Privacy Statement
With this privacy statement, Welna Holding B.V., “WELNA”, Demmersweg 3, 7556 BN Hengelo, The Netherlands (hereinafter referred to as “we”, “us” or “our”) would like to inform you about how we process your personal data when you visit our website www.welna.com.
WHICH PERSONAL DATA DO WE COLLECT FROM USERS?
Enquiry data: We provide contact options on our website where you can choose to have us contact you. This may include, in particular, the following: if you send us general or specific questions via the email addresses provided on our website or via the contact page, we process the information contained therein in order to respond to your enquiry.
Server log data: When you use our websites, usage data (such as the date and time of your visit, the pages accessed and files requested, the type and version of the internet browser used, the type and operating system of your end device and your IP address) is temporarily stored in a log file on our server.
1. FOR WHAT PURPOSES DO WE USE PERSONAL DATA, ON WHAT LEGAL BASIS AND FOR HOW LONG?
If you send us enquiries by email, we process the information you provide in order to respond to you, as well as your IP address and the date and time of your enquiry.
The legal basis for processing is our legitimate interest pursuant to Article 6(1)(f) of the General Data Protection Regulation (“GDPR”) in providing you with the relevant service you have requested (for example, responding to a contact request).
If the enquiry relates to the initiation or performance of a contract (including customer service or warranty matters), an additional legal basis for processing is Article 6(1)(b) GDPR.
You may object to the processing of your data on the basis of Article 6(1)(f) GDPR. In such a case, we may continue processing your data after demonstrating the legal grounds for such processing. This may be necessary in particular to document previous enquiries and communications with the user.
If the above-mentioned legal grounds do not apply, we will discontinue communication with you and delete the data already collected.
The data will be deleted once our communication with you or the relationship established as a result of your enquiry has ended, i.e. once the relevant matter has been conclusively clarified and there is no longer a legitimate reason to retain such data, nor any legal obligation requiring us to retain such data.
1.1 ADVERTISING AND PRODUCT DEVELOPMENT (USER DATA), RIGHT TO OBJECT
We also wish to use the data you enter at any time or that we collect when you use our websites to inform you about products and services related to our product portfolio (“Services”) (advertising), or to improve our product portfolio and Services (product development).
1.2 ANONYMISED USER DATA
We use anonymised and/or aggregated data to understand the behaviour of all visitors and thereby improve the design of our website and our product portfolio in general.
1.3 PERSONALISED AND ANONYMISED USAGE DATA
In addition, we use usage data to gain insight into your browsing behaviour in order to improve the offers we display to you and provide you with personalised information.
1.4 PROVISION OF THE WEBSITE AND SERVICES
The processing of server log data is technically necessary to make the website available and provide services and subsequently to ensure system security.
The legal basis for processing is our legitimate interest in providing our website services (Article 6(1)(f) GDPR).
Processing is a mandatory requirement for the use of our website; therefore, there is no right to object to this processing. The data will be deleted no later than 14 days after collection.
The server log data may subsequently be evaluated in anonymized form for statistical purposes and to improve the quality of our online presence. There is no connection between the server log data and your personal data, and the server log data is not combined with other sources of personal data in any way.
2. DATA TRANSFER
2.1 TRANSFER OF DATA TO DATA PROCESSORS
We make partial use of service providers, in accordance with applicable legal requirements, through relationships with data processors. This means that processing is carried out on our behalf, on the basis of an appropriate contract, in accordance with our instructions and under our control.
The data processors include, in particular:
- technical service providers whose services we use to make the website available, e.g. software maintenance, data processing and hosting providers;
- technical service providers whose services we use to provide functionality, e.g. technically necessary cookies;
- service providers for the practical implementation of advertising and marketing activities, e.g. providers of email distribution services.
In such cases, we remain responsible for the processing of the data. The transfer and processing of personal data by or on behalf of our data processors takes place on the same legal basis on which we are permitted to process the data in each individual case. No separate legal basis is required.
2.2 TRANSFER OF DATA TO THIRD PARTIES
We also transfer some of your data to third parties, i.e. partners with whom we cooperate in addition to processing carried out on a contractual basis.
Such partners provide their services under their own responsibility. The processing of your data by our partners is therefore exclusively subject to the privacy statements of these third parties.
Transfer of data to other entities within the Welna Holding B.V. (‘WELNA’) structure
We may forward your enquiry, together with the information you have provided, to other companies within the Welna Holding B.V. structure and to other countries if this is necessary to respond to your enquiry (for example, because your enquiry relates to a business transaction or an offer from another country).
The legal basis for transferring your data is the performance of the service requested by you, Article 6(1)(b) GDPR, and/or our legitimate interest in responding to your enquiry, Article 6(1)(f) GDPR.
Please note that, depending on the nature of your enquiry, this may involve the transfer of your personal data to countries outside the European Economic Area (“EEA”) that may not necessarily provide the same level of data protection.
