Privacy Statement E-RetailCom B.V.

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November, 17th 2020

Your privacy is of great importance to E-RetailCom B.V. (acting under the name Accelerate2). We therefore comply with the relevant laws and regulations on privacy, including the General Data Protection Regulation (further: GDPR). This means that we:

• Clearly state our purposes before we process your personal data, via this privacy statement;
• Storing as little personal data as possible and only the data needed for our purposes;
• Explicitly request permission to process your personal data, should consent be required;
• Take necessary security measures to protect your personal information. We also impose these obligations on parties who process personal data for us;
• Respect your rights, such as the right to access, correct or delete, your personal data.

Your data is safe with us and we will always use this data properly. In this privacy statement, we explain what we do with information we have about you.

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Our service

When using our service, your (mobile) phone number is entered into our system by the store you have visited (the controller of your personal data). We use the phone number to send you a link to the online form, to provide your personal details necessary for the store’s loyalty program. As mentioned above, the store (our customer) is the controller for the personal data collected from you. E-RetailCom is a data processor. If you have any questions about the processing of your personal data for this purpose, or you wish to exercise one of the rights you have under the GDPR, please contact the store via the designated contact details in their privacy statement.

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Website

In order to be able to offer the website, we receive some usage data. This data is not easily traceable to you as an individual. Nevertheless, they are personal data under the definition of the GDPR. The following types of data are collected by us:

• IP-address
• Browser information
• Browsing behaviour on our website

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Contact form

By filling out a contact form on the website, you provide us with your personal data. To fully answer and correctly handle your request, the data will be saved for as long as necessary to answer or address your request. By filling out the contact form, we ask you to provide the following data:

• Name
• Email address
• Phone number
• (any other information you mention in your post)

We process this data on the legal basis performance of a contract. We will retain this information until we are sure that you are satisfied with our response.

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Sharing personal data with other companies or institutions

We do not provide your personal data to other companies or institutions under any circumstances, except for cloud hosting purposes, which is necessary for the provision of our services, and if we are required by law (for example, criminal investigation).

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Security

We have implemented technical and organizational measures to protect your personal data against loss or any form of unlawful processing. In particular, we have implemented the following measures:

• ‍Time-limited access to sensitive components;
• Two-factor authentication for sensitive components;
• Employees have access to data on a need-to-know basis;
• Four-eye-principle for various data, including financial data;
• Comprehensive logging and monitoring (internal and external);
• Outsourcing policy with confidentiality agreement;
• Data retention policy; and
• Deployment of internal and external Compliance Officers to validate compliance with internal procedures, including the required PES (which also includes a Certificate of Good Conduct from the Ministry of Justice) for every newly hired employee.

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Changes to this privacy statement

When our website changes, we also need to change the privacy statement. So always pay attention to the date above and check regularly for new versions.

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Your rights

If you have any questions or want to know what personal data we have of you, you can always contact us. See the contact details below.

You have the following rights:

• Get an explanation about what personal data we have and what we do with it;
• Access to the personal data we have;
• Having errors corrected;
• Having outdated personal data deleted;
• Having personal data transferred to another party;
• Withdrawal of consent;
• Restrict a particular processing;
• Object to a particular use.

Please note that you always clearly indicate who you are, so that we can be sure that we are not modifying or deleting data from the wrong person.

We will in principle comply with your request within a month. However, this period may be extended on grounds relating to the specific rights of other data subjects or the complexity of the request. If we extend this period, we will notify you in time.

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Filing a complaint

If you wish to file a complaint about the use of your personal data, you can send an email to info@e-retailcom.nl. We will handle each complaint internally and communicate the outcome with you.

If you feel that we are not helping you in the right way, then you have the right to file a complaint with the Dutch Data Protection Authority. This is called the Autoriteit Persoonsgegevens.

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Contact details

E-RetailCom B.V.
Bijsterhuizen 2401
6604 LK Wijchen
E-mailadres: info@e-retailcom.nl

Dutch Chamber of Commerce (KvK) registration number: 69181950