1 What is this privacy statement for?

This is the privacy statement by Within Reach. This privacy statement describes the policy used by Within Reach regarding the privacy of information in our possession.

Within Reach conceives, develops and supplies innovative communication resources for the commercial market. As a result of this kind of service provision, Within Reach possesses personal information. Do you use Within Reach services? Then this privacy statement is intended for you. In this privacy statement, you can read about the information Within Reach collects, what Within Reach uses this information for, how Within Reach protects privacy and personal information, how long the information is stored and how you can view and/or correct your personal information.

Within Reach does not share personal information with third parties, unless this is (1) legally required, (2) necessary to supply a service or (3) specifically requested by the customer that has provided the personal information.

1.1 Legal requirement

Within Reach is legally obliged to store certain information from customers for a specific time period for the purposes of legal investigations. Within Reach must cooperate with requests for personal information from the judicial authorities or other authorised government institutions, as well as with requests for information we process and store as part of our normal business operations. For example information from your telephone records or about your data usage. When the storage period has elapsed, stored information is destroyed or made anonymous. Another example of a legal requirement is the calling of the emergency number 112. When you do this, your telephone number and the location of your telephone are always transmitted to the 112 control room, even when you have blocked the display of your telephone number. This is a legal requirement.

1.2 Necessary for our service provision

Within Reach does not always supply its services itself, but uses, for example, Wholesalers to supply its services. In such a case, it is necessary that we share the information that is required for the provision of certain services with Wholesalers. For example, when Within Reach shares information with its Wholesaler, the Wholesaler must comply with the conditions specified by Within Reach and the same privacy requirements we adhere to also apply to that company.

1.3 At the request of the customer

It is also possible that you as the customer purchase certain services for which personal information is required. For example an App that uses GPS data. In such cases you can use your telephone or the App to specify whether or not you wish to share this information, and then give this permission to the App provider. Within Reach is then not the party that processes your personal information.

1.4 Who can I ask questions about my information?

Naturally, we would be happy to answer any questions you have regarding your personal information. You can ask your questions by sending an email to info@withinreach.nl. We will then provide a substantive answer to your question and contact you if necessary.

1.5 Where can I find the latest version of the privacy statement?

Rapid technological developments, legislation or changes to business processes mean that Within Reach has to alter this Privacy Statement fairly regularly. The date at the top of this Privacy Statement shows when it was last updated. Within Reach can change this privacy statement unilaterally. We therefore recommend that you regularly check this privacy statement for changes.

1.6 Who is responsible for your information?

Within Reach in Almere, the Netherlands, is responsible for the collection and use of your information.

2 What information do we collect?

2.1 Personal and User Information

When you purchase a service from Within Reach , or when you contact us, Within Reach processes your Personal Information. Personal information is information that can be traced to an individual. The word ‘process’ has a very broad definition. It refers to all actions relating to personal information, including the collection, storage, changing, viewing and using, provision, grouping, shielding, erasing and destruction of information.

The information requested by Within Reach when you purchase a service is your: name, address, telephone number, email address and bank account number.

2.2 Traffic data

When using our services, traffic data are processed. These are data that are required to set up communication. Traffic data say something about the communication, such as the sender and destination numbers that were called, the date, time and duration of the call, and the fees that were charged for this. This information does not concern the content of the communication. In the case of a data session, we also register the amount of data, and when roaming, we register the network that was used.

Within Reach also processes internet data. When an email is sent, we process the sender and destination numbers, the IP addresses of those involved, the size of the email message, and the date and time of sending. Once again, we do not store the content of the message.

Traffic data are generated and processed automatically.

2.3 Location data

When you set up a call or data session, Within Reach processes information that can make a very rough determination of your location at that moment. We use this information to determine whether the call or data session is happening in the Netherlands or not.

Within Reach uses KPN’s mobile network. KPN is able to accurately determine your location by looking at which transmission tower was used for your call or data session. Within Reach does not have access to this information.

2.4 Website

WithinReach.com and our customer portal Operator use cookies to optimise the functionality of certain pages on the websites. Cookies are small text files that are placed on the visitor’s computer by a page on the website. In these cookies certain information is stored, such as certain preferences the visitor has. This allows Within Reach to serve the visitor even better when they next visit the site. The visitor can decide how cookies should be handled. He or she can set up the browser so that it permits, partly permits or forbids the use of cookies. In case of partial permission, it is possible to choose which websites may use cookies. They are then blocked for all other websites.

