E&A Scheer Privacy Notice
This privacy notice (“Notice”) explains why E&A Scheer (“E&A Scheer”, “we”, “us”, “our”) processes your personal data when you (“User”, “you”, “your”) use our website (https://www.rum.nl/; “Website”) and when you use our blending tool (https://www.rum.nl/blending-tool/; “Blending Tool”) and which rights you have in relation to this processing.
1. Who is responsible and what for?
1. When you use our Website and/or the Blending Tool, E&A Scheer BV, incorporated under the laws of The Netherlands under enterprise number kvk 33158894 and having its registered seat at Herengracht 316, 1016CD Amsterdam, is responsible for the processing of your personal data.
2. If you have any questions regarding the processing of your personal data as described herein or regarding the content of this Notice, you can contact us using the e-mail address listed in the last clause of this Notice.
3. We reserve the right to change, amend or revise this Notice at our discretion and from time to time. We will inform you of such changes, amendments or revisions through the Website before these changes, amendments or revisions take effect. When we have been processing your personal data on the basis of your consent, we will again ask your consent with the changes, amendments or revisions to the Notice to the extent that they relate to the processing based on your consent.
2. The categories of personal data which we process, the reasons for doing so and the period for which we retain your personal data
1. Use of the Website
- When you use the Website, we collect automatically generated information (e.g. IP address, URLs you are visiting) and your interactions with the Website. All of this information is collected to allow you to use our Website.
- This information is collected on the basis of our legitimate interest to provide information to the market via a company website. You understand that such collection is required whenever you visit our Website.
- This information is only retained for a very short period, as required to provide you with the Website and keeping the Website safe.
2. Communication via the contact form, e-mail, telephone or social media
- When you communicate with us via the contact form on the Website, via e-mail, telephone or social media, we collect your name, contact information, the company you work for, your function, content of your communication and the metadata associated with the communication (e.g. which communication channel you use, when you communicated with us, who the participants to the communication were, any responses, etc.). All of this information is collected to be able to communicate with you.
- This information is collected on the basis of our legitimate interest to be able to respond to queries we receive from our correspondents and to maintain a relationship with those correspondents. You understand that if we were not able to process these personal data, responding to your inquiries would become difficult if not impossible.
- This information is only retained for as long as required to give due consideration to your inquiry. However, if you are or represent a customer or supplier, we will retain such communication as long as indicated under point 5 below. If you are an applicant, we will retain such communication as long as indicated under point 6 below.
3. Use of the Blending Tool
- When you use the Blending Tool, we collect your name, contact information, the company you work for, your function, the choices you select in the Blending Tool and the metadata associated with using the Blending Tool. This information is collected to allow you to use the Blending Tool and to build new relationships with potential customers. When you click the “get your TARGET sheet” button, you confirm that you understand that we will e-mail you a sheet with your personalized Rum Blend TARGET and that we will inquire whether you wish to receive further information.
- This information is collected on the basis of our legitimate interest to be able to inform the market of the possibilities of our products and to find new potential customers. You understand that if we were not able to process these personal data, it becomes impossible to use the Blending Tool.
- This information is retained for as long as required to follow up on your used of the Blending Tool or, if you become a customer, for the same duration as indicated under point 5 below.
4. Newsletters and digital marketing materials
- When we send you our newsletters or other digital marketing materials, we use your name, contact information, products and services which you purchased from or through us, your interactions with these materials once you have received them, your interests and your preferences related to receiving such materials.
- For our existing users we rely on our legitimate interest to send you our marketing materials to the extent that such materials relate to our existing or similar services which you already have bought or used form us. In all other circumstances, with the exception of sending you the sheet when using the Blending Tool as explained above, we will ask for your consent before we send you these materials. You are entitled to withdraw such consent at any time.
- This information is retained for as long as you remain a customer or, when you have given your consent, up until such time when you withdraw your consent.
5. You represent or act on behalf of one of our customers or suppliers
- We collect and use your name, function, company you work for, other contact details, information about the products and/or services which we procure from you, invoicing and financial information and, when available, information about the quality of the products and/or services you provide. We obtain this information directly from our interactions with you or from the company on behalf of which you have been in contact with us.
- We collect and use your information for relationship management and invoicing purposes and we rely on the necessity of this processing to perform our agreement with you, or – when you act on behalf of a company – because it is in our interest to be able to fulfil our contractual obligations to that company. It is in our interest to keep track of the quality of the products and services provided to us.
- This information is retained for as long as you remain, or continue to represent, our customer or supplier and until 7 years thereafter. For invoices the legal retention period will apply.
6. You apply for a job with us
- We collect and use your name, recruitment-related information, contact information, career information, information related to education, your personality, interests, family situation and all other information which you disclose through your cover letter, resume or during our interviews with you. All this information is obtained directly from you. If we do reference checks, we will inform you accordingly.
- We collect and use this information because it is necessary for our recruitment purposes. You understand that if you do not provide us with this information, we will not be able to consider you for the position for which you apply. We rely on the necessity of the processing to come to an employment agreement with you whenever you are participating in the application process. When we do not have an immediate position for you available, but we wish to retain your information for a potential future opportunity of which we wish to inform you via e-mail, we will ask for your consent.
- This information will be retained for as long as you are participating to the application process and until two months thereafter, unless you consented to us retaining your information for future opportunities. In the latter instance, we will retain your information for a maximum of two years.
