PRIVACY POLICY

Reesink UK LTD

CUSTOMER PRIVACY POLICY

Version: March 2018

This Privacy Policy sets out (in full transparency and in accordance with applicable laws and regulations) the basis on which we use your personal data when you access our websites, purchase our products, interact with us or otherwise use our services (“Services”).

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

SCOPE
For purposes of this Privacy Policy, “Personal Data” means any information through which we can identify you as an individual, as further described below in “Personal Data we collect”.

This Privacy Policy applies to all Personal Data that we collect and use of the following persons:

i. Customers: When we are doing business with our (corporate) customers (business-to-business), the Personal Data we collect concerns the data that relates to our customers and their representatives / contact persons, such as a representative’s email address, professional phone number and work address. This type of Personal Data is collected through various channels, such as via our website, in a sales process, via telephone calls, via forms you submit to us, via email or via business events. This Privacy Policy does not apply to corporate company information if no personal data from individuals can be derived from such corporate information.

ii. Website visitors: When you visit our website (either as customer, it’s representative or in another capacity), the Personal Data we collect about you includes data collected through registrations, applications, purchases, in connection with your inquiries, subscription for receiving direct marketing, and data collected automatically when you browse our website.

WHO WE ARE
This website is operated and controlled by Reesink UK LTD | 1-3 Station Road, St Neots PE19 1QF, such depending on where you live and which of our Services you are using (hereinafter “Reesink UK LTD”, “we” or “us”).

If you have used our Services (such as purchasing our products) outside of this website, the Royal Reesink company responsible for using your Personal Data will depend on the Royal Reesink entity that you entered into a contract with. An overview of the applicable responsible Royal Reesink companies be found here.

PERSONAL DATA WE COLLECT
The Personal Data we collect about you when you use our Services include the following:

• Your contact details. Your name, postal address and other contact details, such as your telephone number and e-mail address, and any other contact details you provide to us.
• Data collected automatically. When visiting our website, we collect data automatically through your browser or device, by making use of cookies and other technologies to track visitors on the website (including Google Analytics) and to collect information about your use of our website. Please see our Cookie Policy to find out more.
• Your financial details. The financial information that has been disclosed to us (either upon request or voluntarily) and can be linked to you as a customer or it’s representative or individual, such as bank account details or invoicing details.
• Your personal characteristics. Including your gender or other personal characteristics that are requested to identify you as a customer or it’s representative.
• Recording of video footage. When you enter or buildings or premises, you are recorded by our video surveillance systems (CCTV). You can also be recorded on video footage during events or fairs that we attend and during which we make video footage.
• Your profession and job title. This includes information on the specific (sub)sector that you operate in.
• Your use of our Services. We collect information relating to your use of our Services, such as which purchases you make (either online or as part of a sales process), the amount and date of your purchase, the product or service you purchase, location of purchase, payment method, etc.
• Your communication data. Your requests, any complaints you may have and any other data that we receive if we communicate with you via email or online.
• Any other personal data. This includes any personal data that you disclose to us during the course of your contractual relationship with us, either voluntarily or upon request.

WHAT WE DO WITH YOUR PERSONAL DATA
Reesink UK LTD collects and uses your Personal Data for the purposes below and on a lawful basis. Please know that insofar we already hold information about you, we may use that information for the same purposes.

For the performance of our agreement with you: In order to carry out our obligations arising from any contracts entered into between you and us, and to provide you with the information and services that you request, including managing and handling your requests, inquiries or complaints. This also includes responding to your requests to provide customer service, respond to your inquiries, providing you with technical support, provide you with essential information regarding the Services you use, etc.

For our legitimate commercial interests: We may use your Personal Data (both on aggregated and on individual basis), such as your contact details and your electronic identification data for the purpose of advertising our products and services, making contact with you for marketing or other commercial purposes if you are an existing customer. We may also use your Personal Data for analysing and improving the quality of our products and services, such as providing you with customer services and aftersales, and to understand you as a customer (customer optimization). This enables us to assess what may interest you, to measure or understand the effectiveness of advertising we serve to you and others and to deliver relevant advertising. In addition, based on your historical use of our Services we may target you with advertisement or other marketing materials that are customized to your personal preferences and experiences.

We may also use your Personal Data, for our other legitimate commercial interests such as, to operate and expand our business activities, to develop and improve or modify our Services, to generate aggregated statistics about the users of our Services; to assist in security and fraud prevention; to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, and statistical purposes. For system integrity purposes (for example the prevention of hacking, spamming etc.); to facilitate our business operations, to operate company policies and procedures; to enable us to make corporate transactions, such as any merger, sale, reorganization, transfer of Reesink UK LTD or Royal Reesink’ assets or businesses, acquisition, bankruptcy, or similar event; or for other legitimate business purposes permitted by applicable law.

USE OF INFORMATION BASED ON YOUR CONSENT
We may use your Personal Data referred to above in the section ‘Personal Data we collect’ to send you marketing communications (such as newsletters, promotions, news on products or service updates) via email or other electronic means, via telephone or via hardcopy mail (such as flyers), but we will only do so after we have received your consent to do so.

You can withdraw your consent at any time; see the section Your rights below.

