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PRIVACY STATEMENT 2.0
Last updated: 03-09-2023

1. General Information

We understand that your privacy is important to us and we want to make sure that you fully understand how we handle your data. Our focus on fairness means that we apply the same principles to both our products and our approach to data protection.

This privacy statement describes how Upfront BV, located at Van Nelleweg 1, 3044 BC Rotterdam, the Netherlands, hereinafter referred to as "we", "us" or "our", collects, uses, stores and protects your personal data.

This privacy statement applies only to the services of www.upfront.nl . This website may contain links to third-party websites, plug-ins and applications. We are not responsible for the privacy practices of other websites or resources. It is important to remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services.

2. What personal data do we collect?

Personal data is information that provides information about an identifiable natural person. We collect personal data in the following situations:

2.1 creating a personal profile and/or placing an order

We collect data when you create a personal profile or place an order. The following categories of personal data can be collected by us:

• Identity data: first name and last name
• Contact details : address and email address
• Financial information: bank account number or credit card details
• Transaction data: order history, preferences and reviews

When you send an email or other messages to us, we may retain those messages. Sometimes we ask for your personal information that is relevant to the situation.

We collect data about the use of our site. For this purpose, we collect information about how you use our website. We can use this data to improve our site and for communication and marketing purposes. You can unsubscribe from marketing emails at any time by clicking the unsubscribe button at the bottom of our emails.

3. Why is my data used?

We use your personal data for the following purposes:

• Processing your orders and delivering the products you purchased. When you place an order, we need your information to process your order.
• To effectively assist you with resolving specific questions and issues and by providing personalized assistance when contacting our customer service.
• Analyzing and improving our webshop experience.
• Personal marketing
• Compliance with legal obligations

4. What are the legal bases?

We process your personal data on the basis of the following legal grounds:

• The performance of the contract between you and us in relation to your order
• Legitimate interests
• Based on consent

• Compliance with legal obligations to which we are subject

5. Will my data be shared?

Upfront does not sell your data. We only make your data available to third parties when processing your order and for operational purposes. These third parties are required to treat your data confidentially. These third parties include:

• Payment providers and shipping services to process and deliver your order ( Shopify and PostNL )
• Third-party service providers for technical and operational support ( Shopify , Klaviyo , Triple Whale ).
• Government agencies when required by law

Furthermore, in some cases the information may be shared internally. Our employees are required to respect the confidentiality of your data.

Certain data about customer behavior on our website can be shared with Meta and TikTok. Read more about this in chapter 7.3 of this privacy statement.

We retain your personal data for as long as necessary to fulfil the purposes described above for which it was collected, unless a longer retention period is required by law.

Our website uses cookies (text files placed on your computer) to ensure optimal functioning of our website and to help analyze how users use our site. We use this information to track how you use the website, to create reports

to compile reports on website activity and to provide other services relating to website activity and internet usage.

we use the following cookies:

7.1 Functional cookies

Functional cookies are essential for the operation of our webshop. They do not store personal information, but ensure that the website functions properly. For example, they remember your preferences and settings, so that you do not have to enter the same data every time.

7.2 Analytical cookies

Analytical cookies collect information about how users use our webshop. These cookies help us understand how visitors navigate through the site, which pages they view and how long they stay on the site. This data is used to improve the performance and ease of use of our webshop. We can also use this data to show personalized e-mails and advertisements.

7.3 Pixels

Our website uses Meta and TikTok pixels. These pixels allow us to collect data about the performance of our advertisements and the use of our website. This data helps us to optimize our online marketing strategies and to present relevant content to our target group. The information generated by these pixels is transmitted and stored on the servers of Meta and TikTok.

7.3.1 Meta-pixel

Our Meta pixel collects, among other things, your name, location, email address, phone number and browsing behavior on our website. Meta uses email or other login or device information to identify users of our website on their platform and link them to a Meta user account. We can analyze the data that Meta keeps for us. This allows us to know, for example, which of our products you are interested in. This allows us to show you Meta messages and advertisements that you find interesting later on. And Meta can ensure that our advertisements are seen by people who are likely to be interested in Upfront.

