Privacy statement

At TulipBlu BV (trade name: Basic Water Needs – BWN), we believe trust is the cornerstone of all relationships. This notice describes the personal information BWN may collect about you through websites, applications or other means, how we may use and disclose this information, and other related information that is important for you to know.

WHO WE ARE AND HOW THIS NOTICE APPLIES TO YOU

BWN values your privacy. This notice describes the personal information BWN may collect about you:

through websites operated by us, from which you are accessing this Privacy Notice (the “Websites”),
through the software applications made available by us for use on or through computers and mobile devices (the “Apps”),
through our social media pages and apps that we control from which you are accessing this Privacy Notice (collectively, our “Social Media Pages”),
through HTML-formatted email messages that we send to you that link to this Privacy Notice, and
through offline interactions you have with us.

Collectively, we refer to the Websites, the Apps, Social Media Pages, emails and offline activities as the “Services.”

For the purposes of this notice, “BWN” refers to TulipBlu BV.

When BWN collects your personal information, we seek to collect what is relevant, adequate, and not excessive for the purpose it is collected. We may collect, create, and observe personal information about you from a variety of sources, including directly from you, from technology such as cookies, and from third parties. These types of data may include, for example, contact information, communications and payment data, or marketing data. We will keep your personal information for the period necessary to fulfil the purposes described in this Privacy Notice unless a longer retention period is permitted by law.

HOW WE COLLECT AND RETAIN YOUR PERSONAL INFORMATION

“Personal information” is information that identifies you as an individual or relates to an identifiable individual. When BWN collects your personal information, we seek to collect what is relevant, adequate, and not excessive for the purpose it is collected.

The ways that we may collect information about you include the following:
- We may collect personal information from a variety of sources, such as the telephone, our sites, our online or mobile applications or services, our transfer agent or our online advertisements.
- Through the Services: For example, we may collect personal information during the initiation or execution of business relationships, during events or tradeshows, when you subscribe to newsletters or request publications, complete surveys, register for BWN events or online services, contact us for further information, or visit our sites while or before logged into a social media platform.
- From other sources: We may also collect personal information from public sources or third party data providers. For example, our HR team may utilize LinkedIn or other social media platforms to identify employment candidates. Each social media platform has their own policy on the way they process your personal information when you access their sites. If you have any concerns or questions about their use of your personal information, you should read their privacy policies carefully before using them. We may also work with joint marketing partners to identify potential customers, with transfer agents to coordinate interaction with our shareholders or with other third parties to provide services to BWN employees.
The types of personal information that we may collect about you include:
- Contact information, such as name, title, phone number, mailing address, and e-mail address;
- Communication information submitted by you, such as orders, questions, and feedback;
- Demographic information, such as language, age, and gender;
- Marketing preferences, such as e-mail subscription and frequency preferences;
- Payment data, such as account information.

We need to collect personal information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any personal information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Notice.

How long we retain your personal information depends on the purpose for which it was obtained and its nature. We will keep your personal information for the period necessary to fulfil the purposes described in this Privacy Notice unless a longer retention period is permitted or required by law. The primary criteria we use to determine our retention periods include:
- The length of time you have an active account or relationship with BWN;
- When we are getting to know you as a potential customer;
- When we need to comply with a court order, law or legal process;
- When legal requirements and professional guidelines require it – such as tax and audit purposes, information on aspects of health and safety, or in regard to applicable statutes of limitations, litigation or regulatory investigations.

BWN may use your personal information to serve you, improve our services, or fulfil the purpose for which you gave us your personal information, such as to carry out a transaction, communicate with you, and run our business operations. BWN relies on several legal bases, such as your consent or BWN’s legitimate interests, for using your personal information depending on the circumstances.

SENSITIVE PERSONAL INFORMATION

Under data protection law, certain categories of personal information are recognised as sensitive, including health information and information regarding race, religious beliefs, and political opinions. This is known as ‘sensitive personal data’. We do not routinely collect sensitive personal data, but we will collect this information where there is clear reason for doing so, such as where we need this information to ensure we provide appropriate facilities or support to you.

HOW WE USE YOUR PERSONAL INFORMATION

BWN may use your personal information to serve you, improve our services, and fulfil the purpose for which you gave us your personal information, and for other legitimate business purposes, including to:

Provide the functionality of the Services and fulfil your requests.
- Carry out transactions you have requested, such as processing orders, registering purchased products, handling warranty claims, and providing related customer service;
- Communicate with you about your account, respond to your inquiries and fulfil your requests;
- Send administrative information to you, such as changes to our terms, conditions and policies;

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

Provide you with information and/or other marketing materials.
- Inform you of products or services available from BWN in which you may be interested;
- Send you surveys regarding your use of BWN products and services;
- Facilitate social sharing functionality that you choose to use.

