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1. Introduction

Wulro Food Group BV (hereinafter: “WFG”) processes personal data on a daily basis. In doing so, WFG complies with the law. WFG respects the privacy of the persons whose personal data are received, and treats the personal data as strictly confidential. In this privacy policy, we will explain what personal data are processed by WFG and for what purposes. We recommend that you carefully read this privacy policy.

WFG has its registered office in Weert and its principal place of business in (6004 RL) Weert at Seelenstraat 7. WFG is listed in the trade register of the Chamber of Commerce under number NUMBER. WFG is the controller with respect to the processing and storage of your personal data. If you have any questions about the contents of the privacy policy, please contact NAME.
 

2. Personal data

WFG processes various kinds of personal data for different purposes. The personal data and purposes in question are detailed below.

Services
To be able to provide our services, we need your name and contact details. Aside from that, we are required by law to verify your identity based on a valid proof of ID. Depending on the contents of our services, we may need additional personal data. If necessary to be able to provide our services, we will transfer your personal data to third parties.

(Direct) Marketing
To be awarded new contracts, we collect commercially interesting information about companies, such as a company’s current market position, details of a company's possible (further) interest in our services, and details of persons working at the company with whom we want to get in touch, or who we have contacted. We collect contact details of such persons, take notes based on (phone) conversations with them, and compile visit reports. We collect the same kind of data about (potential) suppliers and service providers. These data are carefully organised and stored in a database that only authorised employees can access. We do this on the grounds of a legitimate interest pursued by us.

Social media
WFG has a presence on various social media, including LinkedIn and Twitter. We may process your personal data when you use features on our websites. If you opt to use such a feature, we may obtain your personal data through the social media in question.

Application procedure
WFG collects and processes personal data of applicants, as provided in personal contacts, by post, by email, and/or in phone conversations. Personal data that we collect include the applicant's name, gender, contact details, application letters, information about their level of education, and their work history. These data are relevant to the application procedure and will be erased no later than 4 weeks after termination of the procedure. If you consent to it, WFG may keep your personal data in its records for longer, so as to be able to contact you again in the future.

Employees
WFG also processes personal data of employees as part of the performance of the employment contract and based on lawful grounds. Employees of WFG have been made aware of this.
 

3. Recipient

We do not share your personal data with companies, organisations, and individuals outside WFG, except in any of the following cases.

Performance of a contract
Disclosure of personal data to third parties is permitted as and when it is considered necessary in order for us to meet our contractual obligations towards you. Aside from that, we provide your personal data to the mail deliverer/courier to have documents delivered to you as and when necessary.

With your consent
If you consent to it, we can transfer your personal data to third parties. Such consent is valid only if it is clear what you are consenting to and what the consequences are.

For external processing
We transfer personal data to our partners to enable them to process data on our behalf, based on our instructions and in compliance with our privacy policy and other applicable confidentiality and security measures. Our partners include our IT suppliers and our website administrator (ADD MORE IF NECESSARY).

For legal reasons
We disclose personal data if we are of the opinion that disclosure of personal data is necessary to comply with applicable legislation and regulations, legal procedures, or requests from government agencies.

Legal obligation
If required by a legal obligation, we will disclose your personal data.

Agreements
WFG  enters into data processing agreements with the recipients of your personal data to make sure your personal data are treated as confidential and secured.

Storage period
We will not store your personal data for longer than is necessary, unless we are under a legal obligation to store your personal data for longer. Our basic principle is that we only store personal data for as long as is needed to be able to provide our services to you. After that, we will erase your personal data insofar as possible. If you have provided, for example, your email address to enable us to keep you informed of our services, we will retain your personal data for that very purpose.
 

4. Transfer of personal data to third countries

WFG may transfer your personal data from the Netherlands to other countries. Countries that make up the European Economic Area (EEA) offer the same level of protection of personal data as the Netherlands. We may transfer your personal data to third countries, albeit only in compliance with the general requirements from the general data protection regulation. We may, for example, proceed to such a transfer within our group for the purpose of ensuring effective operations.
 

