers in general. If you consent thereto, we may combine the information we collect with information we lawfully obtain from third parties.

On what grounds do we process your personal data when we combine and analyse data?

We process this personal information based on your consent where required, for example if we combine third party databases with ours. We also process this information based on our legitimate business purposes, which includes the ability to enhance, modify, personalise or otherwise improve our services and communications towards our customers, to better understand how people interact directly with us (through our communications or our websites), determine the effectiveness of promotional campaigns or advertising, and/or to identify and prevent fraud.

4.4 To develop and improve our services
We use aggregated personal data to analyse customer behaviour and to adjust our products and services accordingly. We may also process your personal data to compile analytics reports.  We use aggregated personal data to analyse customer behaviour and to adjust our products and services accordingly, to ensure that it is relevant to our customers.  This means that we analyse how often you read our newsletters, how often you visit our website and which pages you click on to understand which products and services you like.

We also test the level of satisfaction of our customers, using surveys.  Such research is conducted through Kubus Sports.  We use your responses to such surveys for quality assessments and to improve your customer experience.

Based on the information above, we can adjust our offerings, promotions, our newsletters or our website to make these more relevant and attractive for our customers.

On what grounds do we process your personal data? 

We process this personal information for legitimate business purposes, which includes the ability to enhance, modify, personalise or otherwise improve our services and communications towards our customers, to better understand how people interact directly with us (through our communications or our websites), determine the effectiveness of promotional campaigns or advertising, and/or to identify and prevent fraud.

4.5 To comply with the law
In some cases, Kubus Sports processes your personal data to comply with laws and regulations

On what grounds do we process your personal data? 

We process this personal information based on a legal obligation to disclose such personal information.

4.6 When your interact with Kubus Sports directly
If you contact our Customer Service (or vice versa), we will use personal information such as your order information and contact history to process your request and provide you with the best service possible. We will process your personal information in this way if it is necessary for the performance of a contract with a Kubus Sports company or if it is required for us to comply with any legal obligations.

4.7 When you enter into a business relationship with us
You may provide personal information to Kubus Sports based on a contract or a broader business relationship. In this part of the policy, we set out how we may process such personal data.

– For the assessment and acceptance of a business partner
When you get in contact with Kubus Sports, we process your personal data for assessment and acceptance purposes, for example in order to confirm and verify your identity. Kubus Sports further processes personal data of business partners for other administrative purposes such as due diligence and screening against publicly available government and/or law enforcement agency sanctions lists.

– For the conclusion and execution of agreements with business partners
We process your personal data for administrative purposes such as sending invoices and making payments. We also use your personal data to deliver or receive and administer our or your products or services. Kubus Sports will process your personal data to further execute our agreement, including for the delivery of customer services.

– For relationship management and marketing
Kubus Sports uses the information stored in its CRM database to send you suitable offers and newsletters, and to provide services, perform account management and communicate recalls. We also use your personal data for the development, execution and analysis of market surveys and marketing strategies.

– For business process execution
We process your personal data in the performance and organisation of our business. This includes general management, order management and management of Kubus Sports’s assets. Kubus Sports also processes your personal data for its internal management. We provide central processing facilities to work more efficiently. We conduct audits and investigations, implement business controls, and manage and use customer, supplier and business partner directories. Also, we process your personal data for finance and accounting, archiving and insurance purposes, legal and business consulting and in the context of dispute resolution.

– To monitor compliance
Kubus Sports monitors its IT systems to check compliance with Kubus Sports’s internal policies and regulations, such as the Code of Conduct, the Privacy Policy and the Information Security Policy. During monitoring activities, your personal data may be accessed and viewed.

5. WHO HAS ACCESS TO YOUR PERSONAL DATA?

5.1 Access to your personal data within Kubus Sports
As a global organisation, all the personal data we collect may be transferred internationally throughout Kubus Sports’s organisation, but only if Kubus Sports has a legitimate interest to do so (as set out in Chapter 4 above).  Based on such legitimate business interest, your personal data may be exchanged with the Kubus Sports group and with companies working under the Kubus Sports brand.  We exchange your data within the Kubus Sports group for administrative purposes to create a complete overview of your contacts and contracts.

