1.Privacy Policy

Last revision: May 2026

1. Data controller

This Privacy Policy applies to the website www.best-poppers.eu (the “website”) operated by Dutch Trading Company B.V. (“DTC”, “we”, “us”, “our”), a private limited company incorporated under the laws of the Netherlands, with registered office at Beitel 110, 6422 PB Heerlen, the Netherlands, registered with the Dutch Chamber of Commerce (Kamer van Koophandel) under KvK number 82516480 (hereinafter the “website” or “Best-Poppers”). The terms “user”, “visitor”, “you”, “your” refer to you, as the user of our website and online shop.

In this overview, you will find out what data Best-Poppers collects from you as the data controller and for what purposes we use this data. We always endeavour to ensure that the personal data we receive and use is stored, used, transferred and otherwise processed in compliance with our legal obligations.

For any question regarding this Privacy Policy or to exercise the rights described in §9, contact us at contact@kink-cartel.com.

2. When is personal data used and processed?

This policy deals in detail with the personal data that we collect, use and transfer (i.e. process). This generally includes your name, address, phone number, e-mail address, IP address, billing and account information, and other data resulting from the fact that we provide you with our goods and services. We know that the careful handling of your personal data is very important to you. As data protection is therefore also a high priority for us, we strictly adhere to EU Regulation 2016/679 (General Data Protection Regulation, “GDPR”), the Dutch GDPR Implementation Act (Uitvoeringswet Algemene Verordening Gegevensbescherming, “UAVG”) and the Dutch Telecommunications Act (Telecommunicatiewet) when collecting, processing and using data.

In principle, you can visit our website without providing any personal data. However, in some cases we require such data from you:

when placing an order

when you contact us

when using the protected “customer account” area

when subscribing / unsubscribing to the newsletter

Your data helps us to personalise and continuously improve your shopping experience with us. We use the personal data in detail to process orders, to deliver the goods, to process payments, to prevent misuse of our website and to inform you about orders, products, services and offers. In order to be able to contact you more easily and quickly than by post, we ask you to provide us with your e-mail address. Of course, we will only use this for advertising purposes if you have explicitly given your consent.

3. What personal data do we process?

3.1. The personal data that you provide to us

We process personal data that you provide to us yourself. We store the personal data primarily to optimise order processing and may pass it on to other companies for this purpose. An example in this context is the forwarding of data to a shipping provider who delivers the goods to you, or the forwarding of data to our contractually authorised partners for financial services (credit card).

3.1.1. When placing an order

When you order goods or services from us, for example, we require information from you that is marked as mandatory in the ordering process (this is primarily your first name, surname and address). Without this information, we cannot deliver the goods to you correctly. Furthermore, for the purpose of selling goods or services, we require your e-mail address, to which we will send you an order confirmation, which also serves as confirmation of the concluded purchase contract.

When ordering goods or services, you can also fill in optional information. These help us to fulfil the contract better and more efficiently. For example, if you provide your telephone number, we can send you information about the delivery of goods, etc. You provide us with this optional data voluntarily.

After the goods have been delivered to you, you may receive an e-mail asking you to rate the purchased goods.

By completing the optional information in your user profile, you also provide us with your other personal data, such as frequently used delivery addresses.

3.1.2. When you contact us

If you send us a message, we will also process the personal data contained in this message.

3.1.3. When using the secured area “User account”

Online visitors have the option of creating an account on our website. To create an account, you must enter your name, e-mail address, a password, your address and phone number. By doing so, you consent to the processing of your personal data. You will also find your order history in your user account.

3.1.4. When subscribing/unsubscribing to the newsletter

When you subscribe to our newsletter (i.e. “opt-in”), you will be asked to provide your e-mail address and consent to the processing of your personal data. If you subscribe to our newsletter, you will receive information by e-mail about products and offers that we offer.

3.2. Personal data that we process automatically

We process browsing data that shows which areas of our website visitors access. This data allows us to determine which areas of our website are visited most frequently and helps us to improve the quality of your online experience by recognising and developing the most popular functions and services. We may also process other, non-personal data (for example, domain type, browser version or service provider), which provides us with information about the general use of our website.

