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Hunkemöller Privacy Statement
Date: 06/09/23
Hunkemöller B.V. and its subsidiaries (hereinafter also referred to as Hunkemöller, or we, us, our) are committed to protecting your personal data. It is important for us to use your personal data carefully and securely in a transparent manner in accordance with the applicable privacy laws (including the General Data Protection Regulation).
What information you can find in this Privacy Statement
In this Privacy Statement we explain:
- What personal data we collect.
- When we collect your personal data.
- How we use such personal data.
- How long do we keep your personal data in relation to our stores, webshop and app.
- Who we share your data with.
- Your data subject rights and how we respect them.
This privacy statement may be updated in the event of new developments, such as changes to our use of your personal data or to reflect changes in regulatory requirements. When there is an update, we will notify you in this Privacy Statement. We will notify you separately of any significant changes to our Privacy Statement via email.
INDEX
1. Who is responsible for the processing of your personal data?
Hunkemöller B.V. is the main data controller responsible for the processing of your personal data. If you have any questions about our Privacy Statement or want to exercise your rights as explained in our Privacy Statement, please let us know.
2. When do we collect personal data and when does this privacy statement apply?
2.1 If you become a member (in-store and online) of Hunkemöller and create a My Hunkemöller account
- by receiving a physical membercard in any of our stores and registering it in the store, with the assistance of one of our co-workers and activating it online in a My Hunkemöller account (see below for more information), or
- by registering directly online on our website or app by creating a My Hunkemöller account. You can only create an account if you also wish to become a member.
If you obtained your membercard in one of our stores, you will need to activate your membercard in our webshop or app by creating a My Hunkemöller account to be able to redeem your collected Passion Points and shop credit. If you become a member and you have activated your membership, you will receive the full benefits of our loyalty programme for members, including receiving and redeeming Passion Points and shop credit, receiving gifts with purchase, surprises on your birthday, and getting access to exclusive member days.
Tailoring marketing communications to your interests: Tailor marketing communications to your interests: As a member, you will receive by email, regular mail or, depending on your cookie choice, online personalised advertisements (for more details please see Section 3 of this Privacy Policy), offers, information on our promotions and events, product suggestions and recommendations you may be interested in that are even more relevant to your online shopping with us, if you have provided consent to receiving marketing communications from us.
- Personalisation and targeting with cookies: If you are logged-in on your My Hunkemöller account as a member and provided your consent to the use of cookies via the cookie banner on our webshop or app, we will collect the products or content you viewed, products you added to your shopping basket but did not yet purchase, to track your shopping habits, advertisements you viewed or interacted with, and your potential interests gleaned from such browsing behaviour.
- You can of course always choose not to use your membercard when purchasing products in one of our stores, webshop or app, or choose not to be logged-in in your My Hunkemöller account when ordering products on our webshop or app. You will then however not benefit fully from your membercard, and you will not receive Passion Points for such purchases.
- Managing your membercard and personal data: In addition to contacting us using the contact details below, you can also directly manage your privacy settings (providing your consent or withdrawing your consent to receiving marketing communications), or, adjust or correct your address, email address, preferences, and size information via your My Hunkemöller account. If you want to cancel your membership, please contact us..
- Children and becoming a member and shopping online: You need to be 12 years or older to become a member of Hunkemöller. If you are above 12 years but under 16 years, you can still become a member, but you will not receive marketing communications from us and we will only process your personal data for when you have bought products in one of our stores, and letting you collect, administer and redeem Passion Points and credits in our stores. You need to be 16 years or older to be able to shop online. If you are under 16 years, please do not shop on our webshop or via the app. We do not knowingly collect personal data from children under the age of 12. If you are a parent or legal guardian and have reason to believe that your child under the age of 12 has provided personal data to us, please email us using the contact details below, or email our data protection officer at Privacy@hunkemoller.com, and we will endeavour to delete that information from our databases.
Picking-up online orders or returning products ordered online in one of our stores.
When picking up an order in one of our stores, we ask you to show an email/text message (e.g. confirmation email) where the name of the original purchaser and order number is stated as a proof of purchase. If someone else picks up your parcel, we ask this person to show an identification document with his/her name and signature on it (e.g. ID, drivers’ license or credit card). The collector is also asked to show an email/text message where the name of the original purchaser and the order number is stated. We will not copy or collect your identity details from your identity document. We will only record your name, the date when the order arrived and when it was collected, the details of your order and payment, and any feedback you have on the pick-up form you have to sign when picking-up a product in one of our stores. The signed pick-up forms will be retained for 6 months.
2.1.1 What personal data do we collect?
To provide you all benefits of your membercard and allow you to benefit from a more personal shopping experience tailored to your interest, preferences, wishes, and things you may love, we collect and use the following personal data of you, depending on whether you have activated your membercard (if you have not yet activated your My Hunkemöller account, we will only process the member registration details you provided in-store and your in-store purchases to provide and administer Passion Points), completed your My Hunkemöller account registration details, and your interactions with us:
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2.1.2 Why do we collect this personal data?
When you become a member, we use your personal data for the following purposes:
2.1.3 Legal processing grounds for using your personal data
We process your personal data only if this is allowed under one of the legal processing grounds. We rely on one of the following legal grounds for the processing of your member data:
2.1.4 How did we obtain your personal data?
We may obtain your personal data directly from you, such as when you register or activate your membercard, create a My Hunkemöller account, visit our webshop, use our app, place orders, make in-store purchases, ask questions or give feedback. We may also receive your personal data from third parties, such as the cookie providers listed in our Cookie Policy, loyalty services we use to make sure that you can save and redeem Passion Points and credits, Facebook if you have used your Facebook account to login to our website, logistic services we use to handle online orders and returns, the package delivery company we use to send your package, and payment service provider Adyen N.V.
2.1.5 How long do we retain your personal data?
We will not retain your personal data longer than necessary in relation to the purposes for which the data are processed. If you are a member, we will hold on to your information for as long as you continue to be an active member, or as long as is needed for us to be able to provide the relevant products or services to you. If you are inactive as a member by not using your membercard for six (6) years, we will send you an email asking whether you still wish to be a member. If you remain inactive thereafter, we will cancel your membership and My Hunkemöller account and delete your personal data related to your membership. We are required to retain receipts and refunds to comply with fiscal minimum retention obligations.Please read our Cookie Policy for more information on how long cookies remain valid.
