Privacy Policy

Stichting Kunst- en Natuurkring Wemeldinge
 

Last updated: April 2026

1. Identity of the Data Controller

This Privacy Policy applies to the processing of personal data by:

Stichting Kunst- en Natuurkring Wemeldinge
Dorpsstraat 87A
4424 CW Wemeldinge
The Netherlands
KvK: 22052170
Email: info@kunstennatuurroute.nl

Hereinafter referred to as “the Controller”.

2. Scope of This Policy

This Privacy Policy governs the use of personal data in connection with the K&N Route app (the “App”), which provides information regarding the Kunst- en Natuurroute, including locations, artists, venues, and sponsors.

3. Categories of Personal Data

The Controller does not actively collect directly identifiable personal data such as names, email addresses, or telephone numbers. However, the following categories of data may be processed:

3.1 Technical and Usage Data

• IP address
• Device identifiers
• Operating system and device type
• App interaction data and usage statistics

3.2 Location Data

• Precise or approximate location data (GPS), subject to user consent

3.3 User-Generated Content

• Any data voluntarily submitted by users (e.g. messages, comments, or media uploads)

3.4 Push Notification Data

• Device tokens and interaction data related to push notifications

4. Purposes of Processing

Personal data is processed for the following purposes:

• Provision and maintenance of the App
• Display of relevant location-based content
• Performance monitoring and analytics
• Improvement of functionality and user experience
• Prevention of fraud, misuse, and security incidents

5. Legal Bases for Processing (Article 6 GDPR)

Processing is carried out on the following legal grounds:

• Consent (Article 6(1)(a) GDPR)
  For location services, push notifications, and where required for tracking technologies
• Legitimate Interest (Article 6(1)(f) GDPR)
  For analytics, security, and technical improvement of the App

Where processing is based on consent, users may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Third-Party Processors

The Controller engages third-party service providers that may process personal data:

• GoodBarber – hosting and app infrastructure
• Google Analytics – analytics services
• Social media platforms (e.g. Facebook, Instagram integrations)

These processors may act as data processors or independent controllers depending on their role.

Where personal data is transferred outside the European Economic Area (EEA), appropriate safeguards are implemented, such as Standard Contractual Clauses (SCCs).

7. Data Retention

Personal data shall not be retained longer than necessary for the purposes for which it was collected, unless a longer retention period is required or permitted by law.

8. Data Security

The Controller implements appropriate technical and organisational measures in accordance with Article 32 GDPR, including but not limited to:

• Encryption via HTTPS/SSL
• Access control and authentication measures
• Platform-level safeguards provided by GoodBarber

9. Rights of Data Subjects

Under the GDPR, users have the following rights:

• Right of access (Article 15 GDPR)
• Right to rectification (Article 16 GDPR)
• Right to erasure (Article 17 GDPR)
• Right to restriction of processing (Article 18 GDPR)
• Right to object (Article 21 GDPR)
• Right to withdraw consent (Article 7 GDPR)

Requests may be submitted to:
info@kunstennatuurroute.nl

Data subjects also have the right to lodge a complaint with the Dutch supervisory authority:
Autoriteit Persoonsgegevens.

10. Cookies and Tracking Technologies

The App and associated services may use tracking technologies (including SDKs and similar technologies), particularly through Google Analytics.

Where legally required, prior consent will be obtained before such technologies are activated.

11. International Data Transfers

Where personal data is transferred to countries outside the EEA, the Controller ensures compliance with Chapter V GDPR through:

• Adequacy decisions by the European Commission; or
• Standard Contractual Clauses (SCCs); or
• Other appropriate safeguards

12. Children

The App is not directed at individuals under the age of 16. The Controller does not knowingly collect personal data from children.

13. Apple App Store Requirements

In accordance with the policies of Apple and the Apple App Store:

• The Controller confirms that any data collection is limited to what is necessary for the functionality of the App
• Users will be asked for permission before accessing sensitive data (such as location services)
• Data collected will not be used for tracking across third-party apps without explicit user consent
• The Controller does not sell personal data to third parties
• The App complies with Apple’s App Tracking Transparency (ATT) framework where applicable

14. Google Play Requirements

In accordance with the policies of Google and Google Play:

• The App adheres to Google Play’s User Data policies
• Data collection and processing are transparent and limited to disclosed purposes
• Personal and sensitive data (such as location) is only accessed when necessary and with user consent
• Users are provided with clear information regarding data usage within this Privacy Policy
• The Controller ensures secure handling of user data in compliance with Google Play requirements

15. Liability and Disclaimer

While the Controller exercises due care in the processing of personal data, it shall not be liable for damages resulting from:

• Unlawful third-party access beyond its reasonable control
• User misuse of the App
• Failures attributable to third-party service providers, except where required by law

Nothing in this clause limits statutory rights under applicable data protection laws.

16. Amendments

The Controller reserves the right to amend this Privacy Policy at any time. Updated versions will be made available within the App and/or via associated digital channels.

17. Contact

For any questions regarding this Privacy Policy or data processing activities:

info@kunstennatuurroute.nl