Privacy Policy

1. Introduction
This is the Privacy Policy of DOUXE B.V. (Hellingweg 96D, 2583 WH, Den Haag, the Netherlands) (hereinafter referred to as ‘DOUXE’, ‘we’ or ‘us/our’). Handling personal data correctly is extremely important to us. We therefore take great care in processing and protecting your personal data. We do so in accordance with the provisions of the applicable privacy legislation (including the General Data Protection Regulation). 

To safeguard your privacy as far as possible, we adhere to the following core values: 

Information: We want to inform you about why and how we use your personal data. This is described in this Privacy Policy.

Limited collection: We take great care to limit the information we collect and use to only the information that is necessary for selling our products and/or providing our services (as defined below).

Security: We take appropriate measures to secure your personal data and require the same of the parties that use your data on our behalf. DOUXE proactively and continuously tests its websites and apps by means of an automated security scan.

Rights of individuals: We respect your rights under the applicable privacy laws (including the right to access, correct or erase your personal data in accordance with such laws).

This Privacy Policy describes how we implement these core values and how we respect and protect your right to privacy. We urge you to read this statement carefully, as it sets out the basis on which we use your personal data when you buy our products online, in one of our stores or through other DOUXE points of sale (‘Products’), when you access our websites, are in contact with us or otherwise use our services and applications (together referred to as ‘Services’). 

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. 

2. Personal data that we collect and use
The personal data we collect about you when you buy our products or use our services include the following (hereinafter together referred to as ‘Personal Data’): 

Your contact details. Your name, postal address and other contact details, such as your telephone number and email address, and any other contact details you provide to us (including your delivery address when you buy our Products online).

Your electronic identification data and other information we collect automatically when you use our online Services. When you visit our websites or apps, use (opening, clicking, reading, cursor movements, etc.) our newsletter or are shown online marketing advertisements from DOUXE, we automatically collect data via your browser or device, using cookies and other technologies to track visitors to the website (including web analytics), such as your IP address, MAC address, your browsing behaviour, the Products and Services you like and the contents of your abandoned shopping basket. 

Your account details. To complete your DOUXE account online (if applicable), we use your name, gender, contact details, date of birth (plus your citizen service number, or burgerservicenummer, if under local legislation it is linked to your date of birth) and other information you provide to us voluntarily.

Your online purchases. To complete your online purchases via the official DOUXE webshop or via other official DOUXE social media channels, we use your name, gender, telephone number, contact details and all relevant information about your purchases, such as the amount and date of your purchases, the product or products you buy, the device with which you make your purchases, payment method, payment status, bank account details, (employee) discount, voucher code used (if any), gift with purchase (if applicable), optional additional personal card or engraving details, delivery method and delivery address.

Your data when you subscribe to our newsletter. To be able to send you the DOUXE newsletter with inspiring and commercial content, we use your email address and additional information if you add it to your profile, such as your name and date of birth. DOUXE also sends personalised newsletters based on your personal preferences if you have provided them to us.

Recordings. If you attend events or trade fairs organised or attended by DOUXE, you may also be recorded if we make video footage of such events or trade fairs.

Your communication data. All data you share when you communicate with us by email, online, by telephone, via social media or in any other form, such as questions, requests or complaints.

Your data relating to lotteries, subscribe-and-win promotions, lead generation campaigns, competitions or trial promotions. All data you share when you take part in a lottery, a sales promotion campaign, competition or trial promotion, or when you subscribe and win.

Your ratings, reviews and feedback. The opinions, experiences, preferences and interests, and Product or event reviews, that you publish on our websites or share with us online or via social media.

3. Purposes of the use of personal data
The Personal Data we collect are used exclusively for the following purposes: 

For the performance of our agreement with you: To perform our obligations arising from contracts between you and us and to provide you with the Products, Services and information you request, including managing and handling your requests, questions or complaints. This also includes enabling you to purchase our Products, responding to your requests in order to provide customer service, responding to your questions, providing essential information about the products and services you request, etc. 

For our legitimate commercial interests: We use your Personal Data as described above (on both an aggregated and an individual basis) for the purpose of advertising our Products and Services and of contacting you by email, ordinary post, social media or otherwise for direct marketing or other commercial purposes. We also use your Personal Data to analyse and improve the quality of our Products and Services, such as the provision of customer service and aftersales, and to understand you as a customer (customer optimisation). This enables us to find out what may interest you, to measure and understand the effectiveness of the advertisements we offer to you and others, and to deliver relevant advertisements. In addition, based on your use of our Services and the Products you have purchased, we may approach you with advertisements or other marketing material tailored to your personal preferences and experiences. 

