CSafe Global Privacy Notice

Effective Date: from 25 May 2018

Introduction

This Privacy Notice explains how particular companies in the CSafe Global Group collect, use and disclose your personal data, and your rights in relation to the personal data it holds.

This Privacy Notice applies to the processing activities of CSafe Global Coöperatief U.A., a private company with limited liability organized and existing under the laws of the Netherlands, having its registered address at Strawinskylaan 3127, Atrium Building, 8th floor, 1077 ZX Amsterdam, the Netherlands, who is the data controller of your personal data and who is subject to the EU General Data Protection Regulation 2016/679 (the “GDPR”).

You can reach us at the following address: Strawinskylaan 3127, Atrium Building, 8th floor, 1077 ZX Amsterdam, the Netherlands or email address: data-protection-team@csafeglobal.com or by phone: +3188-560 9950.

This Privacy Notice supersedes any previous Privacy Notice or equivalent which you may have been provided with or seen prior to the Effective Date stated above.

 

Your rights

Under the GDPR you have the following rights:

  • To obtain access to, and copies of, the personal data that we hold about you;
  • To object to the processing of your personal data, including requiring us not to send you direct marketing communications;
  • To require us to erase your personal data;
  • To require us to restrict our data processing activities in relation to your personal data;
  • To receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller; and
  • To require us to correct the personal data we hold about you if it is incorrect.

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

You can learn more about your rights at https://autoriteitpersoonsgegevens.nl/en. If you have any questions about how we use your personal data, or you wish to exercise any of the rights set out above, please contact us.

Under certain conditions you can object to the processing of your personal data and ask to restrict the usage of it. Further, you might also have the right to ask for erasure or portability of the data you provided to us.  To help us process your request, please provide sufficient information to allow us to identify you in our records.

If you are not satisfied with how we are processing your personal data, you can file a complaint with the Dutch Data Protection Authority.

 

How we collect your data

We collect your personal data in a number of ways:

  • From the information you provide to us when you meet us or when you visit our website, or when you request information from our website or from the information to be included in the distribution of our corporate newsletter;
  • From information about you provided to us by your company or an intermediary;
  • When you communicate with us by telephone, fax, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
  • When you complete any type of forms;
  • From other companies in the CSafe Group;
  • From your agents, advisers, intermediaries, and custodians of your assets;
  • From publicly available sources or from third parties, most commonly where we need to conduct background checks about you.

 

The categories of personal data we collect

We collect the following categories of personal data about you:

  • Your name, business or home address, email address, telephone number;
  • Personal identification information which may confirm your identity including your date/country of birth, tax identification number and your passport number, driving license or national identity card details, your BSN, country of domicile your nationality (where relevant);
  • Information relating to your financial situation such as creditworthiness and your bank account details, (where relevant, for execution of an agreement);
  • For each visitor to our website, we may gather certain information and store it in log files including IP addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, pages visited, date/time stamp, and clickstream data;
  • Information to assess whether you may represent a politically exposed person or money laundering risk (where relevant, for execution of an agreement).

 

Collection and use of information while visiting our website

The information we collect depends on what you do when you visit our website. Please note that we collect personal data about you if you choose to provide such information to us by registering with us, running an investigation, setting up an account, and/or contacting us regarding the website or our services.  If at any time you do provide us with such information, we will collect it.

Upon request we provide website visitors with access to their personal data that we maintain about them. You can access this information by sending your request to: data-protection-team@csafeglobal.com.

We reserve the right to ask for information verifying your identity prior to disclosing any information to you.  Should we ask for verification, the information you provide to verify your identify will be used only for that purpose, and all copies of this information in our possession will be destroyed when the process is complete.

We also offer visitors the opportunity to have inaccuracies corrected in information that is collected from this website for marketing purposes by contacting us at: data-protection-team@csafeglobal.com.

 

Registration and Ordering through the website

You may provide information on your initiative to register on our website or order one of our products. We will use this information to provide you with further details about CSafe, our services, and/or other information you might be interested in.

 

Cookies

Please see our Cookie Policy for more information about our use of Cookies.

 

The basis for processing your personal data, how we use that personal data and whom we share it with

 

(i) Customers management and performance of a contract with you

We process your personal data because it is necessary for the performance of a contract to which you are a party to or in order to take steps upon your request prior to entering into a contract. In this respect, we use your personal data for the following purposes:

  • To execute the agreement with you and to provide you with the services as set out in the respective services agreement that we have concluded with you, or to deliver goods to you as set out in the delivery agreements;
  • To deal with any complaints or feedback you may have;
  • To provide you with the information about the goods we are delivering and services we are providing;
  • To inform you about the recent up-dates in our services;
  • To draft a proposal for you regarding the services we offer and goods we deliver;
  • KYC purposes (when applicable);
  • For any other purpose for which you provide us with your personal data.

In this respect, we may share your personal data with, or transfer it to, the following:

  • Your agents, advisers, intermediaries, and custodians of your assets who you tell us about;
  • Third parties whom we engage to assist in delivering the services to you, including other companies in the CSafe Global Group;
  • Our professional advisers where it is necessary for us to obtain their advice or assistance, including lawyers, accountants, IT or public relations advisers;
  • Other third parties such as intermediaries who we introduce to you. We will wherever possible tell you who they are before we introduce you; and
  • Our data storage providers.

