Privacy Policy

Effective date: 12 April 2025

At Licenty, your privacy matters.
The protection and security of personal data belonging to our customers and prospective customers (referred to as “you” or “your”) is a key priority for Licenty (“Licenty”, “we”, “us”, or “our”). We are committed to complying with all applicable data protection regulations, particularly the General Data Protection Regulation (GDPR). Terms used within this policy carry the same meaning as defined in the GDPR.

This Privacy Policy outlines the types of personal information we may collect and how that information is used and processed—whether you visit our physical stores or customer care centers, contact our support team, or interact with our website (hereinafter referred to as the “Website”).

Please note that this policy does not cover our data protection practices related to job applicants, employees, or other individuals engaged in an employment relationship with us. Additionally, it does not apply to data that is not subject to applicable data protection laws. This policy is not a contract and does not create any legal rights or obligations beyond what is provided by law.

1. Data controller

Licenty VOF, a company registered under Dutch law with its headquarters at Van Aeswijnstraat 15, 7783GM Gramsbergen, The Netherlands, and reachable via contact@licenty.com, acts—together with its affiliated companies—as the data controller in accordance with applicable data protection laws. These entities process personal data to provide you with the highest quality of service.

Within this policy, the term “Licenty” may refer either to the group of affiliated companies as a whole or to the specific entity responsible for data processing in your country of interaction.

Regional data controllers and contact details:

Licenty’s Global Data Commitments

Licenty’s data processing activities involve a network of affiliated data controllers. When you interact with Licenty—such as by visiting one of our stores or accessing region‑specific sections of our website—the Licenty‑affiliated entity located in the country where the interaction occurs will collect and process your personal data in its capacity as an independent data controller.

Your personal data may subsequently be transferred to, stored, and processed by other Licenty‑affiliated entities located in the countries listed below. Each of these entities may also act as an independent data controller to deliver a consistent level of service, regardless of where in the world you engage with us.

Central corporate entity: Licenty VOF, Van Aeswijnstraat 15, 7783GM Gramsbergen, The Netherlands. Licenty VOF sets group‑wide data governance practices (including policies related to data sharing and direct communications) and also receives and processes personal data from clients and prospective clients of all affiliated companies.

Data controllers in the Netherlands

Country/Region	Data controller	Address
Netherlands	Licenty VOF	Van Aeswijnstraat 15, 7783GM, Gramsbergen, The Netherlands

Data controllers within the European Economic Area (EEA)

Region	Data controller	Address
European Union Countries	Licenty	Van Aeswijnstraat 15, 7783GM, Gramsbergen, The Netherlands

Data controllers outside the EEA

Region	Data controller	Address
Non‑EU / International	Licenty	Van Aeswijnstraat 15, 7783GM, Gramsbergen, The Netherlands

2. Data protection officer

Licenty has appointed a Data Protection Officer (“DPO”) to oversee matters related to the protection of personal data.

If you have any questions about how Licenty handles your personal data, you can contact the DPO via the following email address: contact@licenty.com.

3. Personal data we collect

Depending on the services provided, Licenty may collect and process the following categories of personal data:

Identity information – First and last name, title, gender, date of birth, customer ID, identity document details, etc.
Contact information – Billing and shipping address, email address, phone number, preferred method of communication, etc.
Transaction details – Shopping cart contents, order history, returns, refunds or exchanges, payment information, bank details, etc.
Customer relationship information – Purchase and repair history, customer service interactions (records of your inquiries and claims), feedback and satisfaction ratings, etc.
Preferences, interests & inferred data – Product preferences, buying behavior, demographic data, interests, and other details shared during interactions with sales advisors, etc.
Online browsing data – Browsing information collected via cookies and similar technologies, browsing behavior, interaction with online ads, etc.
Technical and connection data – IP address, device identifiers, username and password, login records, browser data, general device location (such as city or region), etc.
Audio/Visual data – CCTV footage from our stores, call recordings with customer service, etc.

As a general rule, Licenty does not intentionally collect sensitive or special categories of personal data. This includes data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data for unique identification, health information, or data concerning an individual’s sexual orientation or sex life.

