MAX EUROPE BV - Data Protection Notice

Effective date: Apr 01, 2020

The protection of your personal data is of great importance to MAX EUROPE BV ("us", "we", or "our"). This privacy policy (the “Data Protection Notice”) therefore intends to inform you about how we collect and processes your personal data that you submit or disclose to us. We also act as data processor when we process your personal data received or obtained through third-parties. We process this personal data in accordance with the applicable European Union (“EU”) and Member State regulations on data protection, in particular, the EU General Data Protection Regulation No 2016/679 (the “GDPR”).

We encourage you to read this Data Protection Notice carefully. This Data Protection Notice describes how we collect, process and use your personal data when you visit and/or interact with our services, website, and the choices we offer. Unless otherwise stated, MAX EUROPE BV. is the data controller for personal data we collect through the services, websites and apps subject to this Data Protection Notice.

Our office address is MAX EUROPE BV, Antennestraat 45, 1322AH, Almere, The Netherlands

The Autoriteit Persoonsgegevens (Dutch Data Protection Authority) is our lead authority for the European Economic Area. The Autoriteit Persoonsgegevens can be reached at the following address:

Autoriteit Persoonsgegevens
PO Box 93374
2509 AJ DEN HAAG
Phone: (+31) - (0)70 - 888 85 00

You have the right to lodge a complaint also with your local supervisory authority, which you can find here.

If you have any queries or comments relating to this Data Protection Notice, please contact us at privacypolicy@max-europe.com.

1. Terms

Terms used in this Data Protection Notice shall have the following meaning:

Terms like “we”, “us”, “our”, etc. in this Data Protection Notice refer to MAX EUROPE BV.

Terms like “you”, “your”, “yours”, etc. refer to you as a natural person.

The term “personal data” as used in this Data Protection Notice means any information, whether such information was entered by you, collected from you or otherwise obtained, relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier like in our case such as a name, company, a MAX EUROPE BV identification number or other technical online identifiers.

2. Responsibility for the Handling of Your Personal Data

The party responsible for the collection, processing and use of personal data is MAX EUROPE BV as the provider of the services and websites.

3. Applicability

This notice applies to all MAX EUROPE BV services and websites that link to this document. This Data Protection Notice does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you in search results, sites that may include MAX EUROPE BV services, or other sites linked from our services.

Our Data Protection Notice does not cover the information practices of other companies and organizations who advertise our services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

4. Types of Personal Data We Collect, Process and Use

Personal data that we collect, process and use in connection with the services, websites and apps includes not only information that we actively collect while you interact with us but also information that you provide to us over the customer service, at any physical locations, and to our sales team.

Data Subject Log Information Device Information Location Information and Unique Identifiers
Website User
  • user preferences (e.g., preferred language settings)
  • automatically log files for troubleshooting and security purposes (e.g. to fend off hacker attacks)
  • log for crash report, and in exceptional cases, such as when malfunctions, errors or security incidents have occurred, a manual analysis of the logs may be performed by us or by our authorized service providers
  • date and time of the request
  • name, URL and amount of data transferred for the requested file
  • report indicating that the retrieval was successful or the reason for its failure
  • type and version of the operating system of the requesting computer (if transmitted)
  • screen resolution and color depth (if transmitted)
  • type and version of the browser used (if transmitted)
  • language setting and plugins installed on the browser used (if transmitted)
  • cookies that uniquely identify your browser
  • IP address, operating system, browser type, browser version, browser configuration
  • name of internet service provider, and other types of computer and connection related information relevant to identifying your type of device connecting to the web-site, enabling data exchange with you and your device, and ensuring a convenient use of the services, websites and apps
  • URL and IP address of the website from which you accessed, or were directed to our website, including date and time
  • subpages visited while on our website, links followed on the website, including date and time
  • subpages visited including date, time and time spent on page – on the apps
  • the full Uniform Resource Locator (URL) click stream to, through and from the website, including date and time
  • device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL
Company Information
  • name, address, department, contact information and other information in relation to a company that you represent and your function within this company
  • customer number
  • VAT number
  • delivery address
  • business email address,
  • order number
  • business telephone number
  • business mobile phone number
  • company
  • contact language
  • customer advisor / point of contact
  • importance of customer
  • organizational unit
  • participation in campaigns or events
  • postal code
  • product history
  • region
  • returns
  • order number
In Person Surveys or Customer Service
  • name
  • address
  • email address

We will seek your consent before collecting, processing and using your personal data for the above-mentioned purposes, where legally required.

