PRIVACY POLICY

CLUSE / EUROPE WATCH GROUP B.V.

INTRODUCTION

By using our websites www.cluse.com and/or b2b.europewatchgroup.com personal data might be collected and processed. The owner of the brand CLUSE is Europe Watch Group B.V. (together with its group companies hereinafter called “CLUSE” or “we” or “us”), which company is responsible for the collection and processing of such personal data.

CLUSE is committed to being open and transparent regarding how we collect, use and protect personal data of our customers, business partners and other individuals. Personal data is information about an identified individual or who is reasonably identifiable by such personal data. In this privacy statement we explain to you how we operate, for example, we indicate what kind of personal data is processed by us and for what purpose.

We are highly dedicated to protect the privacy and personal data of all our customers, business partners and other visitors to our website. All personal data is therefore carefully stored, processed and protected.

CLUSE carefully observes and meets all obligations arising from the General Data Protection Regulation (Regulation (EU) 2016/679) and other Dutch privacy laws.

CONTACT DETAILS

  • Address: CLUSE / Europe Watch Group B.V., Danzigerkade 16 E, 1013 AP Amsterdam, The Netherlands
  • Customer Care contact details:

Registered with the Chamber of Commerce under number 58986502.

PERSONAL DATA; WHICH DATA AND WHY?

When using our website, you share with us certain information or leave certain information behind. For example, this might be the case when placing an order, when you subscribe to a newsletter or when you indicate that you wish to receive information regarding CLUSE products.

GENERAL

The personal data we might collect and process from our website are:

  • your name, date of birth, gender, email and (billing and shipping) address of individuals;
  • company name, chamber of commerce file number and VAT number, if relevant;
  • payment information;
  • your (mobile) telephone number;
  • which product(s) you ordered;
  • your correspondence with CLUSE, if any;
  • behaviour data (online movement, use of the internet and the length of your session); and
  • IP addresses and time stamps.

We may use this personal date for the following purposes:

  • to properly process and fulfil any orders placed assessment and acceptance of our business partners;
  • to analyse and/or improve the quality and quantity of information our products, (customer) services and websites;
  • to fine tune our correspondence (amongst others) with regards to deliveries and refunds;
  • to send information, offers and promotions based on your interest and click and surf behaviour;
  • to answer questions asked through, for example, the website;
  • to provide news and information regarding CLUSE, new products and services;
  • to be able to provide the customer with a personal account on our website;
  • to allow you to connect with our social media accounts;
  • research on the level of satisfaction of the customers, business partners or others; and
  • internal analysis for (consumer) research purposes.

We may analyse your personal information to create a profile of your interests and preferences so that we can tailor and target our communications in a way that is timely and relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively. This allows us to be more focused, efficient and cost effective with our resources and also reduces the risk of someone receiving information they may find inappropriate or irrelevant. For this purpose, we process your personal data based on our legitimate interests.

We may also use data about how you use our website to prevent or detect fraud, abuse, and illegal uses and to comply with court orders, governmental requests or applicable law.

JOB APPLICATION

The personal data we might collect and process if you apply for a job at CLUSE are:

  • your name, date of birth and gender;
  • resume details;
  • contact details: telephone number, email and address.

The personal data you provide in your application for a job opening at CLUSE and as part of the recruitment process will only be held and processed to facilitate the selection process and in connection with any subsequent employment. We process your personal data for this purpose as a preparatory step to possibly entering into an employment contract with you. If you are not selected, we will keep your personal data to contact you for any new job applications, if we think it could be a match. For this purpose, we process your personal data based on your consent.

HOW LONG WILL INFORMATION BE KEPT?

GENERAL

We shall store and process your personal data for as long as we believe would be necessary to fulfil the purposes for which we collected such personal data. Nevertheless, we shall not retain your personal data for a period exceeding five years, unless applicable law requires otherwise, This does not consider (anonymous) information in relation to statistic purposes.

JOB APPLICATION

In case we receive your personal data when you apply for a job opening at CLUSE, we will hold your data for no longer than 12 months. In the event of your application resulting in the offer and your acceptance of a position at CLUSE, the data collected will become part of your employment record and will be used for employment purposes.

THIRD PARTIES

Your personal data may be transferred within the CLUSE group and shared with companies working under the brand CLUSE. Such information may be exchanged for us to have a complete overview of your information within the whole CLUSE group and for administrative purposes.