However, certain parts of the Website, in‑store services, repair processes, or customer support interactions may include open‑ended forms—such as surveys or feedback fields—where you might voluntarily choose to share such information. We encourage you to exercise caution and avoid providing sensitive personal data, in order to prevent any unintended processing.

4. Children’s data protection

In line with applicable local laws, Licenty does not knowingly collect personal data from individuals who are under the legal age of majority. If you are below the minimum required age in your country, please do not provide any personal information without the explicit consent and involvement of a parent or legal guardian.

If you believe that Licenty has collected personal data from a minor without proper authorization, please contact us at contact@licenty.com. We will promptly investigate the matter and delete the data if necessary.

5. Legal bases and purposes of processing

Licenty processes your personal data based on one or more of the following legal grounds, in accordance with Article 6 of the GDPR:

With your explicit consent (Art. 6(1)(a) GDPR);
Where necessary to perform a contract with you (Art. 6(1)(b) GDPR);
To comply with legal obligations (Art. 6(1)(c) GDPR);
For our legitimate interests, especially where needed to support the day‑to‑day operation of our business (Art. 6(1)(f) GDPR).

Below is an overview of the main purposes for which your personal data may be processed, along with their corresponding legal bases:

Purpose	Legal Basis
Customer Relationship To allow you to create and manage a Licenty account, whether online or in-store (either by yourself or with the help of a sales advisor). This includes assigning a unique ID linked to your email address and sending you essential account updates such as status notifications and security alerts.	Legitimate interest in enabling account management.
To manage and process your purchases and orders, including delivery and returns. This includes sending important transaction-related communications (e.g., confirmations, shipping updates, refund info).	Performance of a contract.
To handle invoicing and payment processes related to your transactions.	Performance of a contract.
To ensure transaction security and prevent fraud or payment-related incidents.	Legitimate interest in securing business operations.
To monitor cash transactions in accordance with anti-money laundering and counter-terrorism financing regulations. This may require identity verification with government-issued ID.	Legal obligation.
To support tax-free shopping for eligible customers.	Performance of a contract.
Customer Service (Repair) and Support To manage repair services when you send a Licenty product for repair to our customer service or bring it to one of our stores.	Performance of a contract.
To respond to and manage your inquiries submitted via the “Contact Us” form on the Website, email, or phone. This information will be added to your Licenty account. If you do not have an account, a new contact profile will be created in our database.	Legitimate interest in addressing your inquiries. Performance of a contract, if the request is related to a contractual or pre-contractual action.
To record your customer service phone calls.	Legitimate interest in processing data to improve service quality.
To collect and manage your feedback if you participate in our email surveys. We may also contact you by phone to follow up on your feedback.	Legitimate interest in processing data to improve service quality.
Marketing Activities To send you personalized marketing materials about our offers, products, the latest news, and events (newsletters, event invitations organized by Licenty, including private sales, and other news publications).	Your consent.
To manage our online advertising activities, including custom audiences, “lookalike” audiences, delivering interest-based ads, and tracking the effectiveness of campaigns. Your personal data may also be shared with external partners such as social media companies, online publishers, and marketing agencies.	Your consent.
To manage our centralized customer and prospect database, analyze interactions, and generate statistics to improve our services, create segments, and implement a personalized relationship marketing program.	Legitimate interest in optimizing customer experience.
To manage our social media pages (your interactions with us, content management, and statistics).	Legitimate interest in managing our social media pages.

Other Purposes

Purpose	Legal Basis
To secure and manage Licenty’s IT systems.	Legitimate interest in ensuring the security of our IT infrastructure.
To ensure the safety of goods and individuals, particularly with CCTV installations in certain stores.	Legitimate interest in enforcing law, protecting our property, and exercising our domiciliary rights.
To comply with legal requirements in accordance with applicable laws.	Compliance with a legal obligation.
To defend our rights and manage disputes.	Legitimate interest in defending our rights and managing disputes.
To process your requests to exercise privacy rights.	Compliance with a legal obligation.

Mandatory personal data fields — marked with an asterisk during collection — are essential to fulfill the purposes described above. If you choose not to provide this information, we may not be able to process your request or provide the requested services or products. Any additional information is optional and helps us personalize our communication and improve our services.

