We are 5miles. We believe that learning is personal and that everyone should be able to improve their skills in a safe manner. We respect your privacy and private life, but sometimes we need your Personal Data. We consider Personal Data to be any information relating to an identified or identifiable person, in conformity with the General Data Protection Regulation ( GDPR ). In this Privacy Policy, we explain which Personal Data we use and why we use them. Furthermore, we describe how we save, protect and process these Personal Data.

This Privacy Policy applies to our website https://www.5miles.nl/, blog https://blog.5miles.nl and landing pages https://landings.5miles.nl (the Websites ), our online learning tool and the services we provide (the Services ). We process your Personal Data in accordance with the GDPR and all other relevant legislation and regulations in the field of protection of Personal Data, like the E-Privacy Directive / Dutch Telecommunications Act (Telecommunicatiewet) regarding the use of cookies. Hereinafter, we call the aforementioned legislation the Relevant Legislation.

Are you under the age of 16

If you are younger than 16 years old, you need permission from your parents or legal guardian to use our Websites, online learning tool and Services.

Who is the controller of your Personal Data

5miles is the controller of your Personal Data within the meaning of the Relevant Legislation. At the end of this Privacy Policy, you can find our contact details.

In case you sign up to our Services through your employer, we are the shared controller together with your employer for the Personal Data that your employer provides us with. This Personal Data usually entails name, e-mail address and company name. Should you have any remarks about the Personal Data that your employer shares with us, you should contact your employer.

We need some of your Personal Data in order for you to use our Websites, online learning tool and Services. We are allowed to process your Personal Data, because we comply with the Relevant Legislation, since we only use your Personal Data in accordance with the provided legal bases.

We lawfully process your Personal Data because:

  • Processing Personal Data is necessary in order to perform our contract;
  • We have to comply with a legal obligation to process your Personal Data;
  • We have a legitimate interest to process your Personal Data which outweighs your legitimate interest(s);
  • You have given us consent.

We make sure that the processing of your Personal Data is adequate, relevant and limited to what is necessary in relation to the purpose for which the Data is processed.

We shall only use your Personal Data for the following purposes or for compatible purposes. By doing so, we will not use your Personal Data in an unexpected manner.

Contact Data

(Personal) Data

  • First and/or last name;
  • Email address;
  • Company name;
  • Company team.

We use these data:

  • To get in contact with you;
  • To send you your daily challenge invitation email;
  • To send you personalized messages to complete your learning journey;
  • To inform you on new learning tracks in the 5miles Library.

We process these data based on:

  • A necessity to perform the contract;
  • A legitimate interest that outweighs your legitimate interest, namely research and statistical purposes;
  • Your consent.

Payment data:

(Personal) Data

  • Payment data of the paying party (e.g. IBAN number, name of account holder);
  • Invoices;
  • An overview of purchases.

We use these data:

  • To update our financial administration;
  • To send invoices.

We process these data based on:

  • A necessity to perform the contract;
  • A legal obligation to process your personal data;
  • A legitimate interest that outweighs your legitimate interest, namely managing your use of our Services;
  • Your consent.

Data of partners and suppliers:

(Personal) Data

  • Company name;
  • First and last name;
  • Address;
  • Phone number;
  • Chamber of Commerce number;
  • VAT number;
  • Payment data of the partner or supplier (e.g. IBAN number, name of account holder).

We use these data:

  • To correspond with you;
  • To purchase products or services from you;
  • To update our financial administration;

We process these data based on:

  • A necessity to perform the contract;
  • A legal obligation to process your Personal Data;
  • A legitimate interest that outweighs your legitimate interest, namely maintaining internal processes such as financial controlling and auditing;
  • Your consent.

Data for marketing and promotional reasons

(Personal) Data

  • First and/or last name;
  • Email address;
  • Interests;
  • The purchases of services;

We use these data:

  • For featured updates and training material updates;
  • To send you challenges and reminders.

We process these data based on:

  • A necessity to perform the contract;
  • a legitimate interest that outweighs your legitimate interest, namely direct marketing, research and statistical purposes;
  • Your consent.

Content data related to the service(s)

(Personal) Data

  • Correspondence or chat messages with you;
  • Your results and reviews of our challenges;
  • Technical information regarding your visit(s);
  • Statistics regarding browsing behaviour;
  • Location data;
  • IP address.

We use these data:

  • To provide you with an optimal service of 5miles and its learning materials;
  • To improve the content and material available to you;
  • To keep track of competed challenges;
  • To enable security features;
  • To update your employer on your participation;
  • To update your employer on your aggregated team performance.

We process these data based on:

  • A necessity to perform the contract;
  • A legitimate interest that outweighs your legitimate interest, namely to improve the user experience of our services, research and statistical purposes;
  • Your consent.

