NAVIGATIE PRIVACY STATEMENT 1. Who are we? 1.1. TOPS FOODS as controller With this Statement (hereinafter the "Statement") we would like to inform you why and how your personal data are collected and processed by TOPS FOODS NV, with registered office at 2250 Olen, Lammerdries - Oost 26, with company number 0451.053.463 (hereinafter jointly called "We" or "TOPS FOODS"). You can find our contact details under point 10 of this Statement. We are responsible for the processing of personal data that we request and use. As the controller we take the measures that ensure that you: - remain informed about our processing of your personal data and about your rights; - maintain control over the personal data that We process; - exercise your rights in relation to your personal data. More information about your rights can be found under point 9 of this Statement. 2. What information We collect about you? 2.1. Personal data By "personal data" we mean all information that refers to a certain living natural person. The type of personal data we collect depends on the services you request, and includes, where applicable, details of you and / or your representatives, staff, independent employees and / or directors (hereinafter together also referred to as "U" or " Your"). If We receive from You personal information from Your representatives, personnel, independent employees and / or directors, You must inform them of the existence and content of this Statement, including our duties, their rights and the way in which they can exercise these rights. In particular, we collect administrative data and contact details. With this we can identify you or contact you, or we can do business with you if you are a customer, a supplier or a business partner. This personal data may include contact details such as your name, address, telephone number, e-mail address, or your bank account number. We do not collect and process so-called sensitive data, namely: - personal data showing race or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; - genetic or biometric data (e.g. facial images and fingerprints); - health data; - data relating to sexual behavior or sexual orientation. If such sensitive personal information is provided to us, We will not use it and We will delete it. 2.2. Minors It is not our intention to process personal data of minors. 3. What do we need your data for? 3.1. Service and customer relationship What does this goal mean? We can use your personal data to create you as a customer and to sell our products and realize activities or services. Which personal data do We process for this? We collect and process your name, e-mail address, telephone number, address, national register number and professional capacity. 3.2. Information and commercial communication What does this goal mean? We wish to inform you about our services, events or relevant news items. This can be done at your explicit request, or if we suspect that you are interested in or benefit from a service. You will receive our direct marketing communication if you have given your explicit permission to do so. In particular, we will ask you for explicit permission if you are not a customer of us. But even if you do not give permission, you can still receive offers or advertising from us, especially if you already have an existing customer relationship with us. We rely on our legitimate interest for this. If you do not want any advertising at all, use your right of opposition to direct marketing, as stated in point 9.2 of this Statement. Which personal data do We process for this? We collect and process your name, e-mail address, telephone number, address, as well as data relating to the areas of interest you have indicated. 3.3. Because it is necessary to be able to function as a company What does this goal mean? This purpose amounts to what is called a "legitimate interest". We do indeed have a number of legitimate interests that form the basis for the processing of personal data. This only happens after we have weighed up and the balance between our legitimate interests and the possible impact on your privacy is not disturbed. If you do have objections to these processing operations, you can exercise your right of objection, as stated in point 9.3 of this Statement. For example, personal data are processed in different situations: - Personal data can serve as evidence (archives); - Personal data can be used to establish, exercise, defend and safeguard our rights of or the persons who may represent us, for example in case of disputes; - Personal data can be used for the management, (risk) management and control of our organization, such as compliance (such as money laundering and fraud prevention and investigations, and privacy), risk management, risk functions and inspection, complaints management, internal and external audit; - Personal data can be used to support and simplify the purchase, use and termination of services by the customer, among other things, in order to avoid having to re-enter information that you have already passed on. 3.4. Profiling Your personal data will not be used for profiling purposes. 3.5. Cookies Our websites (www.topsfoods.com and www.topscare.com) use cookies, namely small text files that are stored on your device, and similar technologies. More information about this can be found in our cookie statement that can be consulted on our websites. 4. Do We ask Your permission for processing? 4.1. General Your personal data can only be used and processed lawfully by us if one of the following conditions is met: - The use of your personal data is necessary for the execution of an agreement that you have concluded with us or to take, at your request, the necessary steps to reach an agreement with us. The processing purposes mentioned in section 3.1 of this Statement are based on this basis. - We have your explicit and freely given permission to use your personal data for a specific purpose. For example, we will ask for your permission to register you for direct marketing purposes, as mentioned in section 3.2 of this Statement, if you do not yet have a customer relationship with us. - The use of your personal data is necessary for the representation of our legitimate interests, to the extent that this outweighs your interests and rights; We base the processing that is necessary to function as a company on our legitimate interest, as stated under section 3.3 of this Statement, and to be able to derive our existing customers from direct marketing considerations, as mentioned in section 3.2 of this Statement. - We may be legally obliged to process certain data, and in particular pass on to the authorities involved. 5. With whom do we share your personal data? - Only our employees who need access for the performance of their duties will have access to your data. These persons act under our supervision and responsibility. - We also call on external suppliers who carry out certain processing for us so that We can offer our products and activities to You, such as IT services, financial, accounting and similar other services. Since these third parties have access to personal data within the framework of the services we have requested, We have taken technical, organizational and contractual measures to ensure that your personal data are only processed and used for the purposes mentioned under section 3 of this Statement. - Only if We are legally obliged to do so, Your personal data may be provided to supervisory institutions, tax authorities and research services. 6. Where are the data stored and processed? Your data will not be transported outside the EU and in any case We ensure that the legal minimum requirements and safety standards are respected at all times. If We foresee that Your data will be stored and processed outside the EU, We will explicitly state this and ensure that the same level of protection is applied as applicable within the EU. Your personal data will never be transferred or made available to third parties outside these cases and will only be used for our benefit. Other companies can not use your data to send you e.g. advertising. 