6. How your data is processed

Your personal data is processed using IT tools and/or manually. In some specific cases, we may apply generative artificial intelligence (AI) to assist with specific tasks, improving our operational efficiency and service quality. These AI tools are primarily used to facilitate our operations and/or supporting functions. We ensure that any AI‑driven processing of your personal data complies with the data protection principles outlined in this policy and the requirements of applicable laws. We do not process personal data for fully automated decision‑making that has legal or similarly significant effects on you. As a result, the rights to control such forms of automated decision-making do not apply.

7. Recipients of personal data

7.1. Our affiliates

Personal data that we collect for the purposes defined in this policy may be transferred to, stored, and processed by other Licenty‑affiliated companies to ensure the same quality of service, regardless of where in the world you contact us. This processing of your personal data is based on Licenty’s legitimate interest in optimizing the customer experience.

You can obtain a list of these countries and their affiliated Licenty companies in the addendum below.

7.2. Service providers

We partially rely on service providers, in accordance with legal requirements, through processor relationships. This means that processing is carried out based on a respective agreement in accordance with Article 28 of the GDPR, on our behalf, following our instructions, and under our supervision.

Processors include:

Suppliers responsible for distributing communication materials (e.g., newsletters, invitations, and other publications).
Suppliers responsible for customer relationship management (e.g., solutions that help improve customer service, personalize communication, and manage sales and marketing activities).
Suppliers of data and statistical analysis for cookies and similar technologies.
Media agencies tasked with monitoring Licenty’s social media performance.
Providers of technical services (e.g., cloud hosting and IT infrastructure, software maintenance and development, cybersecurity and network security, AI, and machine learning).
In such cases, we remain responsible for the processing of personal data. The transfer and processing of personal data to or by our processors are based on the legal grounds under which we are allowed to process data in each individual case.

7.3. Third parties

At times, we partner with other organizations who may also handle your data under their own rules. These third parties are considered data controllers. Their processing of your personal data is subject to their own guidelines, which you can obtain by contacting them directly. The rights you have under applicable data protection law can be exercised directly with these third parties.

7.3.1. Payment processing and fraud detection

To process your orders, we share necessary payment information with payment service providers, including your bank and partners like Cybersource, a Visa solution, which is also responsible for automatic fraud detection for online transactions.

See: Visa Privacy Statement.

We may offer other payment methods on our website such as Klarna, PayPal, and Apple Pay. When you choose these options, your personoal data is processed in accordance with their respective privacy policies:
Klarna Privacy Policy · Apple Pay & Privacy · PayPal Privacy Policy.

The legal basis for sharing your personal data is the fulfillment of the contract with you (Article 6(1)(b) of the GDPR) in the case of payment processing; and our legitimate interest in ensuring the security of our transactions (Article 6(1)(f) of the GDPR) in the case of fraud detection and prevention.

7.3.2. Logistics and transportation

To deliver goods related to your transactionswith us, we provide your address and contact details to transportation service providers, including partners like UPS (Privacy Notice) and DHL (Privacy Policy).
The legal basis for transferring your personal data is the fulfillment of the contract with you (Article 6(1)(b) of the GDPR).

7.3.3. Online advertising and tracking

For online advertising and tracking purposes, as outlined in Section 5 of this policy, your
personal data may be shared with our partners in two different ways:

By sharing your personal data: When you consent to marketing communications, we
may share your personal data with our advertising partners, such as Meta (Privacy Center) and Google (Privacy Policy).
Through automatic data collection technologies: When you visit our Website and
consent to the placement of cookies, our partners may access your personal data in
accordance with our Cookie Policy.

With your consent, we may share your personal data with advertising partners and/or allow them to collect data via cookies. See: Meta Privacy Center · Google Privacy Policy.
The legal basis for sharing your personal data is your consent (Article 6(1)(a) of the GDPR).

7.3.4. Legal process

We may disclose your personal data to third parties who help us protect our rights and property or when required by law or legal processes in response to subpoenas, court orders, investigations, or requests from government agencies, or when reasonably necessary to protect the rights or interests of our business, employees, affiliates, or others. The legal basis for transferring your personal data is Article 6(1)(c) of the GDPR in the case of a legal obligation, and Article 6(1)(f) of the GDPR in the case of our legitimate interest in protecting our rights.

