Privacy Policy

1. Introduction 

Milk Design B.V. (hereinafter referred to as "Joolz") respects your privacy and ensures that the personal data you provide to us is treated confidentially. This Privacy Policy explains how Joolz collects, uses, and protects the information it receives when you use this website. Joolz is committed to the protection of your personal data. When we ask you to provide certain information that can identify you when using this website, you can be assured that this information will only be used in accordance with this Privacy Policy. Please read this statement carefully to understand how Joolz may collect, use, and share your personal data. The terms "we," "us," or "Joolz" refer to Joolz. This Privacy Policy is valid as of September 29, 2023. 

2. Identity and Our Contact Information 

If you have any questions, please contact us at: 

Joolz, a brand of Milk Design B.V. 

Milk Design B.V. as the data controller 

Distelweg 89 

1031 HD Amsterdam 

Netherlands 

privacy@joolz.com 

 

3. What Personal Data Do We Collect? 

By filling out a web form, placing an order, creating an account, registering for warranty, subscribing to a newsletter, or as part of other promotional activities, we process, among other things, the following data: 

  • Your name 
  • Information about Joolz products you own 
  • Your contact details, including email address 
  • Demographic data such as postal code, preferences, and interests 
  • Other relevant information for customer surveys and/or offers 
  • Demographic data: These are not personal data in themselves, but, for example, data at the regional level. However, when demographic data are aggregated for an individual, they may be considered personal data. 
  • Transaction data: Personal data arising from transactions between Joolz and yourself 
  • Interaction data: Personal data resulting from correspondence between Joolz and yourself. This includes products you have ordered or registered, service requests you have submitted, your web browser used, the type of device you own, and other cookies/identification data. This also includes offline interactions. 
  • Behavioral information: Personal data about your behavior processed by Joolz, such as preferences, opinions, desires, and needs. For example, we may collect this data by tracking how you navigate through our website or through your interaction with a social media account. We collect and process this information only with your consent and using tracking cookies. 

If you do not wish to receive personalized marketing, you can contact us (see section 2). 

 

4. On What Legal Grounds Does Joolz Process Your Personal Data? 

Processing of personal data at Joolz only occurs on lawful grounds explicitly mentioned in the law. Joolz relies on three of these legal bases: 

  1. Performance of a contract: We use your personal data to take the necessary steps leading to the conclusion of a contract and to perform the contract we have entered into with you. 
  2. Consent granted: With your explicit consent, we have the right to use your personal data for specific marketing purposes and/or to support our market research. It is important to know that you have the right to withdraw your consent at any time. The "Control Over Your Personal Data" section describes how to do that. 
  3. Legitimate interest: We also use your personal data to protect the legitimate interests of Joolz. The following section provides more detailed information on these legitimate interests of Joolz. 

For Joolz, it is necessary to process your personal data to build and maintain a lasting relationship with you as a customer, monitor and improve our products, services, and processes, and protect our reasonable business interests. This includes informing our customers about new products, services, and activities, soliciting feedback on our products, preventing security incidents and misuse of our applications, as well as protecting Joolz's interests in (potential) legal disputes. 

5. How Do We Use Your Personal Data? 

We need this information to understand your needs and provide you with better service, especially for the following reasons: 

  • To deliver, operate, support, and improve Joolz products. This ensures that our customers can have the best possible experience with their newborns. 
  • To answer customer inquiries, perform repairs, and provide other customer service and support. Data processing is necessary to fulfill the contract with them and protect our legitimate interests. 
  • To develop summary analyses and business intelligence to enable us to operate, protect, make informed decisions, and report on our company's performance. 
  • To share and personalize our communication with you. 
  • We collect, combine, and analyze personal data to determine the most relevant target audiences and segments, content types, ads, information, moments, and channels, while limiting the number of contact requests. 

6. Recipients of Your Personal Data 

In the context of the purposes described above, we may share your personal data with Third Parties. 

