Version 1.1, valid from 9th May 2018.
1. What is this policy about?
This policy applies to the personal data that we process about you as a natural person. This policy does not apply if we process anonymous or business data.
2. Who processes your personal data?
We are [INSERT COMPANY NAME ], with our registered office at [INSERT ADDRESS], and registered in the register of legal entities under the number [INSERT COMPANY NUMBER], phone number [INSERT PHONE NUMBER], e-mail [INSERT E-MAIL].
We are the ‘controller’ for the processing of your personal data.
3. What do we expect from you?
We expect that you only communicate personal data about yourself to us. If you also communicate personal data about other people to us, then you must ensure that you are entitled to do so.
We also expect that the personal data that you communicate to us is correct and that, if specific data changes, you promptly inform us of this change.
4. Why do we process your personal data?
The purposes for which we process your personal data depend on how you enter in contact with us.
You browse on our website
You contact us (e.g. by filling in a form on our website, by sending us an e-mail)
- We process your personal data in order to answer and manage your request (e.g. request for information, subscription to our newsletter, complaint). This processing is based on your consent.
You create a personal account on our website or purchase Puratos products/services
- We process your personal data for client management, based upon the performance of the contract to which you are a party. Without your personal data, we cannot perform this contract.
- We may also process your personal data for the direct marketing of our products/services, based upon our legitimate interests. We believe that it is important to keep you, as our client, informed about our products/services. This processing may involve compiling a profile. This profiling has no effect on you, except to the extent that this processing activity might lead to enhancement of customer experience and personalized offers, which is an advantage for you. The provision of your personal data for this purpose is not a requirement and you can object to this processing (see article 8 below).
In any case
- We may process your personal data for the management of compliance and disputes (eg prevention of unlawful activities, prevention of abuse of the Puratos group’s resources, defense of legal claims).
- We may anonymize your personal data and process aggregate data for research and development, based on our legitimate interests (eg statistics about sales, market analysis, development of products/services). Within the Puratos group, we believe that research and development can lead to enhancement of customer experience, product improvement and innovation, which will help the persons concerned by our products/services (such as customers, distributors, suppliers and end consumers). The provision of your personal data for this purpose is not a requirement and you can object to this processing (see article 8 below). Research and development may involve compiling a profile. All identifying elements, such as your name, your address, etc., are eliminated. This profiling has no effect on you, except to the extent that this processing activity might lead to enhancement of customer experience, product improvement and innovation, which is an advantage for you.
- Puratos NV may also process your personal data as a controller, at a group level, for global management and global research, based on its legitimate interests, those of the other group entities and their stakeholders. We believe that this is necessary for the efficiency, consistency and continuity of the Puratos group operations and for the enhancement of customer experience, product improvement and innovation, which will help the persons concerned by our products/services and eventually contribute to safeguarding and promoting the economic, commercial, social and financial interests of the Puratos group. The provision of your personal data for this purpose is not a requirement and you can object to this processing (see article 8 below).
- We may process your personal data for the direct marketing of our products/services and of the products/services of other companies of the Puratos group, based upon your consent, to the extent that you give such consent.
5. With whom do we share your personal data?
We can transfer your personal data to companies that are a part of the Puratos group, to companies that process personal data in our name and on our behalf (known as ‘processors’), to scientific institutions in the context of research, to third parties when there is a legal obligation to do so, to our commercial partners, and to the police or judicial authorities at their request if they are entitled to request the personal data.
6. Is your personal data transferred outside the European Union?
We can transfer your personal data to countries outside the European Union, including the United States. Each transfer will be based on appropriate safeguards (adequacy decision and/or standard data protection clauses of the European Commission). If you would like to know how to obtain a copy of the appropriate safeguards, you can contact us at the address stated above (article 2) or via [INSERT E-MAIL].
7. For how long is your personal data retained?
Your personal data is retained for as long as you are in contact with us (e.g. you ask information, purchase our products/services, subscribe to our newsletter) and for up to maximum 10 years after the end of this relationship
8. What are your rights?
You can contact us to exercise the following rights, in accordance with the conditions laid down in the applicable legislation:
- Withdrawing your consent for the processing of personal data, to the extent that the processing of your personal data was initially based upon your consent.
- Seeking access to, or any correction, deletion or restriction of your personal data.
- Objecting to any processing for direct marketing and/or any processing based on the legitimate interests as processing ground (such as research, development and improvement of our products/services).
- Seeking the portability of your personal data, which you have communicated to us.
You can exercise some of these rights via the settings in your personal account with us (if you have such a personal account).
You can exercise all of these rights by contacting us at the address stated above (article 2) or via [INSERT E-MAIL].
You also have the right to file a complaint with a data protection authority.