Privacy statement

INTRODUCTION

The enclosed statement regarding customers, suppliers and other business partners pertains to how BlueZircle(referred to as “BlueZircle” or ‘The Company”) respects these groups’ concerns about privacy. This privacy statement applies to all entities of BlueZircle and is maintained by the BlueZircle Head office Netherlands, Hogesteeg 25, 3886 MA Garderen. This privacy statement does not address applicants and employees.

This privacy statement can change from time to time and the most current statement is regularly published on the BlueZircle website. If BlueZircle processes major changes to this policy the customer, supplier or business partner will be kept informed by a notification on our website.

The purpose of this privacy statement is to inform individuals on how the Company securely collects and processes data so that privacy is maintained. BlueZircle respects and protects privacy in accordance with the European General Data Protection Regulation (GDPR) and other applicable laws. Further explanation is given here within on what kinds of personal data BlueZircle processes, the purpose of processing and how the Company may share personal data with third parties.

WHAT DATA IS BEING COLLECTED?

BlueZircle may process the below data for the purposes as described below:
- Name, address
- Email address, telephone number
- Data of birth and age
- Gender
- Location
- Bank account number, credit card details
- Clothing sizes
- IP address, Browser ID
- Behaviour on site

This list is not exhaustive and BlueZircle may collect and process data that is useful for its services. Not all data above is collected and processed for every customer, supplier and business partners. Often the data is limited to only a few of the above details. The data collected is dependent upon the purpose of processing.

The Company does not collect and process sensitive data such as ethnic and racial origins, political opinions, religious beliefs, trade union memberships, physical or mental health conditions, genetic or bio metric details or sexual preferences. Unless Customer and The Company mutually agreed otherwise. BlueZircle may use sensitive data such as bank account number. Also, BlueZircle may combine received data points in order to develop a profile useful in sending personalised offers and advertisements. BlueZircle is aware of the sensitivity and impact on individual privacy and has taken appropriate actions to handle all data carefully.

HOW DOES BlueZircle COLLECT DATA?

BlueZircle may collect data for the use of products and services. This data may be directly collected or from individuals or from his/her devices. For example, the Company may collect data from or about the individual through the Company’s website, social media pages, customer service email messages upon sign up for Company newsletters and personalized offers, upon purchase of BlueZircle product or when individuals register for an account. When individuals purchase a product from BlueZircle, the Company may collect his/her registration information, status of order and purchase history. BlueZircle may collect information about the individual from other sources such as public databases, third party processors or social media.

  1. Personal data directly collected from customer, supplier and business partner.
    The Company collects and processes personal data sourced directly from the customer, supplier or other business partners. These parties have made the choice to provide this data to BlueZircle. For example, when parties provide email addresses in order to receive a digital receipt or to conduct business with The Company.
  2. Personal data not obtained directly from customer, supplier and business partner.
    Besides the above, BlueZircle may collect personal data from these groups, obtained via third parties, as part of the service the Company provides or in connection with legal requirements that are applicable to the Company.

List of third parties BlueZircle share their data with are, but is not limited to:

Nedfinity
Shopify
TNT
Google Big Query
Google Analytics Premium
UPS
Adyen
Facebook
DHL
Instagram
PostNL
MyParcel
Google tag manager
Microsoft Azure

HOW DOES BlueZircle USE THIS DATA?

The Company mainly uses this personal data based upon a contractual obligation, legal obligation, consent or legitimate interest.

The Company will process data that is necessary for the performance of a contract with suppliers and other business partners. BlueZircle also processes data under the lawful basis of a legal obligation. Based upon legal obligation, the Company may store specific financial data for a period of time to meet requirements set by national tax authorities. BlueZircle may also process your data for the purpose of a legitimate business interest such as to strengthen our relationship with these parties. The Company may provide these parties with communications regarding its services that it thinks might interest the parties. The Company takes into consideration the balance between privacy impacts and the Company’s legitimate business interest. BlueZircle may process personal data when consented to do so. For example, the Company may lawfully ask these parties for consent to set up a profile in order to send personalised offers. The Company also asks permission to place a cookie on devices in order for the Company to set up profiles and place ads. When BlueZircle processes data based on these legal grounds, these parties have the right to object, restrict, erase, access and ask data portability.


WHY DOES BlueZircle PROCESS THIS DATA?

  1. To respond to questions, when contacted;

When an individual wants to get in contact with BlueZircle, the Company will use this data to reply on the request or question. BlueZircle may process your name, email address and correspondence with BlueZircle. The Company processes this data based on the individuals consent when he/she provided the data.