We ensure an adequate level of protection by entering into the EU Standard Contractual Clauses (Article 46(2) GDPR). A copy of the relevant sections may be requested from the contact person specified in section 8.
2.2.1 LOGISTICS COMPANIES
For the transport of materials and other items ordered by the user, we may, where necessary, provide the user’s address and contact details to parcel carriers and other logistics providers.
The legal basis for the transfer of data is the performance of the contract with the user, Article 6(1)(b) GDPR.
3. COOKIES
3.1 WHAT ARE COOKIES?
We use so-called “cookies” to make our website as user-friendly as possible.
Cookies are small files that are stored on your device. They make it possible to store information for a certain period of time and to identify the user’s device.
Tracking pixels, which are not stored on the user’s hard drive, may also be used for this purpose and can help recognise the user’s device in a similar manner.
The term “cookie” refers to cookies in the technical sense, as well as tracking pixels and other technologies.
3.2 WHICH COOKIES DO WE USE, ON WHAT LEGAL BASIS AND FOR HOW LONG?
We use only one type of cookie on this website: cookies that are necessary for technical purposes and without which the functionality of our website would be limited.
These cookies are essential for the proper functioning and easy navigation of our website. For example, they enable us to offer you the possibility of searching for local retailers that offer our products (for example, by displaying a map of your region), to save your language preference, or to record whether or not you have consented to the use of cookies and selected cookie settings.
Such cookies do not collect information about you for marketing purposes and do not record which websites you visit while browsing the internet.
Deactivating such cookies would limit some or all of the functionality of the website.
The legal basis for this processing is our legitimate interest (Article 6(1)(f) GDPR).
These cookies are specifically set for individual sessions and expire when you leave the website and end your session.
3.3 HOW CAN I DISABLE COOKIES?
If you wish to disable analytical, targeting and advertising cookies in general, you can disable individual cookies by adjusting your browser settings accordingly.
However, please note that the functionality of our website may be reduced if cookies that are necessary for technical purposes are also blocked.
4. LINKS
We may provide links to our other online presentations and to websites and services operated by third parties, for example social media channels such as Facebook, Twitter or YouTube.
These third parties are solely responsible for the processing of data by such other service providers on their websites, and their respective privacy statements apply.
5. SECURITY
We and our service providers take technical and organizational security measures to protect the personal data we manage against accidental or intentional manipulation, loss, destruction or access by unauthorized persons.
Our data processing and security measures are continuously improved in line with technological developments.
When your personal data is transmitted to us, it is encrypted using the SSL (Secure Socket Layer) protocol.
Personal data exchanged between you and us or other participating companies is generally transmitted via encrypted connections that comply with the latest technical standards.
Our employees and the service providers we engage are, of course, subject to confidentiality obligations.
6. YOUR RIGHTS REGARDING ACCESS, RECTIFICATION, RESTRICTION OR ERASURE
In principle, every natural person whose personal data we process has the following rights, subject to the applicable legal requirements:
If you have any questions about our processing of your personal data, we will provide you with information, free of charge and at any time, about the data we hold about you (Article 15 GDPR).
You have the right to have inaccurate data corrected and incomplete data completed (Article 16 GDPR).
You have the right to request the restriction of processing or the erasure of personal data concerning you that is no longer necessary or that is being retained solely due to legal obligations (Articles 17 and 18 GDPR).
You have the right to receive your data in a structured, commonly used and machine-readable format and to have that data transmitted to another controller, insofar as you have provided us with the data on the basis of your consent or a contract between you and us (Article 20 GDPR).
You have the right to object at any time to the processing of your data for direct marketing purposes (see also section 2.2; Article 21(2) and (3) GDPR).
You have the right to object to processing based on legitimate interests. In such a case, we may continue processing your data if we can demonstrate compelling legitimate grounds for the processing (Article 21(1) GDPR). We have indicated above (section 2) the circumstances in which this right applies.
To the extent that you have given your consent to the processing of your data, you may withdraw that consent at any time with effect for the future. The lawfulness of processing carried out before the withdrawal of consent remains unaffected.
After withdrawing your consent, you may no longer be able to use certain services.
If you have any objections, you may submit them in writing (marked “Data Protection”) or by email using the contact details provided in section 9 below.
We reserve the right to verify your identity in order to ensure that your personal data is not disclosed to unauthorized persons.
In addition, you have the right to lodge a complaint with the competent data protection supervisory authority.
7. CONTACT
Please address your questions in writing to:
Welna Holding B.V.
Demmersweg 3
7556 BN Hengelo
The Netherlands
8. CHANGES
It may occasionally be necessary to amend the content of this privacy statement.
We therefore reserve the right to amend this statement at any time. We will publish a revised version of this privacy statement on this website.
We therefore recommend that you review this privacy statement again when you visit our website in the future.