7. General purposes for processing your personal data (using the personal data mentioned above)
a) Management reporting and statistics
- We process your personal data to be able to generate aggregated statistics which we use for internal management reporting as well as for discovering and communicating about trends, developments and opportunities. We rely on our legitimate interest to investigate, better understand and report on our business to process your personal data for this purpose. The aggregated statistics will be kept indefinitely, considering that they are completely de-identified.
– We process your personal data to keep our Website, the Blending Tool, its users, underlying systems and data safe and secure from incidents and threats, for which we rely on our legitimate interest to keep our services safe. The information we retain for security purposes are kept in automatic log files, which are kept for a maximum period of one year.
c) Legal obligations and legitimate requests
– We process your personal data to comply with legal obligations as well as to comply with any legitimate order from competent officials or representatives of the police, judicial authorities, government agencies or bodies including data protection authorities, for which we rely on our legal obligations. Any information required for this purpose will be retained as long as required by the relevant law or order.
d) Mergers and acquisitions
– We process your personal data to prepare and undertake corporate transactions such as mergers, acquisitions or demergers, for which we rely on our legitimate interest to engage in such transactions. The information will be retained for as long as required to finish the transaction process.
e) Defence in disputes and proceedings
– We process your personal data to defend ourselves in disputes and legal or other proceedings as well as to gather evidence and prepare our defence, for which we rely on our legitimate interest to be able to defend ourselves in such circumstances. The information will be retained for as long as it is required for our defence.
3. Who receives personal data which we have collected from you?
1. Affliated companies
– We will make your personal data available to other companies which are affiliated with us, but only to the extent it is relevant for the purposes listed above.
2. Governmental and judicial agencies, authorities or bodies
– We will make your personal data available to governmental and judicial agencies, authorities or bodies to comply with legal obligations or requests as explained above.
3. Debt collection agencies
– We reserve the right to transfer your personal data to a debt collection agency for the handling of unpaid invoices.
4. Service providers
– We rely on carefully selected third parties to assist us in providing you the Website and its associated services and communicating with you, such as financial institutions, insurance companies, external legal support, accountants and marketing and IT service providers. Your personal data are transferred to these service providers insofar necessary for realizing the purposes above.
5. Transport companies
– We send your personal data also to transport companies to the extent required to deliver products you have ordered from or through us.
6. Transfers to third countries
– Your personal data are stored on servers in The Netherlands. We may transfer personal data whenever required for the purposes listed above to the United Kingdom, for which we rely on the adequacy decision issued for the UK by the European Commission.
4. Which assurances do we provide?
1. We process your personal data only for the purposes listed in this Notice and will only share them with the third parties listed in this Notice for such purposes.
2. We take the necessary technical and organisational measures to protect your personal data against unauthorised access or theft and against accidental loss, alteration or destruction. We only allow access to your personal data on a need-to-know basis as explained herein and ensure that anyone who accesses these data on our behalf is bound by a contractual or statutory confidentiality obligation. You understand, however, that safety and security are only best-efforts obligations which can never be guaranteed.
5. Which rights do you have?
a). Right to access
– You have the right to request access to all personal data processed by us pertaining to you. To be able to grant this request, you must explain to which data you would like to have access. We reserve the right to charge an administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to us.
b). Right to rectification
– You have the right to ask that any personal data pertaining to you that are inaccurate, are corrected free of charge. If a request for correction is submitted, such request shall be accompanied of proof of the flawed nature of the data for which correction is asked.
c). Right to erasure
– You have the right to request that personal data pertaining to you will be deleted if they are no longer required in light of the purposes which are outlined above or if you deem the processing to be unlawful. However, you need to keep in mind that we will evaluate a request for deletion against:
1) our overriding interests or a third party’s to the extent legally allowed;
2) legal or regulatory obligations or governmental or judicial orders which may contradict such deletion.
Instead of deletion you can also ask that we limit the processing of your personal data if and when (a) you contest the accuracy of that data, (b) the processing is illegitimate or (c) the data are no longer needed for the purposes which are outlined above, but you need them to defend yourself in judicial proceedings.
d). Right to oppose
– You have the right to oppose the processing of personal data, but you must explain the serious and justified reasons connected with your particular circumstances which would warrant such opposition. This explanation is not needed when you oppose our processing of your personal data for direct marketing purposes.
5. How to exercise your rights
– If you wish to submit a request to exercise one or more of the rights listed above, you can send an e-mail to email@example.com for all data subject rights matters. An e-mail requesting to exercise a right shall not be construed as consent with the processing of your personal data beyond what is required for handling your request.
- Such request should clearly state and specify which right you wish to exercise and the reasons for it if such is legally required. It should also be dated and signed and accompanied by a digitally scanned copy of your valid identity card proving your identity. This we ask to avoid that unauthorized individuals would misuse your rights.
- We will promptly inform you of having received this request. If the request proves valid, we will notify you as soon as reasonably possible and at the latest thirty (30) days after having received the request.
- If you have any complaint regarding the processing of your personal data by us, you may always contact us via the e-mail address mentioned in the first paragraph of this clause. If you remain unsatisfied with our response, you are free to file a complaint with the competent data protection authority (https://autoriteitpersoonsgegevens.nl/).