In some circumstances, such as to meet our legal or regulatory (accounting and fiscal) minimum retention term obligations, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions, we may hold on to your personal data after we have cancelled your membership or finished providing products and services to you.
- (Full) Name
- Date of birth
- Complete (home) address (billing)
- Mail address (shipping)
- Email address
- Membercard number
- Phone number(s)
- Gender
- Outstanding and redeemed Passion Points
- Credit balance and redeemed credit
- Your in-store and online purchased products, and their size, color, price and other product details
- Where you have purchased products, such as which shop
- Time and date of your purchases
- Returned products, date on which you indicated you wish to return products, date of returning products.
- Sizes (bra size, brief size, fashion size)
- Sexy Shape(s)
- Favourite Fit(s)
- Whether you provided consent to receiving marketing communications, via which channel (online, in-store, app) and date and time.
- Payment details: bank account number, bank or credit card number, time and date of payment. We do not store any bank account or credit card numbers (unless you have provided your consent, we store this encrypted so that you don’t have to fill in these details for your next purchase) once the transaction has successfully been completed. We share your personal information with credit card companies and other payment providers only for the payment of your transaction.
- If you selected to pay your order after delivery, whether the third party you selected accepted you as a debtor. These third parties will check your credit worthiness and check for fraud. We do not receive the actual credit and fraud checks. We only receive whether the order can be completed.
- If you liked us or shared our posts on social media, such as Facebook or Instagram, and additional Passion Points given for such likes or shares.
- For more information on the personal data we collect and use if you, visit our stores and purchase products or use our webshop and place orders (without an account), use our app, or join events, please refer to the relevant sections in this Privacy Statement.
- To give you Passion Points, based on your purchases and likes on social media, administering your Passion Points, and let you redeem Passion Points and credits.
- To provide Passion Points or other surprises on your birthday.
- If you provided consent to receiving marketing communications such as newsletters and push notifications via the app, we will use you contact details to send you marketing communications.
- To provide you personalized and more relevant offers, discounts, invitations, online and in-store suggestions and recommendations tailored to you based on your personal data collected in our stores or online in our webshop or app, including your purchases, where you have purchased products, such as which shop, size information, Sexy Shapes, Favourite Fits, date of birth, Passion Points & credit balance, viewed products and advertisements, products added to your online shopping basket, or advertisements you interacted with.
- If you provided consent, to show you relevant advertising on social media, such as Facebook and Instagram or on websites of third parties, such as search engines or third party advertising that may appear on other websites of third parties you visit.
- Contact you with important information relating to your membercard, Passion Points and credits, or purchases, including confirming your order.
- To process purchases, orders, payments, returns and debt collections.
- To manage your My Hunkemöller account you use as a member.
- To provide you the functionalities of your My Hunkemöller account by allowing you to keep wish lists, place orders more easily and quickly, and placing orders similar to your previous orders
- To provide customer support and appropriately handle and respond to your questions, requests, feedback, or complaint
- To secure your My Hunkemöller account and our systems
- To analyze the use of membercards, products purchased, used services, and abandoned shopping baskets in our webshop on an aggregate basis to improve and optimize our products and services, including in-store and online offerings, on a general basis.
- To prevent, investigate, handle or report fraud or theft.
- To comply with a legal obligation, a court order, or to exercise or defend legal claims.
- Consent
- If you provide your consent, we will use your contact details to send you marketing communications or show relevant advertisements on social media platforms you are using, such as Facebook, Instagram, Snapchat and Pinterest.
- Should you consent to our use of cookies, we will also collect information on your browsing behavior and shopping habits to determine your interests and things you may love and link such collected information to your My Hunkemöller account if you are logged-in. For further information about cookies, the information collected via cookies, and how Hunkemöller uses such information, please read our Cookie Policy.
You can withdraw your consent to receiving marketing communications at any time at the bottom of every newsletter you receive, by contacting us, or if you have a My Hunkemöller account under your profile details. Please read our Cookie Policy for how you can withdraw your consent for cookies at any time. Withdrawing your consent will not affect the lawfulness of our use of your personal data before your withdrawal.
- Performance of a contract with you
- If you are a member, we also process your personal data for entering into and performance of a contract with you, namely to carry out the member programme and provide you the benefits thereof. This sees to rewarding you with Passion Points, administering your Passion Points, letting you redeem Passion Points and credits, giving your birthday surprise, allowing you to join our exclusive member events, and handling your in-store or online purchases. We need your personal data to perform the member programme and handle your purchases and returns. If you do not activate your membercard or do not fully complete your registration, you may not redeem any collected Passion Points. Please see our terms and conditions for our membercard here for more information.
- To provide you the functionalities of your My Hunkemöller account.
- Legal obligation
We process your personal data if necessary for complying with one of our legal obligations.- We are required to process your information to comply with accounting requirements.
- We are also required to retain receipts and refunds to comply with fiscal minimum retention obligations.
- We may also be required to process or disclose your personal data based on a court order or order of a competent governmental authority.
- Legitimate interests
We process your personal data as necessary for achieving our legitimate interests:- At Hunkemöller we like to get to know our valued members, their preferences, interests, and things they may love, and segment them into specific customer audience groups based on the information obtained or analyzed from your personal data, including purchasing and browsing behavior, shopping habits, demographics, and other personal data as described under "what personal data do we collect". This allows us to improve our business by finding new ways to provide you with a more personal and seamless shopping experience and increasing customer satisfaction, such as by recommending products that would be a better fit for you to help you pick the right products that you will love to wear and make your shopping more efficient.
- Sending you a message within 1 hour if you are logged in on whether you wish to complete your order for the products added and left in your shopping basket on our webshop after you closed our webshop or app for managing inventory, increase customer satisfaction by reminding you on (sale) products you still wish to purchase, and improve our business.
- Reduce business risks by detecting and reducing credit and fraud risks and verifying your identity.
- Evaluating and improving the quality of our products and services, including developing new products and services, to improve our business.
- To protect our business against unlawful activities by implementing security measures.