7. How long do we keep your personal data? We will only keep Your data for as long as necessary for the purposes for which We use the data as mentioned under section 3 of this Statement. Any deviations or clarifications of this principle are explicitly mentioned under the various purposes mentioned under section 3 of this Statement. Because the need to store data may vary depending on the data type as well as on the purpose of the processing, actual retention periods may vary considerably. We can hereby inform you that We include the following criteria in determining the claim times: - How long do We need to retain personal data to be able to provide the requested service? - Have We established and announced a specific retention period? - Have We received permission for a longer storage period? - Do we have a legal, contractual or comparable obligation to keep the data? As soon as your data is no longer required and we do not have a legal obligation to retain it, we will permanently delete it or, if this is not possible, make it anonymous in our systems. Your personal data will be retained and used for as long as necessary to comply with our legal obligations, to settle disputes or to enforce our agreements. 8. How do we secure your personal data? Your personal data are considered to be strictly confidential. We take the appropriate technical and organizational measures to protect the provided and collected personal data against destruction, loss, accidental alteration, damage, accidental or unlawful access or any other unauthorized processing of personal data. 9. Wat are Your rights? 9.1. Right of access, rectification, erasure, transferability of data and of objection 9.1.1. Right to inspect Your personal data You always have the right to access and view your personal data that we process. We will provide You with a free copy of this personal data if You so request. For the exercise of your rights we refer to section 9.3. of this Statement. 9.1.2. Right to improve your personal data You always have the right to have incorrect, incomplete, inappropriate or outdated personal data removed or rectified. For the exercise of your rights we refer to section 9.3. of this Statement. If you dispute the accuracy of the personal data, you may also request a limitation of the processing during a period that enables us to check the correctness of the personal data. If you have obtained the right to the limitation of the processing, we will, apart from storing the data, no longer carry out any transactions with the personal data concerned. 9.1.3. Right to withdraw your consent If the processing is based on your consent as set out in section 4.1., You have the right to withdraw this consent at any time. For the exercise of your rights we refer to section 9.3. of this Statement. 9.1.4. Right to object to certain processing operations When your personal data are processed on the basis of a legitimate interest on our part, you have the right to object to the processing of your personal data in case of reasons related to Your specific situation. For the exercise of your rights we refer to section 9.3. of this Statement. If you object to a particular processing for which we rely on our legitimate interest, you may also request a limitation of the processing during a period that enables us to check the correctness of the personal data. If you have obtained the right to the limitation of the processing, we will, apart from storing the data, no longer carry out any transactions with the personal data concerned. 9.1.5. Right to erase your personal data You have a right to erase your personal data. On this basis, if you no longer wish to have a relationship with us, you can ask us to stop using your personal data. However, we can keep personal data that is required for proof purposes. Under this removal right you also have the right to ask us at any time to stop using your personal data processed on the basis of your permission or our legitimate interest. Due to legitimate interests, we can still process your personal data after weighing your interests with ours, unless you decide to terminate the relationship with us. For the exercise of your rights we refer to section 9.3. of this Statement. 9.1.6. Right to transfer personal data With regard to the processing of your personal data on the basis of your consent or because this is necessary for the delivery of the requested products or services, you can ask us to send your personal data - in a structured, current and digital form - to you. so that you can save it for personal (re) use, or to forward this personal data directly to another data processing officer, as far as this is technically possible for us. For the exercise of your rights we refer to section 9.3. of this Statement. 9.2. Right of objection against direct marketing As stated above in section 4.1 We ask Your permission to address commercial information, advertising or personal proposals to you (via direct marketing campaigns or electronic newsletters). You have the right to object to the processing of your data for direct marketing purposes, if you do not wish to receive such communications (anymore) from us. In this case, we will no longer process your data for direct marketing purposes. Your application will be executed as soon as possible. For the exercise of your rights we refer to section 9.3. of this Statement. If you have exercised your right of objection, you can, if you wish, reinstate direct marketing activities via the same channels. We draw your attention to the fact that your exercise of the right of objection does not prevent us from contacting you for any other purpose, including the execution of the contract, in accordance with this Statement. 9.3. How exercise this right? To exercise the above mentioned rights, you can address a request to us in the following manner: In writing to the following postal address: 2250 Olen, Lammerdries - Oost 26 (with respect to the Office Manager) When exercising your right, we request that you clearly state the right to which you wish to appeal and against which processing(s) you oppose or which consent you wish to withdraw. 9.4. Points of attention when exercising the rights We wish to inform you that the objection to certain processing or the withdrawal of your consent for certain processing of your personal data may result in you no longer being informed or being able to use our offered activities or services. 10. How to submit questions or complaints If you have a question or complaint about how we process personal data, you can contact us using the following channels: In writing to the following mailing address: 2250 Olen, Lammerdries - Oost 26 (with respect to the Office Manager) If you are not satisfied with our reply, if you have comments about the exercise of your rights or if you believe that our processing of your personal data is not in accordance with the legislation, then you have the right to submit a complaint about this to the Data protection authority. All information can be found here: https://www.gegevensbeschermingsautoriteit.be/. 11. Adjustments to this Statement This Statement can be adjusted or completed by us when deemed necessary. If significant changes are made to this Statement, the date of the statement will be modified and We will inform You of this change and provide you with a copy of the updated statement. We also encourage you to periodically review this Statement to find out how We process and protect Your personal data. QUESTIONS ABOUT OUR PRIVACY POLICY? CONTACT US! TOPS FOODS NV | Lammerdries - Oost 26 | B-2250 OLEN | VAT BE0451.053.463 RPR Turnhout Tel.: 0032 (0) 14 28 55 60 | Fax.: 0032 (0) 14 28 55 80 | E-mail: info@topsfoods.com | www.topsfoods.com Privacy statement Disclaimer Made by Liswood & Tache in Browsbox