3.2.1. Cookies

In accordance with article 11.7a of the Dutch Telecommunications Act (Telecommunicatiewet), we obtain your prior consent for any non-functional cookies via our cookie banner. You may withdraw that consent at any time via the cookie-settings link in the website footer.

We also use cookies automatically to make your shopping experience as pleasant as possible. For example, they allow you to conveniently view your shopping cart across pages, where you can see how many items are currently in your shopping cart and the current value of your purchase. To be able to use all the functions of our shop, you must activate permanent cookies in your browser. If you do not enable permanent cookies, you will be able to visit our shop, but you will not be able to see the status of your shopping cart, for example.

3.2.1.1. What is a cookie?

It is a small text file that is created when you visit a website. It is used as a standard tool to store information about how our website is used.

This allows us to distinguish (but not identify) individual users and customise content to specific preferences. Cookies are important. Without them, surfing the internet would be much more difficult.

3.2.1.2. What are cookies used for?

Cookies serve various purposes. We use the following cookies in our online shop:

Technical cookies: These are absolutely necessary for the functioning of the website and the functions you have selected. Without them, our website would not work, e.g. you would not be able to log in to your user account.

Functional cookies: These cookies enable us to save your basic settings and improve user-friendliness, e.g. your choice of language or the option to remain logged in permanently.

Social networking cookies: These cookies allow us to conveniently connect you to your profile on a social network and, for example, allow you to share products and services with friends and family.

Personalisation of content: These cookies allow us to show you content and advertisements based on the information available about you so that we can best meet your needs. This includes what content you have viewed or what device you use to access our website.

Non-personalised advertising: These cookies allow us to show you general advertising for products and services.

Personalised advertising: These cookies allow us and our partners to offer you relevant and tailored products and services based on your purchases, behaviour and preferences.

Audience measurement: These cookies allow us to optimise our website for you based on your usage behaviour in order to remember or anticipate your preferences. This includes, for example, the use of functions, their placement and your behaviour on the site.

We and our partner companies are authorised to collect, process or use personal data via our website using cookies. Without your explicit refusal, the data stored in the used cookies may be linked to your personal data (name, address, etc.).

You can deactivate personalised and targeted advertising at any time in the data-protection settings.

3.2.1.3. How you can control which of your cookies we process

If you do not want us to analyse your anonymous browsing and purchasing behaviour through your use of this service, you can deactivate the setting for accepting cookies in your web browser. In this case, however, you will no longer be able to use certain functions and services that we offer on our website, e.g. you will no longer be able to shop in our online store.

You can prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

4. Why we collect and process your personal data

We process the data collected via our website in compliance with the applicable Privacy Policy and for the following purposes:

Purchase of goods and services: We process your personal data primarily to properly process and deliver your order. In the event of any difficulties, your personal data will help us to know who to contact.

Customer support: If you contact us with a question/problem, we need to process your data to answer/solve the problem. In some cases, personal data may also be shared with third parties (e.g. shipping providers of goods).

User account: With personal data that you provide to us in your user profile, you can use a number of useful functions (e.g. if you provide your phone number, we can easily inform you when your order will be delivered). You can change the data you provide at any time, with the exception of your e-mail address, which is used to access your user account.

Marketing activities:

Email marketing: We will send you commercial email messages based on your consent. You can easily unsubscribe from receiving marketing communications by editing your user profile settings or using the contact form.

Phone calls: A customer support representative may call you.

Marketing competitions: In some cases, the winner of a competition may be photographed or filmed, in particular to increase the transparency of our marketing competitions. We carry out this processing of personal data on the basis of our legitimate interest to increase the credibility of our marketing competitions in the eyes of other participants and to increase the attractiveness of these competitions.

Retargeting: In some cases, we use retargeting methods.

To improve our services: to understand your needs and preferences and to develop, sell or offer products and services and to conduct surveys, research and analyses where appropriate. We may also use multivariate testing tools (“A/B testing”), Google Analytics, Facebook Analytics, etc. to optimise on-site and off-site elements (personalised advertising on third-party websites).

Customer reviews of goods and services: After you have purchased goods or services from us, you may be asked to rate them. You can also submit a review on your own initiative.