We might share your personal data with the following third party service providers processing personal data on behalf of Europe Watch Group B.V.:

  1. media agencies and technical suppliers for distribution of physical and digital direct marketing and CLUSE product promotions,
  2. companies to validate your address, communication agencies to send you order confirmation, warehouse and distribution suppliers in connection with the delivery of your order, payment service providers for your payment,
  3. debt collection agencies,
  4. research and analysis agencies for our internal data analysis purposes.

KLARNA

We offer Klarna as payment option in our checkout. When selecting Klarna as your payment method, we will transfer your personal data in the form of contact and order details to Klarna when the checkout is loaded, in order for Klarna to manage your purchase and payment. Klarna processes your data in line with their own privacy policy.

CUSTOM AUDIENCES

In addition to above-mentioned uses of your personal data, we occasionally may use available information about our customers to generate “custom” or “lookalike” audiences through Facebook/Instagram, Google platforms, TikTok, Snapchat, Pinterest, Adroll, Quantcast and Microsoft Advertising. This allows us to target advertisements on their networks to potential customers who appear to have shared interests or similar demographics to our existing customers, based on the platforms’ own data. We typically share hashed portions of personal data by uploading a list to these platforms. We do not have access to the identity of any person targeted in the lookalike audiences, unless this person would click on one of our advertisements. The use of custom audiences may result that you will be excluded from certain marketing campaign(s), if we and/or the platform(s) do not deem a certain marketing campaign relevant to you based on the data shared. The shared lists with the encrypted data will only be used for the purposes mentioned here.

If you wish to opt-out of the use of your personal data for custom or lookalike audiences, please email us at care@cluse.com , and we will begin the process of removing your data from the lists that are shared with above-mentioned platforms.

BROWSER SESSIONS AND IP ADDRESS

We use the IP address of your computer. This IP address is a number that is automatically assigned to your computer during a browsing session. The IP address of your computer can be used to see how websites are used and for the preparation of analyzes.

COOKIES

As indicated in the cookie banner on our website, CLUSE makes use of various types of cookies on our website. In this section we explain what kinds of cookies these are, what they are used for and how you can adjust your browser settings to accept or refuse cookies. Accepting cookies is not a condition for visiting our website.

PERMISSION

According to European law, you have to give permission for the use of cookies. This cookie policy explains which cookies these are. You can accept our cookies in two ways: by closing the cookie notification you see on your first visit, or simply by continuing on our website.

You continue on our website (and thus agree to the placement of all cookies) by clicking on any part of the CLUSE web pages (except for opening this cookie policy) or by browsing other pages on the CLUSE website.

WHAT ARE COOKIES?

A cookie is a small text file that is placed on your computer during a visit to a website. Information is saved in this text file. This information can be read by the website or by third parties on a later visit. Some of the cookies are necessary for the website to function properly. Other cookies are used to increase the user-friendliness of the site for visitors or to show targeted advertisements on, for example, our social media channels. A JavaScript is a programme that is placed on the user’s peripheral devices and executed by them. The execution of this programme allows CLUSE to establish the location of the visitor and which actions they perform. This gives CLUSE greater insight into the behaviour of its visitors.

DELETING OR DISABLING COOKIES

You can disable JavaScript and cookies. However, you should take into account that our website will then not function optimally. Methods for disabling or deleting cookies are listed here:

WHICH TYPES OF COOKIES DOES CLUSE USE, AND WHAT FOR?

The cookies used by CLUSE can be divided into different categories:

FUNCTIONAL COOKIES

This category of cookies is necessary to ensure the proper functioning of the website. They ensure, for example, that information from one page is carried over to the next. This means you don’t have to repeatedly fill in the same information. These cookies also ensure that certain preferences that you’ve indicated for the use of the website (such as language settings) are retained. Your prior consent is not required for the use of these cookies.

ANALYTICAL COOKIES

These cookies are necessary to align our website as well as possible with the wishes of our users, by determining how our visitors use our website. With Google Analytics, we measure the way you use our website and how you found us. We use this information to improve our site. We use VWO to A/B test content. VWO keeps track of where you look and click on our sites. With this information we can optimize our webpages to display the most relevant information in the best places. For more details about the cookies that these parties place and the data that can be collected with them, we refer below to the statements by these parties. Your consent is not required for the use of these cookies.

