Privacy statement Privacy Statement Seafood Connection B.V. Updated: 7 December 2018 1. General information Seafood Connection B.V. (hereinafter referred to as “Seafood Connection”, “we” or “us”) is an international trading company specializing in the import, export and distribution of frozen fish products. The company focuses on the import and trading of high-quality and sustainably produced frozen fish fillets. We are active in 3 continents and since 2013 are part of the Japanese multinational Maruha Nichiro Corporation. On the 25th of May 2018, the EU General Data Protection Regulation (GDPR) was enforced. The goal of this regulation is to protect the privacy of individuals with new standards regarding personal data processing. In short, this is about any kind of use of personal data about individuals. 2. Privacy matters to us We at the Seafood Connection are committed to ensure the privacy of all parties involved with our organisation. As our headquarters is located in the Netherlands, European legislation applies to our organisation. This Privacy Statement aims to give you an explanation of the GDPR and your rights as an individual under this regulation. It also describes how we use and process the personal data we obtain from you when you apply for a job at Seafood Connection or when you work with us as a business partner. As a visitor of our website, we do not collect or use any personal data. We may update this Privacy Statement from time to time. We encourage you periodically to review this page for the latest information on our privacy practices. 3. When and how do we collect personal data about you? We may process personal data from our employees, job applicants, our business partners and/or our customers. We may collect information about you: - directly from you, such as the information you provided to us when you are an employee of one of our business partners; - from other sources, such as your (former) employer or via our agents; and - from publicly available sources such as LinkedIn or the corporate website of the organisation you are working for. 4. Which personal data do we process, for what purposes and on what legal basis According to the GDPR personal data is considered to be any information that relates to an identified or identifiable individual. • Customers: If you are our (potential) customer, we may have your contact details e.g. name, business address and phone number and e-mail address, the contact person at your organisation, their and your position and may have your bank account and VAT number. We will process the personal data from our customers for purposes of selling and delivering our products. The legal basis for such processing personal data is the performance of a contract. For contractual reasons, we also need personal data to provide our services and comply with the obligations arising from contractual agreements concluded with you. This data is used e. g. for performing a contract, managing customer data, handling payments and providing you with information our product and prices. We will also use your personal data for sending you our price list via e-mail. The legal basis for such processing personal data is the performance of a contract or our legitimate interest. Our legitimate interest translates into our objective to communicate relevant news regarding our products. • Business partners: If you are (working for) one of our business partners, we may have your contact details e.g. name, business address and phone number and e-mail address, the contact person at your organisation, their and your position and may have your bank account and VAT number. We will process personal data from our business partners for purposes of importing, exporting and distributing our products. The legal basis for such processing personal data is the performance of a contract. For contractual reasons, we also need personal data to provide our services and comply with the obligations arising from contractual agreements concluded with you. This data is used e.g. for performing a contract, managing customer data, handling payments and providing you with information our product and prices. We will also use your personal data for sending you our price list via e-mail. The legal basis for such processing personal data is the performance of a contract or our legitimate interest. Our legitimate interest translates into our objective to communicate relevant news regarding our products. • Job applicants: When you apply for job, we will process your personal data to determine if you are eligible for a certain position within Seafood Connection. When evaluating you application we will process the personal data provided by you. The types of personal data that we may process about you are: name, gender, nationality, date of birth, telephone number, email address, cv, education, experience, position and salary expectations and/or current salary, if your CV includes a photograph, we will also process that. The legal basis for such processing is performance of a (possible future) contract. • Visitors of our website: When visiting this website, we do not collect any personal data. We do not use cookies to collect personally identifiable information about you. • Employees: Employees are notified of the personal data that we may process about them via their employment contract and internal information channels. The legal basis for processing is performance of a contract, consent or our legitimate interest. 