The Kugi company: Privacy Policy

This website www.thekugicompany.com is managed by The KUGI Company B.V. (hereinafter, also referred to as: we, us/our).

In this Privacy Statement we inform you as best we can about the processing of your personal data. Please read the Privacy Policy carefully as it contains important information about how we process personal data that you make available to us or that we otherwise collect as part of the website (hereinafter “Personal Data”). The KUGI Company B.V. is the data controller of the collected and processed Personal Data.

We respect your privacy and we make every effort to secure and manage your Personal Data according to the legal obligations we have according to the applicable data protection legislation.

We may amend this Privacy Statement at any time. Last update of this Privacy Statement of The KUGI Company: 16 april 2020.

1. Who does this Privacy Policy apply to?

Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognize you and make your next visit easier and the Service more useful to you. Cookies can be “persistent” or “session” cookies.

How the KuGi Company uses cookies

1.1 This privacy statement applies to the personal data we collect and use in relation to your interactions with us as a visitor to our website, a visitor to our webshop, when you buy our products in our webshop, when you contact our customer service or when you are a supplier or business partner or work for us.

1.2 The personal information we obtain and use depends on your choices and interactions with us. Depending on your situation, we will collect and use your personal data in the activities described below, such as when you visit our website or webshop, when you become a KUGI member, when you create a KUGI account in our webshop, when you buy products in our webshop, if you subscribe to our newsletters/events, contact us through various channels, such as by phone, email or social media channels, fill out customer satisfaction surveys or if you share your social media messages with us, including photos.

2. What personal data of yours does The KUGI Company process?

2.1 If you have opened an account, became a member or ordered our products in our webshop, we may amongst other things process the following data of yours: your name, email address, date of birth, address, phone number, your bank account number, login credentials for accessing your Account and other information you provide us.

2.2 We also automatically process the following categories of information of all our website visitors: information with regard to your visit to our website, browsing behaviour, information about the computer used, such as IP address, browser specifications and operating system.

3. For which purposes do we use your personal data?

3.1 We process your personal data so you can use the features of our website as optimally as possible and in order to provide our services to you.

3.2 We will process your personal data solely for the following purposes:

• Processing your payment;
• Responding to questions and requests;
• Responding to questions and requests;
• Sending notices and materials of interest to you (such as newsletters);
• Direct marketing analysis and offers;
• Security, including access control and improvement of our Site;
• Knowledge acquisition for quality and merchandise improvement;
• Market research and other analysis for quality and merchandise improvement;
• Complying with applicable laws and regulations;
• Other uses clearly stated at the Personal Data is obtained.

3.3 Your personal data is not processed for any other purposes other than described in this Privacy Statement.

3.4 We entered into a data processing agreement with Stripe, PayPal and FedEx about the processing of personal data in connection with the administration and receipt of payments to be made. In addition, we may also engage external service providers that also provide services as a data processor according to the General Data Protection Regulation GDPR in connection with which your personal data is processed. Besides Stripe, PayPal and Budbee, another example of such a processor is the service provider for the hosting and maintenance of our website. Data processors may process your personal data only on our behalf and in accordance with our instructions. We conclude a data processing agreement with each data processor for this purpose in accordance with the Guidelines on the protection of personal data (Richtsnoeren inzake de beveiliging van persoonsgegevens) from the CBP.

3.5 Other than the situations described in this Privacy Statement, we will not disclose your personal data to others, unless we consider it necessary for complying with our legal obligations, protecting our or others’ rights, or to enforce compliance with this Privacy Statement.

4. Security

We do our very best to implement appropriate technical and organisational security measures to protect against loss, abuse and alteration of your personal information under our control. Although we exercise all reasonably required care for a secure data processing in accordance with the General Data Protection Regulation (GDPR), we can not guarantee that the processing of data remains secure at all times. We accept no liability for damages suffered by you or third parties as a result of unauthorised access to your (personal) data, unless such damage is caused by intent or gross negligence on our part.

5. Retention of your personal data

5.1 We will retain your Personal Data as long as required by law or as necessary to provide any services requested to you or as necessary for the other purposes set forth in this Privacy Policy. The specific retention periods are set out in this Privacy Policy for all relevant purposes.

5.2 We will take reasonable steps to destroy or make Personal Data anonymous when it is no longer needed for the above mentioned purposes or when the specific retention period for it has expired.

6. Social Media

You can choose to share information on our website through social media such as Facebook, Instagram and Twitter. This means that the information you share of your personal pages will be visible to visitors. We encourage you to carefully read the privacy policies of the social networks, as these policies apply to the processing of your Personal Data by these parties.

7. Privacy for minors

This website is not intended for persons under 18 years of age (or the legal minimum age for consumption of our products). We never knowingly collect Personal Data about anyone under the age of 18.

8. Cookies

You can find more information about the use of cookies on this website in our Cookie Policy.

9. Your right of access, correction, deletion, restriction and transfer of data

9.1 You have the right to request an overview of the Personal Data processed by us or on our behalf. You have the right to correct, delete or limit your data (as the case may be). You can exercise this right by contacting privacy@thekugicompany.com. Please note that in the event of requests that do not comply with the requirements set by applicable laws or guidelines of The KUGI Company, you may be asked to resubmit them or they may ultimately be refused and that certain Personal Data may be excluded from such requests for access, correction and deletion under applicable data protection laws or other laws and regulations.

9.2 You have the right to receive the Personal Data you have provided to us in a structured and commonly used and machine-readable format. If this is technically possible, we will transfer your Data to another administrator at your request under certain circumstances.

10. Your right of objection

You also have the right, under certain circumstances, to request us to stop processing your Personal Data. However, if we have compelling legal reasons to do so, we will continue to process your Personal Data. However, you have the right to object to the use of your Personal Data for direct marketing purposes. If you submit such a request to us, we will comply with it. Where you have consented to our use of your Personal Data, you have the right to withdraw your consent, without prejudice to the lawfulness of our use of such Data prior to the withdrawal of your consent.

11. Contact

If you have any questions or if you wish to object to our use of your Personal Data, have a complaint about this Privacy Policy or about our processing of your Personal Data, please send an e-mail to privacy@thekugicompany.com. You also have the right to complain to your local data protection authority.