Applicability
This Pon App Privacy Statement applies to the collection, use and other processing of personal data by Pon Holdings B.V. (‘Pon’) in connection with the Pon App.
Who is responsible for the processing of your personal data?
Pon (Rondebeltweg 31, 1329 BN Almere, The Netherlands) is the legal entity responsible for all the collecting and processing of your personal data in connection with the Pon App.
Pon is committed to respecting and protecting your privacy and the protection of the personal data you share with us.
Why do we collect your personal data?
Personal data is any information about an identified or identifiable natural person. Pon makes the Pon App available to its employees so that they can access Pon’s latest news, important links and information anytime and anywhere. If you choose to use the Pon App, we will collect some personal data from you. This personal data, as listed under the heading ‘Which personal data do we process’, is processed for the following purposes:
- to communicate with you personally or to inform you about Pon’s brand products and/or services;
- to process your participation in contests, promotions, surveys or app features;
- to carry out and report on statistical analyses;
- to provide app functionalities, including sending relevant messages;
- to meet our legal responsibilities, settle disputes and enforce our agreements;
- as otherwise indicated at or around the time the personal data is collected.
Which personal data do we process?
To use the Pon App, you must first activate the App with your Okta account. In doing so we collect and process the following personal data as recorded in your Pon-Okta account: yourbusiness email address
In addition, we collect and process metadata about the device on which the app is installed, including its software version and model type, in order to ensure the correct operation of the app.
Your personal data is processed in the Pon App on the legal ground that the processing is necessary to represent a legitimate interest of Pon. Our legitimate interest is to provide employees with relevant information within the App. The processing may also be necessary for the execution of the (employment) contract with you.
If you have consented to the processing of your personal data, you have the right to revoke it at any time by sending a request to [email protected].
How do we share or transfer your personal information?
You should be aware that departments (such as marketing and IT) may be part of Pon’s global businesses. As a result your personal information may be shared and/or transferred to other business group companies or other Pon business units worldwide. You can consult the list and location of our companies here: https://pon.com/en/about-us/companies/
Pon may also share your personal information with third parties to perform certain activities on Pon’s behalf and to facilitate the services they provide to us. These may include service providers such as website hosting, data analysis, payment processing, order processing, information technology and related infrastructure, customer service, email delivery, audits and other services. Pon may also share your personal information with third parties so that they can send you communications in accordance with your choices. Pon demands of these third parties that they carefully process and protect your personal data. Pon will not sell your personal data to third parties.
Pon may reorganize, merge, or sell or divest (part of) a company in some other way to another company. If such a business is related to Pon, such a transfer of ownership may include the transfer of your personal information to the new owner and its advisers.
We will only disclose your personal data if this is permitted or authorized by law, is necessary to prevent or combat fraud, is necessary for the resolution of disputes or is necessary for any other legitimate need that, in the circumstances, outweighs your privacy interests, such as the security of our business and the safety of our staff.
How do we protect your personal data?
Pon will take appropriate technical and organizational security measures to prevent the loss or unlawful processing of your personal data. This may include the use of secure registration forms, data encryption and access restrictions to your personal data.
Some countries do not have an adequate level of protection for personal data. However, you can rest assured that Pon will take appropriate security measures with regard to the confidentiality and protection of your information. For transfers from the EEA to countries which, according to the European Commission, do not provide an adequate level of data protection, we have taken adequate measures by concluding contractual agreements, as approved by the European Commission, with third parties. You can request a copy of these measures by contacting us at [email protected]
How long do we retain your personal data?
We will retain personal data for as long as is necessary or allowed for the purposes described in this Privacy Statement and in accordance with applicable law.
The following criteria are used to determine our retention period:
- The period of time during which we have a current (employment) relationship with you and provide the services to you (for example, as long as you have an account with us or continue to use the Pon App);
- Whether there is a legal obligation with which we must comply (for example certain laws require us to retain our transactions for a certain period of time before we can delete them); or
- It is desirable, based on our legal position, to retain personal data (for example with regard to limitation periods, disputes or investigations by regulatory bodies).
Analytical cookies
Analytical cookies help us to measure how often the Pon App is visited and which parts of the App are most frequently viewed. We can use this information to keep improving the App. To do this we use Google Analytics which is a web analytics service provided by Google Inc. (Google). Google Analytics uses cookies to analyze the use of the App by users. Google uses aggregated statistical data to provide Pon with an insight into how users use the App. Based on the guidelines of the Dutch Data Protection Authority we have made Google Analytics more privacy friendly:
- by ensuring that we have a ‘Processor Agreement’ with Google;
- by anonymizing IP addresses to be activated in Google Analytics;
- by ensuring that data is not shared with Google.
Google may only transfer this data to third parties if Google is required by law to do so or to the extent necessary for third parties to process data on Google’s behalf.
Your rights
If you wish to review, correct, update, limit or delete your personal data processed by us, object to the processing of personal data, or if you wish to receive an electronic copy of your personal data in order to pass it on to another company (to the extent that you have this right to data portability Almere, The Netherlands. We will respond to your request in accordance with the applicable law.
Please describe as clearly as possible in your application which personal data your request relates to. For your safety we will only process requests relating to the personal data associated with the specific email address you use to send us your request, and we may ask you to verify your identity before we comply with your request. We will try to comply with your request as soon as reasonably practicable and, in any event, within the time limits required by law.
Contact, questions, feedback and data protection officer
Please send your questions and comments about this Privacy Statement to [email protected].
Our Data Protection Officer (DPO) can also be reached via the above email address. You have the right to file a complaint with a data protection authority in your country or region, or where an alleged breach of applicable privacy law is taking place.
Policy changes
We may amend this Privacy Statement from time to time. Changes to this privacy statement will come into effect when we publish the revised statement. We will inform you of any changes to our Privacy Statement as necessary. This Privacy Statement was last amended on 23 August 2019.