 

(ii) Marketing

CSafe may also use this information to send you information on products, services, special offers and promotions in which you might have an interest. The means by which CSafe will use to contact you with this information will depend on the type of information you have provided.  For example, if you provide us with your email address, you may receive periodic promotional emails from us. If you provide us with your postal address, you may receive periodic mailings from us with information on new products and services.

We will send you marketing about similar services we provide and goods we deliver, as well as other information in the form of alerts, newsletters and invitations to events or functions which we believe might be of interest to you. We will communicate this to you in a number of ways including by post, telephone, email, SMS or other digital channels.

If you do not wish to receive special offers and other promotional information from us, you may opt out of receiving such communications by sending an email to data-protection-team@csafeglobal.com or by the “unsubscribe” button in any direct marketing message you receive from us.

 

(iii) Supplies management

We process your personal data for prospecting for potential supplies and for their assessment; in order for us to perform the supplies administration and control the supplies payments.

 

(iv) Improving our Website

For each visitor to our website, we may gather certain information and store it in log files including IP addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, pages visited, date/time stamp, and clickstream data.  We collect and store this information on an individual basis and in aggregate, or combined, form.  We use this information to analyze trends, to administer the site, to track users’ movements around the site, and to gather demographic information about our user base as a whole.  We also use this information to improve the content of our web pages, and to customize the content and layout of our pages.  All of this is done with the intention of making our website more useful to visitors.  We treat this data as personal data, but do not correlate this information with other data about individual users. We may also use third-party services and programs to assist us in analyzing this data to better our website.

 

(v) Legitimate interests

We also process your personal data because it is necessary for our legitimate interests, or sometimes necessary for the legitimate interests of another person.

In this respect, we use your personal data for the following purposes:

  • For marketing activities. In this respect, see the separate section on Marketing above;
  • Training our staff or monitoring their performance;
  • For the administration and management of our business, including recovering money you owe to us, and archiving or statistical analysis;
  • Seeking advice on our rights and obligations, such as where we require our own legal advice;
  • Handling legal claims and proceedings; and
  • For the safety and integrity of CSafe Global Group and its employees and visitors.

In this respect we will share your personal data with:

  • Our advisers or agents where it is necessary for us to obtain their advice or assistance;
  • Third parties and their advisers where those third parties are acquiring, or considering acquiring, all or part of our business;
  • Other companies in the CSafe Global Group.

 

(vi) Legal obligations

We also process your personal data for our compliance with a legal obligation that applies to us.

In this respect, we will use your personal data for the following purposes:

  • To meet our compliance and regulatory obligations, such as compliance with anti-money laundering laws which may include the fact that we conduct a (criminal) background check (when applicable);
  • As required by tax authorities or any competent court or legal authority.

In this respect, we will share your personal data with:

  • Our advisers where it is necessary for us to obtain their advice or assistance;
  • Our auditors where it is necessary as part of their auditing functions;
  • Third parties who assist us in conducting background checks;
  • Relevant regulators or law enforcement agencies where we are required to do so.

 

Withdrawal of Consent

If you have given your consent and you wish to withdraw it at any time, please send an email to data-protection-team@csafeglobal.com or by opting out via the “unsubscribe” button in any direct marketing message you receive from us.

 

Transfer and processing of your personal data outside the European Union

When sharing your personal data with third parties as set out in this Privacy Notice, it may be transferred outside the European Union. In these circumstances, your personal data will only be transferred on one of the following bases:

  • the country that we send the personal data to is approved by the European Commission as providing an adequate level of protection for personal data;
  • the transfer is to a recipient in the United States of America who has registered under the EU/US Privacy Shield;
  • the recipient has entered into European Commission standard contractual clauses with us; or
  • you have explicitly consented to the same.

To find out more about transfers by us of your personal data outside the European Union and the countries concerned, please send an email to data-protection-team@csafeglobal.com.

 

Children

CSafe does not offer its services or promote its website to, nor does it intentionally collect or retain personal information from, children who are younger than 13 years of age. Visitors to the website are cautioned, however, that the collection of personal information submitted in an e-mail or through the website will be treated as though it was submitted by an adult, and may, unless exempted from access by law, be subject to public access. If you believe your child may have submitted information to CSafe without indicating their actual age and would like it removed, please contact us at data-protection-team@csafeglobal.com and we will delete it immediately.

 

Security

The security of your personal information is important to us.  We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it, and to guard that information against loss, misuse or alteration. When you enter sensitive and/or personal data on our registration or order forms, we encrypt that information using secure socket layer technology (SSL).

Please note, however, that no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, while we use commercially-reasonable means to protect your personal data, we cannot guarantee its absolute security.

 

Retention of your data

CSafe strives to retain personal data for no longer than is necessary for its purposes. The applicable retention period depends on the purpose for which personal data was obtained and on specific data retention obligations arising from applicable laws that may require the data to be held for a certain period of time.

 

Third party websites

From time to time, our website may link you to other sites (“Linked Sites”) that are not owned by CSafe.  We do not control the collection or use of any information, including personally-identifying information, which occurs during your visit to the Linked Sites.  Further, we make no representations about the privacy policies or practices of the Linked Sites, and CSafe is not responsible for the privacy practices of these Linked Sites.

Be careful of disclosing any of your personal data when leaving our website. We encourage you to be aware when you leave our website and to read the privacy statements of each and every website that collects personal data.