2.2 If you use our webshop and place orders without an account
You can visit our webshop, and shop in our webshop also without an account. We will then process your personal data in relation to your visit to our webshop or app. If you place orders, we will also process your personal data to ensuring that your order is handled properly. For more information on the personal data we collect and use if you visit our stores and purchase products or become a member, use our app, or join events, prizes, and competitions, please refer to the relevant sections in this Privacy Statement.
- · Targeting you using cookies: If you provided your consent to the use of cookies via the cookie banner on our webshop, the advertising cookies from third parties we use allow these third parties and us to recognize your device and track your browsing behaviour on our webshop and on third-party websites, which results in online personalised advertisements (for more details please see Section 3 of this Privacy Policy).
2.2.1 What personal data do we collect?
If you use our webshop and order products without an account, we use the following personal data of you:
- If you visit our webshop:
- If you accepted cookies on our webshop, information collected via the advertising cookies of third parties we use on our webshop, such as viewed webpages, products you have shown an interest in by clicking or viewing the product or adding it to your shopping basket or by clicking on an advertisement in our webshop or websites of third parties. For further information about cookies, the information collected via cookies, and how Hunkemöller uses such information, please read our Cookie Policy.
- IP-address and time and date of your visit.
- Any questions, requests, feedback, or complaints.
- Whether you subscribed to receiving our marketing communications by email or other contact details you provided.
- If you allow browser push notifications on our website, we will send you marketing communication via your web browser. We will collect your Membercard number, first and last name and your Device ID.
- Any questions, requests, feedback, or complaints.
- If you write a product review on our website: email address, IP address, device information and unique identifier from Yotpo (third party service).
- In addition, we also use the following personal data of you if you place an order:
- Name
- Address
- Delivery and billing address: Your delivery address will be shared with our external delivery/transport partners who will take care of the delivery of your purchases to your delivery address.
- Email address
- Personal note (optional when you buy a gift
- Track&trace number
- Details of your order: time of your purchases, purchased products, details of the purchased products, including their size, color, and price.
- Payment details: bank account number, bank or credit card number, time of payment, payment method, including if you selected to pay your order after delivery. We do not store any payment account or card numbers once the transaction has been completed. We share your personal information with credit card companies and other payment providers for the payment of your transaction.
- If you choose to pick-up your order in one of our stores, your pick-up location.
- Information on returns and reimbursements.
2.2.2 Why do we collect this personal data?
When you visit our webshop, or place orders, we use your personal data for the following purposes:
- To process purchases, orders, payments, and debt collections.
- To provide you the functionalities our webshop such as required in order to remain logged in while shopping, save your current language selection.
- If you provided consent to receiving marketing communications such as newsletters, push notifications in your browser, to send you such marketing communications.
- To provide you offers, discounts, invitations, suggestions and recommendations on our webshop or websites of third parties tailored to you based on the information collected online via our use of third party advertising cookies, including your purchases, viewed products and advertisements, products added to your online shopping basket, or advertisements you interacted with.
- If you provided your consent to receiving marketing communications from us, such communications will also be tailored to you.
- If you write a product review on our website: to collect the reviews and display them on our website, to analyze on an aggregate basis to improve our products, authenticity and fraud detection and hosted authentication.
- Contact you with important information relating to your purchases, including confirming your order.
- To provide customer support and appropriately handle and respond to products you wish to return, reimbursement of your payments, and your questions, requests, feedback, or complaints.
- To secure your use of our webshop, placement of an order, and our systems.
- To analyze the use of our webshop, such as products purchased, used services, and abandoned shopping baskets, on an aggregate basis to improve and optimize our products and services, including our webshop, on a general basis.
- To prevent, investigate, handle or report fraud or theft.
- To comply with a legal obligation, a court order, or to exercise or defend legal claims.
2.2.3 Legal processing grounds for using your personal data
We process your personal data only if this is allowed under one of the legal processing grounds. We rely on one of the following legal grounds for the processing of your personal data in relation to your use of our webshop and online orders:
- Consent
- If you provide your consent, we will use your contact details to send you marketing communications or show relevant advertisements on social media platforms you are using, such as Facebook and Instagram.
- Should you consent to our use of cookies, we will also collect information on your browsing behavior and shopping habits to determine your interests and things you may love. For further information about cookies, the information collected via cookies, and how we use such information, please read our Cookie Policy.
- If you write a product review on our website, we will only place such review if you provide your consent.
You can withdraw your consent to receiving marketing communications at any time at the bottom of every newsletter you receive or by contacting us. Please read our Cookie Policy for how you can withdraw your consent for cookies at any time. Withdrawing your consent will not affect the lawfulness of our use of your personal data before your withdrawal.
- Performance of a contract with you
- We also process your personal data for entering into and performance of a contract with you, namely to provide you the functionalities of our webshop and handling your online purchases.
- Legal obligation
We process your personal data if necessary for complying with one of our legal obligations.
- We are required to process your information to comply with accounting requirements.
- We are also required to retain receipts and refunds to comply with fiscal minimum retention obligations.
- We may also be required to process or disclose your personal data based on a court order or order of a competent governmental authority.
- Legitimate interests
We process your personal data as necessary for achieving our legitimate interests:
- At Hunkemöller we like to get to know our customers, their preferences, interests, and things they may love obtained or analyzed from your personal data, including purchasing and browsing behavior, shopping habits, demographics, and other personal data as described under "what personal data do we collect". This allows us to improve our business by finding new ways to provide you with a more personal and seamless shopping experience and increasing customer satisfaction, such as by recommending products that would be a better fit for you to help you pick the right products that you will love to wear and make your shopping more user friendly and efficient.
- Reduce business risks by detecting and reducing credit and fraud risks.
- Evaluating and improving the quality of our products and services, including developing new products and services, to improve our business.
- To protect our business against unlawful activities by implementing security measures.
2.2.4 How did we obtain your personal data?
We obtain your personal data directly from you when you provide your information when placing an order or visit our web shop, allow push notifications in your browser, write a product review, ask questions or make requests. We may also receive your personal data from third parties, namely cookie providers listed in our Cookie Policy, logistic services we use to handle online orders and returns, the package delivery company we use to send your package, and payment service providers we use to process your payment, namely Adyen N.V.
