Privacy- en Cookieverklaring
13 March 2020
Waarop is deze privacy- en cookieverklaring van toepassing?
This Privacy Statement, as summarised in Appendix 1, governs the processing of your personal data by a Milcobel Group entity (jointly referred to hereinafter as: “Milcobel”, “we” and “us”), when you:
- visit one of our websites (referred to hereinafter as: “the Websites”);
- wish to communicate with us by email, telephone, fax and social media (referred to hereinafter as: “Social Media channels”, for example, Facebook, LinkedIn, Instagram and the like); or
- wish to communicate with us at trade shows and events.
- Your personal data are processed by an entity belonging to the Milcobel group, acting in its capacity as controller. The contact details of our head office, which you can address if you have any questions and/or remarks whatsoever relating to this Privacy Statement are: Milcobel, Fabriekstraat 141, haven 1140, 9120 Kallo (Beveren) in Belgium, the enterprise number of which is 0870.019.427. You can send your questions by email to the person in charge of privacy at Milcobel: Christophe Guilmin, email@example.com.
- You must interpret the concepts in this statement in the manner referred to in the General Data Protection Regulation (Directive (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data and repealing Directive 95/46/EC).
- Where reference is made to certain laws or regulations, such reference also includes any amendment, replacement or declaration of nullity of the said laws or directives, including any related implementation decrees.
- Milcobel reserves the right to change or adjust this Privacy Statement from time to time. Such change or adjustment will be communicated through the Websites
Types of personal data we process
- We collect the following when you visit our Websites and Social Media channels:
- technical information about the device that you use, such as your IP address, type of browser, geographic location and operating system;
- information about your surfing behaviour, such as how long you visit a page, which links you click, which pages you visit and how often you visit a page.
- We collect the following when you complete the contact form on our Website or contact us by email, telephone, fax or Social Media channels and ask a practical question, submit a complaint or request that you be sent our newsletter:
- the basic identity details that you send us, such as name, email address, correspondence address and telephone number;
- the content of your communication and the technical details of the communication as such (with which one of us you correspond, the date, time, etc.);
- publicly available information on your profile on the Social Media channels;
- any other personal data that you send us (such as your allergies).
- We collect the following when you solve a competition question on our Websites or Social Media channels:
- the basic identity details that you send us, such as name, email address, correspondence address, telephone number and your address;
- the answers to the question.
- We collect the following when you submit a request for sponsorship by email, telephone, fax and Social Media channels:
- the basic identity details that you send us, such as name, email address, correspondence address, telephone number, the company for which you work and your position;
- information regarding the event sponsored, such as the nature of the event, the date and location of the event and other information that you send us and
- your photograph.
- When we organise events that you attend, we collect the following:
- the basic identity data that you send us, such as your name, email address, correspondence address, the company for which you work, telephone number and your position;
- data relating to your stay in a hotel, such as the location of the hotel, the time of the stay in the hotel and the type of hotel;
- your photograph when we make images of the event.
- We can collect the following about you when you leave your business card with us or speak to us at trade shows and events that we attend:
- the basic identity data that you send us, such as name, email address, correspondence address, telephone number, the company for which you work and your position (i.e. when you provide such data or where they are stated on your business card);
- your photograph.
- We collect the following about you when you wish to use an e-coupon:
- the basic identity data that you send us, such as name, email address and correspondence address;
- your consumption habits;
- the electronic identification data.
Purposes for which Milcobel uses your personal data
- Milcobel processes your personal data to enable us to react to your complaint and/or question or to communicate with you at a trade show or event.
- Milcobel processes your personal data to contact you if you have won a competition in which you participated.
- Milcobel processes your personal data to finalise your application for sponsorship and perhaps conclude a sponsorship agreement with you.
- Milcobel processes your personal data where that is necessary to enable us to defend ourselves in proceedings in court or in any other procedures.
- Milcobel processes your personal data to perform statistic analyses and thereby improve our Websites and services or develop new products and services.
- Milcobel processes your personal data to arrange your accommodation if you come to a trade show or event that we organise and where we assume responsibility for the accommodation arrangements.
- Milcobel processes your personal data to share them on our Websites or Social Media channels.
- Milcobel processes your personal data to make an e-coupon available to you.
