Privacy Policy

1) Introduction

This privacy policy explains how we process your personal data. The term ‘personal data’ refers to any information relating to an identified or identifiable natural person. Additionally, this policy provides information about your privacy rights and our obligations. The privacy policy is divided into the following sections:

1. Introduction
2. Which personal data do we process, for what purposes, and on what basis?
3. With whom may we share your personal data?
4. How long do we retain your personal data?
5. How do we protect your personal data?
6. What are your privacy rights and how can you exercise them?
7. Where can you go if you have a complaint or question about the processing of your personal data?

We reserve the right to amend this privacy policy. The most recent version of this privacy policy is available on our website. If substantial changes occur that may significantly affect one or more individuals, we aim to inform those individuals directly.

In carrying out our activities, we may process personal data. Under the applicable data protection laws – in particular, the General Data Protection Regulation (GDPR) – we qualify as the data controller.

2) Which personal data do we process, for what purposes, and on what basis?

Depending on the relationship you have with us, we process certain personal data.

• If you are a business relation, refer to section 2.1 of this privacy policy.
• If you have ordered a product in our webshop, refer to section 2.2.
• If you have purchased a product in one of our physical stores, refer to section 2.3.
• If you are applying for a job with us, refer to section 2.4.
• If you visit one of our events, refer to section 2.5.
• If you visit one of our locations, refer to section 2.6.
• If you visit our website, refer to section 2.7.
• If you contact us via email or otherwise, refer to section 2.8.

In these sections, we also indicate why we process this personal data (‘purposes’) and on which legal grounds we base this. We process your personal data on one or more of the following legal grounds:

• When it is necessary for the performance of a contract to which you are a party or to take pre-contractual steps at your request;
• When it is necessary to comply with a legal obligation;
• When it is necessary to protect our legitimate interests or those of a third party;
• With your consent.

When we process your personal data based on your consent, we will ask for this separately. You can always withdraw your consent (see also section 6, “What are your privacy rights and how can you exercise them?”). Please note that withdrawing your consent does not affect the lawfulness of processing based on consent before its withdrawal.

When processing is based on ‘legitimate interest,’ this interest is briefly explained. If you have specific questions about this, you can always contact us.

2.1) You are a business relation

In the context of establishing a business relationship and concluding an agreement, we may process the following personal data that we collect directly from you or from public sources (such as the Commercial Register and the Chamber of Commerce):

• Initials, first and last name, title, gender, signature, address;
• Other contact details such as phone number, email address, and fax number;
• Payment information (including bank account number), company information, information about the legal representative, information about the Ultimate Beneficial Owner, certain identity document details, function, extracts from registers (public or not), VAT registration, order information.

Here we indicate for which purposes we process this personal data, with the associated legal grounds (a to d as described above):

• To register you, identify you, and verify if you are authorized to represent our customer (a, b, c: the interest to offer and provide or receive services);
• To draw up and conclude agreements with you (a, b, c: the interest to offer and provide or receive services);
• To provide the agreed services to you or receive them from you (a, b, c: the interest to offer and provide or receive services);
• To maintain proper administration (a, b, c: the interest to maintain proper administration);
• For invoicing and payment purposes, including debt collection (a, b, c: the interest to maintain proper administration and make or collect payments);
• To conduct audits, internal controls, and accountant checks (a, b, c: the interest to maintain proper administration);
• To keep in contact with you and communicate with you (a, b, c: the interest to bring our services to the attention of existing customers), d;
• To send you newsletters and keep you informed about offers (a, b, c: the interest to bring our services to the attention of existing customers, d);
• To handle any complaints and disputes, including assessing our legal position, defending it, and exercising our rights (a, b, and c: for the defense of rights, maintaining and improving existing relationships through good complaint handling, improving the quality of service);
• To comply with our legal obligations (b, c: the interest to meet these legal obligations).

2.2) You have ordered a product in our webshop

When you order a product in our webshop, we may process the following personal data provided by you:

• Initials, first and last name, title, gender, address;
• Other contact details such as phone number, email address, and fax number;
• Payment information (including bank account number), order information.

