NewCold Privacy Statement

NewCold Coöperatief UA and its affiliates (together: “NewCold” or “we”) have created this Privacy Statement to demonstrate our commitment to the individual’s right to data protection and privacy.

This Privacy Statement applies to the processing of Personal Data in the context of our global business operations. This includes the processing of Personal Data through our websites: www.newcold.com, www.davantigroup.com, www.coraxwms.com and www.coraxsaaswms.com(each individually: “Website”). This Privacy Statement contains information on the categories of Personal Data we collect, why we collect it, what we do with it, and how we protect it, as well as your individual rights.

NewCold is the so-called controller in the sense of the General Data Protection Regulation (‘GDPR’). This Privacy Statement explains in general terms how we seek to comply with data protection laws and regulations, including but not limited to the European General Data Protection Regulation (“GDPR”) and national laws implementing the GDPR, as well as state security breach laws and data protection laws in the United States, and applicable data protection legislation in other jurisdictions, such as Australia.

If, after reading our Privacy Statement, or in a more general sense, you have any questions or wish to contact us, you can do so via the contact details at the end of this Privacy Statement.

Collection and Processing of your Personal Data

We process Personal Data of (contact persons at) our customers, suppliers and other relations, of students and job applicants, and of visitors of our Websites. We obtain your Personal Data i) from you, ii) from third parties (such as customers, suppliers and chain partners), or iii) from public sources, for example, the Trade Register of the Chamber of Commerce.

Personal Data that we may process are:

• basic information such as your first and last name, title, gender;
• contact details such as your e-mail address, postal address, telephone number, the company you work for and your position;
• financial information, such as IBAN/bank account number;
• IP address and statistical data about your use of our Websites;
• Personal Data you provide us with when applying for a job with us, such as an application letter, CV, date of birth, education and career information;
• any other Personal Data we obtain from or about you that we use for the purposes mentioned below.

We do not always process all of the above data, this depends on the type of relationship, the service in question and (if applicable) the consent you have given us.

Purposes for the processing of personal data

We process your Personal Data for one or more of the following purposes (depending on our relationship with you):

Marketing and acquisition purposes

We use your Personal Data to send out newsletters, invitations to our events and other marketing communications that may be relevant to you, as well as in the context of a (registration for) one of our marketing events. When you have attended one of our events, we may also contact you for feedback.

Executing an agreement

We process your Personal Data insofar as necessary within the context of the products or services provided by us, including the exchange of Personal Data for quotations, the execution and completion (including invoicing) of an order, service request or assignment.

Compliance with legal obligations

We process your Personal Data insofar as necessary to comply with legal obligations. For example, the collection and storage of data and the provision of information to the tax authorities and supervisory authorities.

Job applications and recruitment

The data you share with us if you apply with us (via email/mail, the job application form on our website or via social media) or that we receive via recruiters, is processed by us to contact you for the purposes of our job application procedures and to deal with your job application. We may also process your Personal Data in the context of (a registration for) an internship at one of our branches.

Access control and security

For safety purposes (evacuation in case of calamities) we keep a list of visitors to our business premise(s). These lists are destroyed at the end of the day in question. We also use camera surveillance to protect the possessions and safety of our employees and visitors. For more information regarding camera surveillance we refer to our CCTV Policy, which is available at the front desk of each site and which apply for all NewCold sites. [

Use and improvement of our website

We process statistical data about your visit and use of our website. We do this to analyse and improve the content, layout and use of our website.

Other processing

We may also process your data to carry out customer satisfaction surveys, or to handle any questions or complaints.

Data processing principles

We process your Personal Data on the basis of one or multiple of the following legal grounds:

• The performance of an agreement with you or to take measures before the conclusion of an agreement;
• A legitimate interest;
• Your consent;
• Our compliance with legal obligations.

Sharing your Personal Data

In some cases, we may share your Personal Data with third parties. We will only do this when we consider this necessary. We only share your data with trustworthy parties and ensure that a transfer of your Personal Data is subject to appropriate safeguards. We may share your personal data with:

• Government institutions such as the tax authorities and supervisory authorities.
• NewCold Affiliates, customers, suppliers and subcontractors;
• Chain partners and other service providers such as banks, insurers, bailiffs, accountants, tax advisers and other advisers;
• External suppliers such as IT service providers, hosting and cloud service providers or other suppliers to which we outsource support services.

If the third party with which your Personal Data is shared is designated a processor in the sense of the GDPR, we will also conclude a data processing agreement with this third party.

Storage of Personal Data

We will retain your Personal Data in accordance with applicable data protection legislation and specific mandatory retention periods. The data will not be retained for longer than strictly necessary to achieve the purpose for which the data has been collected and to comply with legal obligations.

Your privacy rights

Under the GDPR, you have the following rights:

You have the right to request us to access, rectify, erase, restrict and transfer your personal data. You also have the right to object to the processing of your personal data. If you wish to exercise your rights, please submit a request per e-mail. Our contact details can be found at the end of this Privacy Statement.

Please note that individuals’ rights under the GDPR are subject to certain restrictions and may not always be granted. A request may be denied in part or in full following these restrictions, such as legal obligations, the rights of third parties and the legitimate interests of NewCold. If we are unable to grant a particular request, we will inform you of this, with statement of reasons.

Insofar as the processing of your Personal Data is based on consent, you have the right to revoke this consent at any time. Any withdrawal of your consent does not affect the lawfulness of processing based on consent before its withdrawal.

Within the EU, EU citizens have the right to lodge a complaint with a supervisory data protection authority. A list of all EU supervisory authorities is available on the European Data Protection Board website: https://edpb.europa.eu/about-edpb/board/members_en. In the Netherlands this is the ‘Autoriteit Persoonsgegevens’ (‘AP’). More information can be found on the website of the AP (https://autoriteitpersoonsgegevens.nl/). We would appreciate it if you would contact us first so that we try to reach an amicable solution.

Data security

We take appropriate security measures to limit abuse of and unauthorized access to Personal Data. For example, we ensure that only authorised persons have access to the data, that access to and transfer of the data is protected by appropriate safeguards such as secured connections and firewalls and that our security measures are evaluated and updated regularly.

Transfer of Personal Data outside the EEA

All information you provide to us via our Websites will be stored on servers in the European Economic Area (EEA). If necessary, we may share information with our Affiliated Companies in and outside the EEA.

We may use MailChimp’s services to send newsletters and digital invitations. MailChimp is based in the United States and is Privacy Shield certified. For more information regarding the processing of personal data by MailChimp, please refer to the privacy policy of MailChimp.

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