How do we receive your Personal Data

Personal Data we receive from you

We receive Personal Data directly from you when you create an account, receive the daily challenges, correspond with us via email or chat, login to the 5miles learning tool, solve the daily challenges, review past challenges and change your settings.

Personal Data of third parties that you provide to us

It is possible that you provide us with Personal Data of third parties. We would like to remind you that it is your own responsibility to verify if those parties agree with the provision of their Personal Data.

Personal Data from external organizations

Besides the information we receive from your employer, it is possible that we receive (additional) Personal Data from external organizations (as far as this is permitted by law),like your employer in the case you signup via your employer.

Are you obliged to share your Personal Data with us

In some cases, the processing of your Personal Data is necessary. This is relevant, for example, when we have to process your Personal Data in order to oblige to a contract with you or to provide a service for you. Without your Personal Data, we cannot provide our Service to you.

Automated individual decision-making

We do not use automated individual decision-making.

How do we protect your Personal Data

We do our utmost to protect your Personal Data from being lost, destroyed, abused, altered or spread by unauthorized parties. For this reason, the persons who have nothing to do with your Personal Data, do not have access to them. We ensure this by taking the following measures:

  • Encryption (encoding) digital files containing Personal Data;
  • Secure network connections with Secure Socket Layer (SSL);
  • The access to the Personal Data is strictly limited to the employees on a 'need to know' basis.

How long do we store your Personal Data

We shall not store your Personal Data longer than the period in which we need them for the aforementioned purposes. We delete the Personal Data after we no longer need them for the purpose we process them for.

With whom do we share your Personal Data

Processors

We may share your Personal Data with data 'processors' within the meaning of the Relevant Legislation. We conclude a data processing agreement with these parties, which entails that they shall process your data carefully and that they shall only receive the Personal Data they need to provide their service. These parties shall only use your Personal Data in accordance with our instructions and not for their own purposes. We only share some of your Personal Data with the following companies, just to perform a specific task:

  • Amazon Web Services to host our servers and databases;
  • Hotjar to provide tracking for supporting purposes;
  • Intercom to manage support and communications with you;
  • Stripe to handle your credit card payments and charges;
  • Typeform to create feedback surveys.

Third parties

We do not share your Personal Data with other parties, who are not processors.

Legal obligation

If we have a legal obligation to share your Personal Data, we will do so. For example, if a public authority legally requires us to share your Personal Data.

Transfer

We shall only process your Personal Data within the European Union. We shall only process your data outside the European Union if that country offers an appropriate level of protection for your Personal Data.

We shall never transfer your Personal Data to other countries or to other parties than those mentioned above.

Our Websites and online learning tool may contain links to other websites. We are not responsible for the content or the privacy protection on these websites. Therefore, we advise you to always read the Privacy Policy of those websites.

Cookies

A cookie is a small text file that can be sent via the server of a website to the browser. The browser saves this file to your computer. Your computer is tagged with a unique number, which enables our site to recognize that computer in the future.

We can use cookies to improve the user experience on our Websites and learning tool. Moreover, cookies ensure that they work faster, that you can visit them safely and that we can track and solve errors on them. We use session cookies to track sessions or login information and cookies for web analysis services (such as Google Analytics). This enables 5miles to provide you with a better user experience.

We can also use cookies for marketing purposes and to track visitors across our Websites and learning tool.

You can always delete or disable cookies via the browser settings. If you do so, no cookies will be stored when you visit our Websites and learning tool. But please note: they might not work as good without cookies.

Modifications to the Privacy Policy

We may modify this Privacy Policy. If we substantially modify the Privacy Policy, we shall place a notification on our Websites, together with the new Privacy Policy. We shall notify registered users in case of a substantial modification. If you are not a registered user, we advise you to consult the Websites and this policy regularly.

Your rights

You have the following rights:

  • You can request access to your Personal Data;
  • You can request us to correct, limit or delete your Personal Data. In the event of fraud, non-payment or other wrongful acts, we can store some of your Personal Data in a register or on a blacklist;
  • You can request a copy of your Personal Data. We can provide this copy to third parties at your request, so you do not have to do so yourself;
  • You can object to the processing of your Personal Data;
  • You can file a complaint at the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) if you are of the opinion that we wrongfully process your data;
  • You can always withdraw your permission to process your Personal Data. From the moment of your withdrawal, we cannot process your Personal Data anymore.

Contact

In the event that you wish to exercise these rights, or in the event of other questions or remarks regarding our Privacy Policy, you can contact us via the following contact details.

5miles B.V.

Office Address: Jollemanhof 17, 1019 GW, Amsterdam, The Netherlands

Chamber of Commerce number: 63716542

Email address: info@5miles.nl

Dates

Last updated: 26th October 2020

Effective date: 1st November 2020