2.2.5 How long do we retain your personal data?
We will not retain your personal data longer than necessary in relation to the purposes for which the data are processed. If you place and order without being a member or without having a My Hunkemöller account, we will hold on to your information for as long as is needed for us to be able to provide the relevant products or services to you. After handling your order, we are required to keep your personal data, including purchased products, to retain this information to comply with fiscal retention obligations.
If you allow to receive push notifications in your browser we will store your personal data for a period of 2 years.
If you write a product review on our website, we retain your personal data for a period of 18 months, unless you request us to remove your review any sooner.
Please read our Cookie Policy for more information on how long cookies remain valid.
In some circumstances, such as to meet our legal or regulatory (fiscal) minimum retention term obligations, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions, we may hold on to your personal data after finishing providing products and services to you.
2.3 If you use our app and place orders using our app
You can choose to download and use our app, also without a My Hunkemöller account. Our app provides various functions which you can also use without registering, such as the possibility to view our products, to scan product information in our stores and to look for a store which is closest to you. We will only process your geolocation for this purpose if you provided your consent to this in our app. You will only be able to place orders via the app if you have or create a My Hunkemöller account and become a member. If you do not want to become a member, you can place an order via our mobile website as a guest. To download and use our app, we will require details of your smartphone or tablet (your IP-address and your devices MAC address, model and operating system). For more information on the personal data we collect and use if visit our stores and purchase products or become a member, or join events, prizes, and competitions, please refer to the relevant sections in this Privacy Statement.
- Targeting you using cookies: If you provided your consent to the use of cookies via the app, we track how you use our app, meaning the content you viewed, products you added to your shopping basket did not yet purchase, track your shopping habits, in-app promotions you viewed or interacted with, and your potential interests collected from such app use and shopping behaviour. Based on the information, we will make your use of our app and shopping from the app more efficient and tailored to you by showing you products in our app you might also love based on products bought by other customers, the closest store near you where products are still on stock, where you can choose to pick-up your order, to offer you coupons in the app, and showing you more relevant advertisements in the app. For further information about our use of cookies, the information collected via cookies, how Hunkemöller uses such information, and how you can withdraw your consent for cookies at any time, please read our Cookie Policy.
2.3.1 What personal data do we collect?
If you use our app, we use the following personal data of you:
- Your IP-address
- Your device's MAC-address
- Your device's model and operating system
- If you accepted cookies on our app, information collected via the cookies of third parties, such as products you have shown an interest in by viewing the product or adding it to your shopping. For further information about cookies, the information collected via cookies, and how Hunkemöller uses such information, please read our Cookie Policy.
- Whether you wish to receive push messages relating to your order, news, events, promotions and other marketing communication.
- App inbox messages we sent to you as push notifications.
- Whether you subscribed to receiving our marketing communications by email or other contact details you provided.
- Your geolocation to show you which stores are nearest to you and send you push notifications with marketing communications when you are near (within approximately 100 meters of) one of our stores. We also process how many times you were near one of our stores to measure on an aggregate level the effectiveness of our advertising campaigns.
- If you write a product review on our app: email address, IP address, device information and unique identifier from Yotpo (third party service).
- Any questions, requests, feedback, or complaints.
- For more information on the personal data we collect and use in relation to your membership and My Hunkemöller account or placing order via the app, please see the section if you become a member (in-store and online) of Hunkemöller.
2.3.2 Why do we collect this personal data?
When you use our app, we use your personal data for the following purposes:
- To provide you the functionalities our app: creating an account, updating your account, placing an order, save your sizes, Sexy Shapes and Favourite Fits.
- If you provided consent to receiving push notifications for marketing communications, to send you such marketing communications to your inbox in our app via push notifications.
- If you provided your consent to receiving marketing communications from us, such communications will also be tailored to you.
- To provide customer support and appropriately handle and respond to products you wish to return, reimbursement of your payments, and your questions, requests, feedback, or complaints.
- If you provided consent to allow us to access your device’s location, to send you push notifications based on when you are near (within approximately 100 meters of) a Hunkemöller store and to show you the nearest store to you. We also use how many times you were near one of our stores to measures the effectiveness of our advertising campaigns and promotions. Depending on the type and version of the operating system of your device, you can choose whether and when we have access to your location.
- To secure your use of our app and your data stored in the app, and our systems.
- To analyze the use of our app, such as used functionalities, products and content viewed, and abandoned shopping baskets, on an aggregate basis to improve and optimize our products and services, including our webshop, on a general basis.
- If you write a product review on our app: to collect the reviews and display them on our website, to analyze on an aggregate basis to improve our products, authenticity and fraud detection and hosted authentication.
- To prevent, investigate, handle or report fraud or theft.
- To comply with a legal obligation, a court order, or to exercise or defend legal claims.
- For information on the purposes for processing your personal data in relation to your membership and My Hunkemöller account or placing order via the app, please see the section if you become a member (in-store and online) of Hunkemöller.
2.3.3 Legal processing grounds for using your personal data
We process your personal data only if this is allowed under one of the legal processing grounds. We rely on one of the following legal grounds for the processing of your personal data in relation to your use of our app:
- Consent
- If you provide your consent, we will use your contact details to send you marketing communications.
- Sending you push notifications, including our marketing related notifications, if you consented to receiving such notifications.
- Using your geolocation to show nearest shops and send you push notifications based on your geolocation when you are near (within approximately 100 meters of) one of our stores.
- Should you consent to our use of cookies, we will also collect information on your app use behavior and shopping habits to determine your interests and things you may love. For further information about cookies, the information collected via cookies, and how we use such information, please read our Cookie Policy.
- If you write a product review on our website, we will only place such review if you provide your consent.
You can withdraw your consent to receiving marketing communications at the bottom of every newsletter you receive from us or by contacting us, or if you have a My Hunkemöller account under your profile details. Please read our Cookie Policy for how you can withdraw your consent for cookies at any time. Withdrawing your consent will not affect the lawfulness of our use of your personal data before your withdrawal.
- • Performance of a contract with you
- We also process your personal data for entering into and performance of a contract with you, namely to provide you the functionalities of our app. If you do not create a My Hunkemöller account, you will not be able to benefit from its functionalities.
