PRIVACY POLICY

This is the privacy statement of the general partnership 28COMMERCE, hereinafter: CULTURE 28. CULTURE 28 is registered with the Chamber of Commerce under number 77253973 and is located at Schaapherderweg 1b (Unit 8506 (2988CK) in Ridderkerk. This document explains how CULTURE 28 handles the processing of your personal data CULTURE 28 takes the greatest possible care when processing your personal data.

Obtaining personal data:
If you use the services of CULTURE 28, you provide a number of personal data to CULTURE 28 yourself, or personal data is obtained from you in the context of the agreement. Personal data is understood to mean all data relating to an identified or identifiable natural person.

Categories of personal data
CULTURE 28 processes the following categories of personal data:

• Contact and name and address data, including location data, telephone number, e-mail address;
• Different delivery address;
• Financial details;
• Account information, including your password and username;
• Other personal data provided by you.

Purpose of the processing
The personal data processed by CULTURE 28 is intended to:

• to contact you to inform you about the services you have purchased and their implementation;
• to be able to perform its services;
• to improve its services;
• to be able to make payments;
• to comply with legal obligations;
• to be able to make marketing and communication expressions, including improving the website by analyzing visitor behavior on the website;
• to be able to send newsletters;
• to exchange data with third parties for the performance of the service, insofar as this is necessary.

Processing basis
The processing of personal data is only possible on the following grounds: (i) legal obligation, (ii) execution of the agreement, (iii) obtained (explicit) consent from the data subjects, and (iv) legitimate interest. When providing the services of CULTURE 28, personal data is processed. CULTURE 28 only processes data that CULTURE 28 deems necessary for (improving) the service and handles the (personal) data it has collected about you and your use of the services with care. The basis for processing this data is the agreement you have entered into with CULTURE 28. Your personal data may also be processed by visiting the websites www.culture28.com, www.culture28.nl and www.culture28.de if you have given permission for this.

Need processing
The processing of your personal data is necessary to be able to perform the service. The services that CULTURE 28 offers cannot be fully performed without the processing of your personal data. If your explicit permission is required for specific purposes with regard to the personal data, you must give permission for this separately.

Automated decision making
There is no automated decision-making.

Retention period
The personal data processed by CULTURE 28 is stored in accordance with the relevant laws and regulations. If a longer retention period is necessary on the basis of legislation or regulations, the personal data will be kept longer in accordance with these requirements. All (obtained) personal data will not be kept longer than is strictly necessary.

Processing by third parties
CULTURE 28 only shares personal data with third parties if this is strictly necessary for the execution of an agreement and to comply with relevant laws and regulations. No personal data is sold. CULTURE 28 may have a legal obligation to share personal data with third parties. If personal data is shared with third parties, processing agreements are concluded for this. The third parties with whom personal data is shared are:

• The delivery service(s) engaged for the purpose of executing the agreement. The categories of personal data that are processed are contact and name and address details.
• The Payment Provider, for the purpose of executing an agreement. The categories of personal data that are processed are financial data.
• The Bookkeeper, for the purpose of executing an agreement. The categories of personal data that are processed are contact and name and address data and financial data.
• Software suppliers, for the purpose of the execution of the agreement. The categories of personal data that are processed are the contact and name and address details.
• Website administrator, for the purpose of executing the agreement. The categories of personal data that are processed are the contact and name and address details.
• Engaged freelancers, for the purpose of executing the agreement. The categories of personal data that are processed are the contact and name and address details.

Security of Personal Data
CULTURE 28 takes the protection of your personal data seriously and takes into account the state of the art, implementation costs, as well as the nature, scope, context and purposes of the processing and the risks to the rights and freedoms of individuals, varying in likelihood and seriousness. , appropriate technical and organizational measures to ensure a level of security appropriate to the risk.