Likewise, if we wish to use your personal data for a new or different purpose, we will notify you thereof and will only make such other use if it is required or permitted by applicable law or if you have consented to it.

Any access to your personal data at MAX EUROPE BV is restricted to those individuals that have a need to know in order to fulfill their job responsibilities. For the purposes mentioned above, only a limited number of individuals within MAX EUROPE BV (e.g. individuals in sales, support, legal, finance, IT and accounting departments, as well as certain managers with assigned responsibility) will receive access to your personal data.

When you contact MAX EUROPE BV, we keep a record of your communication to help solve any issues you might be facing. We may use your provided email address or phone number to inform you about our services, such as letting you know about upcoming changes or improvements.

5. Disclosure and Sharing of Personal Data

We do not sell, trade or rent out your personal data.

For the purposes mentioned in this Data Protection Notice we disclose, transfer or otherwise share your personal data, with other entities of the MAX EUROPE BV’s group of companies to the extent described in the following or as agreed by you in a specific context (e.g., where you consenting to other types of data transfers in connection with enrolling for a specific service). Whenever sharing personal data, we do strictly comply with applicable laws.

We do not share Personal Information with companies, organizations and individuals outside of MAX EUROPE BV, unless one of the following circumstances applies:

Consent:

We will share Personal Information with companies, organizations or individuals outside of MAX EUROPE BV when we have your consent to do so. We require opt-in consent for the sharing of any Personal Information.

External Processing:

We provide Personal Information to our third-party service providers under appropriate instructions as necessary for the respective processing purposes, to perform specific tasks on our behalf and under our instructions. Any third-party provider will have access only to such personal data needed to perform its specific tasks, and only to perform such tasks.

We will ensure that any third-party service provider is aware of and abides to these duties. We will also ensure that any third-party service provider treats your personal data no less protective as required by applicable data protection laws and that they adopt adequate technical and organizational security measures based on our instructions and in compliance with our Data Protection Notice and any other appropriate confidentiality and security measures.

Third party service providers provides services such as hosting, maintenance, support services, email services, marketing, auditing, fulfilling your orders, processing payments, data analytics, providing customer service, conducting customer research and satisfaction surveys.

Legal Requirements:

Without limitation, this include cases in which we are required to share personal data by law or binding order of courts, law enforcement authorities or regulators. Should we decide to disclose personal data in such context we will also consider ways of reducing the scope of the disclosure, for instance by redacting the information provided.

6. Transfer of Data

We take steps to ensure that the data we collect under this Data Protection Notice is processed according to the provisions of this Notice and the requirements of applicable law wherever the data is located. Such transfers may take place for the purposes of providing you customer services, processing your data by Our service provider, or providing you with services at your location. For each of these transfers, we make sure that we provide an adequate level of protection to the data transferred, in particular by entering into standard contract clauses as defined by the European Commission decisions 2001/497/EC, 2002/16/EC, 2004/915/EC and 2010/87/EU.

7. Purposes of Processing Personal Data and Retention Period

To the extent it is technically possible, MAX EUROPE BV is striving in all of its MAX EUROPE BV services and websites to retain personal data no longer than necessary for the described purposes in this notice and/or as required or permitted under applicable law.

The following table gives an overview of the processing activities of MAX EUROPE BV services, websites with their purpose of the data collection, their type, the legal basis and the applicable data retention periods.

