Hatch Global Privacy Statement

Last Update: 14 October 2021

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Hatch B.V., A J Ernststraat 5, 1083 GP Amsterdam, the Netherlands (“Hatch”, “we” or “us”), provides services and technology to companies with the goal to list the appropriate online merchants in relation to a specific product or service. This enables web-based commerce solutions to make it easy for online shoppers to find and buy products whether they originate from retailer websites, manufacturer websites, destination shopping sites, or mobile shopping applications.

We are committed to protecting the privacy of the personal information collected and processed by us. Compliant privacy and data security practices have therefore become integral components of our Services, governance, accountability and risk management. We therefore process only such personal information as is necessary for the provision of the relevant Hatch Products & Services.

Please read this Privacy Statement carefully so that you understand how we collect and use your personal data.

Table of contents

1. Extent of this Privacy Statement

Website visitors/users (“Website Visitors”);

Business Clients (“Clients”);

Business Relations (“Retailers”, “Agencies”); (Individually and collectively also referred to as “you”)

We collect and use your personal information through our Where to Buy solutions (“Products & Services”, “Services”) and through our website(s) (“Website Visitors”).

1.1 Responsibilities of Business Clients and retailers

In the case that Clients or retailers have access to personal information through their own platform(s), the Client or retailer is the data controller responsible for the processing and use thereof. This Statement does not apply to the processing and use of personal data by Clients or retailers.

2. How we collect data

2.1 Through our website

Hatch collects two kinds of information: anonymous and personal data. Anonymous information is not associated with specific individuals. For instance, Hatch may know how many unique browsers view this Privacy Statement today, but we don’t know the names, addresses or any other Personal Data of the individuals at that browser.

Personal Data reveals who you are and/or how you can be contacted. When you interact with us, we may receive and store data you choose to provide while using our general website. We use the information that you provide for such purposes as:

 

  • Responding to your inquiries
  • Improving our contact information

 

We may also receive and store data whenever you interact with us or our website through cookies and similar technologies (Please also read section 2.5 ‘Cookies and Similar Technologies’).

2.2 Through our Where to Buy solutions

The Hatch solution does not use cookies or store any personal data to measure conversion between platforms. When a visitor opens a Channel Buy Link page and clicks on a retailer link, the visitor is transferred through an in-between page from Hatch to the retailer website where the anonymised session is recognized. Personal data processed during this session is the IP address which upon gateway entry is immediately encrypted and anonymised into a session key and removed. Henceforth no personal data is processed.

Hatch typically provides sales tracking insights to its customers through a cookie-less tracking method involving consent given by the visitor on the retail partner website to trigger a pixel. This pixel will only provide the information to match the sale to the session key and cannot be tracked back to an individual.

In addition, an individual is always offered the opportunity to submit a SAR (Subject Access Request) with Hatch, pertaining to any data that might be related directly or indirectly to the individual. In the case that a client has chosen not to use any in-between page, Hatch cannot offer the SAR directly and the visitor would need to contact the brand to submit such request.

2.3 Through our Dashboard

You can choose to create an online Hatch Dashboard account to get access to the performance insights of your implemented Where to Buy solution.

2.4 Offline

You can choose to create an online Hatch Dashboard account to get access to the performance insights of your implemented Where to Buy solution.

2.5 Cookies and similar technologies

Any processing of your personal information via cookies will take place in accordance with our Cookie Policy.

You can easily stop gethatch.com from collecting information by opting-out. This will prevent us from storing data with a cookie, by clicking on the opt-out link. We will install a cookie that will prevent our data collection.

3. For what purposes we collect data

3.1 HATCH WEBSITE VISITORS

3.1.1 To communicate with you

Hatch may contact you with promotional communications via email, SMS and other digital channels, such as mobile apps and social media for which permission is granted. To be able to tailor the communications to your preferences and behavior and provide you with the best, personalized experience, we may analyze and combine all information associated with your account data and data about your interactions with Hatch. We also use this information to create segments of our audience showing which of our products and/or services users are interested in and track success of our marketing efforts.

You can choose to sign up for marketing and promotional communications. When you sign up for marketing and promotional communications, we will use the following Personal Data:

  • Name
  • Salutation
  • Job title
  • Email address
  • Phone number
  • Your company name
  • Your interactions with Hatch Pages, Hatch mobile apps, the emails you clicked and opened and attendance of events.


We use this Personal Data to send you promotional communications – based on your preferences and behavior – about Hatch products, services, events and promotions.

Hatch will give you the opportunity to withdraw your consent for receiving promotional communications at any time via the unsubscribe link at the bottom of each promotional communications email you may receive from us.

We may also send Hatch press releases by email. When Hatch sends press releases, Hatch will process your name, contact details (e.g. email) and company information.

The processing of Personal Data for Promotional Communications are based on either legitimate interest or your consent if you are not a Hatch client, i.e. provided on a voluntary basis; such basis is lawful under article 6 (a) of Regulation (EC) 5419/16. Where Hatch processes your Personal Data based on consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before withdrawing your consent.

