Privacy policy
We know how important it is for you to understand how we use your data. This privacy policy describes how and why we collect, store, process and share your personal data. We will always be transparent with you about what we do with your personal information.
This policy also tells you what your rights are with regard to the personal data you provide to us. If you have any questions about this privacy policy or about your rights under this policy, please contact us:
Address: Welltub, Noordermorssingel 7, 7461 JP, Rijssen, The Netherlands
Telephone: +31 (0)548 870 390
E-mail: info@welltub.nl
We are Rikz kunststofstoffen B.V. (“Welltub Hottubs”). Welltub Hottubs is the “data controller” of all personal data it collects, processes and holds about you, unless we inform you otherwise.

What personal information do we collect?
The personal information we collect directly from you may include your name, email address, telephone number, date of birth, address, your order, your credit card or other payment information and information you give us when you contact our customer service or contact our social media platform (for example, by ‘tagging’ us in a message on Instagram or by writing about us on Facebook). When you shop with us online or browse our website, we may collect your IP address or other device ID specific, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other information about portable devices. We may also, where we have a legitimate basis for doing so, collect personal information about you from third parties who provide us with additional public information about you. We use this information on an anonymous basis and will never use it to identify a particular user. We cannot link this information to other information we hold about you and the purpose of collecting this information is to carry out analyses and help us identify people in our shops in order to maximise the efficiency of our web shop.

When do we collect your personal data?
When you buy products and services from us online, or over the phone.
When you visit our website. Our website also uses cookies; please read our Cookie Policy to learn more about the use of cookies and how you can manage them.
When you contact our customer service team online or by phone.
When you contact us on social media (by mentioning / tagging us or contacting us directly).

How do we use your personal data and what are our legal justifications for doing so? To make our products and services available to you.

We use your personal data to provide you with the information, products and services you request or purchase from us (i.e. to carry out certain tasks, processes or orders on our website, to make online payments (if applicable) and to deliver your products or services) and to communicate with you about the products and services you purchase from us and to respond to your questions and comments;
We may also use your personal information to measure customer satisfaction and provide customer service (including troubleshooting in connection with purchases or your requests for services or when you ask us questions on social media);
We rely on our contractual arrangements with you as the legal basis on which we collect and process your personal data when you place an order for products and services. In some cases, we also depend on our legitimate interests as a company. Where we rely on our legitimate interests, we will always ensure that we weigh those interests against your rights.
For administrative and internal business purposes.
We may use your personal information for internal business purposes, such as improving our website, improving our services and products and identifying trends. We may also use your information to monitor the use of our website and ensure that our website is presented in the most effective and relevant way for you and your device and to set standard options for you (e.g. language and currency);
It is in our legitimate interest as a company to use your personal information in this way. We want to ensure that our website is customer friendly and works well and that our products and services are efficient and of high quality. We also want to make it easy for you to get in touch with us. Where we rely on our legitimate interests, we will always ensure that we weigh those interests against your rights.

For safety and legal reasons.
We use your personal data:
Ensure that the personal and financial information you provide is accurate;
Carry out fraud checks or prevent other illegal activities;
Protect our rights or property (or the property of others); and
comply with our legal and conformity-related obligations.
In some cases we will use your personal data because it is necessary to comply with a legal obligation (such as the legal obligation to keep invoices for at least 5 years). In other cases (such as fraud detection) we will rely on our legitimate interests as a company to use your personal information in this way. Where we rely on our legitimate interests, we will always ensure that we weigh those interests against your rights.

For marketing purposes
We use your personal data to personalize your experience with Welltub:
Provide you with marketing material by post and e-mail if you have given us permission to do so;
process your registration data and purchase history to analyse how you shop and what you have searched for. These can be historical transactions. This enables us to provide a better customer experience;
in some cases, send specific offers to our customers based on historical transactions;
measure the effectiveness of our marketing campaigns and advertisements;
We rely on your consent to send you marketing messages by post and email based on the consent we obtained from you when you contacted us, or when you purchased a product from us.
In other cases (e.g. to measure the effectiveness of our marketing) we will rely on our legitimate interests as a company to communicate with customers in an engaging and efficient manner. Where we rely on our legitimate interests, we will always ensure that we weigh those interests against your rights.

