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Privacy Statement of Appèl App

Annex 1: Privacy Statement for Appèl App

Privacy Statement of Appèl App

December 2023

This privacy statement describes how Appèl (having its registered office in ’s-Hertogenbosch at Mammoet 2, 5236 NV) processes the personal data of individuals, including our working methods for gathering, processing, using maintaining, protecting and disclosing this information. Appèl will take the greatest possible care when processing your personal data.

The design of our app has proactively and intentionally taken account of the user’s privacy. Nor will more data be gathered than is necessary. By logging in to our App you agree that our App gathers and uses your data.

Personal data and Privacy Statement

Appèl complies with the General Data Protection Regulation when using your personal data that you have to enter in our App and that we gather during use.

Appèl App

After downloading our App you log in with your e-mail address and choose your own password. After logging in you have access to the information of the App and you can be rewarded for various loyalty activities. All data is made available to Appèl.

What personal information does the Appèl App gather and process?

The following information concerning you will be recorded:

Name, e-mail address, password, preferred educational institution, transaction information.

The following information can be added voluntarily (optional):

Sex, date of birth, post code, house number, address, city, country, reactions, comments on messages, reactions to polls/quiz questions, claiming and exchanging of vouchers/coupons, exchanging points for gift shop items, questions asked (including recording the type of phone).

Appèl gathers and/or processes personal data when the data subject has provided personal data via the App and because the data subject contacts Appèl.

In addition, Appel gathers static data such as device information, the latest interaction in the app, the time a coupon is claimed and the time of registration, to improve the functionality and performance of the app and to gain insight into the usage pattern of our users.

Purposes and principles for the processing of personal data

The information will only be used internally and will not be passed on to other organisations for commercial purposes. The purpose of the processing of personal data by Appèl is:

  • Being able to provide its services;
  • Contact with you to inform you about its services;
  • Improving its services;
  • Marketing and communications;

The processing of your personal data is necessary to be able to provide the service. Processing of your personal data is necessary for the functionality of the Appèl App and providing services, including contact.

Appèl processes personal data on the basis of one or more processing grounds under the General Data Protection Regulation:

  1. (explicit) consent;
  2. Legitimate interest of Appèl.

If Appèl processes personal data on the basis of a legitimate interest, such processing relates to marketing, researching its own products or services, IT management and security.

Use is not made of automated decision making.

Provision of personal data to third parties

Appèl will not provide personal data to third parties, unless it is provided to a processor engaged by Appèl, who will process the personal data in accordance with this privacy statement and the purposes laid down therein on behalf of Appèl. Appèl will in such case make a contract with the processor in which the processor is obliged to take adequate technical and organisational measures, in order to provide suitable safeguards for the intended data processing.

If Appèl is bound on the basis of a statutory obligation to hand over the personal data, Appèl will comply by providing the personal data to an authorised agency.

 

Securing data on the Appèl App

The design of our app has proactively and intentionally taken account of the security of the user’s data.

If we use or process your data in our App, we always use the coding technologies that are recognised as common standards within the IT sector.

We have introduced the necessary security measures to prevent the loss, unlawful use or change of information that we receive in our app.

Processing of personal data outside of the European Economic Area

The processing of personal data in third countries, i.e. countries outside of the European Union (EU) or the European Economic Area (EEA) will only take place when this is necessary for the performance of an assignment or is prescribed by law (e.g. tax reporting obligations), there are appropriate levels of data protection or you have given us consent for such. If the processing takes place outside of the EEA, you will be informed of this.

The processing of your personal data in a third country can also take place in conjunction with the engaging of service providers in the framework of the processing of an assignment that you have given us. Insofar as for the country in question no decision is available from the EU Commission as to whether there is an adequate level of data protection, we ensure by means of appropriate contracts that your rights and freedoms are appropriately protected and guaranteed.

Changes to the Privacy Statement of Appèl App

This privacy statement is aligned to the use of our App. Appèl reserves the right to modify this privacy statement. Any modifications can lead to changes in this privacy statement. This will be communicated via e-mail.

Access, rectification and erasing of personal data in Appèl App

If Appèl processes your personal data, as the data subject you have a number of rights:

  • Right to information: You have the right to receive information regarding the way in which and why Appèl processes your personal data.
  • Right to access: You have the right to access and to receive a copy of the personal data of yours that Appèl processes.
  • Right to rectification: You have the right to rectify and/or supplement the personal data relating to you, if this data is inaccurate or incomplete.
  • Right to restriction of processing: You have the right to ask Appèl to (temporarily) restrict the processing of your personal data, if one of the following situations occurs:
    • you dispute the accuracy of the personal data relating to you. The processing is restricted during the period that Appèl needs to inspect the accuracy of your personal data;
    • the processing of your personal data is unlawful and you object to the erasure of your personal data and instead ask that the processing of the personal data be restricted;
    • Appèl no longer needs the personal data for the processing purposes, but you need it to bring, enforce and substantiate a legal claim.
    • you have objected to the processing and you are awaiting an answer to the question whether the legitimate grounds of Appèl carry greater weight than yours.
  • Right to data portability: you have the right to obtain your personal data that is being processed by Appèl, in a structured and common (digital) format, in order to transfer it to another data controller without disruption.
  • Right to object: you have the right to object to the processing of your personal data, if the processing is based on one of the following processing grounds: ‘performance of a task of public interest’ and/or ‘acting on behalf of the legitimate interests of Appèl’. Appèl will cease the processing of personal data if it cannot present legitimate grounds for the processing that carry greater weight than the interests, rights and freedoms of the data subject.
  • Right to data removal: You have the right to ask Appèl to remove your personal data. Appèl will grant this request if one of the following situations occurs:
    • your personal data is no longer necessary for the purposes for which it was gathered or will otherwise be processed;
    • you have withdrawn your consent for processing your personal data and there is no other legal ground for the processing;
    • you have made a valid objection to the processing of your personal data;
    • your personal data has been unlawfully processed.

If you have given consent for the processing of your personal data, you have the right to withdraw this consent at any time. All processing of personal data that has taken place prior to the withdrawal of consent, is deemed to have been lawful.

If you wish to access, rectify or remove your personal data, please contact us via privacy@appel.nl. Appèl will deal with your request within one month. If the matter concerns a complicated or large number of requests, Appèl can opt to extend this term by two months.

Questions and feedback of Appèl App

We periodically check whether we are in compliance with this privacy statement. If you have questions about this privacy statement, we invite you to contact us via the contact details on our website or in the manner set out below.

Complaint about the processing of personal data:

If you have a complaint about the processing of your personal data, you can report this to us via the contact details at the bottom of this privacy statement. You can also submit your complaint to the Dutch Data Protection Authority:

Autoriteit Persoonsgegevens

Postbus 93374

2509 AJ Den Haag

The Netherlands

www.autoriteitpersoonsgegevens.nl

 

Retention period

Appèl retains the personal data for the period for which it needs the personal data to realise the purpose for which it originally gathered the personal data, unless Appèl is obliged on the basis of a statutory provision to retain the personal data for a longer period of time.

Contact

If you have any questions or remarks in connection with this privacy statement, you can contact us via:

Appèl B.V.

Address: Mammoet 2, 5236 NV ‘s-Hertogenbosch

Mail: info@appel.nl

Tel: 073 612 5050