Privacy statement

Privacy & Cookie Statement – Sorted Management

Introduction

We, Sorted Too B.V. (hereafter "Sorted"), the management bureau of DJ Harwell, can collect data from you and about you when you use our products and services. This might include data you provide to us when buying one of the products and/or services that DJ Harwell supplies, or data that we collect when you use our (mobile) websites, apps, webshops and other services such as online promotions, events, campaigns, pricing requests and possibly loyalty programmes.

We do this so that we can continually improve our products and services on the basis of insights we gain from that data (e.g. by better meeting your requirements). We also do this from a commercial perspective (to gain a better insight into the products and services you are interested in as a user and to use the online capacity we have as efficiently as possible in relation to partnerships we enter into with advertisers and sponsor partners).

This document explains how we deal with our supporters in relation to data, what data we can collect and how, and the purposes for which we can use it. It also explains how you can see your data, how you can change or remove your data (or have this done) and who might potentially receive that data.

Once you've accepted this privacy and cookie statement on the Sorted platform, it also operates as consent for multiple Sorted platforms (domains). The Sorted websites to which domain consent applies are:

Processing by Sorted

This privacy and cookie policy applies to the processing of data by Sorted. The data controller for the processing of personal data is Sorted:

Sorted Too B.V., with its registered office at Generaal Vetterstraat 76-D, 1059BW Amsterdam, registered in the trade register of the Chamber of Commerce in Amsterdam under number 58139559.

Contact

We want to use this privacy and cookie policy to explain to you how we deal with your data. If you have any questions about this document or the processing of data, please ask them using the email address privacy@sortedmanagement.com.

There is no obligation to provide personal data

You are under no obligation to disclose your personal data when you buy a product or service from us. You always have the choice of whether or not to complete your personal data details. However, inserting personal data is necessary in order to be able to use a number of our products and services.

Types of personal data

When offering products and services, we can process (personal) data of customers and visitors/users on our (mobile) websites, apps, webshops and other services such as online promotions, events, campaigns, price requests and potentially loyalty programs. The (personal) data that we can process and the way in which we do so varies for each product and/or service.

We can collect (personal) data in a number of ways:

  • purchasing/supply of products/services: this involves processing personal data you provide to us yourself, such as full name, address, town, country, phone number, gender, age, date of birth (for supply purposes), financial data (for payment purposes) and the knowledge that you as a customer have used that specific product/services (in which you are obviously interested);

  • opening a (Sorted) account on our website, mobile website or in an app. This involves processing personal data that you have provided to us or have allowed us to access (such as when using a social log-in) when opening the account, such as your email address, full name, town and user name;

  • applying for products/services via our websites, mobile website and apps (for instance asking for an email newsletter); this involves processing data you provide to us via the website, such as your email address;

  • using our websites, mobile websites and apps; this involves processing data about your use of these websites, mobile sites and apps, such as page visits and websites within our network, the adverts that are shown and the adverts you have clicked on. We can deduce your possible interest from this data;

  • using our apps; this involves processing personal data you have entered via the app yourself, or data you may have allowed us to access (such as location data).

This data accordingly encompasses not just personal data such as full name, email address, private address, town, country and phone number (data that can directly identify you) but also data that may relate to you but from which you cannot be identified directly or indirectly. This privacy and cookie policy governs how we deal with all of this data.

Does Sorted collect all this data for all the products/services that I buy?

The Sorted websites covered by the domain consent are limited to the following and linked pages:

Exchange of data within Sorted and its subsidiaries

In some cases, we will combine your data with data collected in the context of your purchase and your use of a number of our products/services (and/or the products/services of our subsidiaries), or with data originating from external data sources (such as CDDN, Cendris, EDM or DCN). We compile a profile based on this data, so that we can provide you with a better service and harmonise the content of these products and services (including websites and product/service offer) even more closely to your interests.

Purposes of processing

We collect and process personal data for the following purposes:

  • for the completion and implementation of an agreement concluded with you;

  • to offer you the agreed products, services and/or information, to supply these and adapt them to your requirements and wishes;

  • to afford you the opportunity to place and exchange information on one of the websites or, if the website offers that facility, to make contact with other users;

  • to submit invoices if the product/service has to be paid for. We never publish financial data on a website and never make it available to third parties for purposes other than for implementing the agreement. If payment for our products/services is outstanding, we may, for instance, place the claim in the hands of third parties such as a collection bureau;

  • to make targeted offers, for instance via email or other messaging platforms. An advertisement might also be shown, for instance on a website or in an app, for a product that we suspect you may be interested in on the basis of the personal data we have processed. We may compile a profile of you in the context of optimising offers made to you;

  • for sending you a newsletter, offer, user information, service notice or other electronic message;

  • for analysing our website, mobile websites and apps and associated technologies, maintaining and optimising them, securing them and counteracting fraud;

  • for complying with the legislation and regulations that affect us, for dealing with disputes and for having audits undertaken;

  • for carrying out market research and compiling management information for the purpose of product and/or service development and for determining our general strategy.

Not all data is always used for the same purposes. In principle, we retain your personal data as long as it is needed for the purposes outlined above or to comply with statutory retention rules.

In principle, we prefer to ensure that we only hold your data for as long as necessary. Sorted uses the data in any case for as long as you continue using the services and then for a further period of 3 years if you become inactive. Sorted does this to simplify your use of the service if you come back again.

An exception to this is where the law prescribes that Sorted has to retain data for even longer.