To comply with our legal obligations: Any information referred to above in the section ‘Personal Data we collect’ may be used to comply with a legal obligation to which we are subject, such as maintaining appropriate business records, complying with lawful requests by governmental agencies and public authorities and to comply with applicable laws and regulations or as otherwise required by law.

HOW WE SHARE YOUR DATA
We share your Personal Data with the following parties:

• Data controllers within the Royal Reesink Group. Your Personal Data will be shared between the responsible Royal Reesink companies that may use your Personal Data as described in this Privacy Policy for internal administrative purposes, management purposes, analytical purposes and other business related purposes. Your Personal Data will only be used by Royal Reesink companies for marketing purposes if you have given your explicit consent thereto. An overview of the relevant responsible Royal Reesink companies can be found here.
• Service Providers and Processors. We engage third party vendors, from time to time, including:
  • Business partners, suppliers (such as IT service providers) and sub-contractors for the performance of any contract we enter into with them or to provide services on our behalf;
  • Financial institutions;.
  • Leasing companies;
  • Telemarketing companies and other advertising companies that carry out marketing activities on our behalf;
  • Analytics and search engine providers that assist us in the improvement and optimisation of our website, such as Google Analytics.

In providing their services, they will access, receive, maintain or otherwise process Personal Data on our behalf. Our contracts with these service providers do not permit use of your Personal Data for their own (marketing) purposes. Consistent with applicable legal requirements, we take commercially reasonable steps to require third parties to adequately safeguard your Personal Data and only process it in accordance with our instructions.

• Dealers. We offer our Services to our customers either directly or through our dealers. Where we engage with our dealers, we will need to disclose your Personal Data to those dealers. In accordance with the applicable law, we will take commercially reasonable steps to require dealers to adequately safeguard your Personal Data and only process it in accordance with our instructions. Where legally required, we will ask for your prior consent.
• Third parties in case of legal requirement. We also disclose your Personal Data if disclosure is required by law or in the context of an investigation, regulatory requirement, judicial proceeding, court order or legal process served on us, or to protect the rights or safety of the website, us or our affiliated companies.
• Corporate transaction. In addition, information about our customers, including Personal Data, may be disclosed as part of any merger, sale, transfer of Reesink UK LTD or Royal Reesink’s assets, acquisition, bankruptcy, or similar event.
• With consent. We also disclose information about you, including Personal Data to any other third party, where you have consented or requested that we do so.

INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA
In most cases your Personal Data will be processed within the European Union. However, please be informed that Reesink UK LTD may transfer and process any Personal Data you provide to us to countries other than your country of residence. The laws of these countries may not provide the same level of protection to your Personal Data. Reesink UK LTD or third parties we use will therefore seek to ensure that all adequate safeguards are in place and that all applicable laws and regulations are complied with in connection with such transfer. More in particular for Personal Data transferred to countries outside the European Economic Area. This means that we entered into legally necessary contracts with recipients of your data, including standard contractual clauses as approved by the European Commission or other supervisory authority where required.

You are entitled to receive a copy of any documentation showing the suitable safeguards that have been taken by making a request via gdpr@royal.reesink.nl.

SECURITY
Reesink UK LTD will take reasonable steps to ensure that your Personal Data are properly secured using appropriate technical, physical, and organizational measures, so that they are protected against unauthorised or unlawful use, alteration, unauthorised access or disclosure, accidental or wrongful destruction, and loss.

We take steps to limit access to your Personal Data to those persons who need to have access to it for one of the purposes listed in this Privacy Policy. Furthermore, we contractually ensure that any third party processing your Personal Data equally provide for confidentiality and integrity of your data in a secure way.

DATA RETENTION
We retain your Personal Data for as long as required to satisfy the purpose for which they were collected and used (for example, for the time necessary for us to provide you with customer service, answer queries or resolve technical problems), unless a longer period is necessary for our legal obligations or to defend a legal claim.

YOUR RIGHTS
Subject to the conditions set forth in the applicable law, you have the right to request, review, correct, update, suppress, restrict or delete Personal Data that you have provided to us or if you would like to request to receive an electronic copy of such personal data for purposes of transmitting it to another company, by sending an email to gdpr@royal.reesink.nl specifying your request. We will respond to your request consistent with applicable law.

In your request, please tell us what Personal Data you would like to have changed, whether you would like to have it suppressed from our database, or otherwise let us know what limitations you would like to put on our use of it. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain Personal Data for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.

In the event your personal data is processed on the basis of your consent, you can withdraw consent at any time by sending an email to gdpr@royal.reesink.nl specifying your request, without affecting the lawfulness of processing based on consent before its withdrawal.

You may lodge a complaint with a supervisory authority, in particular in your Member State of residence, if you consider that the collection and use of your Personal Data infringes this Privacy Policy or applicable law.

OTHER WEBSITES
Our websites may, from time to time, contain links to and from third-party websites, such as our business partners, social media networks, branch organizations and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please consult these policies before you submit any personal data to these websites.

CHANGES TO THE POLICY
This Privacy Policy may be revised from time to time. If a fundamental change to the nature of the use of your personal data is involved or if the change is in any other manner relevant to you, we will ensure that information is provided to you well in advance of the change actually taking effect.

CONTACT US
If you have any queries about this Privacy Policy or our handling of your Personal Data in general, or if you want to exercise your rights, please email us at gdpr@royal.reesink.nl and be sure to indicate the nature of your query.