Legal reasons — exercise of rights and legal claims and control by authorities: We may also process your personal data because we need it to exercise our rights and legal claims (e.g. in the case of proof of delivery of goods ordered). We may also process your personal data because we need it for inspections by authorities and for other, similarly mandatory reasons.

Security reasons:

To detect and protect us and other third parties from negligence, fraud, theft and other illegal activities and to verify compliance with our and your internal policies.

To carry out appropriate fraud checks, whereby the personal data you provide may be transferred to an information file which may store this data.

To confirm addresses you provide on the website, which may be transferred to an address-verification service provider who may store them in their records.

4.1. Legal basis for the processing of personal data

4.1.1. Fulfilment and conclusion of the contract (Art. 6(1)(b) GDPR)

We need a large part of your personal data in order to be able to conclude a purchase or other contract with you for the goods or services you wish to purchase from us. Once the contract has been concluded, we process your personal data in order to properly deliver the purchased goods to you or to properly provide the purchased services. On the basis of this legal basis, we therefore primarily process invoice and delivery data.

4.1.2. Legitimate interests (Art. 6(1)(f) GDPR)

We also use your personal data to offer you relevant content, i.e. content that is of interest to you. On the basis of legitimate interests, we process in particular personal data that we process automatically and cookies for this purpose. For the same legal reason, we may send you as a customer e-mail and SMS messages.

Where we rely on legitimate interests, we have carried out a balancing test and you have the right to object to such processing at any time (see §9).

4.1.3. Consent to use the personal data (Art. 6(1)(a) GDPR)

By providing us with your personal data, you consent to the collection, use and disclosure of this data for the purposes and in the manner described in this Privacy Policy.

We process your personal data on the basis of your consent in order to send you commercial communications (e-mail marketing).

If you have given us your consent to process your personal data, you can withdraw this at any time, e.g. via our contact form or by e-mailing contact@kink-cartel.com. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

4.1.4. Compliance with a legal obligation (Art. 6(1)(c) GDPR)

We process certain personal data because we are required to do so by law — in particular Dutch tax, accounting and consumer-protection legislation (see also §7 on retention periods).

5. Transfer of personal data to third parties

In these cases, we transfer your personal data to third parties (i.e. we act as the controller in relation to this personal data):

Delivery of goods: the shipping provider you have chosen can only deliver the goods you have ordered if we tell them, among other things, where and to whom the goods should be delivered. We will pass this data on to the shipping provider as you have specified in the order. The data transferred includes, in particular, your first and last name, your delivery address and a phone number at which the shipping provider can reach you. The shipping provider is authorised to process the personal data provided by us only for the purpose of delivering the goods and to delete it immediately afterwards.

Delivery of goods stocked by a contractual partner: If you order goods from us that are in the warehouse of our contractual partner, we must transfer your personal data to this contractual partner in order to process the order. The data transferred includes, in particular, your name, your delivery address and the phone number at which the delivery person can reach you. The contractual partner must then pass on the personal data to the shipping provider who delivers the goods, as the shipping provider would otherwise not be able to deliver the goods to you. Both the contractual partner who stocks the goods for us and the shipping provider are obliged to use the personal data that we transfer to them only for the purpose of storing/delivering the goods and to delete it immediately afterwards.

Credit cards: Our company does not have the details of the credit cards you use to pay with us (unless they are saved, see next paragraph). Only the secure payment gateway and the bank concerned have your credit-card details. If you have saved your credit card to speed up further purchases in our online shop, we only have incomplete information about your payment card (the first and last digits of the payment card linked to your user account). If you would also like to delete this data, go to the settings of your user profile and simply delete the credit-card data there.

Commercial communication: In the case of sending commercial communication (e.g. by e-mail or SMS) or contacting you by phone, we may engage a third party to send the communications or make the phone calls. This company is obliged to maintain confidentiality and is not authorised to use your personal data for other purposes.

Exercise of rights and legal claims, state authorities: In order to exercise our rights and legal claims, e.g. if you fail to meet your obligations to Best-Poppers, fail to pay for goods received or otherwise enrich yourself at Best-Poppers’ expense, etc., we may also disclose your personal data to (i) debt-collection agencies that assist us in the collection of debts, (ii) companies that express an interest in purchasing a Best-Poppers claim against you, (iii) a company that will purchase such a claim (in the event of an assignment of the claim), (iv) a lawyer or (v) an administrative authority. If we are required by law or regulation to disclose your personal data to them, we must do so.