- Legal obligation
We process your personal data if necessary for complying with one of our legal obligations.
- We may also be required to process or disclose your personal data based on a court order or order of a competent governmental authority.
- Legitimate interests
We process your personal data as necessary for achieving our legitimate interests:
- At Hunkemöller we like to get to know our customers, their preferences, interests, and things they may love, and segment them into specific customer audience groups based on the information obtained or analyzed from your personal data, including purchasing and app use behavior, shopping habits, demographics, and other personal data as described under "what personal data do we collect". This allows us to improve our business by finding new ways to provide you with a more personal and seamless shopping experience and increasing customer satisfaction, such as by recommending products that would be a better fit for you to help you pick the right products that you will love to wear and make your shopping more efficient.
- Reduce business risks by detecting and reducing credit and fraud risks and verifying your identify.
- Evaluating and improving the quality of our products and services, including developing new products and services, to improve our business.
- To protect our business against unlawful activities by implementing security measures.li>
2.3.4 How did we obtain your personal data?
We obtain your personal data directly from you through your use of our app and information you enter in the app, if you give us access to your location, or when you ask questions or make requests.
2.3.5 How long do we retain your personal data?
The app itself does not retain any of our personal data. The app has only access to your personal data stored in our supplier's systems. See who will have access to your personal data for more information on our suppliers. We will not retain your personal data longer than necessary in relation to the purposes for which the data are processed. Your personal data obtained by the app will be stored for 2 years. Please read our Cookie Policy for more information on how long cookies remain valid. If you write a product review on our app, we retain your personal data for a period of 18 months, unless you request us to remove your review any sooner.
2.4 If you visit our stores, including CCTV and if you use in-store Wi-Fi
You can of course visit and shop in our stores. At Hunkemöller, we find it very important that you have a wonderful shopping experience in our stores and receive excellent customer service. Our co-workers are trained and pride themselves in advising you on our products and the best fit for you. Our co-workers can also provide information on and register your membercard, scan your membercard and let you collect and redeem Passion Points. For more information on the personal data we collect and use if you visit our stores and are a member, and the seamless shopping experience between your online and in-store shopping, please refer to If you become a member.
Using in-store Wi-Fi: We also offer free Wi-Fi in some of our stores, so you can easily stay connected, look-up information, or share your experience on social media. After your first use of our in-store Wi-Fi, you will be automatically re-connected to our Wi-Fi network when you return into the store, so you do not have to run the entire process again. Our in-store Wi-Fi is provided by SoWifi.
Security camera: There is CCTV surveillance in our stores to protect us and our valued customers against theft and ensure the safety of our customers and co-workers. If you visit our stores, you will be informed of the presence of CCTV cameras via clearly visible signs. When there is a serious incident, such a theft, we will provide relevant CCTV recordings to the competent authorities, such as the police.
3D body scanner: to help you in finding your best fit, there is a scanner available in the fitting rooms of a limited number of stores. You can use these scanners to take your measurements if you wish so. As we find your privacy very important, these scanners only start scanning if you indicate so on the screen, and the scanners do not store, print, or allow us to collect photo or video materials. They only take your measurements and print those measurements for your future reference. If you choose so, you can also email those measurements to yourself or someone else. These emails are immediately deleted from the scanner and our systems upon sending the email.
Wi-Fi and Bluetooth tracking beacons: some of our stores have one or more beacons placed inside the store. If Wi-Fi and/or Bluetooth is turned on, on your device, (smartphones or tablet). your device is sending Wi-Fi and Bluetooth signals and can receive such signals from beacons. Based on signal strengths, these beacons can be used to track your location within our store with an accuracy of 20 centimeters. If you have downloaded our app, given permission to share your locationand you have turned on your Bluetooth, we can see if and when you have visited us.
2.4.1 What personal data do we collect?
If you visit or shop in our stores, we use the following personal data of you:
- If you purchase products: your encrypted bank account or credit card number, debit card number, and time and date of your payment, purchased products and your receipt.
- If you pick-up products ordered online: name, date or arrival of your order, when you picked-up your order from our store, details of your order, and payment details.
- Email address, if you wish to receive receipts via email or indicate to our co-worker that you wish to receive marketing communications from us by email or other channels.
- If you return products: our staff has access to your order information if you ordered the products online, to be able to process your return. We also process your return information, namely the date and time of your return, reimbursements you receive, items you have returned, and items you keep (if any).
- Any questions, requests, feedback, or complaints you may have.
- CCTV recordings.
- If you use our in-store Wi-Fi: we collect your MAC address, user agent, data and time of presence and browser language. If you log in with Facebook, we process your user ID, name, date of birth, email, city, gender and access token. If you log in with Twitter / Instagram, we process your user ID, user name, name and access token. If you log in with your Linked in profile, we process your user ID, profile link, name, email address and access token. We do not offer in-store Wi-Fi in all stores.
- If you voluntarily use our 3D body scanner (available in a limited number of stores): you need to create an account to receive your results by email. To register, we require the following information: your name, email address, password, phone number, weight, height and gender. This information will not be stored.
- Beacons: if you have downloaded our app, given permission to share your location and you have turned on your Bluetooth, we can see if and when you’ve visited us.
- If you are a member: current Passion Points and credit balance.
- For more information on the personal data we collect and use in relation to your membership and My Hunkemöller account, please see the section if you become a member (in-store and online) of Hunkemöller.
2.4.2 Why do we collect this personal data?
When you visit and shop in our stores, we use your personal data for the following purposes:
- To provide customer support and appropriately handle and respond to products you wish to pick-up, return, reimbursement of your payments, and your questions, requests, feedback, or complaint.
- To secure our store, ensure the safety of our co-workers and customer, and prevent, limit or deal with incidents.
- If you provided consent to receiving marketing communications by email or other communication channels, to send you such marketing communications.
- If you use a body scanner, to allow you to take your own measurements and, if you wish so, to print or email only the measurements to yourself.
- To analyze visits, pick-ups, purchases and returns in our stores on an aggregate basis to improve and optimize our products, services and marketing on a general basis.
- To prevent, investigate, handle or report theft.
- To comply with a legal obligation, a court order, or to exercise or defend legal claims.