- Milcobel processes your personal data to comply with the statutory obligations or to comply with any reasonable request by competent policemen or police representatives, agents or representatives of judicial authorities, government institutions or authorities, including competent data protection authorities. Milcobel can, at its own initiative, transmit your personal data to the police or to the judicial authorities as proof or, if there is a legitimate assumption of an unlawful act or crime that you have committed by, or with the aid of, the use of the Websites, our Social Media channels or other communication with us.
- Milcobel can process your personal data to protect the legitimate interests of Milcobel, its partners or any third party and if your use of the Websites or communication via our Social Media channels can be regarded as (a) a breach of the applicable terms and conditions of use or of intellectual property rights or of any other third-party right, (b) a threat to the safety and integrity of the website, (c) a danger to the website or one of the underlying systems of Milcobel or its subcontractors pursuant to viruses, Trojan horses, spyware, malware or any other form of harmful code, or (d) that is vindictive, obscene, discriminating, racist, defamatory, hateful, hurtful or inappropriate or illegal in any other manner whatsoever.
- Milcobel can process your personal data to inform any third party within the context of a possible merger with, acquisition of/by or splitting-off of such third party or comparable corporate transaction, even where such third party is established outside the EU.
- Milcobel processes your personal data for marketing purposes, i.e. to provide you with targeted communication, promotions, offers and other advertisements of Milcobel and selected partners. Unless you are a current customer who has already bought similar goods or services from us and whom we wish to target with our own marketing resources, Milcobel will send you notifications, promotions, offers, newsletters and other advertisements by email or other direct person-to-person electronic communication systems only if you have expressly consented to receiving such communications, offers, newsletters and other advertisements.
Grounds for processing your personal data
- The processing of your personal data for the purposes outlined in clauses 3.2, 3.6, 3.7 and 3.8 is based on your consent. If we collect health data from you (such as information on your allergies) within the context of a question or complaint addressed to us such as set out in clause 3.1, you acknowledge that posing the question or making the complaint entails your consent to processing such personal data. We will also ask you for your consent if we collect your personal data and you are not yet one of our customers as referred to in clause 3.12. By consenting to the processing of your personal data for the dispatch of notifications, promotions, offers, newsletters and other advertisements by email or other person-to-person electronic communication systems, you consent to allowing us to process your personal data for this purpose in the manner and subject to the terms and conditions laid down in this Privacy Statement.
- Processing your personal data for the purpose set out in Article 3.3 is necessary for the steps that we take before concluding a sponsorship agreement with you.
- Processing your personal data for the purposes referred to in Article 3.9 is necessary to enable Milcobel to comply with the statutory obligations on our part.
- Processing your personal data for the purposes referred to in clauses 3.1, 3.4, 3.5, 3.10, 3.11 and 3.12 is necessary for the legitimate interest of Milcobel, namely, to:
- be able to appropriately react to your requests regarding information and other requests and to communicate with you;
- enable us to defend ourselves in judicial proceedings;
- continuously make it possible to improve the Websites of Milcobel, the Social Media channels, products and services;
- protect our Websites, Social Media channels, products and services from being misused and against illegal activities;
- protect our commercial and real interest and to accommodate the needs in the light of changing market circumstances;
- to enable the conventional direct marketing and promotion of our products, services, brands and successful commercialisation of our products and services.
Recipients and transfers
- Except for the situation outlined in clause 5.2 below, Milcobel will not identifiably transmit your personal data to third parties without your express consent. However, you should understand that if you use our Social Media channels, your personal data will also be processed by the persons providing such social media. You will find more information regarding the manner in which such providers process your personal data in their respective privacy statement.
- Milcobel collaborates with external processors such as IT providers and marketing service providers to provide you with the Websites, to allow us to advertise and to process your personal data for us. Such external processors may only process your personal data for Milcobel at the express and written instruction of Milcobel. Milcobel guarantees that all external processors are selected with the necessary care and are obliged to duly regard the safety and integrity of your personal data.
- Milcobel does everything possible to process only those personal data that are necessary to achieve the purposes outlined above.
- Your personal data are only kept for as long as this is necessary to achieve the objectives outlined above or until the moment that you withdraw your consent to processing them. Please note that withdrawing the consent can have the consequence that you will no longer be able to use the full or a part of the Websites or that we will need to discontinue providing certain services. Milcobel will de-identify your personal data when they are no longer necessary for the purposes outlined above unless:
- there is a decisively important interest of Milcobel or of another party to keep your personal data identifiable;
- there is a statutory or regulatory obligation or a judicial or administrative order that prevents Milcobel from identifying them.