5. Your rights

When it comes to our processing of your personal data, you can exercise several rights, namely the right of access, the right to rectification or completion, the right to erasure of data, the right to restriction of processing, the right to data portability, and the right to object. These rights are detailed below, along with instructions on how to exercise your rights.

Right of access
On your request, we can let you know in writing whether we process any of your personal data. When submitting such a request, you will be required to provide proof of ID by including a copy of your driving licence or identity document. In our response, we will explain what personal data of yours we have processed or will process, and give you a copy of the processing operation. We will also explain the purposes for which we processed or will process your personal data, with whom your personal data are shared, how long your personal data will be stored for, and what other rights you can exercise.

Rectification or completion
After having been given access to the processing of your personal data, you can ask us to rectify inaccuracies or to have incomplete personal data completed. We will come back to you with a reasoned response. If we proceed to rectify or complete your personal data, we will provide you with an additional statement. This same statement will also be sent to recipients who may have received your inaccurate or incomplete personal data.

Erasure
You can ask us to erase your personal data from our systems in one or several of the following cases:
the personal data are no longer needed for the purposes for which we have processed them
you withdraw your consent for (further) processing, and there is no other purpose for processing
you lodge a reasoned objection to the processing, and there are no important reasons for us not to oblige
we have processed the personal data unlawfully
we are required by law to erase your personal data
we have collected your personal data through mobile telephony or online services

Restriction of processing
If you have reported inaccuracy or incompleteness in your personal data to us, you can ask us to restrict the processing of your personal data while we deal with your request. You can also ask us to restrict the processing of your personal data if you feel that we are processing your personal data unlawfully or no longer need your personal data, or if you have objected to the (further) processing of your personal data. After receipt of your request for restriction of processing, we will only process your personal data with your consent or on account of substantial reasons (such as a legal procedure).

Data portability
If you have provided personal data to us in a structured standardised digital file format, and we have processed your personal data with your consent or in the performance of a contract with you, you have the right to ask us for a copy of the data. You can in such cases also request that we send your personal data to another service provider directly.

Objection
You can at all time object to the processing of your personal data. This applies in particular to profiles that we have created based on your personal data. After we receive your objection, we will cease to process your personal data, unless there are important legitimate reasons that override your interests, rights, and freedoms.
If we process your personal data for direct marketing purposes, you can at all time object to it, following which we will immediately cease such processing.

Exercising your rights
If you want to exercise one or several of the rights specified above, please contact us on the following email address: info@wulro.nl. WFG will have a decision for you in response to your request within 4 weeks, unless we let you know within that 4-week period that we need more time to come to a decision. If your personal data are processed with your consent, you have the right to withdraw your consent. Withdrawal of consent will not affect previous processing operations that were performed with your consent.
 

6. Cookies

Our website uses functional (necessary) and analytical cookies to enable visitors to browse the website. These cookies are, however, only used for the duration of your browser session. Analytical cookies record how visitors use our website. The data collected is used to analyse how the website is used and to generate statistics. Such statistical information gives WFG insight into what website visitors look for, and WFG can use that insight and experience to improve the website. The service we use for this is Google Analytics. These cookies never collect data that can be traced back to individuals, meaning that website visitors always remain anonymous. We have entered into a data processing agreement with Google. The final octet of the IP address is hidden. Data sharing has been disabled and no other Google services are used in combination with Google Analytics cookies. WFG treats data and insights generated by cookies as confidential, unless there are reasons, such as legal obligations, compelling WFG to disclose this information.
 

7. Complaints

If you have a complaint about the processing of your personal data, we refer you to the complaints procedure of the Dutch Data Protection Authority. This is the authority that is competent to handle your complaint.
 

8. Questions?

If you have any remaining questions, please email them to: info@wulro.nl
This privacy policy complies with the General Data Protection Regulation. We reserve the right to amend this privacy policy on a periodic basis. The latest version will always be published on this page.

July 2018