- For information on the purposes for processing your personal data in relation to your membership or My Hunkemöller account, please see the sections if you become a member (in-store and online) of Hunkemöller.
2.4.3 Legal processing grounds for using your personal data
We process your personal data only if this is allowed under one of the legal processing grounds. We rely on one of the following legal grounds for the processing of your personal data in relation to your visit to our shops:
- Consent
- If you provide your consent, we will use your contact details to send you marketing communications or show relevant advertisements on social media platforms you are using, such as Facebook and Instagram.
- If you wish so, you can use a body scanner to take your own measurements and print or email only the measurements obtained upon your use of a body scanner. These measurements are immediately deleted after your use or printing or emailing of the measurements.
You can withdraw your consent to receiving marketing communications at the bottom of every newsletter you receive from us or by contacting us, or if you have a My Hunkemöller account under your profile details. Withdrawing your consent will not affect the lawfulness of our use of your personal data before your withdrawal.
- Performance of a contract with you
- We also process your personal data for entering into and performance of a contract with you, namely when handling your purchases, including in-store pick-ups, or returns.
- Legal obligation
We process your personal data if necessary for complying with one of our legal obligations.
- We are required to process your information to comply with accounting requirements.
- If you want to reclaim the VAT payed on your purchase, we need to process your personal data for this purpose.
- We are also required to retain receipts and refunds to comply with fiscal minimum retention obligations.
- We may also be required to process or disclose your personal data based on a court order or order of a competent governmental authority.
- Legitimate interests
We process your personal data as necessary for achieving our legitimate interests:
- At Hunkemöller we like to get to know our customers, their preferences, interests, and things they may love. This allows our co-work to advise you better and make more relevant suggestions and recommendation to you, which increase customer satisfaction.
- Evaluating and improving the quality of our products and services, including developing new products and services, to improve our business.
- O To protect our business, co-workers, and customers against unlawful activities and ensure their safety by implementing security measures.
2.4.4 How did we obtain your personal data?
We obtain your personal data directly from you if you visit our store, connect to our Wi-Fi, purchase, pick-up, or return products, redeem Passion Points or credits as a member, use a body scanner or when you ask questions or make requests.
2.4.5 How long do we retain your personal data?
We will not retain your personal data longer than necessary in relation to the purposes for which the data are processed.
Encrypted payment details are only stored locally on our till systems for 3 months. For pick-up (click & collect) online orders and returns: our store staff only has access to your personal data within the return period or pick-up period of your order. After this period the order is no longer visible to our store staff. Signed pick-up forms are stored for 6 months.
We retain the usage information of our in-store Wi-Fi for 4 years. CCTV footage is stored for 10 days and will be deleted afterwards. Beacon location data is stored for a maximum of 2 years, in order to compare marketing campaigns against the previous year. Body scanner data will not be stored and will only be used to send you your information.
2.5 If you participate in events or competitions run by Hunkemöller
We love to do something extra for our customers and give you the opportunity to enjoy shopping events, enter competitions to get access to exclusive events, and win great prizes. If you participate in any event, prize draw or competition we organize for our customers, we find it important to protect your privacy and only collect the information necessary to participate in the event, prize draw or competition and provide your prize if you win a prize draw of competition. We have various win contests and prize draws on our social media channels and blog, via the app and if you review or test our products. Specific additional terms and conditions apply to each prize draw or competition. Please read such additional terms and conditions for more information on the rules for how you can participate and win. You must be at least 16 years or older to be able to participate in event and private draws and competitions.
2.5.1 What personal data do we collect?
If you participate in our events, prize draws or competitions, we process the following personal data:
- (full) Name
- Email address
- Home address
- Membercard number (if applicable)
2.5.2 Why do we collect this personal data?
If you participate in our events, prize draws or competitions, we use your personal data for the following purposes:
- · To allow you to and check whether you are eligible to participate in an event, prize draw or competition. To communicate with you on your participation to our events, prize draws and competitions.
- To provide your prize, if you win.
- To analyze and evaluate on a general aggregated basis the participation in events, prize draws and competitions and improve them, so our customers enjoy such evens, prize draws and competitions even more. We do not use your personal data obtained in relation to events, prize draws or competitions for any other purposes, including not to enrich other personal data collected from you.
2.5.3 Legal processing grounds for using your personal data
We process your personal data only if this is allowed under one of the legal processing grounds. We rely on one of the following legal grounds for the processing of your personal data:
- Performance of a contract with you
- o If you participate in an event, prize draw, or competition, we process your personal data for entering into and performance of a contract with you, namely to allow you to participate in the event, prize draw or competition and providing you an opportunity to win, determining whether you have won, and giving the prize you have won. If you do not provide the required personal data, you will not be able to participate in events, prize draws or competitions and win prizes.
- Legitimate interests
- We process your personal data as necessary for achieving our legitimate interests:
- At Hunkemöller we like to get to provide exciting extras to our valued customers. Therefore, we analyze the success of our events, prize draws and competitions by looking at the number, type and demographics of participants and their engagement. This allows us to improve our events, prize draws and competitions, and increase customer satisfaction.
2.5.4 How did we obtain your personal data?
We obtain your personal data directly from you when you enter event, the prize draw or win contest.
2.5.5 How long do we retain your personal data?
We will not retain your personal data longer than necessary in relation to the purposes for which the data are processed, with a maximum of 2 months after the end of the event, prize draw or competition you participated in.
2.6 If you are or work for a supplier or business partner
We work together with several suppliers and business partners. As a supplier or business partner with you own business as a sole trader, or as a person working for one of our suppliers or business partners, we process limited personal data when you, as a representative or contact person of our supplier or business partner, enter into an agreement with us, trade or provide services to us, or visit our premises.
2.6.1 What personal data do we collect?
We process the following personal data.
- (full) Name
- Title and function
- Business name and other information on the supplier or business partner you represent
- Work address
- Signature (if applicable)
- If you visited on of our premises: the date and time of your visit and CCTV recordings, for safety and security purposes. If you visit our warehouse, we may also check for theft.
2.6.2 Why do we collect this personal data?
We use your personal data for the following purposes:
· To enter into, administer, and perform an agreement with the supplier or business partner you represent, including invoicing and collections.