Here we indicate the purposes for which we process this personal data, with the associated legal grounds (a to d as described above):

• To offer and provide the agreed services to you, including creating an account with the option to log in and place an order (a, b, c: the interest to offer and provide services);
• To draw up and conclude agreements with you (a, b, c: the interest to offer or receive services);
• To maintain proper administration (a, b, c: the interest to maintain proper administration);
• To optimize and personalize your shopping experience (c: the interest to provide you with the best possible personalized shopping experience and d);
• To keep in contact with you and communicate with you (a, b, c: the interest to bring our services to the attention of existing customers);
• To send you newsletters and keep you informed about offers (c: the interest to bring our services to the attention of existing customers, d);
• To handle any complaints and disputes, including assessing our legal position, defending it, and exercising our rights (a, b, and c: for the defense of rights, maintaining and improving existing relationships through good complaint handling, improving the quality of service);
• To comply with our legal obligations (b, c: the interest to meet these legal obligations).

2.3) You have purchased a product in one of our physical stores

When you purchase a product in one of our stores, return it, or request a repair, we may process the following personal data provided by you:

• Initials, first and last name, title, gender, signature, address;
• Other contact details such as phone number and email address;
• Payment information, order information.

Here we indicate the purposes for which we process this personal data, with the associated legal grounds (a to d as described above):

• To offer and provide the agreed services to you (a, b, c: the interest to offer and provide services);
• To maintain proper administration (a, b, c: the interest to maintain proper administration);
• To keep in contact with you and communicate with you (a, b, c: the interest to bring our services to the attention of existing customers);
• To handle any complaints and disputes, including assessing our legal position, defending it, and exercising our rights (a, b, c: for the defense of rights, maintaining and improving existing relationships through good complaint handling, improving the quality of service);
• To comply with our legal obligations (b, c: the interest to meet these legal obligations).

2.4) You want to apply for a job with us or have applied

When you apply for a job with us, we may process the following personal data provided by you or via third parties (such as an employment agency or recruitment firm) or obtained by us from other public sources (such as social media):

• Initials, first and last name, title, gender, address;
• Other contact details such as phone number and email address;
• Nationality, place, and date of birth;
• Availability, CV (possibly with photo) and work history, educational history (copies of diplomas, certificates, testimonials), cover letter;
• Notes from interviews and written communication with the applicant;
• Where relevant for the open vacancy: (written) references, screening results, Certificate of Conduct (VOG), Security Screening (VGB).

Here we indicate the purposes for which we process this personal data, with the associated legal grounds (a to d as described above):

• Recruitment and selection (a, b, c: our interest to assess if you are suitable for the open vacancy and d: consent if you wish to remain in our portfolio longer, see: “How long do we retain your personal data?”);
• To keep in contact with you and communicate with you (a, b, c: the interest to properly follow the procedure);
• To comply with agreements we have with employment agencies and secondment agencies (a, b, c: our interest to comply with our agreements);
• Internal control and corporate security (c: our interest in processing correct information and creating a safe environment for our employees and visitors);
• Improvement of the application process (c: our interest in improving our application process);
• Handling questions, comments, and complaints (a, b: maintaining and improving contact with applicants through good complaint handling, improving our application process, and resolving complaints);
• To comply with our legal obligations (b, c: the interest to meet these legal obligations).

2.5) You visit one of our events

When you visit an event, we may process, depending on the type of event, the following personal data provided by you or created by us:

• Initials, first and last name, title, gender, address;
• Other contact details such as phone number and email address;
• Place and date of birth;
• CV (possibly with photo) and work history, cover letter;
• Photo and video images of the event.