  1. To complete orders and when an account is registered;

BlueZircle asks to fill in personal information when an individual wants to complete an order and/or registers for an account. Some of this information is required: title, first name, last name, address, email, password. The information required for a purchase is based on a contractual obligation and to inform the individual about the status of the order. In order to complete a purchase The Company may use data for processing payment, delivery, status updates and other communication such as, notification of the delivery status or sending information. Information BlueZircle may process is name, gender, contact details, email address, purchase history, bank account details. Personal information and order history are saved on a secure server.

  1. For development and improvement of products and services;

For the legitimate interest to develop and improve products and services, The Company may collect and process personal data. Based on analysis of customers’ behaviour BlueZircle can modify its products and services. This customer behaviour is based on visitor statistics and how often visitors have clicked on website pages and the items purchased. The Company may use third parties such as google analytics to analyse the visitor behaviour in order to improve its services. BlueZircle may share personal data with third parties who provide BlueZircle with web hosting, analysis, payments and other similar services. The personal data BlueZircle may use are contact details, email address, payment information, correspondence and technical data from the individuals devices such as IP-address, Browser ID and the pages the individual visited on the BlueZircle website.

  1. To comply with law and regulations;

The Company shall comply with laws and regulations and therefore personal data could be required to comply, for example for legal obligations such as tax purposes. Personal data BlueZircle may process are name and contact details.

  1. To deliver greater website functionality;

The Company may process technical data if an individual uses BlueZircle’s website. This technical data is used for managing and improving the websites. If an individual chooses to enter location and preferences the Company processes this data in order to save this for the next visit. BlueZircle uses cookies on their website in order to make sure a visit is easy to access and use. Read more about cookies in the cookie policy. BlueZircle may process the data that is entered by the individual on our website which is linked to IP address and Browser ID.

  1. To connect with parties through social media;

The Company makes use of social media accounts such as LinkedIn, Instagram and Facebook. The Company processes data based on consent. If an individual contacts BlueZircle through one of the mediums the data is used in order to reply on these messages. If an individual connects through a social media account with BlueZircle, the Company may share data with the provider of this account. The information BlueZircle shares is governed by the social media provider Privacy Policy. Personal data BlueZircle may process are name and email address and the data used in your message. If an individual clicks on one of the icons on the website the individual will be linked through to these third party website. If an individual enters these websites these third parties may be able to place a cookie on the same device. Read more about cookies in the cookie policy.

  1. For assessment or acceptance of customers, suppliers and other business partners;

When a customer orders at or supplier or business partner works with BlueZircle, the Company may process personal data to assess the identity and screening based on a contractual obligation. BlueZircle may process contact details, name, address, email address and bank account information.

  1. For executing (contractual) agreements;

The Company may process data when a customer purchases items on the website. The data BlueZircle processes is based on the transaction such as name, shipping information, bank account details, consent for personalised offers and terms and conditions. BlueZircle works with suppliers and other business partners wherefore the Company processes data for invoices, payment information and delivery information. BlueZircle processes data such as name, address, email address, telephone number, order history and bank account number. BlueZircle processes this data based on a performance of a contract.

  1. To show personalised advertisements;

The Company may send personalised offers if the individual has given consent. An individual can sign up for the BlueZircle newsletter and personalised offers by submitting an e-mail address in the newsletter and personalised offer module found at the bottom of any page on this site or in the store. BlueZircle does not send newsletters and personalised offers to customers or registered visitors unless the individual has given consent for the newsletter and personalised offers specifically. All newsletters and personalised offers contain an opt-out link in case the individual wishes to unsubscribe from receiving further newsletters and personalised offers at any time. Personalised offers are send to an email address which could contain advertisements that might interest the individual based on purchase history and online behaviour such as an abandoned shopping cart.

Personal data BlueZircle process for sending out personalised offers are data the individuals shared actively with BlueZircle such as name, email address and purchase history and data BlueZircle obtained based on the individuals interaction with the website. v may use IP address and Browser ID to track your behaviour on our website if you have given consent for accepting cookies.

If an individual does not want to receive these emails anymore the individual is able to withdraw consent at any time or able to unsubscribe from these newsletters and personalised offers via marketing email received.

TO WHOM DOES BlueZircle SHARE PERSONAL DATA?

