Privacy Policy

Privacy Policy
Updated: November 2006

On-Line Registration
This policy tells you how we collect information from you on-line, how we protect it and how we use it. The ClubPinkels Group and Heforce(a company inporated in The Netherlands), controls all personal information which you provide on the www.clubpinkels.com website, unless otherwise specified on the website, where a different Privacy Policy will be displayed.

What type of information we collect about you
We will collect personally identifiable information from you in a variety of ways including when you register on the website and enter competitions. We will also notify you at the point of collection when information is being retained and display the relevant Privacy Policy, e.g. when you purchase on-line, or when you are directed to other websites.
This Privacy Policy explains how the above mentioned company and other companies within the ClubPinkels Group collect, record and use information about you and the choices you can make about how the information is collected and used. The clicking of the "Register" button during your initial registration with our website will indicate your consent to this Privacy Policy.

What we do with Personally Identifiable Information
This information may be used for marketing, to inform you if you are a winner of a competition and what prizes you have won and to send you newsletters and information about other exciting events happening on www.ClubPinkels.com and about ClubPinkels related products and services.
When you register on line you will be given the option to receive marketing information. Where we have obtained your consent we may use your information to market our own goods and services, services on behalf of selected third parties, and disclose the information to other organisations who we are working with in co-branding activities or other carefully selected third parties who may market directly to you. Your participation in our marketing activities is voluntary and you can change your marketing preferences or opt out from receiving further marketing at any time. Details on how to do this are set out below.

This personal information may be used by ClubPinkels, Heforce and other members of the ClubPinkels Group worldwide. As used in this Privacy Policy the ClubPinkels Group includes ClubPinkels, Heforce and all of its subsidiary and affiliated entities, including companies such as those branded that generally do not offer their products and services under the “ClubPinkels” brand name, as well as companies that generally do offer their products and services under the “ClubPinkels” brand name. Heforce (including its subsidiaries) is a member of the ClubPinkels Group, and is referred to in this Privacy Policy as “we”, “us”, “our” and “ourselves”. Wherever your information is processed by the ClubPinkels Group, we will ensure that it is protected appropriately.

We will only pass on your information to third parties in the following situations:

• If this was clearly stated at the time of collection or registration and, where required, if you have given permission for this;
  
• If we employ another organisation to perform tasks on our behalf – such as delivering goods to you. In this case, the organisations may only use your information to fulfil this specific task;
• If we sell the business of some of the Pinkels Media Group of companies to another organisation or merge with other businesses. In this case, the buyer will only be able to use your information as set out in this Privacy Policy;
• If we have reason to believe that disclosing this information is necessary for legal proceedings. We may also disclose member information when we believe in good faith that applicable law or regulation requires it;
• If we use third party processors to administer and process for the purposes notified in the Privacy Policy. We may also share details with third parties (such as auditors or legal advisors) to obtain advice. Any such processing will be governed by an agreement in the form required by law, preserving any statutory data protection rights.

International Transfers
As the Pinkels Media Group operates globally, it may be necessary to transfer your information internationally, and in particular your information may either be stored on the servers of the Pinkels B.V. in the Netherlands or transferred to Pinkels OU (part of the Pinkels Media Group) in Tallinn, Estonia for maintenance purposes, and stored on its servers in the US. Pinkels Media Group will adhere to the “Safe Harbour Principles” officially declared by the European Commission as providing an adequate level of protection as compared to the data protection laws of the European Union countries, before your information is stored in its servers, and Pinkels Media Group will adhere to the terms of this Privacy Policy . Please be assured that we take all reasonable steps to ensure that your privacy is protected.

Pinkels Policies for Children
We encourage parents and guardians to spend time on-line with their children and to participate in the interactive activities offered on these websites. If you are a child (a person who is not of legal age to give consent to the collection and processing of their data) and want to register with us, you must ask your parent or guardian for permission to register, confirm you have permission to register and provide an email address for the parent or guardian. We will then send a message to your parent that you have registered on the website and depending on your age and location may also ask your parent to confirm consent to the registration. If you have indicated that you would like to receive additional Pinkels material or services (only available to specified age groups as indicated when you register), then where required we will also ask your parent for consent. No information should be submitted to or posted to Pinkels Media Group or any Pinkels affiliate without consent of the relevant parent or guardian.

Our Registration Policy – How to remove or amend your Information
If you register with us, you will receive an e-mail either confirming your registration or asking you to confirm your registration (depending on your location). You can ask us to modify or remove your personal information from any or all of our mailing lists at any time by clicking on the Register link under the ‘Contact Us’ menu on Pinkels.co.uk. We will only send e-mail and text messages to you if you have given us express permission to do so. In addition you will also be able to unsubscribe from email communications via unsubscribe links in those emails.
You may be given the opportunity to submit information about other people to enable them to receive information on our products or services. You must obtain permission from such other people prior to submitting their information to us. The types of information that are collected about other people include: recipient's first and last name, phone number, address, e-mail address, and interests.

Use of Cookies
We collect information through technology to make our websites more interesting and useful to you. For instance, when you come to one of our websites, we collect your IP address. An IP address is often associated with the portal through which you enter the Internet, like your ISP (Internet service provider), your company, or your university. Standing alone, your IP address is not personally identifiable. At times, we also use IP addresses to collect information regarding the frequency with which our guests visit various parts of our websites. We may combine this information with personally identifiable information.
Our websites also use cookies. Cookies are pieces of information that a website sends to your computer while you are viewing the website. We and other companies use cookies for a variety of purposes. For instance, when you return to one of our websites after logging in, cookies provide information to the website so that the website will remember who you are. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Firefox or Internet Explorer) settings. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you won't have access to many features that make your Web experience smoother, like the features mentioned above, and some of our services will not function properly.
Our websites use a variety of technical methods for tracking purposes, including Web beacons. Web beacons are small pieces of data that are embedded in images on the pages of websites. We also use these technical methods to analyse the traffic patterns on our websites, such as the frequency with which our users visit various parts of our websites. These technical methods may involve the transmission of information either directly to us or to another party authorised by us to collect information on our behalf. We also use these technical methods in HTML e-mails that we send our guests to determine whether our guests have opened those e-mails and/or clicked on links in those e-mails. The information from use of these technical methods may be collected in a form that is personally identifiable.

Changes to this Policy
We may change this policy and our terms and conditions from time to time and will post the latest version of the privacy policy on the Pinkels.co.uk website. If we ever wish to use your personal information in a way which is incompatible with the information in this Privacy Policy, we will only do so with your consent.

Queries
If you have queries about our use of personal information, you can write to us at:
Pinkels B.V. – Prinsengracht 13, 1015DK Amsterdam, The Netherlands,
 
or send an e-mail to: support@pinkels.org