Privacy

wandel.nl privacy statement

Version of February 2021

Our primary aim in recording information is to make your visit to our website as smooth as possible. We therefore only record data that we deem necessary for this purpose. You are not under an obligation to share this information with us and you can access virtually all of the content on this website without sharing any personal data with us. The www.wandel.nl website is operated by the Royal Dutch Walking Association (Koninklijke Wandel Bond Nederland, hereinafter: ‘KWBN’). When you visit this website, KWBN will store some of your personal data. We also store personal data when you buy something on this website, order a ticket to a walking event on this website, register for a newsletter on this website, sign up for membership on this website, and/or when you contact KWBN about any of these things. 

KWBN takes personal data protection very seriously. In this privacy and cookie statement, KWBN will explain the nature, extent and purpose of its personal data processing.

It will also provide brief details of the rights that every data subject has. Data subjects are the people whose personal data we process. 

1.  Controller or processor?

In principle, KWBN is the controller for the personal data processed on www.wandel.nl and/or in relation to any contact with and regarding this website.

Walking events

If you order tickets to walking events on the website or contact us about these tickets and/or the events, KWBN is only the processor, meaning that this privacy statement does not apply in those cases. The organisers of the walking event in question are the controller. They are the ones who have to inform you about how your personal data is processed.

2.  Controller details

Koninklijke Wandel Bond Nederland
Berg en Dalseweg 125
6522 BE Nijmegen, Netherlands
info@kwbn.nl
+31 (0)24 3655575

If you have any questions about KWBN’s personal data processing practices, or if you want to exercise your legal rights as a data subject, please contact us.

3.  The personal data we process

KWBN processes the following personal data:

• name, gender, age, address, contact details (including telephone number, email address and postal address) that you submit to us for mailing lists and questionnaires, to log in as a member, to sign up for campaigns/courses/membership, or to order products on our website;
• the bank details we need for a transaction if you buy products on our website or to pay the membership fee;
• information on your purchasing behaviour on KWBN websites;
• general information regarding your visits to KWBN websites. This concerns your Internet Protocol address or the IP address of your proxy server; your Internet Service Provider, depending on how it is configured; the duration of your visit to our website; the number of times you visit our website; the pages you visit; third-party websites you visit by clicking a link on our website; basic domain information; your behaviour on the website; the website where you clicked a link that took you to our website; information about the operating system and internet browser you use to access the website;
• location details when using the KWBN ‘Wandel.nl’ app; in order to be able to track your walking progress, the app always needs to know your location (without location data, the app cannot track or measure anything). This data is recorded only locally on your mobile phone as you use the app and not shared with third parties.

4.  How we collect personal data

Your personal data may be collected in a variety of ways:

•  you submit the personal data yourself;
• someone else provides your personal data: members of KWBN-affiliate organisations are automatically also members of KWBN; other than that, someone could have an order shipped to a third person’s address (for which the recipient’s personal data will have to be processed); when signing up for an event, the registering organisation may be authorised to provide certain data to KWBN;
• your personal data is collected through cookies.

5.  Cookies

KWBN uses cookies on various pages of its websites.

Cookies are small (identification) files that are downloaded along with pages of the KWBN websites and stored by the visitor’s browser on the hard drive of the computer used to access these websites. The information stored in cookies can then be sent back to KWBN’s servers the next time you visit a KWBN website.

For more details of how cookies work, what cookies KWBN uses, how to block and/or delete cookies and the possible consequences thereof, please refer to KWBN’s cookie policy on this website.

6.  Purpose and legal basis of the processing

We process personal data for various purposes. In the following, we will detail the purpose and legal basis of KWBN’s personal data processing by category of personal data:

a. name, address, contact details (including gender, address, email address and telephone number):

-  purpose 1: to perform the contract to which the data subject is a party. The legal basis is Article 6(1)(b) of the General Data Protection Regulation (hereinafter: ‘GDPR’): processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;

- purpose 2: to comply with legal obligations, such as the retention obligation. The legal basis in this case is Article 6(1)(c) of the GDPR: processing is necessary for compliance with a legal obligation to which the controller is subject;

- purpose 3: to maintain contact in the broadest sense of the word, including sending invitations for events, newsletters, campaigns/special offers, courses or a membership. The legal basis in this case is Article 6(1)(f) of the GDPR: processing is necessary for the purposes of the legitimate interests pursued by the controller. In this case, these interests are KWBN’s commercial/non-commercial interests;

- purpose 4: to be able to allow a supervisory authority to conduct an audit. The legal basis in this case is Article 6(1)(c) of the GDPR: processing is necessary for compliance with a legal obligation to which the controller is subject;

b. bank, financial and sales transaction details:

-  purpose 1: to perform the contract to which the data subject is a party. The legal basis is Article 6(1)(b) of the GDPR: processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;

