This Privacy Statement Pon governs the collection, use and other forms of processing of personal data by Pon Holdings B.V. (“Pon”) related to our services, our Pon products and this website.
Who is responsible for collecting and processing of your personal data?
Pon Holdings B.V. (Rondebeltweg 31, 1329 BN Almere, Nederland) is the legal entity responsible for all collection and all processing of your personal data in connection with the products, services and websites of Pon. Pon is committed to respecting and safeguarding your privacy and the security of your personal data you share with us.
Why do we collect your personal data?
Personal data is information that identifies you as an individual or relates to an identifiable individual. When you choose to register your personal data, contact us, or visit our websites, we will collect some personal data about you. We process these personal data for the following purposes:
- communicate with you in a personal way or to inform you about Pon products or services, consistent with your choices;
- provide customer service, including service around the purchase of services and products, fulfil warranty obligations and product recalls for our own services and those of related companies, and to deal with any enquiries or complaints;
- administer your participation in any contests, promotions, surveys or website features;
- perform market research and improve our business, services and Pon products or to develop new business, services and products;
- perform statistical analyses and reporting;
- providing services on the internet;
- communicating with participants and offering a loyalty program;
- provide app functionality, including providing relevant commercial messages;
- to communicate future promotional and marketing information including direct marketing purposes and retargeting;
- to aggregate and/or anonymize personal data in order to generate other data for our use;
- to comply with our legal obligations, resolve disputes, or enforce our agreements;
- as otherwise stated at or about the time information is collected.
Which personal data we process?
Which personal data we exactly process, depends on which websites, products or services you use. We process the following personal data.
Personal data you provide to us:
- This is the personal data that you enter when you use our websites, products or services. This data includes e.g. your name, address, gender, email address, phone number, age and birth date.
How do we collect your personal data?
In the table below we describe per way of collecting: the categories of personal data and the purposes for which we process the personal data as well as the legal basis for the processing:
|Ways of collecting||Categories of personal data collected||Purposes for processing the personal data||Legal basis|
|Contact form customer service||The above described purposes: 1, 2, 4, 5, 6, 9, 10, 11 and 12||Performance of a contract or legitimate interest|
|Attend to product promotion, events or online forum||The above described purposes: 1, 3, 4, 5, 6, 9, 10, 11 and 12||Consent or legitimate interest|
|Log on our websites via social media||NB: we never get access to your social media account||The above described purposes: 1, 4, 5, 6, 9, 10, 11 and 12||Consent or legitimate interest|
|Use of our app||–||The above described purposes: 1, 2, 4, 5, 6, 8, 9, 10, 11 and 12||Consent or legitimate interest|
Our legitimate interests include: marketing, advertising, security, (crime) prevention, IT management, research and analysis of our products or services, business management, legal affairs, internal management.
You have the right to withdraw your consent which you may have given to the processing of your personal data at any time by sending your withdrawal request to email@example.com.
How do we share or transfer your personal data?
You should be aware that that departments (like IT, Marketing) can be located in Pon companies around the world. As a consequence your personal data may be shared within and/or transferred to other business group companies or other Pon companies around the world. You can consult the list and location of our companies here: http://www.pon.com/en/our-business/bedrijven.
Pon may share your personal data also with third parties to perform certain processing activities on behalf of Pon and to facilitate services they provide to us. These can include providers of services such as website hosting, data analysis, payment processing, order fulfilment, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services. Pon may also share your personal data to third parties, to permit them to send you marketing communications, consistent with your choices. Pon requires these third parties to process and protect your personal data diligently. Ponwill not sell your personal data to third parties.
Pon might reorganize, merge or in any other way sell or dispose (part of) a business company to another company. Where such business relates to Pon, such transfer of ownership may include the transfer of your personal data to the new owner and its advisors.
We will otherwise only disclose your personal data if so required or authorized by law, where necessary for preventing or combating fraud, where necessary for dispute resolution, or for any other pressing legitimate need which under the circumstances must outweigh 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 against loss or unlawful processing of personal data. This may include using secure registration forms, encryption of data, and restricting access to your personal data.
Please note that some third countries do not provide for an adequate level of protection for your personal data. However, you can be assured that Pon will take appropriate safeguards for the confidentiality and protection of your data. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission, to protect your personal data. You may obtain a copy of these measures by contacting firstname.lastname@example.org.
How long do we retain your personal data?
We retain personal data for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.
The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide our services to you (for example, for as long as you have an account with us or keep using our services);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Cookies, web beacons and similar techniques
If you would like to request to review, correct, update, suppress, restrict or delete personal data, object to the processing of personal data, or if you would like to request to receive an electronic copy of your personal data for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us via email@example.com or by sending a request to the postal address: Rondebeltweg 31, 1329 BN Almere, Nederland. We will respond to your request consistent with applicable law.
In your request, please make as clear as possible what personal data your request relates to. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event within any applicable legally required timeframes.
Contact, questions, feedback and Data Protection Officer
If you have any questions about this Privacy Statement, please contact us at firstname.lastname@example.org.
You may also contact our Data Protection Officer (DPO) via email@example.com. You have the right to lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs.
We may change this Privacy Statement from time to time. Any changes will become effective when we post the revised Privacy Statement. If necessary, we will inform you when we change the Privacy Statement. This statement was last modified on 12 June 2019.