We may also use your Personal Data for our other legitimate commercial interests, such as operating and expanding our business activities; developing and improving or adapting our Products and Services; generating aggregated statistics about the users of our Products and Services; enabling our business activities; implementing the company’s policies and procedures; enabling us to carry out business transactions, such as a merger, sale, reorganisation, transfer of assets or business activities of DOUXE, acquisition, bankruptcy or similar event; or for other legitimate business purposes permitted by applicable law. 

Use of information based on your consent: 
If you have not bought a Product from us, we will only send you direct marketing messages (such as newsletters, promotions, product news or service updates) by email, other electronic means, by telephone or by regular mail (such as leaflets) after we have obtained your consent to do so. 

Children under the age of 16 cannot legally give consent. Instead, consent must be given by their parent or legal guardian. 

You can withdraw your consent at any time (see the section Your rights below). 

To comply with our legal obligations: All Personal Data we collect may be used to comply with a legal obligation to which we are subject, such as supervisory authorities, tax authorities or investigative bodies.  

4. Social media
When you take part in various social media forums such as Facebook, Twitter, Pinterest, Instagram, LinkedIn, etc., you should be familiar with and understand the tools of those sites, so that you can make choices about how you share the personal data in your social media profile(s). 

DOUXE is not responsible for the privacy practices or policies of these third parties, so we recommend that you read the applicable privacy statements, terms of use and related information about how your personal data are used in these social media environments. 

Depending on the choices you have made regarding your settings on various social media sites (and/or in combination with your settings on the DOUXE pages), certain personal data about your online activities and social media profiles may be shared with DOUXE (e.g. interests, marital status, gender, username, photo, comments and content you have posted/shared, etc.). 

5. Sharing your personal data
We share your Personal Data with the following parties:

Other entities within the DOUXE Group. Your Personal Data are shared between the responsible DOUXE entities, which may use your personal data as described in this Privacy Policy. An overview of the relevant responsible DOUXE entities can be found here.

External suppliers. From time to time we contact third parties to help us deliver our Products and Services to you, including:

- Business partners, suppliers and subcontractors; 

- Advertising and media companies that carry out marketing and media activities for us; 

- Providers of analytics services and search engines that help us improve and optimise our website and apps, such as Google Analytics. 

In providing their services, they will access, receive, maintain or otherwise process Personal Data on our behalf. Our contracts with these service providers do not permit the use of your Personal Data for their own (marketing) purposes. In accordance with applicable legal requirements, we take commercially reasonable steps to require third-party suppliers to protect your personal data adequately and to process them only in accordance with our instructions. 

Business transaction. In addition, Personal Data may be disclosed as part of a merger, sale or transfer of DOUXE’s assets.

Third parties in the event of a legal requirement. We may disclose your Personal Data if we believe this is required by law.

With consent. We may also disclose information about you, including personal data, to another third party where you have given consent or have asked us to do so, for example in the case of a promotional campaign with another sponsor.

6. International transfers of your personal data
In most cases, your Personal Data are processed within the European Union. Please note, however, that DOUXE may transfer all Personal Data you provide to us to, and process them in, countries other than the country in which you reside. The laws of these countries may not offer the same level of protection for your Personal Data. DOUXE or the external suppliers we use will therefore ensure that all adequate safeguards are taken and that all applicable laws and regulations are complied with in connection with such transfer, more particularly for Personal Data transferred to countries outside the European Economic Area. This means that we have concluded legally necessary contracts with recipients of your data, including standard contractual clauses as approved by the European Commission or other supervisory authorities, where required. 

You are entitled to a copy of all documentation showing the appropriate security measures that have been taken, by submitting a request via customercare@douxe.eu.

7. Security
We will take reasonable steps to ensure that your Personal Data are properly secured by means of appropriate technical, physical and organisational measures, so that they are protected against unauthorised or unlawful use, alteration, unauthorised access or disclosure, accidental or unlawful destruction and loss. 

We take steps to limit access to your Personal Data to those persons who need access to them for one of the purposes stated in this Privacy Policy. In addition, we ensure contractually that any external supplier processing your Personal Data safeguards the confidentiality and integrity of your data in a secure manner. 

