LAST UPDATED: 25 MAY 2018
AETN Benelux (“AETN, “we”, “us” or “our””) is committed to respecting your privacy.
The following Privacy Notice (“Privacy Notice”) sets out how we collect, store, use and share personal information relating to you which we collect via our websites (including: at www.crimeandinvestigation.nl), our applications, widgets, blogs, games, competitions and other online or digital services that we offer to our users, (“Digital Media”); and applies to all use of personal information by us.
The data controller of your personal information is AETN UK, Company Number 03105704, of 1 Queen Caroline Street, Hammersmith, London W6 9YN.
If you have any questions or concerns about your privacy or our use of your personal information, please contact us at email@example.com.
1. WHAT PERSONAL INFORMATION DO WE COLLECT AND WHY?
The personal information that we may collect about you broadly falls into the following categories:
Information that you provide voluntarily
Certain parts of our Digital Media may ask you to provide personal information voluntarily: for example, we may ask you to provide your contact details (i.e. name, email address, address and phone number), gender and age in order to register an account with us (at which point you will set up a username and password), to subscribe to marketing communications from us, to enter competitions and receive prizes, and/or to submit enquiries to us. If you submit any enquiry to us, or otherwise communicate with us, we will also collect any content that you send to us, including your comments and marketing preferences, or responses to surveys. We may use this information to record of our discussion for future reference and so we can provide services to you more efficiently. We will also use your personal information to manage your user account, to contact you with news (including monthly newsletters to notify you about competitions, to offer you additional services, or to otherwise market to you) where permitted by law, and to provide features and content which are better suited to you and to analyse your interest in our services and general consumer trends. Information we collect may also be used to enable our compliance with applicable laws and regulations, to verify your identity, to prevent fraud or reduce credit risk, to enable our compliance with any agreements that we have entered into (including to enable you to use our Digital Media and services), to understand how the Digital Media is being used, to provide you with an up to date, efficient and reliable service and to generally run and improve our Digital Media. Generally, the personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.
Information that we collect automatically
When you visit our Digital Media, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include information like your IP address, device type, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Digital Media, including the pages accessed and links clicked.
Collecting this information enables us to better understand the visitors who use our Digital Media, (including who is using our Digital Media and how they use the Digital Media, and what content on our Digital Media is of interest to them) and which webpages those users have come from. We use this information for our internal analytics purposes (for example, to record and report user profile, behavior, location, audience, demographic and interest data) and to improve the quality and relevance of our Digital Media to our visitors. We will also use this information to enable aspects of the Digital Media to be customized or remember your preferences and to provide you with relevant advertising.
Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology” below.
2. WHO DOES AETN SHARE MY PERSONAL INFORMATION WITH?
We may disclose personal information about you to the following categories of recipients:
• to our group companies, third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Digital Media), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information. This may include the operators, promoters or prize providers of competitions, or third parties who we use to facilitate the sending of our newsletters.
• to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights or those legal rights of a third party, or (iii) to protect your vital interests or those of any other person;
• to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
• to any other person with your consent to the disclosure.
3. LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Digital Media and to communicate with you as necessary to provide our services to you; and/or for our legitimate commercial interest, for instance, when responding to your queries, improving our Digital Media, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided at the top of this Privacy Notice.
4. COOKIES AND OTHER TRACKING TECHNOLOGY
We use ‘cookies’ and similar tracking technologies (collectively, “Cookies”) to collect and use personal information about you, including to serve interest-based advertising. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice.
5. HOW DOES AETN KEEP MY PERSONAL INFORMATION SECURE?
We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures we use include, but are not limited to, encrypting your personal information and using password protection.
6. CHILDREN’S PRIVACY
We do not anticipate that our Digital Media will be used by individuals under 16 years of age (each a “Minor”), nor that we will collect and use personal information about Minors. If you are a Minor, please get your parent or your legal guardian’s permission before you provide any personal information to AETN.
If we become aware that a Minor has provided us with personal information without the permission of his or her parent or legal guardian, we will remove this information from our systems.
7. DATA RETENTION
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
8. INTERNATIONAL DATA TRANSFERS
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
Specifically, our Website servers are located in the US, and our group companies and third party service providers and partners operate around the world. This means that when we collect your personal information we may process it in any of these countries.
However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice. These include implementing an intra-group agreement incorporating the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the EEA in accordance with European Union data protection law.
Our Standard Contractual Clauses can be provided on request. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.
9. YOUR DATA PROTECTION RIGHTS
You have the following data protection rights:
• If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided at the top of this Privacy Notice.
• In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided at the top of this Privacy Notice.
• You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided at the top of this Privacy Notice.
• Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact the Information Commissioner’s Office at: https://ico.org.uk/global/contact-us/
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
10. THIRD PARTY WEBSITES
If you follow a link from our Digital Media to any third party websites or other digital media, you should be aware that those websites or digital media will not be governed by this Privacy Notice and may have their own privacy policies. We do not accept any responsibility or liability for those third party websites and digital media. Please check the policies of any third party websites or digital media before submitting any personal data to them.
11. UPDATES TO THIS PRIVACY NOTICE
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.
You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.