- purpose 2: to comply with legal obligations, such as the retention obligation. The legal basis in this case is Article 6(1)(c) of the GDPR: processing is necessary for compliance with a legal obligation to which the controller is subject;

- purpose 3: to be able to allow a supervisory authority to conduct an audit. The legal basis in this case is Article 6(1)(c) of the GDPR: processing is necessary for compliance with a legal obligation to which the controller is subject;

c. information about queries, complaints and other matters for which the customer support department is contacted:

-  purpose 1: to perform the (support) contract to which the data subject is a party. The legal basis is Article 6(1)(b) of the GDPR: processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;

- purpose 2: to comply with legal obligations, such as the retention obligation. The legal basis in this case is Article 6(1)(c) of the GDPR: processing is necessary for compliance with a legal obligation to which the controller is subject;

- purpose 3: to deal with queries and complaints as well as to improve KWBN’s services and the functionality of its websites. The legal basis is Article 6(1)(f) of the GDPR: processing is necessary for the purposes of the legitimate interests pursued by the controller. In this case, these interests are KWBN’s commercial/non-commercial interests;

d. general information regarding visits to KWBN websites:

- the purpose is - as specified above - to improve services and website functionality and to gain insight into website visitors’ surfing behaviour to maximise findability and effectiveness of these websites for KWBN. The legal basis is Article 6(1)(f) of the GDPR: processing is necessary for the purposes of the legitimate interests pursued by the controller. In this case, these interests are KWBN’s commercial/non-commercial interests;

e. more specific information regarding visits to KWBN websites:

- the purpose is to make offers that are aligned with the details that KWBN has on file for the visitor. Please also refer to the information provided under point 11 of this privacy statement. The legal basis is Article 6(1)(f) of the GDPR: processing is necessary for the purposes of the legitimate interests pursued by the controller. In this case, these interests are KWBN’s commercial/non-commercial interests.

7.  Categories of personal data recipients

KWBN will transfer the personal data specified above - if and to the extent applicable - to the following categories of recipients:

1. processors, including providers of secretarial and administrative services, providers of IT services (including hosting), Google Analytics (part of Google Inc.), and Facebook, Twitter and/or LinkedIn when sharing KWBN website content on social media, and parties that take care of the logistical processing of orders, such as medal makers and delivery companies and the parties involved in the distribution of the association’s magazine;

2. to the extent that these cannot be designated as processors in this context: legal services providers, courts and insurers;

3. other than that, KWBN only transfers personal data to third parties (including the authorities) that cannot be designated as third parties engaged by KWBN, if and to the extent that KWBN is required to do so by law, regulations and/or a court order, or specific consent to do so has been granted by the data subject.

8.  Transfer of personal data to third countries

KWBN may transfer personal data to parties in third countries through the following parties:

1. Google Analytics (see Section 5 ‘Cookies’ for details);

2. when sharing content from one of KWBN’s websites on social media, information may be transferred to Facebook, Twitter and/or Instagram (see Section 5 ‘Cookies’ for details).

9.  Duration of storage

KWBN will only process personal data (which includes storing personal data) over the period required to fulfil the purpose for which this personal data is stored. This also includes legal retention periods.

Back-ups in back-up systems are automatically deleted, albeit with a slight delay.

10.  Data subject rights

The General Data Protection Regulation affords a data subject the following and other rights:

1. right of access and right of confirmation of processing of personal data (Article 15 of the GDPR);

2. right to rectification (Article 16 of the GDPR);

3. right to erasure (Article 17 of the GDPR);

4. right to restriction of processing (Article 18 of the GDPR);

5. right to data portability (Article 20 of the GDPR);

6. right to object to processing (Article 21 of the GDPR);

7. right to withdraw consent for personal data processing (Article 7(3) of the GDPR).

If a data subject wants to exercise one of the above rights (or would like further information about their rights), a request to this effect can be submitted in writing to info@kwbn.nl or by post to the address at the top of this statement.

Finally, a data subject has the right to contact the supervisory authority in the member state where the data subject lives or works or where the data subject suspects that the processing of their personal data is in breach of the GDPR. The competent authority in the Netherlands is the Dutch Data Protection Authority.

11.  Is it compulsory to provide personal data? Consequences of refusing/failing to provide personal data

Not providing the above personal data will mean that KWBN will not enter into an agreement or will terminate an existing agreement with the party in question.

12.  Existence of automated decision-making/profiling

KWBN tracks the behaviour of visitors on its website to personalise content for the individual visitor as much as possible. The content shown to a visitor, including special offers, depends on their surfing behaviour up to that point and on information provided by this visitor through questionnaires.

13.  Protection of personal data

KWBN uses appropriate technical and organisational security measures to ensure a level of protection of the personal data that is aligned with the risk.

14.  Privacy statement and cookie policy amendments

KWBN reserves the right to unilaterally amend this privacy statement and its cookie policy without prior notice. Such amendments will be published on this website.