Privacy Statement

PS Poelman, POSH by Poelman and Haboob, as shoe labels, are part of Poelman B.V., hereinafter referred to as “we”

Address: Professor Asserweg 4, 5144 NC Waalwijk Telephone: 0031 (0)416-568 001 KvK: 18085365 We sell our PS Poelman, POSH by Poelman and Haboob shoe collections directly to our customers (retailers) via this B2B portal. We use personal data for our sales and services. We also work together with other companies or organizations, including, for example, our parent or sister company. We consider it very important that personal data is handled accurately. We therefore process and secure personal data carefully and comply with privacy legislation.

In this privacy statement we would like to explain to you exactly what we do with personal data obtained and why. In addition, we would like to inform you about what you can expect from us and what rights you have. We process personal data when selling our shoes, in order to offer services, to improve our services and to communicate with you personally. You can also sign up to receive a newsletter or other forms of communication. Last updated on: September 07, 2023. Below you will find an overview of the personal data we process: We process personal data because you buy shoes or other products from us, use our services and/or because you provide them to us yourself. Below you will find an overview of the personal data that we process, for example:

• name and address details;
• Sex;
• Telephone number and similar data necessary for communication;
• E-mail address
• Marketing Preferences
• Information about your activities on our website;
• Data about your surfing behavior across different websites (for example because this company is part of an advertising network);
• Internet browser and device type;
• IP address;
• Payment details;
• Financial data (bank account number, debts, invoices);
• VAT number;
• Other personal data that you actively provide, for example by creating a profile on our website, in correspondence and/or by telephone.
• Delivering the shoes, products and/or services requested by you;
• To be able to call or e-mail you if this is necessary to perform our services;
• inform you about changes to our products and services;
• Handling a payment;
• consultancy;
• Sending our newsletter;
• Offering other products that could be of interest to you;
• Customer satisfaction research;
• To offer you the opportunity to create an account;
• Analyzing your behavior on the website in order to improve the website and to tailor the range of products and services to your preferences;
• Tracking your surfing behavior on various websites with which we tailor our products and services to your needs;
• Internal reporting, statistical analysis, marketing of Poelman products and services and product and service improvement;
• Compliance with legal obligations;
• Recruitment and selection (application)

We base our processing on the following bases:

1. Execution of the agreement: In the context of our services and entering into agreements, we collect and use the necessary personal data for making an offer, the formation and implementation of the agreement.
2. Legal obligation: The processing of data may be necessary for compliance with legal obligations.
3. Legitimate interest: The collection and use of certain personal data is necessary to give substance to business interests and business operations. Think of commercial purposes, such as offering products or services that may be of interest to you or in connection with market research to improve our products and services.
4. Consent: We may process personal data on the basis of consent. You are always free to withhold or withdraw consent. In that case it may not be possible to implement the agreement or service.

We have tried to provide the best possible overview of the personal data that we process or have processed on your behalf, stating the purposes and legal grounds. However, we also realize that it is impossible to do this completely and in all detail. Partly due to the fact that other or unforeseen purposes may play a role in the future, for which personal data must be processed. However, we would like to emphasize that in such cases we will continue to handle personal data obtained carefully and carefully.

Accuracy of data

For the correct execution of the agreement or service, we rely on the correctness of the data known to us. If your details change, we request that you inform us about this.

Retention period of personal data

Poelman does not store personal data for longer than is strictly necessary to achieve the purposes for which this data is collected, or as required by law and regulations. The starting point is that we store your personal data in accordance with the fiscal retention period of at least 7 years, unless a longer retention period of your personal data is required or indicated by law, other regulations or due to legitimate interests.

Sharing personal data with third parties We only share your personal data with third parties if this is necessary for the execution of the agreement, in connection with the service, due to a legitimate interest and/or to comply with any legal obligation. In that context, we can provide data to, but not exhaustively:

• Government authorities and/or regulators, where necessary to comply with our legal obligations;
• Marketing and communication agencies for marketing and communication activities;
• Third parties who supply parts, materials and products to us;
• Third parties in case of outsourcing of work. This work will be carried out under our responsibility, in accordance with our security standards and on our instructions.

Processing within the EU

We are an organization with business processes, management structures and technical systems that transcend geographic boundaries. Due to the international nature of the services provided by us, personal data may be transferred to, used, stored and otherwise processed in countries other than the country where the information was obtained. In all cases, Poelman will ensure an adequate level of protection by means of standard EU agreements or a permit.