MARKETING COOKIES

With Google Analytics, Adwords, YouTube and Adroll cookies, we measure how you use the CLUSE website. We use this information to help you choose the product that suits you the best and to show you offers for products you may be interested in during remarketing campaigns. We use Facebook & Instagram cookies to see which products you view. This enables us to show you relevant advertisements on Facebook and Instagram. For more details about the cookies that these parties place and the data that can be collected with them, we refer below to the statements by these parties. Your consent is required for the use of these cookies.

SOCIAL MEDIA (PLUGIN) COOKIES

You can share the content on our website with social media parties by using buttons. For more details about the cookies that these social media parties place when you click on the buttons, we refer below to the statements by these parties. Your consent is required for the use of these cookies.

CHANGES TO THE COOKIE POLICY

From time to time, we may make changes to this cookie policy without notifying you, for example because the website or the cookie regulations have changed. Changes will take effect immediately after these have been published on the website. We therefore advise you to consult our cookie policy regularly in order to remain informed about any changes and, if desired, to change the settings. By continuing to use this website, you agree to any changes to the cookie policy.

STOP COOKIES?

If you do not want us to use cookies then you can easily stop them. Also, you are able to turn on your notifications to become aware of when cookies are used. For this, you will have to adopt the appropriate settings on your browser.

YOUR RIGHTS; WITHDRAWAL, ACCESS, CORRECTION AND REMOVAL

You are entitled to be obtain free-of-charge information concerning data stored about your person and, as the case may be, to correct, restrict the processing, enable the portability of, or delete those data. If you have any questions about how we collect, process or use your personal data, want to enquire about, correct, block or delete your data, or withdraw any consents you have given, or opt-out of any particular data use, please send an email to us by using the email address stated under ‘Contact Details’.

You may also submit a complaint to the responsible data protection supervisory authority, if you believe that we have not respected your rights.

EMAIL ADVERTISING: UNSUBSCRIBE AND RIGHT TO OPT-OUT

E-mail advertising if you do not subscribe to the newsletter and your right to opt out.

If we receive your e-mail address in connection with the sale of a product or service and you have not opted out, we reserve the right to regularly email you offers for products from our product range that are similar to those you have already purchased. This serves the protection of our legitimate interests in promoting and advertising our products to customers that are overriding in the process of balancing of interests.

You can opt out of this use of your email address at any time by sending a message to the contact option specified below or by using the opt-out link in the advertising email, without incurring any costs beyond the cost of transfer calculated at the base rates.

E-mail advertising if you subscribe to the newsletter.

If you subscribe to our newsletter, we will regularly send you our e-mail newsletter based on your consent, using the data required or disclosed by you separately for this purpose.

You may unsubscribe from the newsletter service at any time. For this purpose you can either send a message to the contact option specified below or use the opt-out link in the newsletter. Upon unsubscription, we will delete your email address unless you have expressly consented to the further use of your data or we reserve the right to further use your personal data in the scope and manner permitted by the law, of which we inform you in this notice.

PROTECTION AND MANAGEMENT OF YOUR PERSONAL DATA

We use a variety of security measures, including encryption for account passwords and authentication tools, to maintain the safety of your personal data. Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems.

The personal data of customers we collect or generate and process in the context of our website will be stored in the Netherlands and may be further stored for process purposes in the United Kingdom and Ireland.

UNSUBSCRIBE (TO NEWSLETTERS)

We will send you information about CLUSE, our products that are the same or similar to those that you have ordered from us and/or other information of which we believe that you will find useful. If you no longer wish to receive any information about CLUSE, you can at any time follow the unsubscribe instructions included in each marketing email that you receive from CLUSE.

DATA PROTECTION AUTHORITY

We will be happy to assist you with any complaints which you may have about the processing of your personal data. However, please note that you also have the right to file a complaint with the Data PROTECTION Authority if you believe that we do not comply with applicable privacy law.

ADJUSTMENTS TO THIS PRIVACY STATEMENT

The type of personal data that we need and the purposes we need such personal data for may change over time. Therefore, we reserve the right to amend our privacy statement at any time. The most up-to-date version of this privacy statement is published on our website and will apply upon publication on our website.

If you have any further questions about our privacy statement, please contact us by using the information stated above under ‘Contact Details’.

SECURITY DISCLAIMER

You should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of information whilst it is in transit over the internet and any such submission is at your own risk. All we can do is use all our reasonable efforts to safeguard your personal data and ensure that we maintain a reliable and safe environment to use your personal data. It is advisable to close your browser when you have finished your user session to help ensure others do not access your personal data if you use a shared computer or a computer in a public place.

This privacy statement was last modified in June 2019.