3.1.2 To facilitate social sharing functionality

Our websites may contain various social media sharing functionalities, such as Facebook, Twitter or LinkedIn buttons, which -with your consent- you may use to share information provided on our websites with the social media of your choosing. Our websites may also contain links to our own social media pages, such as our Hatch Facebook or LinkedIn pages or our Twitter feed, which you may choose to use to post feedback.

Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Twitter, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any personal information you disclose to other organizations through or in connection with our social media functionalities.

For this purpose, we process your name, email address, IP-address, photo and/or logo, list of social media contacts and any other information that may be accessible to us when using social media functionalities.

With whom do we share your personal information?
See section 5 ‘Sharing data with Third-Parties’.

3.2 HATCH BUSINESS PURPOSES

3.2.1 Management reporting

We process personal information for various Hatch business-related purposes for which we have a legitimate interest to process these data, such as data analysis, audits, developing new products, enhancing, improving or modifying our websites, Products & Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.

To facilitate your use of our online services or applications, we may analyze data that we collect when using our digital media and combine it with information collected via cookies. For example, to better understand which digital channel (Google search, e-mail, social media) or device (desktop, tablet or mobile) you prefer, we can optimize or limit our communication and marketing activities by channel and by device.

For this purpose, we may process your name, your email address, your IP address, gender, date of birth, place of residence, digits of your postal code and any other information mentioned in this Statement or otherwise provided to us by you, if such is required for one of the purposes mentioned in the previous paragraph.

3.2.2 Surveys or other marketing communication

We process your personal information when we send you periodic surveys to request your feedback on our Services, for which we have legitimate interest to process these data. With your consent or where you have provided your business contact information and we have a legitimate interest, we may send you marketing communication, to keep you updated on product developments, events, special offers, possibilities and current and future products and services of Hatch. When we contact you in regard of surveys or marketing communication, we will do so either by email, phone, or by postal newsletters/brochures/magazines (postal mailings). If you would no longer like to receive surveys or marketing communication from us, please contact us via info@gethatch.com or unsubscribe through the provided link in any email communication. This would mean that you have withdrawn your consent and we cannot contact you again for these reasons unless you resubscribe and give us a new consent.

With whom do we share your personal information?
See section 5 ‘Sharing data with Third-Parties’.

3.3 HATCH PROVIDED SOLUTIONS & TECHNOLOGY

3.3.1 Where to Buy solutions

The Hatch solution allows to measure conversion from one platform to the next and enables clients who purchase Hatch’s services to better understand how their products are selling through their digital channels. Hatch uses a cookie-less technique (as described in the section 2)  to identify conversions through a session key, consisting of a anonymised lead ID, product, and date combination.

With whom do we share your personal information?
See section 5 ‘Sharing data with Third-Parties’.

4. Data concerning clients and prospective clients

4.1 CLIENT ACCOUNT MANAGEMENT

4.1.1 To enter into, provide, manage and administer the Client account

We collect your information to enable us to enter into a Client relationship with you, handle day-to-day management and administration of the Client accounts, such as maintaining contracts, and keep you informed of important developments concerning the Products & Services and other information which is relevant for the Client contract and account. This processing is done based on our legitimate interest (the performance of the contract that we have with the Client) and to adhere to guidance and best practice issued by regulators to which the relevant local Hatch office is subject or based on a legal obligation.

For this purpose, when you create a Hatch account, we collect the following Personal Data:

  1. Name;
  2. Salutation;
  3. Email address;
  4. Password;
  5. Country and language preference determined by your browser settings
  6. Furthermore, we may need the following information when you interact with Hatch as a Client or a retailer:
    • Company name
    • Company address
    • Company phone number
    • Organization Type
    • Job title

We use this Personal Data in order to create and maintain your account. Your Hatch account creation only happens at your request. Therefore, we consider the processing of your account data to be necessary for the performance of the contract to which you are party and lawful under Article 6(b) Regulation (EC) 5419/16.

With whom do we share your personal information?
See section 5 ‘Sharing data with Third-Parties’.

4.2 HATCH LOCATIONS

4.2.1 Access to and security control of Hatch locations

What is the purpose and which personal information does it concern?
We may process your personal information when you visit us on our premises for the purpose of ensuring appropriate access controls and security, for which we have legitimate interest (safety and security of our assets).

For this purpose, we may process your name, your contact information and the person you are visiting.

With whom do we share your personal information?
See section 5 ‘Sharing data with Third-Parties’.

4.3 CLIENT REPORTING

4.3.1 Hatch reporting dashboard

What is the purpose and which personal information does it concern?
We provide online reporting tools. Clients’ contact persons can log onto this dashboard to review the status of their Where to Buy Products & Services, and to use other reporting functionalities, such as dashboard reporting and trend analysis reporting. This processing is done based on our legitimate interest (the performance of the contractual agreement that we have with the Client).

With whom do we share your personal information?
See section 5 ‘Sharing data with Third-Parties’.