We will engage in these activities with your consent or where we have a legitimate interest.

Analyse personal information for business reporting and providing personalized services.
- Analyse or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services;
- Better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests;
- Better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.

We will provide personalized services either with your consent or because we have a legitimate interest.

Accomplish our business purposes.
- Run our business operations and manage our risks, including protecting the rights and property of BWN and others;
- Comply with legal requirements and internal policies, such as audit and security policies;
- Develop new products or services;
- Improve, enhance or modify our products and services;
- Identify usage trends, for example, understanding which parts of our Services are of most interest to users;
- Determine the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.

Allow you to participate in sweepstakes, contests or other promotions.
- We may offer you the opportunity to participate in a sweepstakes, contest or other promotion.
- Some of these promotions have additional rules containing information about how we will use and disclose your personal information.

We use this information to manage our contractual relationship with you.

Aggregate and/or anonymize personal information.
- We may aggregate and/or anonymize personal information so that it will no longer be considered personal information. We do so to generate other data for our use, which we may use and disclose for any purpose.

BWN may share your personal information with third parties for processing on our behalf, with your consent, or where permitted or required by law. Recipients of personal information may be located outside the country in which the information was collected, including in countries outside the European Economic Area (EEA). In such cases, BWN takes measures to ensure an appropriate level of data privacy protection.

HOW WE SHARE YOUR PERSONAL INFORMATION

BWN will never sell your details and, except as detailed below, will only share your details with third parties (who are not service providers working at our direction) if you ask us to. BWN may share your personal information with other entities to serve you, including for the activities listed in this Privacy Notice.

We share personal information:

With trusted third-party service providers that carry out activities at our direction. These activities could include any of the activities that BWN carries out as described in the above section, ‘HOW WE USE YOUR PERSONAL INFORMATION.’ For example, these activities can include website hosting, data analysis, payment processing, order fulfilment, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
With third parties, to permit them to send you marketing communications, consistent with your choices.
By using the Services, you may elect to disclose personal information on message boards, chat, profile pages, blogs and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
When you connect with your social media account, you will share information with your friends associated with your social media account, with other users, and with your social media account provider. By doing so, you authorize us to facilitate this sharing of information, and you understand that the use of shared information will be governed by the social media provider’s privacy policy.
To third-party sponsors of sweepstakes, contests, and similar promotions.

We also use and disclose your personal information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so.

OTHER USES AND DISCLOSURES OF YOUR PERSONAL INFORMATION

We also use and disclose your personal information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

To comply with applicable law and regulations, which can include laws outside your country of residence.
To cooperate with public and government authorities, such as to respond to a request or to provide information we believe is important. These can include authorities outside your country of residence.
To cooperate with law enforcement, for example, when we respond to law enforcement requests and orders or provide information we believe is important.
For other legal reasons, including to enforce our terms and conditions and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
We have a legitimate interest in disclosing or transferring your personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.

We may collect, use and disclose Other Information that does not reveal your specific identity or does not directly relate to an identifiable individual, including: browser and device information, app usage data, and information collected through cookies, pixel tags and other technologies.

OTHER INFORMATION

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual, such as:

Browser and device information
App usage data
Information collected through cookies, pixel tags and other technologies
Demographic information and other information provided by you that does not reveal your specific identity
Information that has been aggregated in a manner such that it no longer reveals your specific identity

If we are required to treat Other Information as personal information under applicable law, then we may use and disclose it for the purposes for which we use and disclose personal information as detailed in this Notice.

Collection of Other Information

We may collect Other Information in a variety of ways, including:

Through your browser or device:
- Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
Through your use of an App:
- When you download and use an App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
Using Cookies:
- Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services. We may also use cookies or other technologies in online advertising to track responses to our ads.We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. You also may not receive advertising or other offers from us that are relevant to your interests and needs.

Using pixel tags and other similar technologies:
- Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
Analytics. We use Google Analytics and Adobe Analytics, which use cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. These services may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and exercise the opt out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout. You can exercise the opt-out provided by Adobe by visiting: https://www.adobe.com/privacy/opt-out.html.
IP Address:
- Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.

Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with personal information. If we do, we will treat the combined information as personal information as long as it is combined.
The security of your personal information is important to us. BWN has put in place technical and organizational safeguards to protect the confidentiality, integrity, and availability of your personal information.

SECURITY OF YOUR PERSONAL INFORMATION

The security of your information is important to us. BWN has put in place technical and organizational safeguards to protect the confidentiality, integrity, and availability of your personal information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.

You may review, and request corrections to or deletion of your personal information, where applicable, by contacting us using the contact information below. Please notify us of any change to your contact information or other personal information. You may unsubscribe from our promotional e-mails by using the unsubscribe instructions located at the bottom of the message or by contacting us.

ACCESSING AND MAKING CHOICES ABOUT YOUR PERSONAL INFORMATION

You may request to review, correct, update, suppress, restrict or delete personal information that you have previously provided to us, or request to receive an electronic copy of your personal information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), by contacting us in accordance with the “Contact Us” section below. We will respond to your request consistent with applicable law.

In your request, please make clear what personal information you would like to have changed, whether you would like to have your personal information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your personal information.

We will try to comply with your request as soon as reasonably practicable. We may take steps to verify your identity before providing you access to your personal information. For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request. In some instances, we may not be able to exercise your requested choices, such as when we need to retain your contact information for contractual obligations and/or to complete any transactions that you began prior to requesting a change or deletion. Please notify us of any change to your contact information or other personal information.

You may unsubscribe from our promotional e-mails by using the unsubscribe instructions located at the bottom of the message or by contacting us. This action may not unsubscribe you from administrative messages regarding your account, such as security campaigns, and order fulfilment messages.

You have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the US and Canada) are available here.)

JOB APPLICATIONS AND CURRENT AND FORMER EMPLOYEES

If you apply to work at TulipBlu B.V., we will only use the information you give us to process your application and to monitor recruitment statistics. If we want to disclose information to someone outside TulipBlu B.V. – for example, if we need a reference, plan to use an external supplier to run background checks we will make sure we tell you beforehand, unless we are required to disclose this information by law.

If you are unsuccessful in your job application, we will hold your personal information for 6 months after we’ve finished recruiting for the post you applied for. After this date we will destroy or delete your information.

If you begin employment with us, we will put together a file about your employment. We keep the information in this file secure and will only use it for matters that apply directly to your employment.

Once you stop working for us, we will keep this file according to our record retention guidelines. You can contact us to find out more about this by emailing us.

CHILDREN’S INFORMATION

Our Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect personal information from individuals under the age of 16. If you believe that we have collected information about a child under 16, please contact us at info@basicwaterneeds.com, so that we may delete the information.

SENSITIVE INFORMATION

We ask that you not send us, and you not disclose, any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.

THIRD PARTY SERVICES

This Privacy Notice does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any personal information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.

We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services.

THIRD PARTY ADVERTISING

You may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.

If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Notice, please visit:
• From Australia: http://www.youronlinechoices.com.au/
• From Canada: https://youradchoices.ca/
• From Europe: http://www.edaa.eu/
• From the U.S.: http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/
Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures to protect your personal information.

CROSS-BORDER TRANSFER

Our Privacy Policy takes into account the General Data Protection Regulation (EU) 2016/679, which has come into force in the Netherlands on May 25 in 2018.

For financial and technical reasons, we may, on occasion, need to use the services of a service provider outside the European Economic Area (EEA) – this may include a country which does not have the same level of data protection as in the Netherlands. However, unless they are located in a country which has been assessed by the European Commission as ensuring an adequate level of protection for personal data, we will only use a service provider outside the EEA on the basis of an agreement with the service provider, designed to protect your data, in the appropriate form approved for this purpose by the European Commission. We will take all steps reasonably necessary to ensure that your data is processed securely and in accordance with this Privacy Policy.

If you have any questions about this Privacy Notice or our use of your personal information, please contact us at info@basicwaterneeds.com or by using the information below:

tulipBlu B.V. (Trade name: Basic Water Needs)
Leidsekade 12
1016 CW. Amsterdam
The Netherlands

You can lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs. However, before doing so, we encourage you to contact us directly to give us an opportunity to work directly with you to resolve any concerns about your privacy.

HOW WE CHANGE AND UPDATE THIS PRIVACY NOTICE

We may update this Privacy Notice. When we do, we will post the current version on this site, and we will revise the version date located at the top of this page. Any changes will become effective when we post the revised Privacy Notice on the Services. Your use of the Services following these changes means that you accept the revised Privacy Notice.