This Privacy Statement (“Privacy Statement”) aims to explain in simple and transparent way our policies and practices regarding your personal data and how we process it. This Privacy Statement is applied to personal data Milkiland N.V. and its affiliates (“Milkiland”, “we”, “us”, “our”) obtain from you. It also describes how we collect, use, shares and otherwise processes personal data.
If you have any questions or comments regarding the Privacy Statement or our privacy practices, please write to us at:firstname.lastname@example.org.
While this Privacy Statement is intended to describe the broadest range of our information processing activities may be more limited in some jurisdictions based on the restrictions of their laws. For example, the laws of a particular country may limit the types of personal information we can collect or the manner in which we process that information. In those instances, the limited requirements of local law shall apply. In case the jurisdiction allows the collecting and processing of the more personal information that allowed by the General Data Protection Regulation (“GDPR”), the requirements of the GDPR that are reflected in this Privacy Statement and in our internal regulations shall apply.
1. The types of personal data we collect about you
We collect certain types of information from, or about, you throughout our interaction with you, from third party service providers or from publicly available sources. Depending on how you interact with us the personal data we collect includes:
- Identification data, such as your name, surname, date and place of birth, ID number.
- Personal contact information, such as any information that allows us to contact you such as name, email address, postal address, social network details, telephone number.
- Socio-demographic data, such as whether you are married and have children, your gender, age or age range, geographic location.
- Third party social network information, such as information that you share publicly or information that is part of your profile on a third party social network.
- Online behavior and preferences data, such as IP address of your mobile device or computer and the pages you visit on our website.
(hereinafter the “Personal Data”).
We do not record sensitive data relating to your health, ethnicity, religious or political beliefs unless it is strictly necessary. Where it becomes necessary to process your sensitive Personal Data for any reason, we rely on your prior express consent for any processing which is voluntary.
We do not collect data about your children.
2. Use of your Personal Data
The purposes, for which we use Personal Data, and the legal bases for such collecting and processing, are as mentioned below. Please note that not all of the uses below will be relevant to every individual.
- fulfillment of the compliance procedure and due diligence process of potential counterparty;
- fulfillment of the contractual obligations with you;
- consumer goods purposes, including responding to your enquiries;
- to consider individuals for employment and contractor opportunities and manage on-boarding procedures;
- other general business purposes, such as conducting internal or market research and measuring the effectiveness of advertising campaign etc.
3. Sharing of Personal Data
We share Personal Data only on a need-to-know basis and only when the entity/organization/company respects and ensures the same principles and commitments of the GDPR and if they have the legal basis for this transfer. We may share the Personal Data to:
- our affiliates within Milkiland’s group for the purposes described above. The Milkiland’s group companies provides the appropriate safeguards according to the internal Data Protection Policy;
- financial institutions in connection with invoicing and payment;
- government authorities in order to comply with their request or any other enforceable demand;
- suppliers and service providers to enable them to perform functions on our behalf and our instructions in order to carry out the purposes identified above. When we use other service providers we only share Personal Data that is required for a particular assignment. We require such parties by contract to provide reasonable security for Personal Data;
- corporate purchasers, we may share Personal Data with a corporate purchaser to the extent permitted by law as part of any merger, acquisition, sale of Milkiland’s assets. We will disclose your Personal Data for legal reasons or in the context of an acquisition or a merger, sale of assets of Milkiland or Milkiland’s group entity.
All data transfers are in line with our internal Data Protection Policy.
4. Cross-Border Data Transfer
We transfer Personal Data to jurisdictions as necessary for the purposes described above, including to jurisdictions that may not provide the same level of data protection as your home country (these are Poland, Ukraine and Russia).
With respect to transfers originating from the European Economic Area (“EEA”) to Ukraine and other non-EEA jurisdictions, we implement standard contractual clauses approved by the European Commission.
5. Duration of storage of Personal Data
We are only allowed to keep your Personal Data for no longer than is needed for our intended purpose(s). After this we look for feasible solutions, like deleting or archiving it.
6. Technical and organizational measures
7. Your rights
You have the following rights:
- Right of access, you have the right to obtain from us confirmation as to whether or not Personal Data concerning you are being processed, and the overview of your Personal Data that we are processed.
- Right to rectification, if your Personal Data is incorrect, you have the right to ask us to rectify them. If we shared the data about you with a third party that is later corrected, we will also notify that party.
- Right to erasure (“right to be forgotten”), you may ask to erase your Personal data if: — we no longer need your Personal Data in relation to the purposes for which they were collected;
— you withdraw your consent for which the processing is based;
— your Personal Data is unlawfully processed by Milkiland;
— you object to us processing your data for our own legitimate interests or for direct marketing purposes;
— or the erase of your Personal Data is required by the law of the European Union or a member state.
- Right to restrict processing, you have the right to obtain from us restriction of processing your Personal Data if: — you deem that the Personal Data we process about you is inaccurate;
— the processing of your Personal Data by us is unlawful;
— Milkiland no longer needs the Personal Data for the purposes of processing, but you want us to keep it for use in a legal claim;
— you have objected to us processing of your Personal Data for our own legitimate interests.
- Right to data portability, you have the right to ask us to transfer your Personal Data in a structured, commonly used and machine-readable format to you or another company. This applies where processing is based on consent or a contract with you and carried out by automated means.
- Right to object, you can object to Milkiland processing your Personal Data for direct marketing purposes. Also you have the right to object processing your Personal Data for our own legitimate interest unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defense or a legal claim.
- Right to withdraw consent, you have the right to withdraw your consent given to us for a specific purpose.
8. Cookies and similar technologies
Cookies and similar tracking technologies allow us to remember your browsing preferences when you visit our website and to distinguish you from other users of our website. However, it is important to note that we do not collect any information that may be treated as the Personal Data and is only used for reporting/statistical purposes. The tracking technologies we use are as follows:
- Google Analytics by using of which we can see the geographic location of our visitors, frequency of connection to the website, software used for visiting our website. To prevent your data from being used by Google Analytics please visit https://tools.google.com/dlpage/gaoptout?hl=en.
- Our website hosting provider and content manager system thought which we use the type of cookies referred to as “session” or “short-term” cookies and “long-term” cookies. Session or short-term cookies are temporary and are automatically deleted once you leave our website. Long-term cookies are used to remember you preferences (for example, language preferences).
You are not obliged to accept any cookies, if you want to know how to decline the acceptance of cookies please look at your Internet browser settings, typically under the section “Help” or “Internet Options” or contact your system administrator.
9. Changes to our notice
We reserve the right to make changes to this Privacy Statement.
10. Contact us
Please do not hesitate to contact us if you have any questions in regards to the protection of your Personal Data or if you wish to exercise your legal rights.
Please contact: email@example.com
This Privacy Statement dated 25 of May 2018