Under 16 years old?
If you are a minor, i.e. younger than 16, you may only give permission for the processing of your personal data with the permission of one of your parents or legal guardian. It is then important that your parent(s) or guardian read this statement. They can also exercise the rights you have with regard to the personal data you leave with us, such as the right to object to the (further) processing of your personal data or the right to access and correct your data.

Disclaimer
By using the website you agree to the disclaimer. CULTURE 28 reserves the right to change the content of its website and/or this disclaimer at any time without informing its customers and/or users of the website of this change. The content of the website has been compiled with the greatest possible care, but may nevertheless contain possible inaccuracies or be incomplete. CULTURE 28 does not accept any liability whatsoever for damage caused by or resulting from the use of the website. The use of this website is entirely at the expense and risk of a user of the website. No rights can be derived from the content of the website. All texts on the website are copyrighted and property of CULTURE 28 insofar as they do not belong to third parties.

Cookie statement
CULTURE 28 uses technical and functional cookies to optimize the website. Cookies are small text files that are sent along when you visit a website to make the user experience of visitors more efficient. CULTURE 28 may, by law, store cookies on your device if these cookies are strictly necessary to use the website. Other types of cookies require your permission. CULTURE 28 recommends that you accept the cookies in connection with the user-friendliness of the website. Visitors to the website have a check-in option.

The cookies that CULTURE 28 uses are functional cookies: these cookies ensure that the website works properly. These cookies have no consequences for privacy, so that no permission has to be requested and granted. For example, these cookies store your browser settings so that our website can be viewed best, or that the website remains accessible (load balancing), but also cookies that ensure that no other cookies may be placed (no-follow).

With your permission, CULTURE 28 places ''tracking cookies'' on your computer. CULTURE 28 uses these cookies to keep track of which pages you visit, in order to build a profile of your online behavior. This profile is not linked to your name, address, e-mail address and the like, but only to tailor advertisements to your profile so that they are as relevant to you as possible.

Cookies from Google are also placed on the CULTURE 28 website for the benefit of Google Analytic, Facebook Pixels, SnapChat Pixels, TikTok Pixels and Shopify Analytic are also used. This means that CULTURE 28 cannot link information to a natural person. CULTURE 28 does not keep any information about what you do on the Internet. Google Analytics may be required by applicable laws and regulations to provide access to this data. If you have any questions about this, please contact info@culture28.com.

Use social media
CULTURE 28 uses third party cookies to optimize the website. Some cookies are placed by third party services that appear on the website. Third parties mean Google Analytics and social media (Facebook, Instagram, Pinterest). The privacy and cookie policy of the relevant company applies to the use of cookies from other companies (third parties). When you click the social media button on the website, a social media cookie is placed. This allows the social media party to recognize your IP address as soon as you share an article from the website. For the cookies of social media parties and the data and/or personal data they collect with them, CULTURE 28 refers you to the privacy and cookie statements of these parties.

If Facebook Pixel, SnapChat Pixel and TikTok Pixel are used, it is determined which people visit the CULTURE 28 website and Facebook, SnapChat and/or TikTok make a link with the profiles and the associated IP address.

Email newsletter and other marketing emails
You can register via the website for a newsletter and/or for other commercial offers. When you register, CULTURE 28 asks you for permission to process your email address for the purpose of sending you marketing emails containing the latest information about products and services, special offers and marketing campaigns. You will only receive marketing emails if you have given your consent.

Your consent also includes your consent that CULTURE 28 may personalize the content of marketing emails in accordance with your needs and interests based on any user profile created for you.

Your consent to the sending of marketing emails can be withdrawn by you at any time by clicking “Unsubscribe” at the end of the marketing email. Withdrawing consent does not affect the lawfulness of processing carried out prior to the withdrawal of consent.

