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Privacy Policy

# Privacy Policy — Nelvane

## 1 — Who We Are and How to Contact Us

We are pleased that you are visiting our website and thank you for your interest. The following explains how we handle your personal data when you use our website. Personal data refers to any information that can be used to identify you personally.

The data controller responsible for data processing on this website is:

**Nelvane**
Bergweidedijk 34, Deventer, Netherlands
hey@nelvane.com
nelvane.com

For security purposes and to protect the transmission of personal data and other confidential content, our website uses SSL/TLS encryption. You can recognise an encrypted connection by the "https://" prefix and the padlock icon in your browser address bar.

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## 2 — Data Collected When You Visit Our Website

When you visit our website for informational purposes only, without registering or otherwise providing us with information, we only collect data that your browser automatically transmits to our server (so-called "server log files"). When you access our website, we collect the following technically necessary data:

- Page visited
- Date and time of access
- Amount of data transferred (in bytes)
- Source/referral URL
- Browser used
- Operating system used
- IP address (anonymised where applicable)

This processing is carried out on the basis of our legitimate interest in improving the stability and functionality of our website in accordance with Article 6(1)(f) of the EU General Data Protection Regulation (GDPR). The data is not shared or used for any other purpose.

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## 3 — Cookies

To make visiting our website an enjoyable experience and to enable certain features, we use cookies on various pages. Cookies are small text files stored on your device.

Some cookies are deleted at the end of a browser session ("session cookies"), while others remain on your device and allow us or our partners to recognise your browser on future visits ("persistent cookies"). Persistent cookies are automatically deleted after a defined period of time.

Some cookies are used to simplify the ordering process (e.g. saving the contents of your shopping basket for a later visit). Where cookies process personal data, this is done on the basis of contract performance (Article 6(1)(b) GDPR) or our legitimate interest in the optimal functionality of our website (Article 6(1)(f) GDPR).

You can configure your browser to inform you when cookies are set and to decide individually whether to accept them. Please note that declining certain cookies may limit the functionality of our website.

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## 4 — Contact

When you contact us (e.g. via email at hey@nelvane.com), we collect personal data for the purpose of processing your enquiry. This data is stored and used exclusively to respond to your request and for related technical administration, based on our legitimate interest under Article 6(1)(f) GDPR. Data is deleted once your enquiry has been fully resolved and no legal retention obligations apply.

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## 5 — Customer Accounts and Order Processing

If you create a customer account or place an order, we collect and process the personal data you provide in order to fulfil the contract, in accordance with Article 6(1)(b) GDPR. Your customer account can be deleted at any time by contacting us at **hey@nelvane.com**. After deletion or full contract completion, your data will be retained only as required by applicable legal retention periods (e.g. Dutch tax and commercial law), then deleted.

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## 6 — Direct Marketing

### 6.1 Email Newsletter

If you subscribe to our newsletter, we will send you regular updates about our products and offers. We only require your email address to send the newsletter. Additional information provided is voluntary and used to personalise our communications.

We use a **double opt-in** process, meaning we will only send newsletters once you have expressly confirmed your subscription via a confirmation email. Your consent is recorded under Article 6(1)(a) GDPR.

You may unsubscribe from the newsletter at any time using the unsubscribe link included in every email, or by contacting us at **hey@nelvane.com**. Upon unsubscription, your email address will be removed from our mailing list immediately.

### 6.2 Newsletter to Existing Customers

If you have provided your email address during a purchase, we may occasionally send you information about similar products or offers in accordance with Article 6(1)(f) GDPR. No separate consent is required for this. You may object to this use of your email address at any time by contacting us at **hey@nelvane.com**.

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## 7 — Order Processing and Data Sharing

### 7.1 Shipping

We share your personal data with our delivery partners only to the extent necessary for the fulfilment of your order, in accordance with Article 6(1)(b) GDPR.