Where personal data is transferred outside the European Economic Area (EEA), we do so on the basis of an adequacy decision of the European Commission or under the European Commission’s Standard Contractual Clauses (Implementing Decision (EU) 2021/914), supplemented where necessary by additional technical and organisational safeguards.

6. Newsletter

If you have subscribed to our newsletter, we reserve the right to use selected data via an external newsletter service provider to send the newsletter.

By subscribing to the newsletter, you consent to us analysing the use of the newsletter and our website in order to provide you with personalised topics. The analysis will only take place if you have explicitly consented to this or until you withdraw your consent.

If you no longer wish to receive newsletter emails from us, click on “Unsubscribe newsletter” in the last email (newsletter).

Please note: If you wish to be removed from our newsletter e-mail marketing list, you will continue to receive e-mail confirmations from us about orders that you place on our website.

7. How long do we process your personal data?

In principle, all data is deleted when the purpose for which it was stored no longer applies. There is a legal or contractual retention period for certain data.

Primarily, we process your data for the duration of the contractual relationship between us.

In the case of processing for which consent has been given, your personal data will be processed until this consent is withdrawn.

If you subscribe to commercial communications, we will process your personal data until you have opted out of receiving further communications.

Please also note that we must process the personal data necessary for the proper provision of services or for the fulfilment of all our obligations, regardless of whether these obligations arise from a contract between us or from generally binding legal provisions, for the period specified in or in accordance with the relevant legal provisions (e.g. for tax and accounting documents, this period is at least 7 years, in accordance with article 52 of the Dutch General Tax Act / Algemene wet inzake rijksbelastingen), regardless of the consent you have given.

8. How do we protect your personal data?

Your personal data is safe with us. We have taken appropriate technical and organisational measures (Art. 32 GDPR) to prevent unauthorised access to and misuse of your personal data.

The protection of your personal data is extremely important to us at Best-Poppers. For this reason, we not only regularly review its security, but also continuously improve its protection. All communication between your device and our web servers is encrypted.

When you register in the “Customer account” area or place an order, your personal data is passed on to us. To prevent this data from falling into unauthorised hands, we encrypt it using SSL/TLS (Secure Socket Layer / Transport Layer Security). This is currently the most common and secure way of transferring data on the internet. We use it as standard when sensitive data is transmitted. In addition, all customer information is stored on secure servers that are inaccessible to unauthorised persons and protected from external access by a firewall.

In addition, we use a number of other security measures to protect the personal data of our customers. In connection with these security measures, you will occasionally be asked to provide proof of identity before we can access your personal data. An example of this is access to a customer account, which can only be accessed by entering a password. In addition, your data will only be processed by third parties within the scope of the data processing entrusted to us and we regularly check compliance with the technical and organisational measures to protect your data in compliance with the statutory provisions.

In the event of a personal-data breach that is likely to result in a risk to your rights and freedoms, we will notify the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) within 72 hours and, where the breach is likely to result in a high risk, we will also inform you directly (Art. 33–34 GDPR).

9. What rights do you have in relation to the protection of your personal data

In relation to your personal data, you have the following rights under the GDPR and the UAVG:

Right of access (Art. 15 GDPR) — the right to obtain confirmation as to whether or not personal data concerning you are being processed and, if so, to access that data.

Right to rectification (Art. 16 GDPR) — the right to have inaccurate personal data corrected and incomplete personal data completed.

Right to erasure / “right to be forgotten” (Art. 17 GDPR) — the right to have your personal data erased under the conditions set out in §9.2.

Right to restriction of processing (Art. 18 GDPR) — the right to obtain restriction of processing in defined cases.

Right to data portability (Art. 20 GDPR) — the right to receive your personal data in a structured, commonly used and machine-readable format and to transmit it to another controller.

Right to object (Art. 21 GDPR) — the right to object at any time, on grounds relating to your particular situation, to processing based on legitimate interests; and an absolute right to object to processing for direct-marketing purposes.

