Privacy statement

Who are we?

Icemobile Agency B.V. (“Icemobile”) is an agency located in the Netherlands which provides digital solutions for corporations, retailers and other (customer oriented) organisations. When performing our services, we may process the personal data that is described in this privacy statement.

In a number of instances, Icemobile qualifies as ‘data controller’ under the applicable data protection laws. However, in certain cases, we only processes personal data on behalf of our clients, such as the situation in which you participate in a loyalty program. In those cases, Icemobile acts as a data processor.

Icemobile aims to be fully transparent with regard to its data processing. For this reason we have also added the information we process on behalf of our clients when you participate in their loyalty program. Retailers may however also impose additional terms and conditions to their processing of the personal data. Please consult the privacy statement of said retailers for a complete overview of all relevant information regarding the processing of your personal data.

What do we do?

Icemobile develops digital loyalty programs and offers its clients consultancy and support services in the field of (online) retail. When providing our services, we adhere to the following data processing principles that correlate with our beliefs: first and foremost, we believe that protecting the privacy interests of our users is essential for the growth and success of the online digital services provided by Icemobile; second, we believe that a personalized digital experience can provide significant benefits to our clients and their consumers if done properly. That is why Icemobile aims to work with all of its clients and suppliers without compromising on the privacy of individuals.

Purpose of this privacy statement

With this privacy statement, Icemobile informs you about the way in which we use, treat and protect the data relating to you and/or your device.

Since our services are subject to change due to (for example) technological advances, we might be required to update our privacy statement in the future. Any updates or changes to this privacy statement shall always be published on this webpage. We therefore recommend you to regularly check this page in order to stay up to date about the way in which we process your (personal) data.

Which categories of (personal) data may Icemobile collect and/or process in relation to me and/or my devices?

Icemobile processes (personal) data of website visitors, participants of loyalty programs and (the contact persons of) our clients, suppliers and/or other business relations (hereinafter collectively referred to as: ‘Customer data’), which shall be further detailed in the following paragraphs.

1. Processing personal data when visiting our website.

Icemobile collects and processes data relating to you and/or your device if you visit this website:

Cookies

Data from our website users can be collected through the use of cookies. These are small text files that can be stored on a user’s computer, smartphone or tablet. They are designed to hold a modest amount of data specific to a particular user and the device that was used in order to access the website. The information stored by the cookie is shared with our webserver, which allows us to deliver a webpage that is specifically tailored to the preferences of a particular user.

If you visit our website, Icemobile could process the following (technical) data :

(i) browser or device type;

(ii) operating system;

(iii) domain name;

(iv) language preference;

(v) platform type;

(vi) access dates and times;

(vii) referring website addresses; and/or

(viii) browsing and search activity.

If consent is required before certain (types of) cookies are placed, we will ask for your permission in advance through the means of a cookie banner.

More information on our use of cookies, including the purposes for which we use the data gathered by them, can be found in our Cookie Policy.

Other means of processing personal data throughout the use of our website

While browsing or accessing the Icemobile website, you may choose to provide information to us voluntarily if you interact with the website in certain ways. For example, when you fill in a contact form, we shall use that information in order to get in touch with you.

2. Processing personal data when participating in loyalty programs

On behalf of our clients, Icemobile could process your personal data if you participate in one or more of the loyalty programs from our clients. In such cases, Icemobile could collect and/or process the following (categories of) personal data:

(i) name;

(ii) customer ID;

(iii) device ID;

(iv) language preferences;

(v) loyalty program information, including transactional and game balance data; and

(vi) other data collected through the use of cookies (such as the information mentioned preceding paragraph).

Icemobile could also receive your data (in part) from other sources than yourself. Those sources might include: the clients that enlist our services in order to set up/maintain a loyalty program, intermediary parties, market research companies and social media companies.

3. Processing personal data when enlisting our services

Icemobile collects and processes data relating to persons who work with Icemobile and/or enlist our services, such as our clients, suppliers or other business relations. Icemobile may process the following (categories of) personal data:

(i) personal details;

(ii) contact details;

(iii) company details; and

(iv) financial details.

Icemobile could also receive your data (in part) from other sources than yourself. Those sources might include: the Chamber of Commerce and other third parties that aid us when we are fulfilling our legal obligation to take preventive measures to combat corruption, identity theft, financial fraud, money laundering and/or terrorist financing (Know Your Customer procedures).

For which purposes and on what grounds does Icemobile process my Customer data?

Icemobile collects and processes the aforementioned categories of Customer data for the following purposes:

(i) developing loyalty programs and other customer oriented digital content/applications on behalf of our clients;

(ii) marketing activities, which include offering promotions that match the specific preferences of the user;

(iii) enhancing and/or optimizing the website experience for our users, which includes obtaining/processing information about the quality and effectiveness of our digital/online services; and

(iv) accomplishing our own economic and commercial objectives.

Aforementioned (purposes of the) processing activities based on one of the following lawful bases of processing:

(i) you have given consent to the processing of your personal data for one of the aforementioned purposes;

(ii) the processing is necessary for the performance of a contract between you and Icemobile or to take the necessary steps to enter into one;

(v) the processing is necessary to comply with a legal obligation to which Icemobile is subject; or

(vi) the processing is necessary for the legitimate interests pursued by Icemobile, as described above.

