PRIVACY POLICY

WHAT IS OUR PRIVACY POLICY?

This privacy policy applies to the processing of personal data that we collect or you submit when you visit our website and when you use our apps.
BESTSELLER Handels B.V., Koivistokade 1c, 1013 AC Amsterdam, the Netherlands, is the data controller of the personal data covered by this privacy policy. 

Overview

1.    Our statement on privacy 
2.    Collecting & using your personal data
3.    Sharing personal data 
4.    Transferring data outside the EU
5.    How long do we store your data?
6.    Your rights

1. OUR STATEMENT ON PRIVACY

It is our mission to give you a great fashion experience right from the moment you start browsing the many styles, to the time that you actually receive your order. As part of your shopping experience with us, we want to ensure you that we protect and respect your privacy and handle all your personal data with care.
We uphold the following principles when handling your personal data:
1.    We collect and store data for these main purposes: 
-    Packing and delivering your order
-    Customer service
-    Improving your user experience 
-    Marketing
-    Fraud prevention
-    Regulatory requirements
2.    We only collect data that we need for the purposes mentioned above
3.    We delete your personal data when we no longer need it
4.    We do not sell your data
5.    We keep your data secure
Below you can read more about how and why we collect and store your personal data – and who we share it with. 
You can also read about how you can exercise your privacy rights, e.g. how to request access to your personal data. 

2. COLLECTING & USING YOUR PERSONAL DATA

Fulfilment of your order

To handle your order, we need some information from you. When you place an order with us, you provide us with your name, address, email, phone number, payment method and, of course, which products you wish to purchase. We use the information to fulfil your order including sending an order confirmation and packing and delivering your order.

Customer Service

When you contact our customer service via email, chat or phone etc., we will register the personal data that you provide to us. Our customer service has access to all information about your order, so we can help you in the best possible way, whether you have questions about the status of your order, or if you need to return an item, e.g. via our online return portal. Our customer service is also able to see any previous correspondence with you as this allows us to provide you with a better service.
If you use our “Notify Me”-service, we will use your email, in accordance with your request, to notify you when a certain item is back in stock.

Improvement of your user experience

We constantly strive to give you the very best user and shopping experience on our website. We do that in different ways, but an important part of it is by tracking your browsing behaviour on our site as well as our social media platforms in order for us to improve the user friendliness, layout, functionalities, and overall experience of the site. We do that by using cookies. You can read more about cookies HERE. We also use your browsing data to recommend you products that we think you might like.

Marketing

In order for us to present you with the best possible fashion advice and most relevant news and marketing, we and our advertising partners use personal data to personalize the recommendations and promotions on our website and to show you relevant advertising on other websites, social media networks and apps. 
Doing this, we use information about your use of our websites and services including information such as order history, past correspondence and profile information. This information may be combined with other information which you have provided to our advertising partners or which they have collected themselves. Our partners may use cookies to collect information when you visit our website. Read more about the cookies used on our website HERE.
You can always object to our processing of your personal data for direct marketing purposes, including profiling, by using our request form, which can be found HERE

Below you can read more about how we personalize our marketing towards our customer club members, the users of our apps and through our marketing cookies.

I     Customer Clubs

If you have signed up to our customer club we use information about you to send you newsletters with offers, information about new styles, fashion guides etc., based on your preferences. You can read more about the membership in the specific customer club terms & conditions and privacy policy, which can be found HERE.

II     Our App

In our apps you can choose to receive push notifications from us regarding campaigns. 
If you have activated location services on your mobile phone, we may use such information to send push notifications when you are near one of our stores. 
At any time you can deactivate the notifications and location services in the settings on your mobile phone.

III     Cookie based marketing 

Some of our marketing activities are based on cookies. Among other things, the marketing cookies that we use collect information about your style and size preference, device ID, geolocation based on your IP address and your general browsing behavior on our websites. These cookies also track which ads you have already seen, how many times you have seen them, whether you have clicked on any of them and whether or not you have placed an order after clicking. Further, some of the cookies will be able to track you also when you visit other websites or social media networks.  

We use that information to personalize the recommendations and promotions on our websites and to show you relevant advertising on other websites such as social media networks and comparison shopping engines as well as on other applications. For instance, if you have looked at a specific pair of jeans, we may present you with adds for that pair of jeans or similar on your social media news feed. 

In addition, we may also combine the information collected by cookies with your order history, past correspondence and other information you have provided us with for marketing purposes.
You can read more about our use of cookies HERE.

You can also opt-out of interest based advertising by visiting the following websites:

http://www.networkadvertising.org/choices/ 
http://www.youronlinechoices.com/ 

Fraud prevention

We use the personal data submitted by you when you place an order for fraud detection and fraud prevention purposes. For those purposes we may also receive additional information from our payment solution partners. 

Regulatory requirements

We use and store your personal data in order to comply with regulatory requirements, e.g. bookkeeping regulations.

Legal bases for collecting and using your personal data

We collect and use your personal data on the following legal bases: 
1. Our performance of a contract, cf. GDPR article 6, 1 (b)
-    Fulfilment of your order
2. Our legitimate interest, cf. GDPR article 6, 1 (f)
-    Customer service
-    Improvement of your user experience
-    Fraud detection and prevention
-    Analysis, user experience and development, e.g. based on cookies
-    Certain non-cookie-based targeting activities and personalisation.
3. Your consent, cf. GDPR article 6, 1 (a)
-    Customer club
-    Marketing through push messages in apps
-    Cookie-based marketing
4. Our legal obligations, cf. GDPR article 6, 1 (c)
-    Regulatory requirements   

3. SHARING PERSONAL DATA

In order to provide our services, we share personal data with our partners. We only share your data when this is allowed by law and all our partners are committed to keeping your data safe. Some of our partners are “data controllers” and others are “data processors”. 

