Privacy Policy

1 PRIVACY POLICY

This Privacy Policy explains which personal data Combi Terminal Twente BV (“CTT”) and her associated companies collect from you through our interaction with you and through our services and products, how that happens, for which purposes we use personal data, how long we keep personal data, how you can view the personal data stored by us and customize and how your personal data is protected by us.

1.1 OUR COMPANY DETAILS ARE:

Combi Terminal Twente BV / CTT Rotterdam BV
Zuidelijke Havenweg 4
7554 RR Hengelo
The Netherlands
Tel: +31 742040390
Mail: info@ctt-twente.nl
KvK Enschede : 06080134
Chamber of Commerce Rotterdam: 56953038

1.2 QUESTIONS?

If you have questions about our Privacy Policy, or if you want to exercise your rights, or requests regarding transparency, you can contact us by mail and telephone based on the above information or via the personal communication channels you have with CTT.

2 APPLICABILITY GENERAL DATA PROTECTION REGULATION (GDPR)

When processing data, the General Data Protection Regulation (GDPR) applies. The GDPR is applicable when there is a fully or partially automated processing of personal data, but also with the manual processing of personal data contained in a file included or intended to be included therein.
We process your personal data in accordance with the purpose for which it was provided. The goals and type of personal data are described in this Privacy Policy;
1. Processing of your personal data is limited to only that data that is minimally required for the purposes for which they are processed;
2. We ask for you explicit consent when we need it for the processing of your personal data;
3. Have taken appropriate technical and organizational measures to ensure that your personal data is secured;
4. We do not pass on personal data to other parties, unless this is necessary for the execution of the purposes for which they were provided;
5. We point out that you have rights regarding the processing of your personal data.

3 WHICH PERSONAL DATA DO WE PROCESS?

We process the personal data you have provided to us, for example in the context of the delivery of products and / or services to you or obtained by us because you have used our digital services, our website, a contact form was filled in or has registered for our newsletter or your preferences have indicated which information you want to receive from us.

The personal data that we process from you can be the following:
6. your name
7. Your (business -) address
8. Your position within the company where you work
9. Your contact data like telephone number, address, email address, details on your Social Media
10. Birthdate and place
11. The IP address of the computer with which you visit our website.
12. Bank account numbers
13. Identity card details (passport photo and citizen service number)

4 PROCESSING GOALS : WHAT DO WE PROCESS PERSONAL DATA FOR?

CTT uses the data that is processed for:

1. Her business management
2. Recruitment
3. Delivery of products and services
4. Improvement of products and services
5. Organizing events

4.1 BUSINESS MANAGEMENT

CTT as an employer is obliged under Article 28 of the Dutch Wage Tax Act to include a copy or scan of the identity documents of its employees in the payroll administration.

A copy or scan of the identity document is made at the time when an employee is employed by CTT. With it, we can later deliver proof that our employees have properly legitimized themselves and that they were legally in the Netherlands. The copies of the IDs we process are further used for inspections by Dutch Government officials on official duty.

4.2 DELIVERY AND IMPROVEMENT OF PRODUCTS AND SERVICES

CTT is foremost a business – to – business company and therefore delivers products and services to companies rather than consumers.

We collect (personal) information that you have provided to us in the context of supplying those products and services and provide you with the best possible information about our products and services we offer to you.

Furthermore, your personal data can also be used for communication with customers and users of our digital services, for example in providing information about user accounts, security updates and product information.

4.3 RECRUITMENT FOR THE BENEFIT OF CTT

We use personal data for recruitment by CTT and its group companies. We can provide these personal data to these companies.

4.4 CTT EVENTS

Prior to an event, we ask visitors for permission to take photos, video and / or sound recordings. These recordings are saved and may also be used for internal / external communication purposes of CTT, using online and offline resources, both for commercial purposes and recruitment. Visitors and participants of such events can also provide, prior to the event that they wish not to appear recognizable on material from the events. When processing the material, we take into account their objections.

5 HOW IS PERSONAL DATA STORED WITH US?

Personal data are stored by CTT, among others, in the following databases:

– Exact / Afas
– Modality
– Microsoft Office 365 products
– MailChimp
– Habimat phones

This list of important databases is based on a survey at the date this Privacy Policy has been prepared and can change.

6 WITH WHOM CAN YOUR DATA BE SHARED?

Personal data can be passed on to:
– Other CTT companies and companies in which CTT has a majority interest.
– Customers for whom we fulfill services or management functions.
– Social Media.
– Clients, suppliers or subcontractors, government agencies and other business relations.

6.1 BASIS FOR PROVIDING PERSONAL DATA

We do not just provide data to the above mentioned parties “just like that”. A basisfor providing must be available for this. The provision is made on the basis of:

6. A legitimate interest
7. Legal obligation and / or
8. To implement the agreement in accordance with the aforementioned goals
9. Permission

CTT has added the applicable basis in its processing register.

CTT uses the following statements as permission:

– Exchanging visitation cards
– Request for information
– Request for quotation
– Execution of an assignment
– Permission for use of data by email or digital services we use

7 PROCESSING OF PERSONAL DATA

We draw up a Data Processing Agreement with processors of personal data. We record this Data Processing Agreement in a processing register.

The following items are included in this processing register:

– The name and contact details of the responsible person;
– The purposes for which the data is processed;
– The categories of data (such as name and address details, contact details, payment details);
– The categories of stakeholders (for example: customers, employees, suppliers);
– The categories of recipients (to whom are the data provided?);
– Information about possible transfer of data to countries outside the EU;
– The retention periods of the data;
– The ways in which data is secured (for example: encryption, access control, etc.)

7.1 PROCESSING REGISTER

As CTT has no obligation to appoint a data protection officer it is not included in the processing register. CTT instead has the roles of process owner and an application manager included in its processing register. It is stated that the owner can never be the same person as an application manager, hence realizing the “four eyes” principle. The purposes for which the personal data are processed has been given shape by CTT into the process for which the personal details in question are used. In this processing register, the retention period is also recorded and recorded where the data is hosted: NL, EU or outside the EU.

8 YOUR RIGHTS

Every person can exercise certain rights with respect to his or her personal data on the basis of the law. This gives you the right to inspect, rectify and delete personal data. You can also object to the use of your data or request that this use be restricted. In certain cases you can even request your data and take it to another party. Please contact us for all these questions via our telephone number or info@ctt-twente.nl .

9 RETENTION PERIODS

We retain your personal data as long as necessary for the purpose for which we obtained the data, unless a statutory retention period applies .

10 COMPLAINTS?

If you have complaints about how we handle your personal data, you can contact us by sending an email to info@ctt-twente.nl or call us. We are happy to help and find a solution. If it doesn’t work out, you can always contact the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).