7.3.5. Reorganization

In the event of a reorganization of Licenty, including a full or partial transfer of assets, merger, absorption, acquisition, split, or generally any reorganization operation, your data may be shared, subject to appropriate legal, security, and confidentiality measures. The legal basis for the transfer of your personal data is Article 6(1)(f) of the GDPR. We have a legitimate interest in adapting our internal corporate structures.

8. International data transfers

As Licenty has subsidiaries, branches, and affiliated companies abroad, and works with processors located outside the European Economic Area (EEA), the recipients of your personal data may also be based in countries/regions where Licenty operates, including those outside the EEA.For any transfer of personal data outside the EEA, particularly to countries for which the European Commission has not issued a decision on an adequate level of protection under Article 45 of the GDPR, appropriate safeguards will apply. These safeguards may include contractual guarantees in accordance with the rules for the protection of personal data, such as standard contractual clauses for data protection under Article 46(2) of the GDPR.

9. Data retention periods

Your personal data will not be kept in a form that allows identification for longer than necessary to achieve the purposes for which it was collected, or beyond the applicable legal limitation periods. The retention periods for your personal data are as follows:

Prospective customers: three (3) years from your last interaction with us.(you have not made a purchase)
Customers: (i.e.) you made a purchase the duration of your commercial relationship with Licenty, plus ten (10) years.

In some cases, your personal data may be kept for shorter periods. For example, CCTV footage will be retained in accordance with the notice displayed in the store, or customer service records will be retained for the legally required period.

Furthermore, your payment information will be securely stored for as long as necessary to confirm your order and process the payment, after which it will be promptly deleted. In case of a payment default, your personal data will be retained while the issue is resolved.

10. Your rights under data protection laws

In accordance with applicable regulations, you have the following rights:

Withdrawal of Consent (Article 7(3) GDPR): You may withdraw your consent at any time with
regard to any processing of personal data based on consent, without affecting the lawfulness
of the processing that was carried out before the withdrawal.

Access (Article 15 GDPR): You may ask us to confirm whether we are processing your
personal data and, if applicable, to inform you about the details of such processing. You can
request a copy of your personal data and details on how it’s processed.

Rectification (Article 16 GDPR): You may request that we correct inaccurate or incomplete
personal data.

Erasure (Article 17 GDPR): You may request the erasure of your personal data in the
following cases: (i) when the data is no longer necessary for the purposes for which it was
collected; (ii) when you have withdrawn your consent for processing based solely on your
consent; (iii) when you object to the processing of your personal data; (iv) when your
personal data has been unlawfully processed; (v) when your personal data needs to be
erased to comply with a legal obligation. In certain cases, we are not required to comply with
your request, particularly when processing your personal data is necessary to comply with a
legal obligation or for the establishment, exercise, or defense of legal claims.

Restriction (Article 18 GDPR): You may request that we restrict the processing of your
personal data (i.e., retain the data but not use it) in the following cases: (i) when the
accuracy of your personal data is contested; (ii) when the processing is unlawful but you do
not want your personal data erased; (iii) when it is necessary to establish, exercise, or
defend legal claims; (iv) when it is necessary to verify the existence of overriding legitimate
grounds after you have exercised your right to object. We may continue processing your
personal data after a request for restriction if: we have your consent; to establish, exercise or
defend legal claims; or to protect the rights of another individual or legal entity.

Data Portability (Article 20 GDPR): You may request that we provide your personal data to
you in a structured, commonly used, machine-readable format, or request that it be
transferred directly to another controller, but only when the processing is based on (i) your
consent; or (ii) the performance of a contract with you, and the processing is carried out by
automated means.

You also have the right to object under Article 21 of the GDPR:

- For processing activities based on the legitimate interest of Licenty: You may object
  on grounds relating to your specific situation. If you object, we must stop processing
  unless we can demonstrate compelling legitimate grounds for the processing that
  override your interests, rights, and freedoms, or if we need to process the data for the
  establishment, exercise, or defense of legal claims.
- For processing activities aimed at direct marketing: You may,

These rights can be exercised at any time by contacting Licenty’s Data Protection Officer
(DPO) at contact@licenty.com.