Processing Purpose(s) Type of Personal Data Processing Legal Basis Retention Period
To provide, maintain, and improve our services and website
  • User profile information (i.e., first name, name, email address, phone number, address)
  • User preferences (e.g., preferred language settings)
  • IP address, operating system, browser type, browser version, browser configuration, name of internet service provider, and other types of computer and connection related information relevant to identifying your type of device, connecting to the services, websites, enabling data exchange with you and your device, and ensuring a convenient use of the services, websites
  • If you use the mobile version of the services, websites: information on the operating system of your mobile device, used services, websites and apps version, name of internet service provider, and other types of device and connection related information relevant to improve the mobile services, websites, connecting to our servers, enabling and facilitating synchronization services
  • URL and IP address of the website from which you accessed, or were directed to our services, websites and apps, including date and time
  • Subpages visited and functions used when using services, websites, links followed from the services, websites, including date and time
  • The full Uniform Resource Locator (URL) click stream to, through and from the services, websites, including date and time
  • Search terms entered
  • Consents and authorizations granted
 Legitimate interests (Art. 6 (1) (f) GDPR)/ required for the performance of a contract (Art. 6 (1) (b) GDPR) MAX EUROPE BV retains the collected data for an undefined period to fulfill the purposes outlined in this Privacy Policy and will then be anonymized or deleted. If requested, personal data retained will be updated, and, if necessary, archived or deleted.
To provide customer support, respond to your inquiries, comments, and suggestions, or contact you when necessary
  • Name, address, phone number, and email address
  • Information on the device used (browser type, IP-address)
  • Date and time of the contact submission
  • Content of any communication sent through the content form
 Consent (Art. 6 (1) (a) GDPR or Legitimate interests (Art. 6 (1) (f) GDPR):

The processing of personal data is necessary to answer the respective request of the website user which otherwise cannot be fulfilled. Therefore, the processing is justified on the basis of legitimate interests.
for advertising and market research purposes and to enable us to tailor website content to individual preferences
  • User profile information (i.e., first name, name, email address, phone number, address)
  • User preferences (e.g., preferred language settings)
  • IP address, operating system, browser type, browser version, browser configuration, name of internet service provider, and other types of computer and connection related information relevant to identifying your type of device, connecting to the services, websites, enabling data exchange with you and your device, and ensuring a convenient use of the services, websites
  • If you use the mobile version of the services, websites: information on the operating system of your mobile device, used services, websites and apps version, name of internet service provider, and other types of device and connection related information relevant to improve the mobile services, websites, connecting to our servers, enabling and facilitating synchronization services
  • URL and IP address of the website from which you accessed, or were directed to our services, websites and apps, including date and time
  • Subpages visited and functions used when using services, websites, links followed from the services, websites, including date and time
  • The full Uniform Resource Locator (URL) click stream to, through and from the services, websites, including date and time
  • Search terms entered
  • Consents and authorizations granted
 Consent (Art. 6 (1) (a) GDPR
To prevent abusive or illegal use of our services and websites

Compliance with legal obligations, resolving disputes, and enforcement of our agreements		 Any necessary data to fulfill the relevant purposes Legitimate interests (Art. 6 (1) (f) GDPR)/ IT security measure and compliance with a legal obligation (Art. 6 (1) (c) GDPR)
Evaluation of your eligibility for certain types of offers, products or services
  • Name, title and address
  • Personal contact information (phone, email, fax, etc.)
  • Name, address, department, contact information and other information in relation to a company that you represent (if any) and your function within this company
  • VAT number
  • User profile information
  • Confirmation of being either a private or a professional user
  • Newsletter subscriptions, enrollment for promotions, use of special offers, etc
  • Consents, authorizations, etc. granted
 Consent (Art. 6 (1) (a) GDPR)
To communicate with you on other matters (e.g., to send you reminders, technical notices, updates, security alerts, support and administrative messages or service bulletins)
  • Email address
  • Country
  • Language
  • Date of last contact
  • Mobile phone number
 Consent (Art. 6 (1) (a) GDPR or Legitimate interests (Art. 6 (1) (f) GDPR):