Before we use the Meta-pixel, you must give your explicit consent. When you open our website, we inform you which cookies and similar techniques are placed on our website. The Meta-pixel is there. You only give consent if you click on 'I agree', otherwise not. If you do not agree, we will not use the Meta-pixel for your visit to our website.

7.3.2 TikTok Pixel

Our TikTok pixel collects data such as your IP address and email address, as well as other information such as device ID, device type, operating system, and browsing behavior. TikTok uses email or other login or device information to identify users of our website on their platform and associate them with a TikTok user account. We use the information collected by TikTok to better tailor our ads to our audience and to improve ad delivery and personalized ads in general.

Before we use the TikTok pixel, you must give your explicit consent. When you open our website, we inform you which cookies and similar techniques are placed on our website. The TikTok pixel is included. You only give consent if you click on 'I agree ', otherwise not. If you do not agree, we will not use the TikTok pixel for your visit to our website.

7.4 Cookie settings

Most browsers are set to accept cookies by default, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some features and services on our and other websites may not function correctly if cookies are disabled in your browser.

Certain cookies such as analytical cookies and pixels are only used after you have given explicit consent. You can withdraw your consent at any time by adjusting your cookie preferences in the cookie settings of your browser or via our cookie banner on the website.

8. Why do I receive marketing messages via email?

We like to communicate with our customers. Depending on your marketing preferences, we may use your personal information to send you marketing messages via email. Some of these messages may be tailored to you, based on your previous browsing or purchasing activity and other information we have about you.

If you no longer want to receive marketing messages from us, you can change your preferences at any time by contacting us (details below) or clicking on the 'unsubscribe' link in the emails. If you opt out of marketing, we may still contact you from time to time with service messages (for example order and delivery confirmations).

9. Is my data secure?

We have taken appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, theft or manipulation.

10. What are my rights?

You have the following rights with respect to your personal data:

• Right of access : you have the right to know which personal data we process about you and why.
• Right to rectification : if your personal data is incorrect, incomplete or outdated, you can ask us to correct it. You can also adjust data yourself in your personal account.
• Right to erasure (right to be forgotten) : you can request us to erase your personal data if there are no legal reasons for us to retain it.
• Right to restriction of processing : in certain cases you can request that the processing of your personal data be restricted.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used and machine-readable format, and to transmit it to another controller.
• Right to object: you can object to the processing of your personal data based on legitimate interests.
• Right to withdraw consent: If we process your personal data based on your consent, you can withdraw this consent at any time.

To exercise these rights, you can contact us using the contact details provided in this Privacy Statement. We will process your request within 7 days of receipt, unless there are legal reasons to delay this.

11. What do I do if I have a complaint?

Upfront attaches great importance to your satisfaction and the protection of your personal data. However, if you believe that we do not comply with the applicable privacy legislation or if you are dissatisfied with the way we handle your data, you have the right to file a complaint.

Of course, we hope that you will contact us first if you have any questions or concerns regarding your personal data. We are committed to resolving any concerns you may have. You can reach us using the contact details provided in this Privacy Statement. Your feedback is valuable to us, and we will do everything we can to address any concerns you may have in a respectful and efficient manner.

You also have the right to file a complaint with the Dutch Data Protection Authority (AP). They can be reached via the website: https://www.autoriteitpersoonsgegevens.nl/een-tip-of-klacht-indien-bij-de-ap

11. How do I stay informed about changes to the privacy statement?

This Privacy Statement may be revised to reflect changes in the law or business. We recommend that you review this statement regularly to stay informed about how we protect and use your personal data.

12. How do I get in touch?

For questions, requests or comments regarding your personal data and this privacy statement, you can contact us by email info@upfront.nl , or by post:

Van Nelleweg 1 3044 BC Rotterdam