Here we indicate the purposes for which we process this personal data, with the associated legal grounds (a to d as described above):

• To provide you access to the event and identify you where necessary and maintain proper administration (a, b, c: our interest in ensuring a safe environment for employees and visitors and maintaining proper administration);
• To enable payments (a, b, c: our interest in maintaining proper administration);
• To keep in contact with you and communicate with you (a, b, c: the interest to optimally provide our services to you);
• Recruitment and selection (a, b, c: our interest in assessing if you are suitable for the open vacancy and d: consent if you wish to remain in our portfolio longer, see: “How long do we retain your personal data?”);
• Internal control and corporate security (c: our interest in processing correct information and creating a safe environment for our employees and visitors);
• For marketing and promotional purposes (c: concerning existing customers: our interest in bringing our events, products, and services to their attention, d);
• Handling questions, comments, and complaints, including assessing our legal position, defending it, and exercising our rights (a, b, for maintaining and improving contact with applicants through good complaint handling, improving our application process, resolving complaints, and defending rights);
• To comply with our legal obligations (b, c: the interest to meet these legal obligations).

2.6) You visit one of our locations

When you visit one of our locations, we may process the following personal data, which we obtain directly from you or through third parties (such as security services):

• Initials, first and last name, name of organization, contact person;
• Email address, phone number;
• Document number of identification, signature;
• Date, arrival, and departure time;
• Camera footage;
• License plate.

Here we indicate the purposes for which we process this personal data, with the associated legal grounds (a to d as described above):

• To provide you access to our locations and identify you where necessary and maintain a proper access administration (a, b, c: our interest in ensuring a safe environment for employees and visitors and maintaining proper administration);
• The security of our locations, properties, and our employees (b, c: our interest in processing correct information and creating a safe environment for our employees and visitors);
• To investigate and handle incidents and irregularities (b, c: our interest in adequately investigating and addressing incidents);
• To handle any complaints and disputes, including assessing our legal position, defending it, and exercising our rights (a, b, and c: for the defense of rights, maintaining and improving existing relationships through good complaint handling, improving the quality of service);
• To comply with our legal obligations (b, c: the interest to meet these legal obligations).

2.7) You visit our website

When you visit our website, we may process your personal data, such as:

• Information related to the operating system, the browser used, IP address;
• Information related to the unique identifiers linked to the device used;
• Information related to the internet pages visited;
• Information about online viewed products (including information about products that have been searched for or viewed, purchased, or added to an online shopping cart);
• Information related to the time spent on certain parts of the site or an interface site or application, including the date and time of the visit.

Here we indicate the purposes for which we process this personal data, with the associated legal grounds (a to d as described above):

• To optimize and personalize your shopping experience (c: the interest to provide you with the best possible personalized shopping experience and d);
• To personalize your shopping experience based on your account details and search, browsing, and purchase history (c: the interest to provide you with the best possible personalized shopping experience and d);
• To send you personalized advertisements (c: the interest to provide you with the best possible personalized shopping experience and d);
• To perform generic analyses related to browsing behavior on our website(s) (c: the interest to organize our website in the best possible way);
• To send you newsletters and keep you informed about offers (c: the interest to bring our services to the attention of existing customers, d);
• To handle any complaints and disputes, including assessing our legal position, defending it, and exercising our rights (a, b, and c: for the defense of rights, maintaining and improving existing relationships through good complaint handling, improving the quality of service);
• To comply with our legal obligations (b, c: the interest to meet these legal obligations).

We collect this data through the use of cookies and similar techniques. Cookies are small text files that are placed in your browser when a website is visited. Cookies can process personal data. For more information about the use of cookies, you can read our cookie policy.

2.8) You email us or otherwise contact us

When you email us or contact us in another way, we may process the following personal data if you provide it to us:

• First and last name, email address, phone number, and/or the content of your email.

Here we indicate the purposes for which we process this personal data, with the associated legal grounds (a to d as described above):

• To answer your questions and provide you with information (b, c: our and your interest in answering your questions, providing you with information, and optimizing our services);
• To handle any complaints and disputes, including assessing our legal position, defending it, and exercising our rights (a, b, and c: for the defense of rights, maintaining and improving existing relationships through good complaint handling, improving the quality of service);
• To comply with our legal obligations (b, c: the interest to meet these legal obligations).

3) With whom may we share your personal data?