The processing of personal data is necessary to the use of our services and websites which otherwise cannot be fulfilled. Therefore, the processing is justified on the basis of legitimate interests.
To provide you with information about products and services that may be of interest to you through email, telephone and mail.
  • Name
  • Email address
  • Country
  • Language
  • Consent state with date
  • Date of last contact
  • Phone number
 Consent (Art. 6 (1) (a) GDPR

8. Your Privacy and Marketing Choices

We aim to maintain our services and website in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our services and website, we may not immediately delete residual copies from our active servers and may remove information from our backup systems only after certain timeframes in accordance with applicable laws (see pt. 6).

You can set your marketing preferences at any time through our customer service. By signing up for marketing information offered by MAX EUROPE BV, you agree that the data you provided when signing up (e.g. your email address) can be collected, processed and used by MAX EUROPE BV for the regular dispatching of written electronic communication containing company, product and service-related information such as news about new MAX EUROPE BV products or MAX EUROPE BV’s services or about MAX EUROPE BV’s marketing campaigns (e.g. competitions, discounts, promotions), about changes within the company or to invite you to customer surveys (e.g. on customer satisfaction or customer requirements).

You can modify and adjust your consent to use your email address or mobile phone number by contacting us at privacypolicy@max-europe.com.

9. Your Rights Under the GDPR

You can at any time contact us at privacypolicy@max-europe.com to exercise the following rights under the GDPR:

  • Right of access
  • Right to rectification
  • Right to erasure ("right to be forgotten")
  • Right to restriction of processing
  • Right to data portability

Please use the EU website to learn more about these rights.

In the case you withdraw your consent to a processing activity, MAX EUROPE BV. reserves the right to further process and use your personal data to the extent this is required or permitted by law e.g. to administrate your unsubscribe or set an over layer cookie to respect your cookie settings.

10. Other Protections for Your Personal Data

MAX EUROPE BV understands the importance of information and data security and we want your browsing and purchasing experience with us to be as safe as possible. To protect your personal data, we have implemented reasonable and state of the art safeguards and precautions, including technical and organizational measures against unauthorized access, improper use, alteration, unlawful or accidental destruction and accidental loss, both in an online and offline context.

For example:

  • when you use our website, communication with your browser is encrypted using SSL (Secure Socket Layer) technology. This means that when you use our website the personal data you submit during the registration and login processes are encrypted before being sent over the Internet.
  • we review the integrity our information collection process, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.
  • we restrict access to Personal Information for MAX EUROPE BV. employees, contractors and agents based on a need to know approach in order to process it for us. Involved parties are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

11. Cookies

We use cookies and similar technologies in connection with our services and website. For more information, please see our cookie policy.

12. Links to Other Websites

Our services and websites may contain links to other services, websites and apps of interest, once you have used these links you leave our services area. When you visit such other services, websites and apps you should exercise caution and look at the privacy statement applicable to the app or website in question. MAX EUROPE BV cannot, and does not, assume any responsibility or liability for such other websites, the content of such services, websites and apps and their privacy practices, nor do we endorse them.

13. Compliance and Cooperation with Regulatory Authorities

We regularly review our compliance with our Data Protection Notice. We work with the appropriate regulatory authorities, including local data protection authorities. You have the right to lodge a complaint with a supervisory authority.

14. Changes to the Data Protection Notice

We may update our Data Protection Notice from time to time. We will notify you of any changes by posting the new Data Protection Notice on this page. Please check this Data Protection Notice from time to time to ensure that you are comfortable with any changes we had to make. We will not reduce your rights under this Data Protection Notice without your explicit consent.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Data Protection Notice.

15. Contact us

If you have any questions about this Data Protection Notice, please contact us:

By email: privacypolicy@max-europe.com

Postal address: MAX EUROPE BV., attn.: Privacy Office, Antennestraat 45, 1322AH, Almere, The Netherlands