With whom do we share your personal information?
We will never sell your personal information to third parties. In order to provide our services to you, we will share your personal information with our trusted third party service providers or our subsidiaries as described below. When we share your personal information, we put in place security measures which require these organisations to keep your information secure and ensure that they do not use your personal information for their own marketing purposes.

External Service Providers

To execute orders for products and services.
We work with a number of trusted service providers who perform services on our behalf. When you purchase products from us, the services provided by these organisations include, but are not limited to, the transportation of our goods and the processing of payments. It is in our legitimate interest as a company to work with these service providers because we do not have the ability to provide these services ourselves. In any event, we will ensure that the service provider may only use your personal data to provide the services to us and for no other purpose.
To prevent crime and comply with laws
We share your financial information, including your credit card, debit card or other payment information, with third parties to ensure that your payment is secure and that your information is not used fraudulently. This data exchange enables us to conduct a fraud analysis that ensures that real and correct payment information is provided to us for every purchase. We may share your personal data with credit bureaus if you request payment after delivery following the payment option.
There may be other scenarios in which we are required by law to share or disclose your personal information, such as with law enforcement or government agencies, in order to prevent or detect crime or to comply with any other legal requirement.

Other professional services
We may need to disclose your personal information to our insurers when we believe this is required by our contractual relationship with our insurance company.
We work with carefully selected third parties such as our customer database hosting provider, marketing agencies and advertising partners who help us to provide you with a positive customer experience. We work with these third parties to post relevant content and advertisements for you on our website, other websites and online media channels and apps. To do this, we use pixels and cookies. You can consult our cookie policy for more information.

Subsidiaries
We may share the personal data we collect with other organisations in the Welltub group, where the other companies share different operations and business processes with us (Welltub hottubs and Rikz kunststof B.V.). We will do this in order to fulfil our contractual obligations to you, or because it is in our legitimate interest to do so.

Transfer of your personal data outside the EEA
We may need to transfer your personal data outside the European Economic Area (EEA), e.g. the US, in the following circumstances:
Where we work with a supplier who processes some of his personal data outside the EEA.
These countries may not have the same data protection laws as the EEA and therefore your personal data may not be subject to the same protection. In such cases, however, we will ensure that any transfer of your personal data to countries outside the EEA is subject to appropriate safeguards as they apply within the EEA and is processed in accordance with the guiding principles set out in this Privacy Policy.
If you would like more information, please contact us.

Your Rights
You have a number of rights with regard to your personal data and what happens to it. You are entitled to:
To have your data processed in a fair, lawful and transparent manner;
to be kept informed about how your personal data is used;
to obtain access to personal data that we hold about you;
to undertake to correct any errors in your personal data;
Undertake to delete personal data about you in certain situations where there is no legitimate reason for us to continue to process it;
object at any time to the processing of your personal data for direct marketing purposes;
object, in certain other situations, to our continuing processing of your personal data; and
limit or stop (temporarily) the processing of your personal data in certain circumstances.

Changing your preferences
If you no longer wish us to contact you about our products or services, or for other marketing purposes, you can change your preferences or cancel your subscription by contacting us.

Security and retention of your personal information
Security of your personal data
We take the security of your personal data very seriously. We have implemented various strategies, controls, policies to secure your data and monitor these measures closely. We protect your data using encryption techniques and we use other security mechanisms such as IP and password protection mechanisms. This means that your data is protected and can only be accessed by our employees who need it to carry out their tasks. We also ensure that there are strict controls that restrict access to your personal data to keep it secure.
Retention of your personal data
We will only retain your personal information for as long as necessary for the purposes described in this privacy policy. This means that retention periods may vary depending on the type of data and the reason we hold it in the first place.
We have procedures in place regarding our retention periods, which we review on an ongoing basis, taking into account our reasons for processing your personal data and the legal basis for doing so.

Changes to this privacy policy
We may update this privacy policy from time to time. Please check this policy regularly to ensure that you are familiar with the most current version.
This Privacy Policy was last updated on 10 April 2019.