We do not disclose your personal data to third parties (‘recipients’ in the sense of privacy law), unless this is necessary for the proper execution of the purposes described in this privacy policy, when it is legally required, or when you have given your consent. The third parties to whom the personal data is provided are required to handle your personal data confidentially. If these parties are regarded as ‘processors’ in the sense of privacy law, we ensure that a processing agreement is concluded with these parties that meets the applicable requirements.

We may share your data with:

• Our employees (on a ‘need-to-know’ basis);
• Affiliated entities;
• Suppliers (e.g., software suppliers, bailiffs, debt collection agencies, package delivery services, accountants, law firms, etc.);
• Courts and government institutions;
• Other parties, such as regulators and other institutions if legally required or with your consent.

Finally, we note that if we go bankrupt, your data may be shared with the trustee appointed in the bankruptcy.

We may transfer your personal data to a recipient in a country outside the European Union that offers a lower level of personal data protection than European legislation. In that case, we ensure that such a transfer of personal data complies with applicable laws and regulations, for example, by concluding a model contract drawn up and approved by the European Commission for this purpose, and we assess whether additional measures are needed to ensure an appropriate level of protection of your personal data.

4) How long do we retain your personal data?

We do not retain your personal data in an identifiable form longer than necessary to achieve the purposes mentioned in this privacy policy. More specifically, we apply the following retention periods:

• The personal data you provide for your application is retained up to four weeks after the end of the application procedure. If you give your consent, we keep your personal data in our portfolio for up to one year after the end of the application procedure. This allows us to contact you for potential future vacancies. When you start employment with us, the personal data you provided in the context of your application will become part of your personnel file;
• Personal data that must be administered under Article 52 of the General State Taxes Act (AWR) is retained for 7 years (from the end of the year in which the relevant data has lost its current relevance for the (fiscal) business operations) due to our fiscal retention obligation under Article 52(4) of the AWR;
• Camera footage made at our locations is automatically overwritten after 30 days.

The specific retention periods mentioned above may be extended if legal retention obligations apply. We may also retain personal data longer if necessary for the resolution of incidents and/or legal disputes.

5) How do we protect your personal data?

We have implemented technical, organizational, and administrative measures to protect your personal data. These measures include the use of firewalls, authentication passwords, and restricted access. Additionally, a security policy is implemented. For questions about the security of your personal data or if you suspect misuse, you can contact us at:

info@europort-pharma.eu

6) What are your privacy rights and how can you exercise them?

When we process your personal data, you have certain privacy rights. You have:

• The right to clear information about what we do with your personal data;
• The right to request whether we process your personal data, and if so, the right to access your personal data and certain information about the processing of your personal data;
• The right to rectification and supplementation of your personal data if they are incorrect or incomplete;
• The right to have your personal data erased (the ‘right to be forgotten’);
• The right to restrict the processing of your personal data;
• The right to receive or have your personal data transferred to a third party of your choice in a structured, commonly used, and machine-readable format (the ‘right to data portability’);
• The right to object to the processing of your personal data;
• The right to withdraw your consent to the processing of your personal data when the processing is based on your consent.

We do not use automated decision-making as referred to in Article 22 of the GDPR.

To exercise your rights, you can contact us via info@europort-pharma.eu

To prevent us from providing information to the wrong person, we may ask for additional information to verify your identity. In principle, we will inform you within one month of receiving your request whether we can comply with your request. This period may be extended by two months in specific cases, such as in the case of a complex request. We will inform you of such an extension no later than one month after receiving your request. Under privacy law, we may refuse your request under certain circumstances. If this is the case, we will explain why. More information about your privacy rights can be found on the website of the Dutch Data Protection Authority.

7) Where can you go if you have a complaint or question about the processing of your personal data?

If you have a complaint about our processing of your personal data, we are happy to try to resolve this with you. If this does not lead to the desired outcome, you have the right to file a complaint with the competent supervisory authority. In the Netherlands, this is the Dutch Data Protection Authority. If you live or work in another European Union country, you can file a complaint with the supervisory authority in that country.

If you have questions about your privacy rights, this privacy policy, or the processing of your personal data, please feel free to contact us at: info@europort-pharma.eu