  • In certain limited circumstances, we may be legally obligated to share certain personal data, including potentially yours, when we are involved in legal proceedings or comply with legal obligations, a court order, or instructions from insurers or a government entity such as data protection supervisory authorities. 
  • We may engage third parties to process personal data on our behalf (e.g., providers of specific IT applications, software developers, cloud providers, data brokers, direct marketing professionals we use in our operations). 
  • We may share certain personal data with business contacts, individuals, or organizations that have a direct (contractual) relationship with us and other relevant private organizations. 
  • We may also transfer personal data in the event of the sale or transfer of our entire business or a portion thereof, to external advisors, auditors, (potential buyers), government authorities, if required as part of that transaction. 

We ensure that, when applicable, appropriate measures are taken when sharing your personal data with third parties. For example, if necessary, we will enter into a data processing agreement (which includes restrictions on the use of your personal data and obligations regarding the security of your personal data). 

7. Data Transfers Outside the European Economic Area 

Your personal data may be stored and processed in any country where Joolz (and its group companies) are active. 

We may also share your personal data with other third parties outside the European Economic Area, such as business partners, service providers, and/or suppliers who assist us in conducting our operations. 

If your personal data is transferred to a third party or Joolz entity in a country that does not provide adequate protection for personal data, we will, if necessary, take steps to ensure that your personal data is properly protected and transferred in accordance with the General Data Protection Regulation (GDPR). 

You can request a copy of the safeguards applicable to the transfer of your personal data at any time using the contact details provided above in section 2. 

8. Obligations to Provide Your Personal Data 

In some cases, it is necessary for Joolz that you provide your personal data. This is the case, for example, when we enter into a purchase agreement, provide a service, register for warranty, or when you want to create an account. If it is necessary for us that you provide personal data, we will make this clear by using an asterisk (*) in the form. If you decide not to provide the requested personal data, we may not be able to enter into an agreement or offer the relevant service. 

9. How Long Do We Retain Your Personal Data? 

Joolz does not retain your personal data for longer than necessary to achieve the purposes described in this Privacy Policy or to comply with applicable laws and regulations. In some cases, it may be necessary to retain your personal data for a longer period, for example, in the case of a legal proceeding. 

10. Security 

Joolz is committed to the security of your personal data. We use various technical and organizational security measures, such as encryption and authentication tools, to ensure the security of your personal data and protect your information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. If you believe that your personal data is not properly secured, or if there are indications that your personal data has been lost, stolen, misused, or subject to unauthorized access, disclosure, alteration, and/or destruction, you can send an email to privacy@joolz.com. 

11. How Do We Use Cookies? 

A cookie is a small file that asks for permission to be placed on your computer's hard drive. Once you agree, the file is stored, and the cookie then helps analyze web traffic or lets you know when you visit a particular website. Cookies allow web applications to tailor themselves to you as an individual. The web application can adapt to your needs, preferences, and dislikes by gathering and storing information about your preferences. We use traffic log cookies to determine which pages are visited. This helps us analyze website traffic data and improve our website to meet customer needs. We use this information for statistical analysis purposes only. The data is then removed from the system. 

Cookies also help us provide you with a better website by enabling us to track which pages are useful to you and which are not. A cookie in no way gives us access to your computer or information about you, other than the data you choose to provide us. You can accept or decline cookies. However, you can usually modify your browser settings to decline cookies if you prefer. This may prevent you from fully using the website. 

12. Control Over Your Personal Data 

We will not sell, distribute, or lease your personal data to third parties. If you have provided personal data via Joolz.com and wish to access this information, you can send an email to privacy@joolz.com. 

13. Your Rights 

As a data subject, you have, under the General Data Protection Regulation (GDPR), the following rights under certain circumstances: 

  • Under the right of access, you can request access to the personal data concerning you. 
  • The right to correct or rectify your personal data if it is inaccurate or incomplete. 
  • The right to have your personal data erased. Please note that there may be circumstances in which we need to retain your data to comply with our legal obligations. 
  • The right to object to processing or request restrictions on processing. There may be circumstances in which we are legally entitled to deny your request. 
  • Under the 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 this data to another data controller. 
  • The right to object. 
  • The right to withdraw your consent. 

To exercise these rights or if you have questions about how we collect and use your data, you can contact us using the contact information provided in section 2. 

If you are not satisfied with how we process your personal data, please let us know. You also have the right to lodge a complaint with the local data protection authority, which in the Netherlands is the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). You can file a complaint via the following website: https://www.autoriteitpersoonsgegevens.nl/nl/zelf-doen/gebruik-uw-privacyrechten/klacht-melden-bij-de-ap. 

