Privacy Policy myRitmeester
We take privacy seriously. This notice tells you who we are, what information about you we collect, what we do with it and all your rights you have in this connection.
We have a commercial relationship with you or your employer, for example, because you or your employer sell, promote or distribute our products (or support those activities).
1. Who are we and how to contact us?
We are Ritmeester Cigars („RM“), Reitscheweg 55, 5232 BX 's-Hertogenbosch, Netherlands.
If you have any questions about our Company’s privacy policy, the data we hold or you would like to exercise one of your data protection rights, please do not hesitate to contact us.
2. What information about you do we collect?
myRitmeester collects the following information:
- information necessary to manage and administer our relationship with you, your employer or representative (name, address, age, email address, phone number)
- information about what you do in your business concerning our consumers, our products, or us (e.g. displaying our products and point of sale materials, etc.)
- information you give us in forms or surveys or in interactions on myRitmeester
- information about your visits to our events
- information you give us in contacts (such as calls, e-mails, etc.) you have with us
- information about your preferences and interests, given by you
- information necessary to verify your age, identity and authority to act on behalf of your employer if applicable
Information that we collect from you directly will be apparent from the context in which you provide it. For example:
- you may provide information on your product preferences and interests so that we can offer you products and services that will interest you;
- we may collect information that enables us to verify your age, for example your facial image;
- you may send us a photograph of the way you have displayed our products or point of sale materials;
- Information that we collect automatically will generally concern:
- Which events you attend
- your use of digital RM touchpoints (such as the pages you visit, the page from which you came, and the page to which you went when you left, search terms entered, or links clicked within the touchpoint); and
- your device (such as your IP address or unique device identifier, location data, details of any cookies that we may have stored on your device).
- Information that we collect from third parties will generally consist of publicly-available information (such as your preferences and interests), for example from public social media posts.
3. How do we collect information about you?
We collect information about you in various ways:
- You provide us with information directly (e.g. signing a contract, filling in a form, or making a call to us).
- We collect information automatically (e.g. when you use our app or website).
- We acquire information from third parties (e.g. publicly-available information on social media platforms such as LinkedIn, Facebook and Twitter).
In this notice, we refer to all the methods by which you are in contact with myRitmeester. This includes all digital touchpoints regarding to myRitmeester (for example, e-mail correspondence, apps and websites).
We collect information that you provide directly. This happens when you:
- sign up to be a member of myRitmeester
- contact us through a RM touchpoint, or by e-mail, social media or telephone;
- participate in our surveys or (where permitted by law) our competitions or promotions; or
We also collect information about you automatically through the use of cookies and similar tracking technologies on the website of myRitmeester. To learn about the cookies (including Google analytics cookies) and similar technologies used on myRitmeester, including how you can accept or refuse cookies, please see the cookie notice.
4. For what purposes do we use information about you, and on what legal basis?
The purposes for which we use information about you, with corresponding methods of collection and legal basis for use, are:
PURPOSE
- Verify your age, identity and retailer status
- Legal and regulatory disclosure requests
- Investigation of reported allegations of misconduct
LEGAL BASIS FOR PROCESSING
Art. 6 (1) c) GDPR
PURPOSE
Business promotion and relationship management (where permitted by law)
- Inform you of relevant updates, promotions and events via myRitmeester
- Manage our relationship
- Understand your preferences (such as what products or events may interest you or may be better tailored to your needs)
- Administer loyalty programs
- Invite you to participate in, and administer, surveys or market research campaigns
- For market research
- Develop marketing strategies
- Administer marketing campaigns
- Customize your experience of RM touchpoints (for example, to personalize your visit, such as with greetings or suggestions that might interest you)
LEGAL BASIS FOR PROCESSING
Art. 6 (1) f) GDPR
We use it on the grounds that we have a legitimate business interest to manage our relationship and tell you about our business, products and events, to operate myRitmeester, and to customize your experiences, in these ways that is not overridden by your interests, rights and freedoms to protect information about you.
PURPOSE
Business promotion and relationship management (where permitted by law)
- Provide you with information about, and to manage, promotions, products and services, events and the regulation of tobacco products; and to develop and improve tools to pursue these purposes
LEGAL BASIS FOR PROCESSING
We use it on the grounds that we have a legitimate business interest to inform you about these things that is not overridden by your interests, rights and freedoms to protect information about you.
In certain countries, where required by law, we will send you these materials in electronic format only with your consent.
