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Privacy statement

Your privacy: a matter of due care

Privacy policy freetogo.nl and use of Free to go


Euromobil considers it important to ensure that communication remains simple and reliable for you. This also applies to the manner in which we handle your personal and traffic data. These data are the basis of our services to you. Euromobil also processes your personal data if we send you the latest newsletter, for example. Euromobil has rules it complies with where it concerns the use of your data. These are now all bundled into this document: the Euromobil Privacy Statement.

General
Euromobil Nederland will never use data concerning visitors to its website to send product or service offers (direct marketing, spam e-mail and the like). Euromobil Nederland does not make data concerning visitors to its website available to third parties.

If reference is made below to technical characteristics of a query, click, display, search or the like, such will be a reference to: requested URL, IP number, time, HTTP referrer URL (including sometimes your search terms entered in a search engine), user-agent string, browser type, screen size and the like. We do not establish (if that were possible at all) who uses which IP number at what time and we therefore do not trace these data back to your person.

Euromobil Nederland does not register special personal data, concerning for example religion or personal beliefs, race or background, health, sexual preferences, criminal law, political affiliation or membership of a trade union.

Web visits
If you visit our website, the technical characteristics of your queries are stored in so-called log files on our servers. These data are retained for several months exclusively for the purpose of statistical analyses. We do not establish (if that were possible at all) who uses which IP number at what time and we therefore do not trace these data back to your person.

Searches
If you use a search function on our website, your search terms together with the technical characteristics may be stored in so-called log files on our servers. These data are retained for several months exclusively for the purpose of statistical analyses. We do not establish (if that were possible at all) who uses which IP number at what time and we therefore do not trace these data back to your person.

The showing of and clicks on advertisements and cookies

The showing of and clicks on advertisements are registered by Euromobil Nederland and by any advertising networks in which Euromobil Nederland participates.

If you click on an advertisement, the technical characteristics of the click may be stored by Euromobil Nederland in so-called log files that are retained for several months for the purpose of financial reporting. We do not establish (if that were possible at all) who uses which IP number at what time and we therefore do not trace these data back to your person.

Euromobil Nederland participates in the following advertising networks that perform their own registrations and that pursue their own privacy policy:

These parties can place so-called 'cookies' on your web browser and read these from your web browser when displaying advertisements and so-called web beacons. A web beacon is a small, invisible image that is integrated in the website so that it can be registered when that page is requested.

A cookie can be seen as a small file with impersonal data that is used to relate the various queries of your web browser to each other. A cookie may be used by Euromobil Nederland and the advertising networks for example to store your preferences or user settings, to remain logged in on an interactive part of a website, or to align advertisements with the interests and preferences based on your visit to Euromobil Nederland websites and other websites on the internet.

Most browsers accept cookies as part of the standard settings, but you can usually refuse cookies or selectively accept them by adjusting the settings of your browser. Certain functions of our websites may not be available if you turn off cookies, in particular log in mechanisms. You can find information about frequently-used browsers and how you can adjust the cookie settings of the relevant browser at the following websites:

The Google advertising network places a DoubleClick DART-cookie to align advertisements with your interests and preferences based on your visit to the Euromobil Nederland and other websites on the internet. You can deregister for this cookie, after which you will be shown less relevant advertisements.

Google Analytics
Euromobil Nederland can make use of Google Analytics, which is a web analysis service that is offered by Google Inc. ("Google"). Google Analytics uses cookies to help Euromobil Nederland analyse how visitors use the site. The information concerning your use of the website generated by the cookie, including your IP address, is transferred to and stored by Google on servers in the United States of America. Google uses this information to record how you use the website, to draw up reports about website activity for website operators and to offer other services with respect to website activity and internet use. Google will be authorised to provide this information to third parties if Google is required by law to do so, or insofar as said third parties process the information on behalf of Google. Google will not combine your IP address with other data held by Google. You can refuse the use of cookies as indicated above. By making use of this website, you consent to the processing of the information by Google in the manner and for the purposes as described above.

