1.1 1. Introduction
1.1.1 1.1 Questions?
1.2 2. Your rights
1.2.1 2.1 Right to access your personal data
In case you have any questions regarding the personal data we process; you have the right to access any personal information we maintain about you. Provision of such information will be subject to the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address). We may withhold personal information that you request to the extent permitted by law.
1.2.2 2.2 Right to correct or to remove your personal data
In case the personal data we maintain about you is not correct; you have the right to request we either correct or remove the personal data Walraven maintains about you. Please send us a request using the above contact details.
1.2.3 2.3 Use of your personal data for marketing/sales related correspondence
You may instruct us at any time not to process your personal information for marketing/sales related correspondence. In practice, you will usually either expressly agree in advance to our use of your personal information for these purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes. For this, you can use the ‘unsubscribe’ hyperlink in marketing/sales correspondence. You can also send us a request using the above contact details.
1.3 3. Personal data we process
We can maintain personal data depending on your relationship(s) with Walraven. Below we describe the types of relationship(s) you may have with Walraven and how we maintain personal data for each type of relationship.
1.3.1 3.1 Through electronic newsletters
You can subscribe to one or more of our electronic newsletters via our website. We will always ask for an ‘opt-in’, meaning that you will explicitly provide your consent that we may contact you via newsletters. At any time, you can unsubscribe to electronic newsletters by clicking the ‘unsubscribe’ link which is provided in each newsletter. After unsubscribing to our newsletter, your personal data will be removed from our records.
1.3.2 3.2 As a commercial relationship
Walraven’s marketing and sales teams aim to build good relationships with (a) customer contact persons and (b) contact persons of organisations who are not (yet) a customer. In building commercial relationships in most occasions, it is necessary that personal (contact) information is exchanged. For example during a marketing/sales activity or campaign, a meeting with Walraven, during a trade fair, exhibitions, symposia and through direct established contacts by a Walraven employee. Providing personal data in this context is always on a voluntarily basis only. Personal data you provided in this context is maintained in our Customer Relationship Management system, and will be removed when no longer necessary for the purpose you provided this data, unless you notified us that you want to be kept up to date with our solutions and activities.
1.3.3 3.3 As a customer
Walraven is only active in the B2B market. This means that Walraven sells its solutions, products and services to organisations. In case you acquire our solutions, products and/or services directly from Walraven you have become a customer. In this case you will be registered as a customer in our information systems. This registration will include the personal contact details of one or more contact persons of the customer. This personal data will be updated or removed if you are no longer a customer of Walraven and/or there is a change in contact person of your organisation.
1.3.4 3.4 As a supplier / business partner / other business relationship
Walraven maintains relationships with suppliers of raw material, components, trade goods and also maintains relationships with business partners and other organisations (like accountancy / payroll / IT service providers). For these relationships, it is necessary to register the personal contact details of one or more contact person(s). This personal data will be updated or removed if the organisation is no longer a relation of Walraven and/or there is a change in contact person of that organisation.
1.3.5 3.5 As participant of training / visiting showroom
As a training participant or as a visitor to our showroom, in some occasions it is necessary that you leave your personal (contact) details. On a voluntarily basis only. These details we may use to contact you for evaluation purposes or to send you additional information in case you requested this. Personal data you provided in this context will be removed when no longer necessary for the purpose you provided this data, unless you notified us that you want to be kept up to date of our solutions and activities.
1.3.6 3.6 Enquiries
In case you approach Walraven with an enquiry or questions, for instance about our solutions, products or services, we will not record your personal information, unless we need to get back to you for additional support or enquiry. If this is the case, we will remove your personal data as soon as you have been provided with an answer. This includes enquiries via telephone, email, fax and the [local ‘Ask Your Question’] form on our website.
1.3.7 3.7 When visiting our website
Of any person visiting our website, we gather usage statistics including IP address (anonymised, only traceable to a geographic area and not to a specific person/connection), geographical location and visiting statistics (including duration of visit and page views). We use these statistics to improve our website, solutions or services. Please also refer to 7, Cookie and tracking policy.
1.3.8 3.8 When visiting our premises
Our building and surroundings (parking space) may be secured with CCTV (camera). You are notified of this the moment you enter our premises. CCTV data is kept for security purposes only, for 72 hours at a maximum, unless there is a reason to keep this data longer (for instance for a police investigation).
1.4 4. Retention of personal data
In any of the above relationships, we will not keep your personal data for longer than is necessary for that purpose or those purposes. However, we will retain documents (including electronic documents) containing personal data:
* to the extent that we are required to do so by law;
* if we believe that the documents may be relevant to any ongoing or prospective legal proceedings;
* in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
1.5 5. Sharing personal data
In any of the relationships described above, we will use your personal data for the sole purpose of this relationship. We never sell, trade or rent your personal details to others outside Walraven without your consent or without one of the situations described below.
1.5.1 5.1 Sharing of personal data within the Walraven Group
1.6 5.2 Sharing of personal data
1.6.1 5.3 Third parties processing personal data under our control
Walraven uses third parties like service providers (like payroll), external hosting providers or Software as a Service (SaaS) providers that process personal data under our control. In the case where a third party processes personal data under our control, Walraven ensures that a Data Processing Agreement (as described in the GDPR) is in place.
1.6.2 6. Securing personal data
We implemented appropriate technical and organizational measures to protect your personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access and against all other forms of unlawful processing. Also, we require our data processors to implement such appropriate technical and organizational measures. For this, we have implemented an Information Security Management System based on ISO/IEC 27001:2013. In the unlikely event of a (suspected) personal data breach we will notify you and the appropriate Data Protection Authority within 72 hours after discovery, according to the rules set out in the GDPR.
© 2018 Walraven