Sharing and disclosing personal data

We can exchange the personal data that we process with the subsidiary companies mentioned above, just above the heading "Processing by Sorted", and combine it with data processed by these subsidiaries. You can let us know if you have any objections to this via the email address privacy@sortedmanagement.com.

To allow us to focus how we buy in online advertising space, we can offer third parties (advertisers) the facility of using segments into which we divide our visitors (based on the personal data we collect). For instance, an advertiser might indicate that its advert for beer should only be shown to men in the age range 20-34. This lets the advertiser target its advertisements without actually receiving the data itself. Advertisers can use this information on a website or elsewhere.

In special circumstances, we can pass your personal data to third parties without your permission. Special circumstances include, for instance, lawful requests from authorities, summonses or judicial orders, the detection and prevention of loss or fraud, and actions to guarantee the security of our network and services.

We can also provide personal data to "data processors" who supply products/services to you on our instructions and at your request, in which case (unless otherwise indicated) your personal data will only be used to complete the supply obligation. These processors are not entitled to use your data for their own purposes.

Finally, we can pass certain anonymous data to third parties, such as the number of users clicking on a particular advert or link. You will not be able to be identified from that data.

Cookies

Cookies are small files from Sorted's websites or apps that can be saved on the hard drive or in the memory of your computer, tablet or mobile phone. They make it easier, for instance, to recognise a further visit without you having to log in again. Data can also be collected using cookies about the use of Sorted's websites by other visitors (who have not logged in using a Sorted account). There are various types of cookies. In some cases, cookies are automatically deleted when you close your browser, while in other cases these cookies are kept for longer and can also be read when you next use the service. So far as Sorted collects personal data using cookies, that data is processed in accordance with the provisions in this Privacy & Cookie Statement. Sorted will notify you and ask for your consent before placing non-functional cookies. These cookies will only be positioned and read if you give permission.

Sorted itself positions cookies in order to recognise you on a subsequent visit without you having to log in to your account again. Sorted can also position cookies with a view to compiling profiles. Sorted can also position tracking cookies, which Sorted uses if you surf to third party websites while visiting our site, in order to let us position adverts via an RTB and/or programmatic networks. Also, Sorted uses third parties for analysing its content, websites, apps and services. These third parties also position cookies for Sorted, which are used to identify how you use the service. Examples are Google Analytics or BlueConic.

Third-party cookies are positioned by third parties and only those third parties have access to these cookies and the data that they collect. Third parties that position cookies via the service include, for instance, advertising networks that place adverts on the Sorted websites.

Social network services like Facebook, Twitter and Google can also position cookies via the Sorted websites.

The following is an overview of all cookies positioned from the Sorted websites or apps:

Analytical cookies

We use cookies to gain an insight into the use of our website, to improve the website on the basis of these insights and thereby to increase ease of use.

• Google Tag Manager (this cookie allows for monitoring of the surfing behaviour of website visitors by placing ‘tags’. You can find more information about Google Tag Manager in Google's privacy policy);

• BlueConic Plugin (This plug-in allows the collection of data about the website visitor and his or her actual visit. You can find further information about Blueconic at the website for BlueConic);

• Google Analytics (we use these cookies so that Google can provide us with an understanding of how our website is used, reports about the website and information about the effectiveness of our campaigns. You can find more information about Google Analytics in Google's privacy policy).

Advertising cookies

As well as the cookies mentioned above, we use the following advertising cookies to improve our online advertising offer and provide us with an understanding of our campaigns:

• Double Click (one of the purposes of this cookie is to ensure that you do not see the same and had multiple times. You can find more information about Double Click in Google's privacy policy);

• ScoreCard research (analytic pixel used for research);

• Facebook pixel (tracking pixel used for re-targeting inside Facebook).

 

If you would like more information about the cookies positioned by third parties from Sorted websites or apps, and how they are used, please read the privacy and cookie statements of those parties on their websites and/or apps.

Any visitor to the websites and/or apps who absolutely does not want to receive any more cookies will have to change these settings in all browsers and on all devices that are used. If all cookies are rejected and/or removed, you may not be able to use the full service.

 

Security

We maintain a level of security at all times when processing personal data which, given the state of the art, is adequate to prevent unauthorised access to, amendment or disclosure or loss of personal data. These include both technical and organisational measures (such as encryption of data, control of access to our sites, and a restricted group of employees who have access to the data, etc).

 

Persons below the age of 16

If you are not yet 16, you must ask your parents for permission to use our products/services. You should get them to read this Privacy & Cookie Statement.

 

Transfer, examination, amendment and deletion of personal data

We regarded as important to be transparent about how we deal with your personal data. This Privacy & Cookie Statement is our attempt to provide you with clarity and transparency. However, if you still have any questions about how we deal with your personal data, please feel free to contact privacy@sortedmanagement.com.

If you would like to know what personal data we have recorded for you, or if you want to have any data amended or deleted in line with the relevant legislation, you can send an email to privacy@sortedmanagement.com

You can also indicate that you no longer want your personal data to be disclosed to subsidiaries or third parties, or combined into a profile, or used for targeted offers, or for receiving information and offers by email.

We will tell you as quickly as possible after receiving your request whether and how we can actually agree to your request and, if not, why not.

 

Amendments to the Privacy & Cookie Statement

This Privacy & Cookie Statement may be amended. What this means is that you should check this page regularly to see whether any amendments have gone through. If we want to make any fundamental changes, we will make a more conspicuous announcement, for instance via our website or by email.

 

This Privacy & Cookie Statement was most recently amended on Thursday, 24 May 2018.