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Privacy Statement for Customer, Supplier, and Partner Data

1. Introduction

This Privacy Statement applies to the processing of all personal data of consumers, customers, suppliers and partners (hereinafter referred to as "the Partners" or "you") carried out by Nutreco N.V., with its registered office at Stationsstraat 77, Amersfoort, The Netherlands, and any company directly or indirectly owned by, or controlled by Nutreco with whom you interact or maintain a business relationship (hereinafter referred to as "Our Company" or "we"). This Privacy Statement does not apply to data relating to business activities or companies.

Nutreco N.V. and the company directly or indirectly owned by, or controlled by Nutreco, with which you interact or maintain a business relationship, are responsible for the processing of your personal data. In this statement you will find who we are, how and for what purposes we process your personal data, as well as any other information that may be relevant to you. In case you have any questions, you can contact us via the contact details at the end of this statement.

This Privacy Statement is applicable from May 24, 2018 and the last modifications to it have been made on May 24, 2018. Although this may change over time, you will always find the most up-to-date version on our website. When we make material changes, we will notify you.

 

2. For what purposes do we process your personal data?

Our company processes your personal data when you conduct business with us, when you use our websites or apps, or when you interact with us.

To. To answer your questions

When you contact us, we use your personal data to respond to your questions.

To this end,

- we process your personal data based on your consent when you provide us with your personal data, and

- We process, to the extent applicable, your name, your contact details, correspondence you have had with us, and any other personal data that we need to respond to your enquiry.

B. For the development and improvement of products and services

We process your personal data to evaluate, analyse and improve our (customer service) products and services. Nutreco N.V. uses aggregated personal data for the purpose of analyzing customer behavior and adjusting our products and services accordingly. When you use, enter, or search for data through a website or app, we also process your personal data for analytics reporting. Nutreco N.V. uses aggregated personal data in order to analyze customer behavior and adjust our products and services accordingly, to ensure that they are relevant to our customers. This means that we analyse how often you read our newsletters, visit our website or apps, the pages you click on and what products you buy through them. In addition, we may acquire supplemental data from public sources for the purpose of supplementing our database for the purposes described below.

To this end,

- we process your information based on our legitimate interest in developing and improving our products and services, and

- We process your contact details such as your address and email address, and your personal details such as your name and, where applicable, your date of birth, your credit and payment information, and correspondence you have had with us. In addition, we process personal data that you have entered on a website or that has been generated through the functions you have used on a website and technical data from your device such as your IP address, the pages you have visited on our websites, the clicks made, browsing patterns, and the length of your session.

- When you participate in our surveys, we may ask you to provide us with your personal data, so we may also use the personal data you provide in the survey for this purpose.

 

C. For evaluation and acceptance by a customer, supplier, or partner

When you contact us, we process your personal data for assessment and acceptance purposes, for example, to confirm and verify your identity. Our company also processes your personal data for other administrative purposes such as due diligence and, where appropriate, matching against public lists of sanctions imposed by the government or law enforcement.

To this end,

- We process your personal data as it is necessary to enter into a contract between you and us. Our company cannot enter into contracts without first obtaining the required information.

- And we process your contact details such as your address and email, and your personal details such as your name and, where applicable, your date of birth, your credit and payment information, and details of correspondence you have had with us.

D. For the conclusion and execution of agreements

When you purchase a product or service from us as a customer, or when you work with us as a supplier or partner, we process your personal data for administrative purposes such as sending invoices and making payments. In addition, we use your personal data to deliver or receive and manage our or your products and services. Our company processes your personal data in order to be able to continue to enter into agreements, including those for the provision of customer services. When you request access to Our company's premises, we process your personal data in order to verify your identity.

To this end,

- We process your personal data as it is necessary to enter into a contract between you and us. Our company cannot enter into contracts without first obtaining the required information.

- And we process your contact details such as your address and email, and your personal details such as your name and, where applicable, your date of birth, your credit and payment information, and details of correspondence you have had with us.

And. For relationship management and marketing purposes

We use the information stored in our customer database to send you offers and newsletters that are tailored to you, as well as to provide you with customer service, manage our accounts and notify you of product recalls.

We also use your personal data to develop, carry out and analyse market research and marketing strategies.

To this end,

- When we send you newsletters and other marketing and relationship management communications, we process your personal data based on your consent. In addition, we process personal data based on our legitimate interest in improving our marketing strategies.

- We process your contact details such as your address and email, and your personal data such as your name, your contact preferences, your credit and payment information, your order history and correspondence with us.

F. For business process execution and internal management

We process your personal data for the conduct and organisation of our business activities. This includes general management, order administration and management of our assets. In addition, our company processes your personal data for internal management.

To do this, we have central facilities in which we carry out the treatment to work more efficiently. We carry out audits and studies, apply commercial controls, and manage and use directories of customers, suppliers and partners.

