Privacy Policy

1. Who is responsible for your data

The controller within the meaning of the General Data Protection Regulation (GDPR) is:

We have not appointed a data protection officer; for an organisation of this size that is not required. Questions about this policy can be sent via WhatsApp at +44 7448 399511 or by post to Visseringlaan 19, 2288 ER Rijswijk.

2. Which data we process and why

We process the following categories of personal data. For each processing activity we state the purpose, the legal basis under Article 6 GDPR and the retention period.

2.1 Requesting a trial or subscription

Requesting a trial or ordering a subscription happens exclusively via WhatsApp. This website has no form for it and does not itself process any data when you make a request. To create your login details for the trial or subscription and send them to you, we process your name, your WhatsApp or phone number and the content of the WhatsApp conversation, such as the type of device you want to watch on and, if your device needs it (for example a MAG box), the MAC address of that device.

• Purpose: handling your request or order, creating your login details and sending them to you via WhatsApp, and helping you with the setup.
• Legal basis: necessary for the performance of the contract, or for the pre-contractual stage at your request (Article 6(1)(b) GDPR).
• Recipient: Meta Platforms Ireland Limited, via WhatsApp (see 2.2 and section 4).
• Retention period: as described in 2.2; the data stays in our WhatsApp account for as long as it is needed for the customer relationship and our records. Requests that do not lead to a contract are deleted within twelve months.

2.2 Contact via WhatsApp

All our customer contact (questions, requests and orders) runs via WhatsApp. Every button on this website that links to WhatsApp opens a conversation with our number +44 7448 399511. As soon as you start that conversation, Meta Platforms Ireland Limited processes your phone number, your profile name, the content of your messages and the associated metadata (such as timestamps and delivery status).

• Purpose: answering your question, setting up a trial or subscription and providing customer service.
• Legal basis: necessary for the performance of the contract or the pre-contractual stage (Article 6(1)(b) GDPR). For answering general questions we rely on our legitimate interest in customer contact (Article 6(1)(f) GDPR).
• Recipient: Meta Platforms Ireland Limited, and the companies affiliated with Meta outside the European Economic Area to which Meta transfers data (see section 4).
• Retention period: the conversation history stays in our WhatsApp account for as long as it is needed for the customer relationship and our records. Conversations that do not lead to a contract are deleted within twelve months.

Good to know: Meta also processes the data of this conversation for its own purposes, over which we have no control. If you want to reach us without any data going to Meta, send a letter to Visseringlaan 19, 2288 ER Rijswijk.

2.3 Contact by post

• Data: your name and address, and the content of your letter.
• Purpose: answering your message and being able to find the correspondence again.
• Legal basis: performance of the contract (Article 6(1)(b) GDPR) or our legitimate interest in handling your question (Article 6(1)(f) GDPR).
• Retention period: no more than twelve months after the correspondence has been completed, or longer if a statutory retention obligation requires it.

2.4 Hosting and server logs

This website is hosted by Vercel. With every visit, the server records technical data: your IP address, the requested address, the time, browser type and operating system.

• Purpose: making the website work technically, tracing faults and preventing misuse and attacks.
• Legal basis: our legitimate interest in a working and secure website (Article 6(1)(f) GDPR).
• Retention period: short-term, in line with Vercel's standard log retention. We do not use these logs to profile visitors.

2.5 Statistics via Google Analytics

We use Google Analytics 4 to see how visitors use the website. This script loads only after you have explicitly given consent for it via the cookie banner. If you decline, or make no choice, Google Analytics is not loaded and no analytics cookies are set.

• Data: a cookie identifier, your (truncated) IP address, pages visited, referring source, timestamps, and general device and browser characteristics.
• Purpose: measuring and improving the use of the website.
• Legal basis: your consent (Article 6(1)(a) GDPR and Article 11.7a of the Dutch Telecommunications Act).
• Recipient: Google Ireland Limited and Google LLC.
• Retention period: the cookies expire after no more than two years; the data in Google Analytics is kept in line with the retention period set in the property.

You can withdraw your consent at any time, with one click on our cookie policy page. When you withdraw, we also delete the Google Analytics cookies that were already set.

3. What we don't do

To avoid misunderstandings, we also state explicitly what does not happen:

• There is no payment integration on this website. So no bank, iDEAL or credit card details are processed via the site.
• There are no user accounts and no login function on this website.
• We do not keep our own customer database on this website.
• We do not sell your data and do not rent it out to third parties.
• We use no advertising or retargeting pixels, no social media trackers and no heatmap or session recording tools.
• We do not make decisions about you based solely on automated processing, and do not carry out profiling with legal effects.
• We deliberately do not process special categories of personal data and do not target children under the age of 16.

4. Parties that process data for us

We use the parties below. With processors we conclude a data processing agreement, so that they only use your data on our behalf and according to our instructions.

Beyond this, we only provide personal data to third parties if we are legally required to, for example on the basis of a valid order from a competent authority.

5. Transfers outside the European Economic Area

As stated per party above, data goes to service providers in the United States. For that transfer we rely on the European Commission's adequacy decision for the EU-US Data Privacy Framework and, where that does not apply, on the European Commission's standard contractual clauses. You can ask us which safeguard applies to a specific party.

6. Security

We take appropriate technical and organisational measures to protect your data. The website is only accessible over an encrypted connection (HTTPS), access to our systems is limited to the people who need it, and we do not collect more data than the purpose requires.

7. Your rights

Under the GDPR you have the following rights regarding the personal data we process about you:

• Access (Article 15 GDPR): request which data we process about you and for what purpose.
• Rectification (Article 16 GDPR): have incorrect data corrected or incomplete data completed.
• Erasure (Article 17 GDPR): have your data deleted, for example if it is no longer needed or if you withdraw your consent.
• Restriction of processing (Article 18 GDPR): have the processing temporarily paused, for example while the accuracy of data is being checked.
• Objection (Article 21 GDPR): object to processing that we base on our legitimate interest.
• Data portability (Article 20 GDPR): receive the data you provided yourself in a common, machine-readable format, or have it transferred.
• Withdrawal of consent (Article 7(3) GDPR): withdraw consent you have given, such as for Google Analytics, at any time. This does not affect the lawfulness of the processing before the withdrawal.

You can submit your request via WhatsApp at +44 7448 399511 or by post to Visseringlaan 19, 2288 ER Rijswijk. We respond within one month. If your request is complex, we may extend that period by up to two months; in that case we will let you know within the first month. To avoid giving data to the wrong person, we may ask you to make your request from the phone number we have on file.

8. Complaints to the Dutch Data Protection Authority

If you disagree with how we handle your data, we would like to hear it from you first; it can often be resolved quickly. You also always have the right to file a complaint with the supervisory authority. In the Netherlands that is the Autoriteit Persoonsgegevens (Dutch Data Protection Authority), Postbus 93374, 2509 AJ Den Haag, autoriteitpersoonsgegevens.nl. If you live in another EU member state, you can contact the supervisory authority of your country.

9. Changes to this privacy policy

We update this policy when our service or our data processing changes. The date at the top of this page shows when the last change was made. For significant changes that affect you, we will inform you actively through the channel we use to contact you.

10. Contact

Questions about this privacy policy or your data? Get in touch via WhatsApp at +44 7448 399511 or send a letter to Visseringlaan 19, 2288 ER Rijswijk. More contact details are on our contact page.