Right to withdraw consent (Art. 7(3) GDPR) — where processing is based on your consent, the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

Right to be informed of a personal-data breach that is likely to result in a high risk to your rights and freedoms (Art. 34 GDPR).

Right not to be subject to a decision based solely on automated processing which produces legal effects concerning you or similarly significantly affects you (Art. 22 GDPR).

We will respond to your request within one month of receipt; this period may be extended by a further two months for complex or numerous requests, in which case we will inform you of the extension within the initial month (Art. 12(3) GDPR).

9.1. Access, change, correction and completion

You have control over your personal data primarily via your customer account. Here you can change basic information about yourself and change your settings regarding the receiving of commercial communications (or unsubscribe from commercial communications), etc.

Alternatively, you can also contact us via our contact form or by e-mail at contact@kink-cartel.com. However, in order to speed up the correction of your personal data and to make it more convenient for you, we recommend that you edit your personal data in your user profile.

9.2. Erasure

You can also request that we erase your data (however, erasure does not apply to data on documents that we are legally obliged to keep, e.g. invoices or credit notes). If we need your personal data in order to establish, exercise or defend our legal claims, your request may be refused (e.g. in the case of an ongoing complaint).

Please note that if you make a payment without saving your card, your credit-card data will not be stored by us, but by the provider of the payment gateway (third-party provider). Therefore, this data cannot be deleted by us, but you must contact the payment gateway through which you made the payment.

In addition to the cases mentioned above, you have the right to erasure in the following cases:

The personal data are no longer necessary for the purposes for which they were processed.

You have withdrawn your consent on the basis of which the data was processed and there is no further legal basis for processing the data.

You have objected to the processing of the personal data and consider that, after verification of the objection, your interest in the specific situation overrides our interest in processing the personal data.

The personal data is being processed unlawfully.

The obligation to erasure is provided for in a specific legal provision.

It concerns personal data of minors (under 18 years of age — see §10).

9.3. Right to lodge a complaint with the supervisory authority

You have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens), Hoge Nieuwstraat 8, 2514 EL Den Haag, the Netherlands — www.autoriteitpersoonsgegevens.nl — if you consider that our processing of your personal data infringes the GDPR or the UAVG. Before lodging a complaint, we kindly invite you to contact us first so that we can address your concern directly.

10. Data protection for children and juveniles on our website

Our website is not aimed at children and juveniles under the age of 18, and no one under the age of 18 may enter personal data or create an account on our website. Although the UAVG sets the digital-consent age at 16, the products offered through Best-Poppers are intended for adults only; we therefore apply an 18+ threshold for both account creation and data processing. If we become aware that we have inadvertently collected personal data from a person under 18, we will delete that data without undue delay.

11. Links

To make our website more convenient and enjoyable, it may contain links to other websites operated by third parties (“External Websites”). We do not control and are not responsible for the privacy practices or the content of these External Websites. We strongly advise you to review the privacy policy of each External Website to ensure that you are comfortable with the privacy policies and practices of those websites.

12. Revision of the Privacy Policy

As we continue to offer new and different types of content and services to our customers, we may revise this Privacy Policy to reflect changes in the way we collect, use or share information. We will notify you of changes to our Privacy Policy by placing a notice on our website. If there are material changes to our data collection, use and transfer practices, they will only apply to future data collection.

13. Security notice

We restrict the number of employees who have access to the database with personal data. Our employees are also made aware of the importance of keeping this data confidential.

Best-Poppers’ online shop is designed to accept orders via web browsers that allow communication via Secure Socket Layer / Transport Layer Security (SSL/TLS) technology. Although we use the above security measures on this website, you should be aware that 100 per cent security cannot always be guaranteed. You can achieve maximum security by using a reputable provider of VPN software and/or a secure browser.

14. Language versions

Only the version in English is considered to be the legally binding version. The other language versions are for information purposes only.

15. Contact

Questions about this Privacy Policy or about the personal data we hold can be sent to:

Dutch Trading Company B.V.
Beitel 110, 6422 PB Heerlen, the Netherlands
KvK 82516480

E-mail: contact@kink-cartel.com