### 7.2 Payment Providers

**PayPal**
If you pay via PayPal, your payment data is shared with PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg, as required for payment processing under Article 6(1)(b) GDPR. For more information: https://www.paypal.com/en/webapps/mpp/ua/privacy-full

**Klarna / SOFORT**
If you choose to pay via SOFORT, your payment information is processed by SOFORT GmbH (part of the Klarna Group), Theresienhöhe 12, 80339 Munich, Germany. For more information: https://www.klarna.com/sofort/datenschutz

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## 8 — Review Reminders

With your express consent under Article 6(1)(a) GDPR, we may send you a one-time email reminder to leave a review of your order. You may withdraw your consent at any time by contacting us at **hey@nelvane.com**.

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## 9 — Social Media

Our website may include links or plugins for social media platforms including Facebook and Instagram. For security reasons, these are integrated as HTML links only, meaning no connection to the social media servers is made until you actively click on the link.

For information on data processing by these platforms, please refer to their respective privacy policies:
- Facebook / Meta: https://www.facebook.com/policy.php
- Instagram: https://help.instagram.com/155833707900388/

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## 10 — Online Marketing

### Google Analytics

Our website uses Google Analytics, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses cookies to analyse how visitors use our website. We use Google Analytics exclusively with IP anonymisation enabled, in accordance with Article 6(1)(f) GDPR.

You can prevent data collection by Google Analytics by downloading and installing the browser plugin at: https://tools.google.com/dlpage/gaoptout

### Google Ads Remarketing

We use Google Ads to advertise on Google search results and third-party websites, based on our legitimate interest under Article 6(1)(f) GDPR. You can disable personalised ads at: https://www.google.com/settings/ads

### Facebook Pixel

With your explicit consent under Article 6(1)(a) GDPR, our website uses the Facebook Pixel provided by Meta Platforms, Inc. This tool allows us to measure conversions and optimise our advertising. You can manage your advertising preferences at: https://www.aboutads.info/choices/

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## 11 — Customs and Import Duties

Please note that any additional customs clearance charges and/or import duties that may apply are not included in the product price and are the responsibility of the customer.

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## 12 — Your Rights Under the GDPR

Under the EU General Data Protection Regulation (GDPR), you have the following rights:

- **Right of access** (Article 15 GDPR): You have the right to obtain confirmation of whether we process personal data about you and to receive a copy of that data.
- **Right to rectification** (Article 16 GDPR): You have the right to request correction of inaccurate or incomplete personal data.
- **Right to erasure** (Article 17 GDPR): You have the right to request deletion of your personal data where no legal obligation requires us to retain it.
- **Right to restriction of processing** (Article 18 GDPR): You have the right to request that we restrict the processing of your data under certain circumstances.
- **Right to data portability** (Article 20 GDPR): You have the right to receive your personal data in a structured, commonly used, machine-readable format.
- **Right to withdraw consent** (Article 7(3) GDPR): Where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
- **Right to lodge a complaint** (Article 77 GDPR): You have the right to lodge a complaint with the Dutch supervisory authority:

**Autoriteit Persoonsgegevens (AP)**
Postbus 93374
2509 AJ Den Haag
Netherlands
https://autoriteitpersoonsgegevens.nl

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## 13 — Right to Object

Where we process your personal data on the basis of our legitimate interests (Article 6(1)(f) GDPR), you have the right to object to such processing at any time on grounds relating to your particular situation. If you object, we will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms.

You also have the right to object at any time to the processing of your personal data for direct marketing purposes. We will cease processing immediately upon receipt of such an objection.

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## 14 — Retention of Personal Data

Personal data is retained for as long as required by applicable legal retention periods (e.g. Dutch tax law requires a retention period of 7 years for financial records). Once these periods have expired, the data is routinely deleted, provided it is no longer required for the performance of a contract or any other legitimate purpose.

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## 15 — Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time. The most current version will always be available at **nelvane.com/privacy-policy**. We recommend checking this page periodically for any updates.

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*For any questions regarding this Privacy Policy or the processing of your personal data, please contact us at **hey@nelvane.com**.*