8. Data retention
We retain your Personal Data for as long as necessary to fulfil the purpose for which they were collected and used (for example, for the time needed to provide you with customer service, answer questions or resolve technical problems), unless a longer period is necessary for our legal obligations or to defend a legal claim. 

9. Your rights 
Subject to the conditions set out in the applicable legislation, you have the following rights with regard to our processing of your Personal Data: 

Right of access – You have the right to ask for confirmation as to whether DOUXE processes personal data about you and, if so, to access the personal data and additional information. On request, we can also provide you with a copy of the personal data being processed;

Right to rectification – You have the right to request that DOUXE correct, amend or complete your Personal Data if we hold incorrect or incomplete data about you. You can also correct, amend or complete your personal data yourself by updating your profile. We also kindly ask you to ensure that changes in personal circumstances (such as changes of address, bank account, etc.) are reported to DOUXE so that we can ensure your personal data are up to date. DOUXE will take all reasonable steps to ensure that all Personal Data are correct;

Right to withdraw consent – You have the right to withdraw your consent to receiving marketing communications at any time by following the instructions in a marketing communication or by completing the contact form as described below. If we use your Personal Data on the basis of your consent for reasons other than marketing communications, you can withdraw your consent by completing the contact form as described below;

Right to erasure – You have the right to request the erasure of all irrelevant Personal Data we hold about you where (i) the data are no longer necessary in relation to the purposes for which they are collected; (ii) you withdraw your consent and there is no other legal ground for processing; (iii) you object to the processing in the case of direct marketing purposes or - in all other cases - there is no overriding legitimate ground for processing; (iv) we have processed your data unlawfully. If you make such a request and all requirements are met, we will ensure that DOUXE erases the data that we are not legally obliged to retain;

Right to restriction of data use – You have the right to restrict our use of your Personal Data where (i) you contest the accuracy of the Personal Data; (ii) the use is unlawful but you do not want us to erase the data; (iii) we no longer need the Personal Data for the relevant purposes, but you need them for the establishment, exercise or defence of legal claims; or (iv) where you object to data use based on our legitimate interests, pending verification of whether DOUXE does indeed have compelling interests to continue the relevant data use;

Right to data portability – to the extent that we use your Personal Data for the performance of an agreement with you and that personal data are processed automatically, you have the right to receive all such Personal Data that you have provided to DOUXE in a structured, commonly used and machine-readable format, and also to require us to transmit them to another controller where this is technically feasible;

Right to object – insofar as we rely on our legitimate interests to use your Personal Data, you have the right to object to such use and we must stop this processing unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or where we need to process the data for the establishment, exercise or defence of legal claims. You also have the right to object to profiling activities carried out by DOUXE;

Right to lodge a complaint – You also have the right to lodge a complaint with a supervisory authority, in particular in the Member State in which you reside, if you believe that the collection and use of your Personal Data are contrary to this Privacy Policy or the applicable legislation.

For more information about your rights, or how to exercise your rights, please complete this contact form, and do the following: 

Select the option ‘privacy request’ under ‘Choose subject’; and

Select the relevant subcategory; and

Enter all email addresses that you use and have used for all related DOUXE services in the comments field, such as but not limited to the newsletter sign-up, the webshop account, etc.;

Upload a copy of your identity card/passport on which you have blacked out all information that is not required to identify you, which is everything except your first name and surname. For the avoidance of doubt, black out the following information:

- Citizen service number (burgerservicenummer) (please note that on some identity cards/passports this appears in 2 different places);
- Document number; 
- Nationality; 
- Date of birth; 
- Place of birth; 
- Height; 
- Date of issue; 
- Expiry date. 

Please note that the Dutch government has created an app (‘Kopie ID’) that makes it easier to black out lines on passports, see: https://www.rijksoverheid.nl/onderwerpen/identiteitsfraude/vraag-en-antwoord/veilige-kopie-identiteitsbewijs. 

Once we have received all the information set out above, we will respond to your request in accordance with the applicable legislation. 

10. Changes to this policy
This Privacy Policy may be revised from time to time. If there is a fundamental change in the nature of the use of your personal data, or if the change is relevant to you in another way, we will ensure that this information is provided well in advance of the change actually taking effect. 

11. Contact us
If you have any questions about this Privacy Policy or our handling of your Personal Data in general, please send an email to info@douxe.eu and make sure you state the type of your request.