Data controllers

The below described partners are data controllers meaning that they are directly responsible for the processing of your data. We only share personal data to the extent it is required for performance of their services, e.g. shipping.
When you complete an order, your payment is handled by our payment solution partners. Some of our payment solution partners are data controllers such as Klarna, SoFort and PayPal. In order to be able to offer you these payment options, we will pass certain aspects of your personal information, such as contact and order details, in order for the payment providers to assess whether you qualify for their payment options and to tailor the payment options for you. You can find more information about these providers, including their terms and conditions and privacy policies on their websites.
Afterwards, your order is sent to our warehouse partner. When your order is packed and ready to ship, we share your name, address, email and phone number with our carrier partners to fulfil your delivery. 
In situations where your order/part of your order is fulfilled by a BESTSELLER retail store, cf. clause 1 of the Terms and Conditions because the goods are out of stock in the BESTSELLER online shop your personal data, including your name, address and order details will be shared with such store. BESTSELLER and the BESTSELLER retail store will be joint data controllers in such case.
For marketing purposes, we may share non-reversible and encrypted (hashed) information about your use of our websites and services with our advertising partners who may combine it with other information that you have provided to them directly or that they have collected themselves. We also share information such as your IP address and order information with our affiliate partners to settle commission for their reference to our web shop.

Data processors

The partners described below are data processors who are only allowed to process personal data on behalf of us and according to our instructions.
Our payment solution partner Adyen handles your payments as a data processor. Your payment details are send directly to Adyen where it is handled and stored in a highly secure environment in compliance with regulatory standards.
Our technical service providers process your personal data when they have access to our databases or store personal data in their applications. These service providers include, for example, hosting providers, providers of our website platform and providers of message distribution tools. 
In addition we have partners who provide tools related to customer service and customer experiences, e.g. a chat tool on our website or a customer experience feedback tool.
Finally, as part of our advertising campaigns we share non-reversible and encrypted (hashed) customer email addresses with social media networks and with other partners who will make the campaigns available to you on their websites or in your social media news feed. 

Other situations where we share data

For customer club members, we share information about your orders and other activities on our online shops such as your online shopping bag and your wish list with the customer club. 
If we are obliged by law, a court decision or a decision of another authority, we will share personal data with the relevant authority or third party. We also report fraud incidents to the relevant law enforcement authorities.

4. TRANSFERRING DATA OUTSIDE THE EU

Some of your personal data may be handled by our partners (data processors) outside the EU. In such case we always ensure that your personal data is still governed by an adequate level of data protection.  Currently, some of our partners are located in the USA and the data transfers are safeguarded by the EU-US Data Privacy Framework or the EU Commission’s Standard Contractual Clauses. 

In addition, some of our partners may use subcontractors (sub-processors) located outside the EU. In such case, our partner is obligated to keep your personal data equally safeguarded. If you want specific information about our non-EU partners or sub-processors, please contact customerservice@bestseller.com.

5. HOW LONG DO WE STORE YOUR DATA

We only store your personal data for as long as it is necessary to fulfill the purpose for which it was collected, to establish, defend or exercise legal claims or to comply with regulatory requirements, e.g. bookkeeping regulations in the countries where we operate. When this is no longer the case, the information will be deleted.  
You can also request us to delete personal data. We will comply with such request unless we are obligated to store the information for regulatory reasons or unless the information is relevant due to a pending legal case/dispute.  

6. YOUR RIGHTS 

When we collect and use your personal data you have a number of privacy rights. If you wish to exercise any of your rights, please submit our online request form which is available HERE.
You can read more about your various rights below:

Right to withdraw consent

You always have the right to withdraw your consent to the processing of data with effect for the future. In the event of withdrawal, we will delete the data in question immediately, unless our processing may continue based on another legal basis. The withdrawal of your consent does not affect the lawfulness of the processing carried out based on the consent up to the point of withdrawal.

Right of access

One of the most important rights that you have is the right to request access to the data that we have registered on you. If you request access, we will provide you with a copy of your personal data. 

Right to be forgotten

Another important right in terms of your relationship with us is that you have the right to be forgotten, meaning you can file a request asking that we delete the data that we have registered on you. We may not be able to delete all your personal data as we are required to continue to store certain data in order to comply with legal requirements or to establish, defend or exercise legal claims. 

Right to object

You are entitled to object to the processing of your personal data on certain grounds. For example, you can object to the processing of your personal data for direct marketing purposes, including profiling.

Right to rectification

If you believe that the data we have registered on you is inaccurate or incomplete, please let us know and we will make sure to update your information.

Right to restriction

In combination with some of your other rights you can also request that we restrict the use of your personal data, e.g. instead of full erasure or during our assessment of your objection.  

Right to data portability

You can file a request asking us to supply you with the personal data that you have provided to us in a structured, commonly used and machine-readable format and to transmit the data directly to a specific recipient. 

Complaints

If you wish to lodge a complaint about how we handle your personal data, you can always contact our customer service team. You can also file a complaint with your local data supervisory authority.