· To develop and manage our relationship with the supplier or business partner you represent
Handling disputes and auditing
To protect us from, investigate and handle fraud, theft, breach of confidentiality, violations of working conditions by manufacturers, or other violations, including violations of our code of conduct for our suppliers and business partners. Click here to view our code of conduct.
To comply with a legal obligation, a court order, or to exercise or defend legal claims.
2.6.3 Legal processing grounds for using your personal data
We process your personal data only if this is allowed under one of the legal processing grounds. We rely on one of the following legal grounds for the processing of your personal data:
Performance of a contract with you
If you are a sole trader, we process your personal data for entering into and performance of a contract with you. If you do not provide your personal data and sign the agreement where necessary, it will not be possible to enter into an agreement.
Legal obligation: we process your personal data if necessary for complying with one of our legal obligations.
We may be required to process your information to comply with accounting and fiscal minim retention requirements.
We may also be required to process or disclose your personal data based on a court order or order of a competent governmental authority.
Legitimate interests: we process your personal data as necessary for achieving our legitimate interests.
We have a legitimate interest in developing our business and, for this purpose, ensuring that we work with appropriate and reputable suppliers and business partners.
We also have a legitimate interest in protecting the interest and safety of our customers and employees, and of our company assets.
2.6.4 How did we obtain your personal data?
We obtain your personal data directly from you, from the supplier or business partner you represent, or from official trade registers.
2.6.5 How long do we retain your personal data?
We will not retain your personal data longer than necessary in relation to the purposes for which the data are processed. We retain CCTV recordings for 10 days and visitor information for 2 months and we retain agreements as long as the agreement is valid.
- Email address
- (full) Name
- Geboortedatum
- Land
- Membercard number (if applicable)
- To allow you to and check whether you are eligible to participate in an event, prize draw or competition. To communicate with you on your participation to our events, prize draws and competitions.
- To provide your prize, if you win.
- To analyze and evaluate on a general aggregated basis the participation in events, prize draws and competitions and improve them, so our customers enjoy such evens, prize draws and competitions even more. We do not use your personal data obtained in relation to events, prize draws or competitions for any other purposes, including not to enrich other personal data collected from you.
- Performance of a contract with you
- If you participate in an event, prize draw, or competition, we process your personal data for entering into and performance of a contract with you, namely to allow you to participate in the event, prize draw or competition and providing you an opportunity to win, determining whether you have won, and giving the prize you have won. If you do not provide the required personal data, you will not be able to participate in events, prize draws or competitions and win prizes.
Als lid kunt u uw toestemming voor het ontvangen van verzoeken om deel te nemen aan klanttevredenheidsonderzoeken intrekken of uw toestemming intrekken om uw informatie te gebruiken die is verkregen uit de klanttevredenheidsonderzoeken waaraan u deelnam. Dit kunt u doen door te klikken op de link onderaan de e-mail die u hebt ontvangen of door contact met ons op te nemen.. Het intrekken van uw toestemming heeft geen invloed op de rechtmatigheid van ons gebruik van uw persoonsgegevens vóór uw intrekking.
- Legitimate interests
We process your personal data as necessary for achieving our legitimate interests:
- At Hunkemöller we like to get to provide exciting extras to our valued customers. Therefore, we analyze the success of our events, prize draws and competitions by looking at the number, type and demographics of participants and their engagement. This allows us to improve our events, prize draws and competitions, and increase customer satisfaction
2.7 If you contact our customer service
You may contact our customer services via various channels, including via a phone call, email or chat (e.g. WhatsApp or other social media). If you contact our customer services via email, you may be invited to fill in a survey concerning your experience with our customer services. Your answers will only be used to improve our customer services.
2.8.1 What personal data do we collect?
We process the following personal data:
- Voice recording of contact (if you contact customer service via a phone call)
- Copy of correspondence (if you contact customer service via email or chat)
- Date of correspondence
- Origin of correspondence
- Reason of correspondence
- Solution of correspondence
- Resolution date of correspondence
- Name and contact details
- • Feedback to survey concerning your experience with our customer services
2.8.2 Why do we collect this personal data?
We use your personal data for the following purposes:
- To provide you with customer support
- To process your request/question
- To train our customer service agents
- To improve our services
- • To send you a survey concerning your experience with our customer services
2.8.3 Legal processing grounds for using your personal data.
We process your personal data only if this is allowed under one of the legal processing grounds. We rely on one of the following legal grounds for the processing of your personal data:
- Performance of a contract with you: We process your personal data in order to provide you with customer service and answer your questions as you requested.
- Legitimate interests: We process your personal data as necessary for achieving our legitimate interests: At Hunkemöller we like to get to know our customers, their preferences, interests, and things they may love. This allows our co-work to advise you better and make more relevant suggestions and recommendation to you, which increase customer satisfaction. Evaluating and improving the quality of our products and services, including developing new products and services, to improve our business.
2.8.4 How did we obtain your personal data?
We obtain your personal data directly from you, when contacting our customer service via various channels, such as a phone call, via email or chat (e.g. through social media), or when filling in the survey concerning your experience with our customer services.
2.8.5 How long do we retain your personal data?
We will not retain your personal data longer than necessary in relation to the purposes for which the data are processed. If you contact our customer services via a phone call, the voice recording of this call may be stored for 60 days for training and service improvement purposes. If you contact our customer services via email or chat (e.g. through social media), a copy of this correspondence may be stored for 90 days for training and service improvement purposes. Please note that certain social media platforms are located outside the EU and may store copies of correspondence locally. If you fill in the survey concerning your experience with customer services, your answers to the survey will be stored for 1 year. After the expiry of the retention periods, information about the customer service case will be anonymized and we will only store metadata (including date of correspondence, reason of correspondence and contact details) in our customer records, in order to provide you with a better service if you contact us about a similar matter in the future.
3. Who will have access to your personal data?
Your personal data may be collected by, shared with and processed by any member of the Hunkemöller group, specifically also with our local subsidiary located in your country in relation to local events, promotions, and communications, your visits to or shopping in your local store or webshop, the handling of any of your questions or requests, and compliance with applicable local laws and regulations. We have implemented appropriate agreements and internal policies within our group to ensure the protection of your personal data. Your information will be processed by persons working for or on behalf of us on a need-to-know basis only for the purposes specified in this Privacy Statement.