Direct marketing

We will use your personal data for direct marketing, other services and products that we believe may be of interest to you. We will always offer you the opportunity to indicate that your data may not be used for direct marketing purposes (opt-out). For new customers, we will ask you for permission in advance to approach you for marketing purposes.

Use social media

On the B2B portal of Poelman B.V. (www.b2b.poelmanbrands.com) buttons and/or links are included to promote or share web pages on social (media) networks or third-party websites, such as Instagram and Facebook. We do not control and are not responsible for the processing of your personal data by and through such third parties. The use of those media is therefore at your own risk. Before using those third-party services, it is advisable to read the privacy statement of those third parties.

Cookies, or similar techniques, that we use

In order to increase the ease of use of our website, so-called cookies are used. A cookie is a small text file that is stored on your computer, tablet or smartphone when you first visit this website. We use technical and functional cookies. Technical cookies are necessary for the website to function properly, to create an account or to be able to log in, for example. Functional cookies remember your preferences. We use session cookies. By means of a session, status data and preferences are saved during a certain session, so that you remain logged in during a session, for example. We also work with permanent cookies. This allows us to recognize you the next time you visit our website and our website can be specially set to your preferences. We also use retargeting cookies. Using a re-targeting cookie, usage data can be recorded, stored and used. These are stored until the end of the browser session and are retrieved, for example, during a subsequent website visit.

We also use analytical cookies from Google Analytics to broadly track user behavior and general trends and to obtain reports. This helps to improve the functioning of our website. Google may provide this information to third parties if Google is required to do so by law or insofar as third parties process the information on Google's behalf. By using our website, you consent to the processing of the information by Google in the manner and for the purposes described above. Cookies are also placed through the use of buttons and/or links, as described above under “Use of social media”. We have no influence on the placement and use of cookies by those third parties.

All our cookies are necessary for the technical operation of the website and your ease of use. They ensure that the website works properly and, for example, remember your preferred settings. We can also use this to optimize our website. We use a cookie bot. This tool is AVG proof. On the cookie page you can see which cookies have been placed, what they are used for, which personal data is collected and what the expiry date is. The cookies are only placed if you have given us permission to do so. You have the option to refuse cookies and still use our website. You can also refuse or revoke the use of these cookies at any time by adjusting your browser settings. However, this may limit the functionality and ease of use of the website. You can read more about cookies and how you can block or delete them on the website of the Authority for Consumers and Markets (https://www.consuwijzer.nl/telecom-post/internet/privacy/informatie-cookies).

View, modify or delete data You have the right to view, correct or delete your personal data. You also have the right to withdraw your consent to the data processing or to object to the processing of your personal data by Poelman and you have the right to data portability. This means that you can submit a request to us to send the personal data we hold about you in a computer file to you or another organization mentioned by you.

You can send a request for access, correction, deletion, data transfer of your personal data or request for cancellation of your consent or objection to the processing of your personal data to cs@poelmanbv.com. To ensure that the request for inspection has been made by you, we ask you to enclose a copy of your proof of identity with the request. Make your passport photo, MRZ (machine readable zone, the strip with numbers at the bottom of the passport), passport number and citizen service number (BSN) black in this copy. This is to protect your privacy. We will respond to your request as quickly as possible, but within four weeks. If you have any complaints about the processing of your personal data by us, we would of course like to hear about it. In that case, we ask you to contact us. We will then look at a solution together. You have the right to submit a complaint to the privacy supervisor, the Dutch Data Protection Authority (https://autoriteitpersoonsgegevens.nl).

Security of personal data

We take the protection of your data seriously and take appropriate measures to prevent misuse, loss, unauthorized access, unwanted disclosure and unauthorized modification. In addition, the ICT company engaged by us, taking into account the state of the art, has taken appropriate technical and organizational measures to ensure a level of security that is appropriate to the risk to the rights and freedoms of individuals. If you have the impression that your data is not properly secured or there are indications of abuse, please contact our Privacy Consultant via cs@poelmanbv.com.

Adjustment Privacy Statement We have the right to change the content of this Privacy Statement at any time without prior notice. Adjustments to the Privacy Statement are published on the Poelman website. Therefore, regularly consult our website (www.b2b.poelmanbrands.com).

Questions and Contact If you have any questions or comments about the processing of your personal data and this Privacy Statement, please contact our Privacy Consultant. The Privacy Consultant can be reached via cs@poelmanbv.com.