We also process your personal data for financial and accounting, archiving and insurance, legal and business consulting purposes and where necessary to resolve disputes.

To this end,

- we process personal data based on our legitimate interest in improving and maintaining the smooth running of business operations;

- We process your contact details such as your address and email, and your personal data such as your name, your credit and payment information, your order history, the correspondence you have had with Our Company and the data that is generated during the execution of the agreement entered into between you and Our Company.

G. For organizational analysis and development, management reporting, and acquisitions and divestitures

At Our Company, we process your personal data for the preparation and preparation of management and analysis reports. We use aggregated/anonymised personal data for the purpose of creating management reports and analysing our business. We conduct surveys of customers, suppliers and partners to find out more about their views and opinions when preparing our management reports. In addition, we also process your personal data to compile management reports in relation to mergers, acquisitions and divestments, as well as to manage such transactions.

To this end,

- we process personal data based on our legitimate interest in improving and maintaining the smooth running of business operations;

- We process your contact details such as your address and email address, and your personal data such as your name and, where applicable, your date of birth, your credit and payment information, as well as the correspondence you have had with us and the information you provide to us when you respond to our surveys.

H. When you use our websites or apps

When you use our websites or apps, we process technical data about your device to provide you with features and to enable our administrators to manage and improve the performance of our websites and apps. When you enter data on our websites or our apps, such as a product reference or your location to receive relevant information or functionalities, Our company processes this data to provide you with the information or functionalities that you are requesting from us. In addition, we process your personal data to allow you to save your data (such as your preferences and products) in your saved items and share it with others using the sharing options you have set on your device.

To this end,

- We process personal data based on our legitimate interest in providing technically sound websites and apps and to improve their performance. In addition, based on your consent, we process personal data for marketing purposes through the use of marketing and social media cookies on our websites and apps.

- we process personal data that you have entered on our websites and apps, or that have been generated through the functions you have used on our websites and apps, and technical data from your device such as your IP address, your web browser, the pages you have visited on our websites, the clicks made, browsing patterns, and the length of your session. Detailed information on the functions of cookies can be found in the cookie notice of the respective websites and apps.

I. To Allow You to Contact Us

Our company has accounts on social networks such as Facebook, Twitter, LinkedIn and YouTube. When you contact Our company via social media, we process your personal data to respond to your questions and messages.

In addition, when you visit the "Contact Us" section of one of our websites or apps, you can contact us through different communication channels. We provide you with our email address so that you can send us your feedback and suggest improvements, as well as data from our websites, Twitter, Facebook and YouTube. When you click on one of the social media icons, we redirect you to the relevant third party's website or app, either through your email provider or a social media platform.

To this end,

- we process personal data based on our legitimate interest to respond appropriately to your questions and to correctly redirect you to our social media pages;

- We process the communication channel you choose to contact us, as well as the data you provide to Our company. This includes your (username), address, email address and the personal data you include in your message. In addition, when you click on one of the buttons displayed, the relevant third party may place cookies on your device.

J. To monitor and analyze compliance

We monitor our processes to verify compliance with our policies and regulations. During monitoring activities, we may access and visualize your data.

To this end,

- We process your personal data based on our legitimate interest in monitoring our internal processes and complying with the law. We provide you with an ethical/whistleblowing channel. The data of the person who makes the communication and of the employees and third parties affected will be processed to assess the appropriateness of initiating an investigation into the facts denounced and, if deemed appropriate, for the corresponding investigation.

- We may access and view any data that is stored in our systems for compliance purposes. The personal data that we access and view is not stored for compliance purposes unless we need it to further investigate potential non-compliance behavior.

- We do not keep your personal data for this purpose, unless the data is related to non-compliant conduct. In this case, we keep the relevant personal data until the investigation or proceedings are concluded.

K. To protect health and safety, and ensure integrity

At Our Company, we care deeply about your health, safety, and integrity. We process your personal data to protect our employees, customers, suppliers and partners. To do this, we authenticate your rights of access to our premises and, where appropriate, we may check your personal data against public lists of sanctions imposed by the government or law enforcement.

In addition, we also process your personal data to protect our Company's assets, employees, and customers.

To this end,

- we process your personal data based on our legitimate interest to monitor our internal processes and comply with the law;

- We process your contact details such as your address and email, and your personal data such as your name and date of birth, your ID or passport, your car registration number, your order and payment history, and your history of visits to our premises.

L. To comply with the legislation

In some cases, we process your personal data to comply with laws and regulations. This could be the case, for example, when there are tax or conduct-related obligations of the company. In order to comply with applicable laws and regulations, we may need to disclose your personal data to government institutions or supervisory authorities.

To this end,

- we process your personal data to comply with the law;

- We process your contact details such as your address and email, and your personal data such as your name and, where applicable, your date of birth, your payment information, your payment and order history, and your Chamber of Commerce details, your VAT number and your tax details.