5. Sharing data with Third-Parties

In addition to what is indicated for each purpose above regarding sharing of personal information, we may also share personal information:

Within the Hatch B.V. entities for the purposes described in this Statement. You can request the list and location of our Hatch entities here

5.1 To our third-party service partners and providers, to facilitate services they provide to us

In order to provide you with our services, we often work closely with Service Partners and Service Providers. Our Service Partners assist us in providing our ‘Where to Buy’ products and other services to you. Service Providers are companies that support us in running our business, for example to help us maintain our IT network and related infrastructure, and security and access controls to our locations.

Hatch does not resell any Personal Data.

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.

  • This may include sharing information with the authorities and fraud prevention agencies. Please see the relevant sections above for further information and contact details for these agencies.


To cooperate with public and government authorities.

  • These may include regulatory or governmental bodies to which Hatch is subject to
  • To respond to a request or to provide information we believe is important or mandatory by law
  • 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.

  • To enforce our terms and conditions; and
  • To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others


In connection with a sale or business transaction.

  • 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.

6. Links to Third-Party websites and services

Hatch sites and services can provide links to Third-Party websites and services. We do not provide any Personal Data to these advertisers or third-party websites other than as provided in this Privacy Statement. Hatch provides these links as a convenience, and the inclusion of any link does not imply that Hatch endorses any Third-Party, their website or their products or services. Hatch has no control over the websites linked to and is not responsible for the contents, services, or availability of any linked website or service (including any further link contained in a linked third-party website or service). We do not have access to, or control over any tracking technologies or other features that may be used on these third-party websites, thus they are not covered by this Privacy Statement. We therefore refer to the Privacy Policy/Statement of this Third-Party or contact them directly for more information.

7. International Personal Data transfer

Due to the global nature of our organisation and Products & Services, your personal information may be stored and/or processed in a country other than the one you reside in.

Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). For transfers and access to Hatch data from the EEA to countries not considered adequate by the European Commission, we have security measures, binding Business Rules, contractual (data processing) agreements and permission put in place. Please contact us via info@gethatch.com in case you would like to receive more information about these measures and agreements.

8. Security and retention

8.1 How we secure personal data

We seek to use organisational, technical and administrative measures to protect personal information within our organization.

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 (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the Contact details provided in this Statement.

8.2 How long we retain personal data

We will retain your personal information for as long as necessary or permitted in light of the purposes outlined in this Statement and consistent with applicable law.

 

The criteria used to determine our retention periods include:

  • Retention for our business relationship. The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you use Hatch Product or Service);
  • Retention in case of legal obligation. Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)
  • Retention to protect our legal position. Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
  • Retention in case of claims. We will retain your personal information for the period in which you might legally bring claims against us (as relevant).
  • Retention in accordance with regulatory requirements. We will retain your personal information where we are required to do so by regulatory regimes and regulations applicable to us.
  • Retention of prospect non-business personal contact details for our marketing purposes will be for a maximum of two years unless you tell us within that period that you wish to unsubscribe or withdraw your consent.

9. Children’s privacy

Our Products & Services are not directed at individuals under the age of 18.

10. Your rights and contacting us

Your rights

If you would like to request to review, correct, update, suppress, restrict or delete your personal information processed by us, object to the processing of personal information, to object to automated decision making or if or if you would like to 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), you may contact us via the contact form. We will respond to your request consistent in accordance with applicable law.

In your request, please make as clear as possible what personal information your request relates to. For your protection, we will only implement requests with respect to the personal information associated with the particular email address as you indicated in the contact form, and we may request you to provide verification of your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event within any applicable legally required timeframes.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that began prior to requesting such change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.

Questions?

If you have any questions or complaints about this Statement, please contact us via the contact form.

Because email communications are not always secure, please do not include sensitive information in your emails to us.

11. Changes to this Privacy Statement

We may change this Statement at any time. Please take a look at the “Last Updated” legend at the top of this page to see when this Statement was last revised. Any changes to this Statement will become effective when we post the revised Statement on the Services. Your use of the Services following these changes means that you accept the revised Statement.

SUBJECT ACCESS REQUEST

As a data subject, you have a legal right, under EU Regulation 2016/679 General Data Protection Regulation (‘GDPR’) to find out about our use of your personal data as follows:

  • Confirmation that your personal data is being processed by us
  • Access to your personal data
  • How we use your personal data and why
  • Details of any sharing or transfers of your personal data
  • How long we hold your personal data
  • Details of your rights under the GDPR including, but not limited to, your rights to withdraw your consent to our use of your personal data at any time and/or to object to our processing of it.

No fee is payable under normal circumstances. We reserve the right to charge a reasonable fee for requests that are manifestly unfounded, excessive, or repetitive. Such charges will be based only on the administrative cost that we will incur in order to respond.

After receiving your subject access request, we may contact you to request additional supporting information and/or proof of your identity. This helps us to safeguard your privacy and personal data.

We will respond to all subject access requests within 30 days of receipt and will aim to provide all required information to you within the same period. If we require more information from you, or if your request is unusually complicated, we may require more time and will inform you accordingly.

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