2. The objective of processing personal data
When using our products and services, we may collect personal data from and about you. This could be information that you provide us with when buying our products, a contact form that you fill in to contact us or information that we collect when you use our (mobile) websites, apps, online stores and other services such.
We collect personal data in order to better tailor our products and services to your needs on the basis of the insights we obtain from them. We also do this for commercial reasons, namely to execute (future) agreements and gain a better understanding of the products and services that you are interested in as a user.
In this document we explain, among other things, how we deal with your personal data, how and what information we (can) collect and the purposes for which we (may) use them. In addition, this document also contains information on how you can access your data, how you can change or delete data (or have these changed or deleted), and who the (possible) recipients of these data are.
3. Grounds for processing
Personal data may only be processed if there is a legal ground for this. Legal grounds on which Holland Malt can process your personal data are:
Permission: We can speak of legally valid permission if you express in a free, informed and unambiguous way that you agree to a specific processing by Holland Malt, such as when you register for an email newsletter.
Necessary for the execution of an agreement: Your personal data could also be processed by Holland Malt because this is necessary for the execution of an agreement that you have or will conclude with Holland Malt, or to take measures because of your request to conclude of an agreement.
Legal obligation: In some cases, Holland Malt must process your personal data in order to comply with a legal obligation that lies with Holland Malt. An example is the retention of certain data on the basis of tax legislation.
Justified interest: Holland Malt could also process your data when this is necessary for the protection of its legitimate (business) interests or those of a third party, unless your interests, fundamental rights or fundamental freedoms outweigh these. In order to determine whether processing can take place on this legal ground, a weighing of interests must be done in advance between the interests of Holland Malt (or a third party) and the interests of the data subjects. For example, processing for the purpose of fraud prevention (if a prior and careful weighing of interests rules in favor of the business interests) could occur on this legal ground.
4. Which data are processed?
Holland Malt processes personal data that are satisfactory, relevant and limited to what is necessary to achieve its intended purpose. In order to achieve this goal Holland Malt processes, among other things (but not exclusively), data from a, or our, business relations. This may include the following data:
- Names (of contact and company);
- Gender (for communication or legal check;
- Date of birth (if needed for legal check);
- Telephone number, including mobile number;
- Email address;
- Other personal data that are actively provided;
- Data concerning activities on our website;
- Data about your surfing behavior on our websites;
- IP address;
- Location data;
- Internet browser and type of device.
The above is a summary of the data we could collect. This does not mean, however, that we actively request them from everyone and retain them.
4.b The provision of data is not mandatory but sometimes necessary
You are not obliged to disclose your personal details when you communicate with us. You always have the choice whether you want to provide your personal details or not.
However, in order to make use of some of our products and services, entering your personal details is necessary. For example, for the execution of an agreement we will need your details to have the product delivered to you and to prepare an invoice. If you want to receive an offer by email, then we need at least a valid email address.
4.c Participation in campaigns, prize distributions, competitions
We track your use of our online services by means of (a) cookie(s) (see below). This includes that all Holland Malt websites and means of communication, in principle, use the same system and that the data provided could also be combined.
These profiles will only be used to better tailor our offer to your interests. If you object to the exchange and combination of your personal data within Holland Malt and its affiliated companies and/or the creation of an online profile, you can make this known via the contact form. Where possible, we will cease the processing and delete the data.
5. Use of data/data retention periods.
The period(s) during which we use the data depends on the type of information we have and how and why we have received this information.
Holland Malt will not retain the personal data it collected for longer than is necessary to realize the purposes for which the personal data have been processed. Point of departure for Holland Malt is that it will not retain the personal data for more than one year, unless the applicable (civil or tax) legislation prescribes a longer period. At the end of this period, the personal data will be deleted or anonymized by Holland Malt.
Financial data (data relating to the purchase/sale of a product) must in many cases be retained for seven years for tax purposes.
6. Holland Malt’s Responsibility
6.a Processors of Holland Malt
Holland Malt shares the personal data it processes with third parties, if it considers this necessary or useful to optimize a business process, to execute an agreement or to comply with a legal obligation. Holland Malt enters into a processing agreement with all the companies that process personal data on behalf of Holland Malt. This agreement must ensure an equivalent level of security and confidentiality of personal data as is customary at Holland Malt. Holland Malt remains responsible for this processing. Examples of third parties with whom Holland Malt can share personal data are:
- Developers of digital services;
- Delivery services for our products;
- Suppliers of technical platforms,
- Data warehouses and infrastructure management;
- Payment service providers;
- Suppliers of products;
- Debt collection services;
- Analytics and data management services;
- Companies that conduct market research and customer surveys;
- Marketing services (CRM/email marketing platforms, marketing agencies);
- Customer Service;
- Advertising agencies and ad-tech vendors.
Finally, we can share certain anonymized data with third parties, such as the number of users searching for a particular term, or how many users clicked on an ad. You cannot be identified on the basis of this data.
6.b Transfer of data to third parties in other countries and security
When we pass on personal data to third parties causing the personal data to be processed in countries outside the European Economic Area, we will ensure that the data are transferred and processed in a manner that is permitted under applicable privacy legislation.
In the processing of personal data we will, at all times, maintain a level of security which, in view of the state of technology, is appropriate to prevent unauthorized access to and adaptation, disclosure or loss of personal data. This could include both technical and organizational measures (such as encryption of data, a limited group of employees who have access to the data, pseudonymization of data, anonymization of data, etc.).
7. Rights and Contact
You have the following rights:
Right of access: You have the right to inspect your personal data that we have processed free of charge.
Right to rectification: If your retained personal data is incorrect or incomplete, you can ask us to supplement or correct this.
Right to erasure of data: You have the right to have your personal data deleted when (i) the data is no longer required for the purpose for which it was collected, (ii) you withdraw your consent for the processing (and if there is no other legal ground for the processing), (iii) you (legitimately) object to the processing, (iv) the personal data are processed unlawfully, (v) this is required by law or (vi) the personal data have been collected within the context of a so-called information society service. In some cases it will not be possible to delete your personal data, for example when there is a legal obligation for Holland Malt to retain the data, when the data are necessary to execute an agreement with you (e.g. the delivery of a product after ordering it from one of our online stores) or when the right to freedom of speech and information should weigh more heavily in a specific case.
Right to restrict processing: You have the right to request a restriction on the processing of your personal data (e.g. while the accuracy of your personal data is being checked).
The right to data portability: Under certain conditions you have the right to receive the personal data you have provided to us in a structured, current and machine-readable format and to pass on your personal data to a third party of your choice.
Objection to processing: You have the right to object to the processing of your personal data due to reasons related to your specific situation. In this case, a weighing of interests will take place taking your specific situation into account.
You also have the right to file a complaint with Holland Malt or the authoritative body in charge of the protection of personal data, i.e. the Dutch Data Protection Authority. You can also state that you no longer want (i) your personal information to be provided to group companies or to third parties, (ii) your personal data to be combined into a profile, (iii) your data used for making targeted offers or receiving information and offers by e-mail.
By regular post:
Holland Malt Attn. “Privacy”
By email: firstname.lastname@example.org
Remember to clearly state your (full) name, address and place of residence and to include a copy of an identification document (which clearly states that it is a copy and where your phot and CSN number has been made unrecognizable). We need this information in order to determine, with some certainty, whether the data referred to in your request relates to you. The copy of your ID will only be processed for the purpose of your identification within the context of your request and will subsequently be deleted.