Newsletters
If you register or deregister for one of our e-mail newsletters, the technical characteristics of your mutation together with your e-mail address will be retained for several months. In addition, your e-mail address will be stored in the list of subscribers exclusively for the purpose of sending the relevant newsletter during the entire term of your subscription. You are free to use an e-mail address for your subscription that cannot be traced back to your person. You can deregister at any time for one of our newsletters in a reasonable manner that is listed at the bottom of each edition of the relevant newsletter. If you are unable to deregister in this manner, we will remove you from the list of subscribers following a request to that effect in writing.

Contact forms and e-mail
If you fill in and send a contact, registration or information form on one of our websites or if you send us an e-mail, the data you send and the technical characteristics will be retained by us for as long as is necessary or reasonable according to the nature of the form and of your message for a full answer, handling and/or report pursuant to your message. Your message may also be included in our e-mail archive where it can be stored for a period of 7 years as a result of back-up procedures and the statutory retention obligation.

Participation in interactive sections of the website
If you participate in interactive sections of our website (such as a forum, membership site or electronic learning environment) for which you have to register and log in, you are free to enter personal data in your profile, in your signature, in the messages you place, etc. These data are retained for an indefinite period, shown in the relevant section of the website and rendered accessible by search engines. You are the party that discloses those data and this is your own responsibility. You are likewise free to use a fantasy name (pseudonym, nick name) and to enter no or fictitious personal data and only place anonymous messages. The data placed by you are only anonymised or removed in exceptional cases, following a request in writing to that effect providing reasons, with a substantiation of a reasonable interest.

If you register for activities or services of Euromobil Nederland (such as a learning arrangement with access to an electronic learning environment, a training course or a similar meeting) in respect of which you are expected to provide truthful personal data, Euromobil Nederland will only use those data for the relevant purpose (including our business operations, the communication concerning the activity, performing the activity, invoicing and financial reporting, statutory retention obligation and the like).

Interviews and quotations
If you have been interviewed or quoted for our online communication and after some time passed you have a reasonable objection against the continued publication of the text with reference to your name and your name is not actually relevant to the reader, we will be willing in principle to anonymise the interview or quote at your request and replace your name with a fictitious name (while stating "we have used a fictitious name at the request of the person involved").

Exceptions: abuse, obligations
If we consider that our facilities are abused or that improper use is made of them, we will have the right to deny certain IP numbers and/or e-mail addresses access for a definite or indefinite term. In the event of forms of abuse that prejudice the interests of third parties, we will have the right to make the relevant data available to said third parties. In the case of abuse, we may attempt to trace the data back to your person, for example to contact you, a parent, guardian, teacher, supervisor, manager, the person ultimately accountable or some such person, or to file a report with the police or initiate legal proceedings against you.


PRIVACY REGARDING THE USE OF FREE TO GO


For which purposes does Euromobil use your data? Euromobil holds certain data concerning your person as a result of the nature of our services. Below we will provide you with information concerning the purposes for which Euromobil processes these data. We also provide information about what you can decide concerning the use of your data. We make a distinction between your "personal data" and your "traffic data" for the sake of clarity.

Personal data
We process personal data (such as your name, address, place of residence, e-mail address, telephone number, services purchased and invoice details in outline) for the following purposes: 