14. Klarna 

The use of payment methods such as invoice, installment purchase, and direct debit requires a positive credit assessment. In this context, we will transfer your data to Klarna for address and creditworthiness checks in connection with the initiation of the purchase and the processing of the purchase contract. We ask for your understanding that we can only offer those payment methods that are allowed based on the results of the credit check. More information and Klarna's terms of use can be found here. General information about Klarna can be found here. Your personal data is processed by Klarna in accordance with the applicable data protection rules and as described in Klarna's privacy policy. 

If you choose the Klarna payment method, Klarna may, in pursuit of its legitimate interests, conduct a credit check or share the payment data collected for payment processing with an external credit institution. You can object to this at any time. 

15. Email Advertisements with a Newsletter Subscription 

If you subscribe to our newsletter, we will use the necessary data or the data you provide to regularly send you our email newsletter based on your consent in accordance with the GDPR. You can unsubscribe from the newsletter at any time, either by sending a message to the contact information described in section 2 or by using a link provided for this purpose in the newsletter. After unsubscribing, we will delete your email address. 

16. Applicants 

As part of the job application process for a position within our company, we collect and process certain personal data related to you. This section explains how we collect and use your personal data as part of your job application process and for what purposes we process your personal data. Please note that this information only applies to your job application process. Once we have accepted your application, you will receive our internal privacy statement for employees. 

 

In the context of the job application process, we may collect and process the following personal data related to you: 

  1. Identification and contact information (e.g., name, date of birth, gender, place of birth, nationality, address, phone number, and email address). 
  2. Curriculum vitae and (additional) education and/or work history. 
  3. Professional certificates. 
  4. Assessments. 
  5. References. 
  6. Information about your legal and disciplinary history. 
  7. Copy of an identification document (including a driver's license, if relevant for the position). 
  8. Citizen service number (BSN). 
  9. Any other data related to your work experience (if relevant to job performance). 
  10. Any other data you mention in your job application letter and/or CV. 
  11. Government information, such as a copy of a residence permit or work permit (if applicable). 
  12. Assessment results. 
  13. Information from your professional social media profiles. 
  14. Your answers to job application questions. 
  15. In case we offer you a position, we may ask for a Certificate of Good Conduct to ensure suitability, integrity, and reliability for the position. 
  16. We will only use your personal data as described above for the following purposes: 
  17. To determine if you are suitable for and meet the relevant requirements for the position you are applying for. 
  18. For our administration. 
  19. To contact you/communicate with you. 
  20. To enter into an agreement with you. 
  21. To prevent reevaluation of applicants. 

 

We will collect, process, and disclose your personal data when we believe it is necessary to take pre-contractual steps for purposes related to your application or to pursue our legitimate interests. Sometimes, we may request your explicit consent for certain processing activities. If we process personal data based on your consent, you can withdraw that consent at any time by contacting us using the contact details in section 2. 

Your personal data may be obtained directly from you, from publicly available sources, or, if applicable and with your consent, from the following third parties: recruitment agencies or headhunters, your references and/or (other) former employers, teachers/providers of your education and/or training programs and their completion, and assessment bodies. 

We may share your personal information with third parties, such as service providers with whom we contract and our professional advisors, to prepare your employment contract, but only for the purposes outlined above. We ensure that, where applicable, appropriate measures are taken when we disclose your personal data to third parties. 

If you have accepted a position within our company, we will include your application data in your personnel file and refer to our internal privacy statement in this regard. 

If a position has not been offered or accepted within our company, we will delete your data as soon as possible after the end of the job application process. Generally, this will be a maximum period of four (4) weeks from the date the job application process is concluded. Your personal data will only be retained for a longer period if it is necessary to defend our interests in legal proceedings (e.g., in case of a dispute) or when required to comply with our legal obligations. If you want us to retain your personal information for a longer period so that we can contact you in case of another vacancy that matches your profile, please provide your consent for us to retain your personal data for a period of six (6) months. You can withdraw your consent at any time, after which we will delete your personal data as soon as possible, as we have informed you in this statement.