M. When you participate in events or promotions

We send you emails with promotions and invitations to participate in events. When you participate in one of these events, we need your personal data in order to be able to advertise and organise them. In addition, when you participate in any of these activities, we need your personal data to measure response to events and promotions.

To this end,

- We process your personal data based on your consent. You may withdraw your consent at any time, without affecting the lawfulness of the processing carried out on the basis of your consent before withdrawing it.

- We process personal data such as your name, image, address, email and participation in the relevant event.

3. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

In general, Our Company retains Associate Data only for as long as is necessary to serve the applicable Business Purpose, to the extent reasonably necessary to comply with an applicable legal requirement or as otherwise advisable under applicable statutes of limitations.

The information of the ethical/whistleblowing channel will be kept in that system for a period not exceeding THREE months. After this period, the information that makes up the investigations may be kept outside the channel for the time necessary to defend the interests of the channel's titleholder, and may be communicated to judicial bodies or security forces, if appropriate.

The data collected with the consent of the interested party will be kept as long as they do not request their deletion.

Immediately after the applicable retention period, the Data:

(i) are safely disposed of or destroyed; or

(ii) are anonymized; or

(iii) they are blocked by adopting technical and organisational measures to prevent their processing, including their viewing, except for the provision of the data to judges and courts, the Public Prosecutor's Office or the competent Public Administrations, in particular the data protection authorities, for the demand of possible liabilities arising from the processing and only for the limitation period of the same.

4. WHO CAN ACCESS YOUR PERSONAL DATA?

Access to your personal data in Our Company

As a global organisation, the data We collect may be transferred internationally through Our company's worldwide organisation. Your personal data may be exchanged with the group to which Our company belongs, our shareholders and partner companies, for administrative purposes, and so that we can have a complete overview of your contacts and the contracts established with the group to which Our company belongs. In addition, we may also exchange your data in order to offer you a complete package of services and products.

Our company's employees are authorized to access personal data only insofar as it is necessary to achieve the applicable purpose and carry out their work.

In some cases, your personal data may be transferred to a country that does not provide an adequate level of data protection. However, Our Company has taken steps to ensure that your personal data is adequately protected as the Binding Corporate Rules are applicable to the entire group to which Our Company belongs.

Access to your personal data by third parties

Where it is necessary for the provision of their products or services to Our company, third parties may access your personal data.

When we provide third parties with access to your personal data, Our company takes the necessary organisational, technical or contractual measures to ensure that your personal data is only processed to the extent that such processing is necessary for the purpose of the processing that has been agreed with Our company. These third parties only process your personal data in accordance with applicable law.

When personal data is transferred to a country that does not provide an adequate level of protection for personal data, we take steps to ensure that your personal data is adequately protected, such as introducing EU Standard Contractual Clauses with these recipients.

When necessary for the maintenance of the contractual relationship, the following types of third parties may access your personal data: Public Administrations with competence in the matter, banks to proceed with the payment or collection of the amounts owed, insurance companies in the field of contracting credit insurance related to commercial operations under the provisions of the insurance regulations, auditors of accounts, and Security Forces and Corps, as well as Courts and Tribunals (in the event of incidents related to the safety of the facilities, associated with production processes or in the event that it is deemed necessary as a result of a complaint filed through the ethical channel/complaints channel).

In other cases, your personal data is not provided to any third party, unless required by law.

5. HOW DO WE PROTECT YOUR PERSONAL DATA?

In our opinion and based on our risk assessment, we have taken appropriate security measures to ensure the security of your personal data. In our assessment, we have considered the risks of accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access and other forms of unlawful processing (including, but not limited to, unnecessary collection) or further processing.

6. HOW CAN YOU EXERCISE YOUR PRIVACY RIGHTS?

You have the right to request access to or a summary of your personal data, and in certain circumstances, the rectification or deletion of the personal data. In addition, you may also have the right to restriction of processing in relation to your personal data, the right to object to processing, as well as the right to portability of your data.

If you wish to invoke your privacy rights, please contact us using the contact details at the end of this Privacy Statement. Please note that we may ask you for additional information to verify your identity.

8. HOW TO FILE A COMPLAINT OR REPORT A DATA BREACH?

If you wish to make a complaint about Our company's use of your personal data, or if you become aware that Our company has committed a data breach, you can make a complaint or report the data breach using the contact details listed at the end of this statement. In addition to filing a complaint with Our Company, you may also lodge a complaint with your local data protection supervisory authority (Spanish Data Protection Agency www.aepd.es).

9. HOW CAN YOU CONTACT US?

If you have any questions about how we process your personal data, please read this statement first.

For any additional questions, comments, compliments or complaints, please contact Our company's Privacy Officer via the email address privacy@nutreco.com and/or protecciondatos@nutreco.com.