  1. To make the services technically possible, including the establishment of connections.
  2. For accepting your application for a subscription to a Euromobil service, for which purpose we process, inter alia, copies of your proof of identity or residence document (including the passport photo).
  3. The management of the relationship between yourself and Euromobil, including all activities in connection with the preparation and performance of the agreement concluded with you, such as invoice applications, complaints handling, failure resolution and advice. 
  4. The invoicing process, including the preparation and printing of invoices, collection, fraud prevention and fraud investigation, expensive call monitoring, interconnection payments.
  5. Network management, including network planning and network architecture and fraud detection.
  6. For the purpose of responsible business operations, including security, risk limitation, integrity investigations, handling undesirable calls, expansion and improvement of the services.
  7. Compliance with statutory obligations such as the mandatory retention of personal data for a specific period prescribed by law and the provision of that data to the competent authorities within the context of a criminal investigation, and - at your request - providing data to other providers for the purpose of screening the number that has been called on the invoice.
  8. For the purpose of issuing or causing the issue of electronic and other guides and offering subscription information services.
  9. Performing market research and marketing and sales activities (also after the contract has ended) for the purpose of the services and the sale of Euromobil products and services.
  10. The provision to third parties for direct marketing purposes to the extent Euromobil has informed you thereof within the context of the relevant service.
  11. Making automatic calls to your telephone number (voice broadcasts) with offers of Euromobil products and services.
  12. Sending you electronic messages with offers of and information concerning Euromobil products and services (such as text messages, e-mails and IM messages).

Traffic data
We process your traffic data (such as the time and the duration of the use of a connection, IP addresses and URLs) for the following purposes: 

  1. To prepare invoices.
  2. For the purpose of traffic management.
  3. For the purpose of handling requests for information from yourself concerning your own connection.
  4. To detect fraud.
  5. For the purpose of compliance with statutory obligations, such as cooperating in court-ordered wire-tapping and within the context of criminal investigations and the mandatory retention of your traffic data for a period prescribed by law. 
  6. For the purpose of market research and sales activities for Euromobil products and services also after the contract ends, provided you have consented thereto. 
  7. For the purpose of creating viewing and usage profiles for market research and sales activities for Euromobil products and services and electronic communication services of third parties, provided you have consented thereto. Viewing and usage profiles may also be provided to third parties within the context of this purpose. 
  8. For the purpose of showing you personalised advertisements, provided you have consented thereto.
  9. For the purpose of providing added value services, provided you (as contracting party or actual user) have consented thereto.

Location data
We can process your location data (the place where the mobile connection is used), which are not necessary for transmitting communication, for the following purposes: 

  1. For the purpose of statutory obligations, including cooperating in court-ordered wire-tapping and within the context of criminal investigations;
  2. For the purpose of providing added value services (such as (traffic) information services), provided you (as contracting party or as actual user) have consented thereto and you have not temporarily denied Euromobil your consent at any time. 


What does it mean for you as a customer?


The right to inspect your personal data
 
As a customer, you are entitled to inspect your personal data. This means that you have the right to enquire which of your personal data have been registered and for what purposes those data are being used. You can submit your request for information by letter, provided with your name, address, telephone number (land line and/or mobile) and a copy of a valid proof of identity. Euromobil has the right to charge at most €4.50 in administrative charges. You will then receive a written answer within 4 weeks.

The right to correct your personal data 
As a customer, you have the right to have your personal data corrected. You can contact Euromobil customer service for this purpose.

The right to object to the use of your data
As a Euromobil customer you have several legal options to object to the further use of your data. You can object to the further use of your data even you consented at an earlier stage.

You can object to the use of your personal data free of charge if your personal data are used for purposes that are not necessary for the performance of an agreement or necessary for compliance with a statutory obligation. You can, for example, object to the use of your data for direct marketing purposes.

You can object to the use of your traffic data free of charge if your traffic data are used for market research and sales activities concerning electronic communication services and if your traffic data are used to provide added value services (in which case we do point out that you will no longer be able to use these added value services).

Security of your data
Euromobil arranges for appropriate organisational, technical and physical security of its systems in which your data are stored. This allows us to ensure that your data are only accessible to persons who are authorised to do so on the basis of their position and that the data are only used for the purposes for which they were obtained and for services compatible therewith.

More information
You can apply to the Infoline of Postbus 5 for general information about the Personal Data Protection Act and for requesting a brochure. This information line can be reached at toll-free telephone number 0800-8051.

Privacy statement Free to go - Euromobil Nederland b.v. 
18 september 2013