To the extent that the processing activity is necessary in order to pursue a legitimate interest, we have established that the legitimate interests of Icemobile outweigh those of the user, considering that the user is free to refrain from participating in the services provided by Icemobile without suffering any (severe) adverse consequences.

Who may receive my data from Icemobile?

Icemobile will not provide Customer data to third parties, unless:

(i) the Customer data is shared with (sub-)processors engaged by Icemobile, which shall process the Customer data on behalf of either Icemobile or its clients. The sub-processor shall only process the Customer data in accordance with this Privacy Statement and only for the purposes described therein. Icemobile shall also enter into a data processing agreement with those parties, requiring that they take sufficient technical and organizational measures in order to provide an adequate level of protection of your Customer data.

(ii) Icemobile is required by law or a court order to hand over the Customer data to a (government) authority

Does Icemobile protect my Customer data?

The security of your information is important to us. We have implemented appropriate (technical and organizational) security measures to protect the information in our care - both in transit and at rest - in order to protect your data from unauthorized access, as well as unauthorized disclosure or destruction of the data.

However, no transmission of data over the Internet is guaranteed to be 100% secure. While we strive to protect your data, third parties might try to unlawfully intercept or access your data. Icemobile can therefore not ensure or warrant the security or integrity of the information sent to us. Should a security breach occur, we shall notify you about the breach and the possible (negative) consequences that could occur if such a notification is required by the applicable privacy laws and regulations.

Does Icemobile protect my Customer data in case they are transferred outside of the EEA?

In order to provide our services, we might be required to transfer your Customer data to countries outside of the European Economic Area (EEA). In those situations, we shall implement appropriate safeguards to protect your data, including the use of approved certification mechanisms, the Standard Contractual Clauses (SCC’s) approved by the European Commission (Implementing Decision (EU) 2021/914) and/or only process/transfer the Customer data to countries in respect of which the European Commission has adopted an adequacy decision.

How long will Icemobile keep my Customer data?

Customer data will be stored as long as necessary for the purpose for which the data is collected and processed. To determine the data retention period of a particular category of Customer Data, Icemobile uses the following measures and benchmarks:

Icemobile follows maximum data retention periods for certain categories of personal data, as suggested by local regulators and/or supervisory authorities. For example, we shall only store Customer data for a maximum of two years after a (trans-/inter)action has occurred between you and Icemobile, unless a legal obligation requires us to store the data for a shorter or longer period of time, such as our legal obligation to store certain data for a minimum of seven years for tax purposes.

Which rights can I exercise with regards to my personal data that Icemobile processes?

As a user of our website or other services, you are able to exercise the following rights:

Right to information: you have the right to receive information about the ways in which we process your personal data, including the purpose for which we process your personal data.

Right of access: you have the right to access and/or obtain a copy of your personal data that has been processed by us.

Right to rectification: you have the right to rectify and/or request corrections of your personal data in the event that those data are inaccurate or incomplete.

Right to restriction of the processing: you have the right to request us to (temporarily) restrict the processing of your personal data if any of the following situations occur:

(i) you dispute the accuracy/correctness of the personal data relating to you. The processing of those personal data shall then be restricted during the period in which we verify the correctness of your personal data;

(ii) the processing of your personal data is unlawful and you oppose to the erasure of your personal data, instead requesting that our processing of the personal data shall be restricted;

(iii) we no longer need your personal data for the aforementioned processing purposes, but you still need the data in order to establish, exercise and/or substantiate a legal claim; or

(iv) you have objected to our processing of the personal data and are awaiting our response to the balance of interests in the context of the legitimate interests that we try to accomplish with the respective processing activity.

Right to data portability: you have the right to obtain the personal data that we process in a structured and commonly used (digital) format in order to transfer it to another party if and when the processing activity is (solely) based on consent or the performance of a contract.

Right to object: you have the right to object to the processing of your personal data if the processing is based on one of the following lawful bases: ‘necessary for the performance of a task carried out in the public interest’ and/or ‘necessary in order to achieve the legitimate interests that are pursued by us’. Following the opposition, we shall cease the processing of your personal data if we cannot provide a (additional) evidence that our processing activities outweigh your (privacy) interests.

Right to be forgotten (erasure): you have the right to request us to delete your personal data. We shall comply with this request in the following situations:

(i) your personal data is no longer needed for the purposes for which they were initially collected and/or processed;

(ii) you have withdrawn your consent for the processing of your personal data and your consent was the legal bases for the processing at hand;

(iii) you have raised legitimate objections to the processing of your personal data;

(iv) your personal data have been unlawfully processed.

Withdraw consent: if you have consented to the processing of your personal data, you have the right to withdraw your consent at any given time. All processing of your personal data that took place prior to the withdrawal of your consent, shall be deemed to have validly taken place .

You may also unsubscribe from our newsletter by clicking on the unsubscribe link at the bottom of the newsletter or by sending an e-mail to: info@icemobile.com

Who can I contact about my personal data?

If you have a question, want to exercise one of the aforementioned rights and/or would like to submit a complaint with us regarding the collection and processing of your data by Icemobile, you can contact us:

Icemobile International B.V.

Mensinge 2

1083 HA Amsterdam

+31 203 680 645

info@icemobile.com

You are also able to file a complaint with the Dutch supervisory authority (“Autoriteit Persoonsgegevens”) using the (contact) details provided below:

Autoriteit Persoonsgegevens

PO-no. 93374

2509 AJ The Hague

www.autoriteitpersoonsgegevens.nl