Within Reach.com and our customer portal Operator also use Google Analytics, Hotjar and Social Media cookies (such as Facebook and LinkedIn) to analyse how users use the site. For Google Analytics, the information generated by cookies about your visit to the website (including your IP address) is transferred to and stored on servers in the United States by Google. Google uses this information to monitor the way you use the website, compose reports on the website activity for website operators, and offer other services with regard to website activity and internet use.

2.5 Other

When you visit our head office, you will be registered as a guest. We use this registration for safety purposes, so that we can quickly evacuate the premises in case of a disaster, without leaving anyone behind.

We also use camera recordings as a safety measure in our offices. We do this to protect our guests, personnel and the building. You will be clearly informed about the presence of cameras when on our premises.

3 What do we use this information for?

3.1 Providing services and invoicing

Within Reach uses the aforementioned information primarily for the provision and improvement of services purchased by you. For example the delivery of an order to the specified address, or the setting up of a telephone call.

Based on these services and the use thereof, Within Reach drafts an invoice. This invoice shows the fees charged for each service, specified by type of use. You can see fees incurred abroad, call costs, data usage and more. The invoice does not show an overview of all calls or data sessions. A detailed overview, for monitoring or administrative purposes, can be found in Operator.

3.2 Traffic management, network planning and quality of services

For the sake of the maintenance and the improvement of our platform, we analyse information about the use of our network. We do this so that we can, among other things, redirect traffic in case of potential overloading, but especially so that we can prevent this by planning and implementing targeted improvements. In addition, we can use the information to see when malfunctions occur on the platform.

3.3 Security

Based on analyses of call and internet behaviour, Within Reach can proceed to restrict certain destinations when excessive usage is detected. Higher usage than the average call behaviour may indicate fraud. A blockade can limit fraud and misuse, and prevent you from receiving a huge bill for fees that you have not incurred yourself. Within Reach also uses advanced techniques (such as firewalls, spam filters and virus scanners) to protect against security breaches, viruses, spam and malware.

3.4 Caller ID

Within Reach always displays your telephone number to the called number. This means that your number will be visible to the call recipient on the display of their telephone. This can be turned off by calling anonymously. However, we are legally obliged to always reveal your number when you call 112.

3.5 Legal requirements

In some cases Within Reach is legally required to give your information to third parties. For example, the provision of information in the context of a criminal investigation, to authorities, and – at your request – to other providers for the purposes of shielding the called number in the records.

3.6 Training and education of personnel

When you contact our service desk, it is possible that your call will be recorded for training purposes. You will be informed of this prior to the call.

3.7 Malicious or annoying contact

If someone is harassing you by telephone or via internet, then you can report this to us and submit a written request to provide information on the person responsible for this malicious or annoying behaviour. If you harass someone by telephone, then this person can report this to us and make the same request. If we receive such a request, then we follow the procedure described above. If that does not help, then Within Reach will, as a last resort, provide the complainant with your telephone number, name, address and place of residence.

3.8 Number retention and transfer service (COIN)

Within Reach offers you the option of keeping your number when you transfer to a different provider. To do this, we exchange information with your current or next provider. In case of a landline, this information is your current telephone number, your name and your address. For a mobile number, your SIM card number, telephone number and name are shared. The exchange of this information proceeds via the organisation COIN. COIN is a collaboration of providers of electronic communication services and networks in the Netherlands.

4 Viewing and correcting your personal information

4.1 How do you view your personal information?

If you wish to view your personal information, then you can submit a request to us to provide the information. This means that you can ask which personal information about you is registered and for what purposes it is being used. You can submit this request by email. Our email address is info@withinreach.nl. If you are a Within Reach Wholesaler or you use our services as an end user via our Wholesalers, then you can view the personal information via Operator Online as both Wholesaler and end user. Should you have any questions about this as end user, then you can pose them to your supplier, our Wholesaler.

4.2 How do you correct your personal information?

The Within Reach Wholesaler can correct the personal information of its customers, the end users, in Operator Online. The Wholesaler cannot correct its own personal information in Operator. To do this, they must submit an Operator ticket to Within Reach, after which an answer will be given within 2 weeks. If you are a Wholesaler or end user, you can submit a request for correction by email. Our email address is info@withinreach.nl

4.3 Right of opposition

You can oppose the processing of personal information by Within Reach if your personal information is used for purposes that are not necessary for the implementation of an agreement or for compliance with legal obligations. You can submit your objection by email. Our email address is info@withinreach.nl