Kubus Sports employees are authorised to access personal data only to the extent necessary to serve the applicable purpose and to perform their jobs.

5.2 Access to your personal data by third parties
The following third parties may have access to your personal data, where relevant, for the provisioning of their products or services to Kubus Sports or to you:

– Banks payment system operators and credit card companies, for the fulfilment of payments, as identified while you undertake your payment;
– Insurance companies;
– IT suppliers hosting our customer database, websites and technology service providers;
– Parties who support Kubus Sports in their marketing activities, such as digital agencies, mailing houses, statistical research partners, and Google and Facebook;
– Authorised representatives who sell products and services on our behalf as identified by the party you buy the products and services from;
– Debt collectors;
– Fraud bureaus or other organisations to identify, investigate or prevent fraud or other misconduct;
– External dispute resolution schemes;
– Regulatory bodies, government agencies and law enforcement bodies;
– Our financial advisors, legal advisors and auditors; and
– Other third parties with whom we are required by law to share the personal data.

We may also disclose your personal information to others outside the Kubus Sports group where:

– we are required or authorised by law or where we have a public duty to do so;
– you may have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances; or
– we are otherwise permitted to disclose the information under applicable privacy laws.

When such third parties are given access to your personal data, we will take the required contractual, technical and organisational measures to ensure that your personal data are only processed to the extent that such processing is necessary or within the scope of the consent we have received from you. We will ensure that third parties will only process your personal data in accordance with applicable (local) law.

We may need to transfer your personal information outside of the European Economic Area (“EEA”) to a country that is not regarded under European Law as providing the same level of data protection as the country in which you normally use our services. For example, if you register for a Kubus Sports event outside the EU or participate in an accelerator program outside the EU.

In these circumstances we will take appropriate steps to ensure that your personal information is adequately protected. Typically, such steps include carrying out data security reviews of any recipients and putting in place contracts with such recipients to ensure they employ the same or similar appropriate technical and organisational measures as Kubus Sports, so your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the contact details below.

We will not sell, distribute or lease your personal information to third parties other than as set out above, unless we have your permission or are required by law to do so.

5.3 The use of your personal data by data processors
When a third party processes your personal data for or on behalf of Kubus Sports we will enter into an agreement with such third party to agree on appropriate conditions subject to which the processing of personal data is allowed.  In this agreement we include obligations to ensure that your personal data are processed by the data processor solely to provide services to us.

6. HOW IS YOUR PERSONAL DATA SECURED?
Kubus Sports has taken adequate safeguards to ensure the confidentiality and security of your personal data. We have implemented appropriate technical, physical and organisational measures to protect personal data against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorised disclosure or access as well as all other forms of unlawful processing (including, but not limited to, unnecessary collection) or further processing.  Examples are IT security policies, staff training and secure servers.

7. HOW LONG DO WE RETAIN YOUR PERSONAL DATA?
Your personal data will be retained for as long as required for the purposes described in this privacy policy or in so far as such is necessary for compliance with statutory obligations and for solving any disputes.

8. HOW CAN YOU ACCESS, CORRECT OR HAVE YOUR PERSONAL DATA REMOVED?
You can at all times request access, correction, restriction, portability or removal of the data that Kubus Sports processes or if you have any questions regarding the processing of your personal data by sending a request to: info@kubus-sports.nl.

if you prefer to contact us by regular mail, please send your request to the following address:

Kubus Sports B.V.
Compliance
Watergoorweg 79
3861MA Nijkerk
The Netherlands

We are very committed to working with you to always obtain a fair resolution of any complaint or concern you might have in relation to our processing of your personal data. If, however, you feel that we have not been able to assist you adequately and do not comply with applicable privacy rules you have the right to lodge a complaint with the data protection authority using their website.