5. How long do we store your personal data? We only hold your personal information on our systems for as long as is necessary for the purposes outlined above. We remove personal data from our systems once it is no longer required, in line with our guidelines on how long important information must remain accessible for future use or reference, as well as when and how data can be destroyed when it is no longer needed. The length of time each category of data will be retained will vary depending on how long we need to process it for, the reason it was collected and in line with any statutory requirements. After this time the data will either be deleted or we may retain a secure anonymised record for research and analytical purposes. We will store your personal data as listed below or until the moment you have informed us that you no longer wish to receive our mailings, we cease the sending of the relevant mailings, or it appears that your email address is no longer in use (for example when we receive a filed delivery notification). Information relating to one-time events will be deleted when the particular event has taken place and we no longer need that information. Personal data concerning: Retention period Business partners: For as long as the business relationship continues, to a minimum of 7 years after the ending thereof Customers: For as long as the customer relationship continues, to a minimum of 7 years after the ending thereof Job-Applicants: For maximum of one month after the relevant position has been fulfilled. With explicit consent of the job applicant we may extent this period to a maximum of one year Visitors of our website: None 6. Transfer/disclosure of personal data In the context of the purposes as listed above, we may share your personal data with third parties, such as cloud services providers, software providers, payroll administration office, printers and/or event organizers. Processing arrangements Where we use third party service providers we will ensure that, where relevant, contractual safeguards are implemented to ensure the protection of your personal data when disclosing your personal data to a third party. For example, we will enter into data processing agreements with relevant parties (providing for restrictions on the use of your personal data and obligations with respect to the protection and security of your personal data). As a general rule, we only share your personal data as set out above with other parties located in countries outside the European Economic Area, if this is absolutely necessary for the performance of a contract or given our legitimate interest. In such case, it shall be ensured that adequate measures are taken to ensure adequate protection of your personal data in accordance with applicable data protection legislation. Generally, we will enter into the Standard Contractual Clauses (as approved by the European Commission) with the recipient of your personal data. You may contact us via gdpr@seafoodconnection.nl if you wish to obtain a copy of the Standard Contractual Clauses entered into or insight in other adequate measures taken. 7. Protection of personal data? Seafood Connection will take all measures necessary from technical and organisational point of view to prevent unauthorised access to personal data, loss, destruction, falsification and leakage of personal data. We shall select service providers, which handle personal data in an appropriate manner, and will supervise service providers as necessary and appropriate to ensure the security control of the Personal data. 8. Your rights regarding the processing of personal data You have many rights regarding your personal data. Read more about them below. If you would like to exercise them or learn more, feel free to contact us! You can find contact detail at the end of this statement. Please note that some of the rights may not be applicable to your situation. • Right of access You have the right to know what personal data we process and why. That’s why we inform you in advance about our processing activities via this Privacy Statement. If you have any questions, or would you like to learn more about what information we process from you, you are always welcome to contact us and we will provide you with further information. • Right to rectification If you believe we store wrong information about you, such as your name or address, you can ask us to correct this. • Right to erasure / right to be forgotten You have the right to tell us to permanently erase your personal data from our records. You can do this for example if you believe there’s no longer any need for us to keep it. Or, if you previously have given your permission, you can just decide to withdraw it. • Right to restrict the processing activities You have the right to restrict our processing activities in certain situations. This means we will continue to store your information, but we’ll temporarily stop any other processing. Why would you want to do this? For example if you’ve asked us to fix incorrect information. In this situation you may want us to stop processing until the information is correct. • Right to data portability In certain situations you have the right to ask us to send your personal data in digital form to you, so that you can forward it to someone else. • Right to object You have the right to object to the processing of your information, even when we have a legitimate legal reason to process it. You can do this when we process your information on the basis of our legitimate interest, and you believe that your personal interest outweighs ours. If you do not want us using your information for direct marketing purposes, including profiling, we will comply in any case. • Right to withdraw consent If we process your personal data based on your consent, you have the right to withdraw your consent anytime. To exercise your rights, please contact us via gdpr@seafoodconnection.nl. Finally, if you aren’t satisfied with the way we treat your personal data, you have the right to lodge a complaint with the Dutch Data Protection Authority via the website. 9. Contact If you have questions about our privacy statement or practices or wish to exercise your rights, please feel free to get in touch. You can contact us at: Privacy Officer Het Spijk 12 8321 WT Urk The Netherlands gdpr@seafoodconnection.nl Follow us! Privacy