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Privacy Statement

Penal, located at Boterdiep 69-1, 9712 LK Groningen, is responsible for the processing of personal data as shown in this privacy statement.

Contact Information:

https://penalapp.com
Boterdiep 69-1
9712 LK Groningen
The Netherlands

Sebastiaan Pasma is the Data Protection Officer of Penal; he can be reached at [email protected]

Personal data we process:

Penal processes your personal data when you use our services and/or when you provide these data to us yourself. Below you will find an overview of the personal data we process:

- First and last name
- Email address
- Data about your browsing behavior of the app and website
- Internet browser and device type

Special and/or sensitive personal data we process:

Our app and website do not intend to collect data about visitors under the age of 16, unless they have permission from parents or guardians. However, we cannot verify whether a visitor is over 16. Therefore, we recommend that parents be involved in their children's online activities to prevent data about children from being collected without parental consent. If you believe that we have collected personal information about a minor without that consent, please contact us at [email protected], and we will delete this information.

Purpose and basis for processing personal data:Penal processes your personal data for the following purposes:

- Sending our newsletter and/or promotional materials
- Informing you about changes to our services and products
- Providing you with the opportunity to create an account
- Providing you with the opportunity to join various pools
- Providing you with the opportunity to make predictions for sports events
- Penal analyzes your behavior on the app and website to improve them and tailor the offering of products and services to your preferences.

Automated decision-making

Penal makes decisions about matters that may affect individuals based on automated processing. These are decisions made by computer programs or systems without human intervention (for example, by a Penal employee).

How long we retain personal data

Penal does not retain your personal data longer than strictly necessary to achieve the purposes for which your data are collected. We automatically delete accounts that are no longer active. We apply the following retention periods for the following (categories) of personal data if they are no longer active:

First and last name (all account data) > 24 months (2 years)

Sharing personal data with third parties

Penal does not sell your data to third parties and will only provide them if necessary for the performance of our agreement with you or to comply with a legal obligation. We enter into a data processing agreement with companies processing your data on our behalf to ensure the same level of security and confidentiality of your data. Penal remains responsible for these processing activities.

Cookies, or similar techniques, that we use

Penal only uses technical and functional cookies, as well as analytical cookies that do not infringe on your privacy. A cookie is a small text file that is stored on your computer, tablet, or smartphone when you first visit our app and website. The cookies we use are necessary for the technical operation of the app and for your convenience. They ensure that the app and website work properly and remember, for example, your preferences. We can also use them to optimize our website. You can opt out of cookies by configuring your internet browser not to store cookies. Additionally, you can delete all information previously stored through your browser's settings.

Accessing, correcting, or deleting data

You have the right to access, correct, or delete your personal data. You can do this yourself through the personal settings of your account. Additionally, you have the right to revoke any consent for data processing or object to the processing of your personal data by our company, as well as 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 you have mentioned.

If you wish to exercise your right to object and/or your right to data portability or if you have any other questions/comments about data processing, please send a specific request to [email protected].

To ensure that the request for access has been made by you, we ask that you include a copy of your identity document with the request. In this copy, please black out your photo, MRZ (machine-readable zone, the strip with numbers at the bottom of the passport), passport number, and Citizen Service Number (BSN) to protect your privacy.

Penal will respond to your request as soon as possible, but no later than four weeks.

Penal also wants to remind you that you have the option to file a complaint with the national supervisory authority, the Dutch Data Protection Authority. This can be done via the following link: https://autoriteitpersoonsgegevens.nl/nl/contact-met-de-autoriteit-persoonsgegevens/tip-ons

How we secure personal data:

Penal takes the protection of your data seriously and takes appropriate measures to prevent misuse, loss, unauthorized access, unwanted disclosure, and unauthorized alteration. If you believe that your data are not properly secured or if there are indications of abuse, please contact our customer service or email us at [email protected].