We use third party service providers to manage and deliver Customer Relationship Management (CRM), email marketing campaigns, online advertising, customer analytics (such as Selligent and Google Analytics), customer satisfaction surveys (The Choice), uploading and sharing of your social media posts or other content (Flowbox), fulfilment of orders, delivery, returns, refunds, payment providers handling your payment (such as Adyen N.V.), and IT services. In providing the services, your personal data will, where applicable, be processed by the third party service provider on our behalf. When we use the services of such third party service provider that processes your personal data on our behalf, acting as a data processor, we have written data processor agreements in line with applicable data protection laws in place to safeguard the proper and secure processing of your personal data and ensure compliance with international data transfer restrictions.
Depending on your choices, your personal data may also be shared with social media providers such as Facebook and Instagram. Hunkemöller has no control over the privacy practices of these social media providers. Please read their privacy statements carefully for information on how they handle your personal data. When you share social media content that gets featured by us with your consent, your content will be available publicly and third parties could share or use your content without our knowledge and approval. Hunkemöller is not able, nor responsible, for the processing of or removing content that has been obtained or shared by such third parties. You can contact these third parties directly to request them to remove your content.
Advertisements and offers
To be more efficient in our online marketing communications, we work with various social media providers, search engines and advertising networks ("Advertising Partners"). Depending on your cookie choices, your personal data may be shared with social media providers such as Facebook and Instagram and with Google for online advertising networks. Advertising partners use information provided by us and collected through cookies and other technologies to predict your preferences and interests, and take this into account when choosing advertisements in the advertising spaces offered through their online advertising networks. This is a practice known as "retargeting". Advertising partners use cookies and similar technologies to track your use of our websites and services by using data stored on your device or in apps. Read more about cookies and other tracking technologies in our Cookies Policy.
In order to choose the content that suits your interests, we may use information we obtained from you when you signed up for our newsletter or an account, joined or made a purchase from us. We may share this information, such as an encrypted email address, with third parties such as Facebook and Google, for the purpose of showing you relevant ads on third-party websites and apps. To be able to do this, your data is compared with the database of that third party. When a match is found, you'll see promotional and relevant content in your feed or search engine. If no match is found, your data will be safely deleted. If you do not want us to share your data with third parties for this purpose, you can withdraw your consent to marketing at any time. This can be done via the Cookie Settings under "About us", at the bottom of the page. Hunkemöller has no control over the privacy practices of these advertising partners and social media providers. Please read their privacy statements carefully for information on how they handle your personal data. When you share social media content that gets featured by us with your consent, your content will be available publicly and third parties could share or use your content without our knowledge and approval. Hunkemöller is not able, nor responsible, for the processing of or removing content that has been obtained or shared by such third parties. You can contact these third parties directly to request them to remove your content.
4. How do we transfer your personal data outside the EEA?
The processing of your personal data may entail the transfer of your personal data within the Hunkemöller group or a third party service provider located outside of the European Economic Area (EEA). Where applicable, we have taken appropriate safeguards to transfer your personal data to a country located outside the EEA, if that country does not provide an adequate level of protection according to the applicable data protection laws, including by concluding standard contractual clauses approved by the European Commission to safeguard your personal data. You can contact us if you would like to receive more information on the measures we have taken to safeguard your personal data in this respect.
5. How do we protect your personal data?
We are committed to ensuring that your personal data is kept secure. To prevent loss or unauthorized access, disclosure or alteration, we have put in place appropriate physical, technical and organizational measures to safeguard the personal data we collect and process. All of our employees and third party service providers acting as our data processor (i.e. those who process your personal data on our behalf) who have access to, and are associated with the processing of personal data, are obliged to respect the confidentiality of your personal data.
6. How can you access and update your personal data and use your rights as a data subject?
If you have any customer service related questions or requests, for example in relation to your order on our webshop, please contact our customer service using the contact details available here.
As a data subject, you have certain rights concerning our processing of your personal data:
- Your right of access: If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details).
- Your right to correct your personal data: If you believe the personal data we have about you is inaccurate or incomplete, you can ask us to rectify it. If you have a My Hunkemöller or use our app, you can also update your personal data via your My Hunkemöller account or via our app. If we have shared your personal data with others, we will let them know about the changes where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.
- If we have shared your personal data with others, we will let them know about the changes where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.
- Your right to erasure of your personal data: You can ask us to block or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it. It will not stop us from storing your personal data. We will tell you before we lift any restriction. If we have shared your personal data with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.
- Your right to data portability: You have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice. If the third party is unable to receive this data, we will send it to you directly.
- Your right to object: You can ask us to stop processing your personal data, and we will do so, if we are relying on our own or someone else’s legitimate interests to process your personal data, except if we can demonstrate compelling legal grounds for the processing.
- Your rights in relation to automated decision-making, including profiling: You have the right not to be subject to a decision based solely on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such processing is necessary for entering into, or the performance of, a contract between you and us. You always have the right to express your views and contest an automated decision.
- Your right to withdraw consent: If we rely on your consent as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of our use of your personal data before your withdrawal.
- Your right to lodge a complaint with the supervisory authority: If you are concerned about how we have processed your personal data, you can lodge a complaint with your local supervisory authority.
You may send us a request using the contact details below. If you are a member, please include your membercard number. Please also note that proof of ID may be required depending on your question or request. We will handle your questions and requests carefully and in line with the applicable data protection rules. If you request information about your account or request to be deleted, we will store these requests to ensure they are followed up in time. This information will be deleted after 6 months of completing the request.
If you still feel that we have not handled your request satisfactory, or if you have a complaint, please contact our Data Protection Officer at privacy@hunkemoller.com.
7. Our contact details
Please contact us if you have any questions:
Contact our head office, the main data controller responsible for the processing of your personal data, together with its subsidiaries:
Hunkemöller B.V.
Liebergerweg 28
1221 JS Hilversum
Postbus 386, 1200 AJ Hilversum, The Netherlands
Telephone number 0800 - 3680351
Email address: customerservice@hunkemoller.com
Data Protection Officer: If you wish, you can also contact our (local) Data Protection Officer at privacy@hunkemoller.com