BlueZircle is aiming to be a global organisation and may provide data to other BlueZircle stores and offices as this is necessary for the service it offers. This data is processed for administrative purposes. Those countries may not have the same data protection laws as the country in which you initially provided that information. When BlueZircle transfers information from or about its or its use of products to other countries, the Company will protect it as described in this privacy policy. By using products parties give consent the transfer of information from or about the individual or use of BlueZircle’s products to countries outside of country of residence.

BlueZircle may process data to other companies outside of the European Economic Area. If BlueZircle processes data with a country that does not ensure an adequate level of protection of data, BlueZircle ensures appropriate safeguards are in place such as standard contractual clauses from the European Commission or the US Privacy Shield.

BlueZircle may also process data to third parties if this is required by law, regulations or court order.

BlueZircle has data processing agreements with third parties to ensure that data is applied with the same level of security and confidentiality as by BlueZircle. The Company has data processing agreements with third parties which defines the rights and obligations regarding GDPR. BlueZircle decides for which purposes the third party can process data and the third party is obliged to comply with these instructions from BlueZircle.


HOW LONG WILL WE STORE YOUR PERSONAL DATA?

The Company shall store data no longer than necessary. BlueZircle will only store the data in line with legal retention periods and based on lawfulness of processing.

BlueZircle may store personal data to fulfil the legal grounds of a contractual obligation, legal obligation and to prepare, defence or exercise legal claims and in general where BlueZircle has a legitimate interest to doing so. BlueZircle may also store data which is given through consent.

MINORS

Under the age of sixteen (16) BlueZircle requests to make a reasonable effort to verify that a parent or guardian has provided the appropriate consent.

WHAT ARE YOUR RIGHTS?

The individual has the ability to request access, restriction, portability, erasure, rectification and file a complaint by contacting hello@BlueZircle.com.

If the individual would like to file a complaint, the Company asks that the employee sends an email to hello@BlueZircle.com. Please note that you can file a complaint at the Dutch Authority.

The individual has the following rights:
- Right to access the personal data BlueZircle holds at any time.
- Right to ask BlueZircle to correct his or her personal data that is incorrect and to complete incomplete information BlueZircle holds about he or she.
- Right to be forgotten and to object and ask BlueZircle to delete personal data if BlueZircle has no legal or regulatory obligation to keep this data.
- Right to restrict personal data.
- Right to ask BlueZircle to provide the employee with a copy of his/her personal data that BlueZircle holds.
- Right to file a complaint with BlueZircle or with the Supervisory Authority.

BlueZircle shall communicate rectification or erasure of your personal data with third parties unless it proves impossible or involve disproportionate effort. BlueZircle shall inform the individual of the third parties should this matter occur.

When the individual exercises a request please elaborate on the personal data BlueZircle may process about you by giving BlueZircle more background of the personal data. For restriction specify the request to a specific department, process, team, incident or service. Try to include time frames, names, dates, type of processing and documents to enable BlueZircle to process the request as soon as possible. BlueZircle will respond to the request within one month of receipt.

COOKIES, PROFILING AND WITHDRAW CONSENT

BlueZircle may send personalised offers based on account and/or website behaviour. BlueZircle only send out personalised offers if its consented to receive these offers.

BlueZircle uses cookies on its website such as functional, analytical and tracking cookies. BlueZircle uses these cookies to make the shopping experience more personal. BlueZircle shall only place a tracking cookie if explicit consent is given on the website. BlueZircle and third parties are then able to monitor its behaviour and can modify advertisements based on interests.

Parties have the right to withdraw consent at any time to unsubscribe from personalised offers via marketing emails. To withdraw consent for tracking and other cookies can be done in the cookie banner. Under ‘preferences’ the cookie settings can be adjusted.

HOW SHALL WE PROTECT YOUR PERSONAL DATA?

The Company has taken appropriate and reasonable organisational and technical security measures in order to ensure the safety of your personal data in its systems. BlueZircle shall not process data to third parties unless the Company has a legal ground to do so, for example consent is given or if it is required by law.

Additionally, employees at BlueZircle are trained to ensure they handle all personal data with care and strict confidentiality. For staff, personnel access rights have been specified to serve the applicable legitimate purposes required for the individual to perform his or her duties.

LINKS AND CONTACT DETAILS

BlueZircle is not responsible for collection and processing of other organisations. This Privacy statement does not address personal data of any third party operating that is linked to BlueZircle.

For questions or a request please contact customer service:

Email address: hello@BlueZircle.com