Privacy Policy

IJsberg Holdings respects the privacy of the users of the app and visitors of the website Positive Drive. We ensure that the data you provide us with is treated with the upmost confidentiality.

Positive Drive is under the control of IJsberg Holdings B.V. (after this called IJsberg). Your privacy is very important to us. IJsberg will carefully handle your privacy data and follows the European laws regarding privacy. Our privacy measures fall under the current law regarding the protection of personal data and the in 2017 valid regulations regarding data protection.

Privacy by Design – Designed according to the right principles

IJsberg Consultants possesses the knowledge, experience and systems to comply with all laws and regulations regarding Privacy and Data security.

The collection and processing of data

IJsberg ensures the proper processing and storage of the data collected. In previous years, this processes has continually improved. Positive Drive uses, besides the necessary data, The GPS signal from the smartphone. All GPS-coordinates of the users is measured and stored anonymously (local and remote). The responsibility of the storage and processing is with Ijsberg. Our server receives raw GPS data from individual participants and stores these. Our contact partner Locatienet transforms this anonymous raw GPS data into a route and mode of travel before sending this to us. At IJsberg, this data is edited, enriched, linked and partially send back to the participant. The process is secured via http and a API-Key. With Locatienet and Microsoft Azure, an editor’s contract has been signed.

The services from IJsberg is in essence personal route registration.

  • We do not ask for personal data unless it is necessary
  • We do not share your personal data with anyone except to comply with the law, to further develop our services and to protect our rights
  • We treat your personal data with the highest level of privacy and security
  • Data will be stored in a personal profile
  • IJsberg only registers data that is necessary to allow Positive Drive to function properly
  • Registration of your data is only visible to a select authorised group of system managers
  • It is possible for participants to access their own personal data
  • Data will be stored a maximum of 6 months before being deleted from the IJsberg servers.

Personal Data:

Personal data is data with which you could be personally identified, like your name, living/working address and email address. IJsberg respects the privacy of the users of Positive Drive and the registration meets the requirements set by the law regarding the protection of personal data. In order to execute our campaign, to award prizes or to create a personal mobility profile, IJsberg will request your personal data. This data will be stored in IJsbergs database. This way IJsberg tracks what movements (Date, route, mode of transport, speed) where made in traffic. This data is needed to award (s)miles, bonuses and extra’s.

There are different ways to share your personal data with IJsberg. This information may contain information about yourself such as material and activity, routes, name, postal code and email address. IJsberg will also ask for your bank data or payment details if you choose to participate in one of our campaigns. If you choose to share this data with IJsberg, IJsberg can store this data, use it for internal research and other marketing purposes including sending you special programs you might be interested in.

What data do we collect?

  • Your name
  • Your address
  • Your postal code and city
  • Your email
  • Your phone number
  • Your date of birth
  • Your gender

You reserve the right to see this personal data and have it corrected at any time. You also have the ability to have it removed entirely. For this, please contact our helpdesk via 085-303 6484 or email to

What do we use your data for?

  • We use your data to make the app function and display the right information in the app
  • Your data is used to get in contact with you in the event you won a prize or upon purchase of an item in the web shop
  • It is possible that conversations with our helpdesk are recorded to improve our service
  • Your personal data will always be securely stored in our database
  • Outside of IJsberg, only the municipality of Breda can access our database. They reserve the right to contact users via email
  • All participants have the right to see their personal data and have this removed from our servers.

Your data will not be provided to third parties.

We will always inform you if we need your personal data and how this information will be used. We never give out your personal information to third parties unless you give us permission to do so, unless:

  • To third parties who handle the distribution of the prizes you won or saved up for.
  • When we are required by law. For example, in the case of a lawful procedure
  • Whenever it is necessary to protect the rights of the user, our website or our rights

We reserve the right to comply in any form of legal procedures regarding your use of our website or the information you have provided to us.

Safety and Quality

Accounts will be protected by a username and password and are thereby only accessible to the participant. IJsberg uses Standardised Secure Socket Layer (SSL) technology to encrypt sensitive information such as: name, address or credit card number. Besides that, we also secure our servers with advanced firewall technology. Personal data will be stored under pseudonyms so it is impossible to trace back to the user.

We protect the quality and integrity of your personal information. All processing done with your personal data, is reported to the authority personal data. You can rest assured that your data and anonymity is being ensured by the proper techniques and organisation measures:

  • Logical access control using passwords
  • Automatic logging of all actions regarding personal data
  • Physical measures for access control
  • Encryption of digital files and personal data
  • Organisational measures regarding access control
  • Random checks on the execution of the policies
  • Securing of network connections via Secure Socket Layer (SSL) technology
  • Securing of internal network
  • Quick correction of personal data
  • Cooperation with renowned security systems for online payment and transactions, this can be seen by the little lock on the bottom of your internet browser

On our website cookies are used. Cookies are small text files placed on our webpage. These cookies are used to improve the functioning of our website and to monitor website traffic. Using these cookies, we can see the number of visitors to our website during a certain period. We only utilise anonymized data, these cannot be traced back to the individual.

Cookie settings in your browser

You have the ability to change your cookie settings in your browser. This gives you the ability to allow or refuse certain cookies. Nearly all browsers have additional information regarding cookies in their respective “help” sections on how to disable them.

In the case you have set up your browser in such a way that cookies are not permitted, the website might not work to its full potential.


On our website there may be links to third party websites. We do not accept any responsibility for the use of your personal data by these third parties. We highly recommend you read they privacy statement before utilizing the webpage.

Alterations to the Privacy Policy

We reserve the right to alter our privacy policy at all times. We recommend you periodically read the statement to ensure no changes have been made to it.