Text Marketing Terms and Conditions
We are using a text messaging platform, which is subject to the following terms and conditions. By opting in for our text marketing and notifications, you agree to these terms and conditions.
By entering your phone number in the checkout and initialising a purchase, subscribing via our subscription form or a keyword, you agree that we may send you text notifications (for your order, including abandoned cart reminders) and text marketing offers. You acknowledge that consent is not a condition for any purchase.
Your phone number, name, and purchase information will be shared with our SMS platform "SMSBump Inc", an European Union company with an office in Sofia, Bulgaria, EU. This data will be used for sending you targeted marketing messages and notifications. Upon sending the text messages, your phone number will be passed to a text messages operator to fulfill their delivery.
If you wish to unsubscribe from receiving text marketing messages and notifications reply with STOP to any mobile message sent from us or use the unsubscribe link we provided you within any of our messages. You understand and agree that alternative methods of opting out, such as using alternative words or requests will not be accounted as a reasonable means of opting out. Message and data rates may apply.
For any questions please text "HELP" to the number you received the messages from. You can also contact us for more information. If you wish to opt out please follow the procedures above.

Klarna
In order to offer you Klarna’s payment methods, we might in the checkout pass your personal data in the form of contact and order details to Klarna, in order for Klarna to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data transferred is processed in line with Klarna’s own privacy notice.

Browser Settings
If you do not want websites to place cookies on your device that you use to view the website, you can adjust your browser settings. Before a cookie is placed, you will receive a warning and you must give permission for the cookie. Failure to do so may, for example, result in the website not working properly. You can adjust the settings of your browser so that your browser refuses all cookies and also cookies from third parties. You can also delete placed cookies. For this you have to adjust the settings of your browser via preferences and then you can adjust the privacy settings.

This privacy statement does not apply to websites of third parties that are connected to this website by means of links. CULTURE 28 cannot guarantee that these third parties handle your personal data in a reliable or secure manner. CULTURE 28 recommends that you read the privacy statement of these websites before using these websites.

Right of data subjects
As a data subject, you have the following rights:

• Right of access;
• As a data subject, you have the right to obtain a definitive answer as to whether or not your personal data is being processed and, if so, to inspect the processing thereof.
• Right to rectification;
• You have the right to obtain rectification and completion of incorrect data.
• Right to erasure;
• A data subject must obtain erasure of personal data concerning him/her without undue delay.
• Right to restriction of processing;
• As a data subject, you have the right to restrict the processing of your personal data. Please contact CULTURE 28 for this.
• Right to data portability;
• A data subject has the right to obtain the personal data concerning him that he has provided to CULTURE 28 in a structured, commonly used and machine-readable form in order to possibly transfer this personal data to a third party. A data subject can also instruct CULTURE 28 to transfer this data directly to a third party.
• Right to object;
• The data subject has the right to object at any time, on grounds relating to his particular situation, to the processing of personal data concerning him/her, including profiling based on those provisions. CULTURE 28 will cease processing the personal data unless there are compelling legitimate grounds for the processing that outweigh the interests, freedoms and rights of the data subject related to the exercise, establishment or defense of legal claims.

Complaint
If you have a complaint about the way in which CULTURE 28 handles your personal data, or if you wish to exercise one of the above rights, you can contact us via the website or by e-mail at info@culture28.com. To ensure that you wish to exercise a right, CULTURE 28 asks you to enclose a copy of your proof of identity. You can black out your passport photo and MRZ (strip with numbers at the bottom) to protect your privacy. CULTURE 28 will respond to your request as soon as possible, but at the latest within 4 weeks. You can also submit a complaint to the Dutch Data Protection Authority. This is the competent enforcement body. You can contact us via this link:  https://autoriteitpersoonsgegevens.nl/nl/contact-met-de-autoriteit-persoonsgegevens/tip-ons.

Changes to Privacy Statement
CULTURE 28 can change the privacy statement at any time. The most recent version is published on the website. Therefore, always keep an eye on the website for the most recent version. If the new privacy statement has consequences for the way in which CULTURE 28 processes already collected data relating to you, CULTURE 28 will inform you by e-mail.

This version was last adopted on October 18, 2021.