You also have the right to lodge a complaint with a competent supervisory authority,
particularly in the country of your usual residence, the place where you work, or the place of
the alleged infringement, regarding how Licenty collects and processes your personal data.
Contact details for supervisory authorities in the EEA can be found on the website of the
European Data Protection Board (EDPB).

11. Updates to this privacy policy

This policy may be updated from time to time to reflect changes in how we process personal data. The most recent version will always be available on our website.

1. Addendum

Written on April 14, 2025

This impressum also applies to our Social Media pages:

Licenty VOF.

Address:
Van Aeswijnstraat 15, 7783GM Gramsbergen, The Netherlands

Managing Director:
Lisa Spee

Phone:
+31 (0)6 36172922

Email:
contact@licenty.com

VAT Number:
NL864780084B01

Company Registration Number:
88791432

Website design and programming:
With Grace and Tulips

You can use the following links to navigate directly to the relevant sections:

Content of the website
Liability for links
Copyright
Data protection
Collection of data
Processing and use of personal data:
Google Analytics
Privacy policy for the ese of Facebook plugins (like button)
Privacy Policy for the ese of the Google “+1” Button
Privacy Policy for the Use of Hotjar
Online dispute resolution

1. Content of the website

The content of this website is carefully prepared according to the current knowledge of the
author. We are only responsible for this content under general laws. As a service provider,
we are responsible for third-party content only once we become aware of a specific violation
of the law. We reserve the right to change or delete all or part of the informative content, as
long as contractual obligations remain unaffected.

2. Liability for links

The content of external websites linked to directly or indirectly (via “hyperlinks” or “deep
links”) is outside our responsibility and not ours. When the links were created, we could not
identify any illegal content on the linked websites. Since we have no influence on the current
or future design of the linked websites, we explicitly distance ourselves from any content of
linked websites that has been changed after the links were made. For all content, and in
particular for damages that arise from the use of the information available on the linked
websites, the provider of the linked website is solely responsible. If we become aware of
illegal or incorrect content on websites we link to, we will remove the link.

3. Copyright

The content and works on these pages designed by the website operators are subject to the
relevant copyright laws. Duplication, processing, distribution, and any form of
commercialization of such material outside the scope of copyright law requires the prior
written consent of the respective author or creator. Downloads and copies of these pages
are only permitted for private, non-commercial use. Where content on this website has not
been created by the operator, the copyrights of third parties are respected. In particular,
third-party content is marked as such. If you become aware of any copyright infringement,
please let us know. Once we are made aware of such violations, we will immediately remove
such content.

4. Data protection

Thank you for your interest in our website and our company. The protection of your personal
data during collection, processing, and use during your visit to our homepage is important to
us. Your data is protected according to the applicable data protection regulations. Below, you
will find information on which data is collected during your visit to our homepage and how it
is used:

5. Collection of data:

Every access to our homepage and every retrieval of a file stored on the homepage is
logged. The logging serves internal system-related and statistical purposes. Logged: the
name of the retrieved file, the date and time of the retrieval, the amount of data transmitted,
a notification of successful retrieval, the web browser, and the requesting domain.
Additionally, the anonymous IP addresses of the requesting computers are logged. Further
personal data is only collected if you voluntarily provide this information, such as through a
survey or registration.

6. Processing and use of personal data:

If you have provided us with personal data, we will only use it to respond to your inquiries,
process contracts with you, and for technical administration. Your personal data will only be
passed on to third parties or otherwise disclosed if permitted according to legal provisions,
such as for processing contracts, particularly passing order details to suppliers, necessary
for billing purposes, or if you have given prior consent. You have the right to withdraw your
consent at any time with effect for the future. The deletion or blocking of stored personal
data will be carried out in accordance with legal regulations if you withdraw your consent for
storage, if the data is no longer necessary for the purpose for which it was stored, or if its
storage is inadmissible for other legal reasons. Upon written request, we will gladly inform
you about the personal data we have stored about you.

7. Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Inc.
(“Google”). Google Analytics uses “cookies,” which are text files stored on your computer to
help analyze how users use the website. The information generated by the cookie about
your use of the website is transmitted to and stored by Google on servers in the United
States. However, if IP anonymization is enabled on this website, your IP address will be
shortened by Google within the member states of the European Union or in other contracting
states of the Agreement on the European Economic Area. In exceptional cases, the full IP
address will be transmitted to a Google server in the USA and shortened there. On behalf of
the operator of this website, Google will use this information to evaluate your use of the
website, compile reports on website activities, and provide other services relating to website
activity and internet usage to the website operator. The IP address transmitted by your
browser in the context of Google Analytics will not be associated with other Google data. You
can disable the use of cookies in your browser settings, but this may limit the functionality of
the website. Additionally, you can prevent Google from collecting data generated by the
cookie related to your use of the website (including your IP address) and processing this
data by downloading and installing the browser plugin available at the following link:
https://tools.google.com/dlpage/gaoptout?hl=en-EN.

8. Privacy policy for the ese of Facebook plugins (like button)

Our pages integrate plugins from the social network Facebook, 1601 South California
Avenue, Palo Alto, CA 94304, USA. You can recognize the Facebook plugins by the
Facebook logo or the “Like” button on our pages. An overview of the Facebook plugins can
be found here: http://developers.facebook.com/docs/plugins/. When you visit our pages, the
plugin establishes a direct connection between your browser and the Facebook server.
Facebook receives the information that you visited our website with your IP address. If you
click on the Facebook “Like” button while logged into your Facebook account, you can link
the content of our pages to your Facebook profile. This allows Facebook to associate your
visit to our pages with your user account. We point out that we, as the provider of the pages,
do not have knowledge of the content of the transmitted data or its use by Facebook. More
information about this can be found in Facebook’s privacy policy at
http://de-de.facebook.com/policy.php. If you do not want Facebook to associate visits to our
pages with your Facebook user account, please log out of your Facebook user account.

9. Privacy Policy for the ese of the Google “+1” Button

On our website, we use the “+1” button from the social network Google+ (Google Plus) by
Google Inc., 1600 Amphitheatre Parkway, Mountain View, California, 94043, USA
(hereinafter referred to as “Google”). Every time you visit a webpage on our website with a
“+1” button, the button ensures that your browser downloads and displays the visual
representation of the “+1” button from Google’s server. The Google server is informed about
which specific website of our online presence you are currently visiting. Google records your
browser history when a “+1” button is displayed for up to two weeks for system maintenance
and troubleshooting purposes. No further evaluation of your visit to a website with a “+1”
button takes place. If you click the “+1” button while logged into Google+ (Google Plus),
Google collects information about your recommended URL, your IP address, and other
browser-related data via your Google profile so that your “+1” recommendation can be
stored and made publicly available. Your “+1” references may appear as suggestions, along
with your profile name and photo in Google services, such as search results or in your
Google profile (under the “+1” tab in your Google profile), or elsewhere on websites and
advertisements across the internet. You can find Google’s privacy policy for the “+1” button
with more detailed information on the collection, sharing, and use of data by Google, your
rights in this regard, and Google’s privacy policy.

10. Privacy Policy for the Use of Hotjar

This website uses Hotjar, a web analysis service from Hotjar Ltd. (“Hotjar”). Interactions of
randomly selected individual visitors with the website are anonymously recorded. This
results, for example, in a log of mouse movements and clicks, aimed at showing
improvement opportunities for the relevant webpage. Hotjar uses “cookies,” which are text
files stored on your computer to help analyze how users use the website. To eliminate any
personal reference, IP addresses are only processed and stored anonymously. Additionally,
information about operating systems, browsers, incoming and outgoing links, geographical
origin, and screen resolution is evaluated for statistical purposes. The information is
non-personal and is not shared with third parties by us or Hotjar. If you do not wish to work
with cookies, you can disable them in your browser for all websites using Hotjar by setting
the DoNotTrack header in your browser. Further information can be found at
https://www.hotjar.com/opt-out.

11. Online dispute resolution

Online dispute resolution in accordance with Art. 14 par. 1 ODR Regulation: The European
Commission provides an online dispute resolution platform (ODR) accessible at
http://ec.europa.eu/consumers/odr/. We are neither obligated nor willing to participate in
dispute resolution procedures for consumer arbitration.