Business promotion and relationship management (where permitted by law)
This will typically be a combination of information that you provide to us (for example, your name and contact details, your social media handles); information that we collect automatically (for example, using cookies and similar technologies) and (where permitted by law) information that we acquire from third parties (such as public social media posts).
PURPOSE
Security and systems monitoring
- Authentication and access controls and logs, where applicable
- Monitoring of our systems, devices, internet and e-mail to which you are granted access
LEGAL BASIS FOR PROCESSING
Art. 6 (1) f) GDPR
We use it because we have a legitimate business interest in ensuring the confidentiality, integrity and security of our digital infrastructure and premises that is not overridden by your interests, rights and freedoms to protect information about you.
PURPOSE
Support for all the above purposes
- Administering your accounts
- Enabling you to use myRitmeester (for example, allowing you to remain logged in to sections that are reserved for authorized users only, administering your language preference, associating your shopping cart with you)
- Corresponding with you
- Enhancing your experiences, such as suggesting orders of products that might be suitable for you (for example, based on previous orders)
- Administration and troubleshooting
LEGAL BASIS FOR PROCESSING
Art. 6 (1) f) GDPR
We use it on the grounds that correspond to the purpose for using the information that we are supporting. For example, where we administer your account to support a purchase or to provide after-sales service, we use the information to discharge our contractual obligations to you as a buyer of our products; where we administer your account to update you on our products or where we suggest orders that might be suitable for you, we are supporting business development and so we use it on the grounds that we have a legitimate business interest to market our products that is not overridden by your interests, rights and freedoms to protect information about you, and so on.
PURPOSE
Business analytics and improvements
- Allowing us or our business partners to inform you of potential opportunities to get involved in promoting our products
- For business analytics and improvements (including for our products, systems, processes, training, events, digital RM touchpoints and the information that we (or our affiliates) provide to you, your employer or our customers)
LEGAL BASIS FOR PROCESSING
This will typically be a combination of information that you provide to us; information that we collect automatically; and (where permitted by law) information that we acquire from third parties.
We use it on the grounds that we have a legitimate business interest to analyze and to improve our business performance, our products, systems, processes, training, events, RM touchpoints and the information we provide and to invite others to get involved in promoting our products, that is not overridden by interests, rights and freedoms to protect information about you.
Where we do not base our use of information about you on one of the above legal bases, we will ask for your consent before we process the information (these cases will be clear from the context). This applies to your signing-in process to myRitmeester; legal basis for data processing in this case is Art. 6 (1) a) GDPR.
In some instances, we may use information about you in ways that are not described above. Where this is the case, we will provide a supplemental privacy notice that explains such use. You should read any supplemental notice in conjunction with this notice.
5. Who do we share your information with, and for what purposes?
Currently we are sharing your personal data collected via myRitmeester to the extent permitted by law with Ritpromo B.V (“Ritpromo”). Ritpromo belongs to our group and deals with the personal data as follows: your name and interest you provide to myRitmeester by filling in quizzes and tasks. This means we use the personal data on the grounds that we have a legitimate business interest (Art. 6 (1) f) GDPR) to market our products that is not overridden by your interests, rights and freedoms to protect information about you.
6. How do we protect information about you?
We implement appropriate technical and organisational measures to protect personal information that we hold from unauthorised disclosure, use, alteration or destruction. Where appropriate, we use encryption and other technologies that can assist in securing the information you provide. We also require our service providers to comply with strict data privacy and security requirements.
7. How long will information about you be kept?
We will retain information about you for the period necessary to fulfil the purposes for which the information was collected. After that, we will delete it. The period will vary depending on the purposes for which the information was collected. Note that in some circumstances, you have the right to request us to delete the information. Also, we are sometimes legally obliged to retain the information, for example, for tax and accounting purposes.
8. What rights do you have?
You may have some or all of the following rights in respect of information about you that we hold:
- request us to give you access to it;
- request us to rectify it, update it, or erase it;
- request us to restrict our using it, f and to the extent we process your personal data based on Art. 6 (1) e) GDPR or Art. 6 (1) f) GDPR; object to our using it, in certain circumstances;
- withdraw your consent to our using it;
- data portability, in certain circumstances; and
- opt out from our using it for direct marketing.
To exercise said rights, please contact us via our contact data mentioned in no. 1 above.
You have also the right to lodge a complaint with the supervisory authority. Should you wish to report a complaint or if you feel that our company has not addressed your concern in a satisfactory manner, you may contact Autoriteit Persoonsgegevens.
9 Changes to this notice
We may update this notice (and any supplemental privacy notice), from time to time. We will notify you of the changes where required by law to do so.