- Milcobel will take the appropriate technical and organisational measures to protect your personal data against unauthorised access or theft, as well as against unintentional loss, fraud or destruction. Milcobel will only grant access to the personnel or the external processing companies that process our personal data for us on the grounds of the need-to-know principle. This means that both the personnel and such external processing companies are subjected to strict confidentiality obligations. You should understand, however, that safety and protection are obligations to perform to the best of your ability.
- You have the right to request us to view all personal data that we process of you. You must always specify with regard to which processing activities you wish to exercise your viewing right.
However, Milcobel has the right to reject certain requests if such requests are clearly aimed at causing nuisance. Milcobel also has the right to reject a viewing request if granting it has disproportionately negative implications for the rights and freedoms of others, including Milcobel.
- You have the right to request that any personal data that relate to you and that are incorrect, be corrected free of charge. If a request for correction is submitted, such request must be accompanied by proof of the incorrect nature of the data for which correction is requested.
- You have the right to withdraw the consent that you previously granted for processing your personal data under Article 4.4.
- You have the right to request that personal data relating to you be erased if they are no longer required in view of the purposes outlined above or if you withdraw your consent. However, you must keep in mind that a request to Milcobel to erase the data will be weighed up against the following:
- decisively important interests of Milcobel or any other third party;
- statutory or regulatory obligations or administrative orders or orders authorised by law that can contradict such withdrawal.
Instead of erasure, you can also request Milcobel to restrict the processing of your personal data if and when (a) you dispute the correctness of such data, (b) processing them is unlawful or (c) the data are no longer necessary for the purposes outlined above but you need such data to defend yourself in judicial proceedings.
- You have the right to oppose the processing of personal data if you find yourself in a special and specific situation that provides a legitimate cause for such opposition. You must notify us of such situation, however, so that we can correctly assess your request. Yet, if the intended processing can be regarded as direct marketing, you have the right to oppose such processing free of charge and at all times.
- You have the right to receive from us in a structured, generally used and machine-readable format any personal data that you have provided to us as outlined in Articles 4.1 and 4.2.
- You can address the person responsible for privacy at Milcobel to exercise your rights as referred to in this statement. To do so, you must submit a written request by writing to the above-mentioned email address, in which you clearly state to which right your request relates and give reasons for your request. In addition, you must add a copy of your valid identity card on which the validity date and your signature are clearly visible to prevent any unauthorised or fraudulent requests.
You will be sent an acknowledgement of receipt of your request as soon as the person responsible for privacy at Milcobel has received it. Your request will then be handled within a reasonable period.
If you are still dissatisfied thereafter, you can address the Belgian Data Protection Authority, https://www.gegevensbeschermingsautoriteit.be/verzoek-klacht-indienen.
The Milcobel group consists of the following entities and this Privacy Statement therefore applies to them:
- Milcobel CV, Fabriekstraat 141, haven 1140, 9120 Kallo (Beveren) in Belgium, the enterprise number of which is 0870.019.427. Please note that this entity is the head office of the Milcobel group. All questions and/or comments regarding this Privacy Statement are addressed to and subsequently answered by this entity in accordance with this Privacy Statement;
- Milcobel 3 F CV, Fabriekstraat 141, haven 1140, 9120 Kallo (Beveren) in Belgium, the enterprise number of which is 0424.899.491;
- Belgomilk CV, Fabriekstraat 141, haven 1140, 9120 Kallo (Beveren) in Belgium, the enterprise number of which is 0870.017.447;
- Kaasimport Jan Dupont NV, Lieven Bauwensstraat 9, 8200 Bruges in Belgium, with enterprise number 0405.109.216;
- Cheeseline NV, Lieven Bauwensstraat 9, 8200 Bruges in Belgium with enterprise number 0441.187.078;
- Dupontcheese Nederland BV, Escudoweg 1, 2153 PC Nieuw-Vennep in the Netherlands, with Chamber of Commerce number 28047982;
- Camal SA, Rue Légipont 12, 4671 Blégny in Belgium with enterprise number 0412.859.912;
- Ysco NV, Fabriekstraat 141, haven 1140, 9120 Kallo (Beveren) in Belgium with enterprise number 0472.336.451 and
- Ysco France SAS, 53 Avenue de la 2e D.B., 61206 Argentan, France, with enterprise number 43531711000011.