Raffinerie Tirlemontoise - General data protection policy
In the course of its activities, Raffinerie Tirlemontoise SA, Avenue de Tervuren 182, B-1150 Brussels ("Raffinerie Tirlemontoise"), collects and uses information about individuals like you (also known as "personal data").
Raffinerie Tirlemontoise attaches great importance to protecting your privacy. Consequently, Raffinerie Tirlemontoise undertakes to process the information it collects about you only in the manner provided for in this policy. In this context, Raffinerie Tirlemontoise complies with applicable privacy legislation, including the General Data Protection Regulations or "GDPR".
As part of this commitment, Raffinerie Tirlemontoise would like to outline its data protection policy to you, explain why and how we process your personal data and your resulting rights and obligations. This policy also tells you whom you can contact at Raffinerie Tirlemontoise for enquiries or to exercise your rights. (see point 7).
This data protection policy applies to all types of use of personal data with regard to:
- current, former and future customers (natural persons, including farmers and growers);
- current, former and future suppliers (natural persons);
- customer representatives and employees (legal entities);
- supplier representatives and employees (legal entities);
- visitors to our premises; and
- visitors to our websites and agroportal.
This policy does not apply to information relating to legal entities. The so-called "controller" is the legal entity that decides on the purposes and means of collecting and using your personal data. Unless otherwise specified in a supplementary policy on a specific processing operation, Raffinerie Tirlemontoise is the controller.
2. What personal data does Raffinerie Tirlemontoise collect about you?
2.1 General information
First, we collect the identification and contact details of the people with whom we communicate, including their name, e-mail and/or postal address, fixed and/or mobile phone number. We also record the content of any communications you exchange with us by mail or e-mail.
If you are a natural person (individual) who is also a business customer or supplier, we also collect your title, position, the name of your company, payment data such as bank account numbers, IBAN, BIC and, if applicable, your VAT number, as well as your sales or purchase history with Raffinerie Tirlemontoise. The information collected also includes personal details such as gender, age and date of birth (if you have supplied them).
If you are a representative or employee of one of our customers or suppliers that is a legal entity, the data collected also includes your title, position and the name of your company.
For raw material suppliers (e.g. farmers and growers) we also collect information about your deliveries, such as the quantity and quality of the product delivered.
Raffinerie Tirlemontoise also collects any purchase history and personal characteristics, such as gender, age and date of birth (if specified) of any customers who contact Raffinerie Tirlemontoise (regardless of the fact that we do not sell our products directly to individuals).
2.4 Visitors to our premises
If you visit one of our premises you may be filmed by our security cameras. These cameras are always indicated by an appropriate pictogram.
If you have an appointment with one of our employees, you must also give your name at the reception desk and indicate your contact person at Raffinerie Tirlemontoise.
If you visit our subsidiaries in Wanze or Longchamps, your license plate number will be automatically recorded by our license plate recognition system, as will your arrival and departure times. This is also indicated by the relevant pictogram.
2.5 Visitors to our websites
When you visit our websites or our agroportal, we also collect certain connection and communication data (such as your IP address, the domain name of your Internet service provider, your browser type, operating system and platform), statistical data and information about your behaviour, habits and preferences (such as information about the pages visited, the information requested and the time spent on our website).
3. How is personal data collected?
We collect your personal data directly or indirectly through one or more of the following channels:
- (i) when you contact us and communicate with our employees and/or computer systems;
- (ii) when you give us your business card;
- (iii) in online surveys;
- (iv) when you order or purchase our products or services;
- (v) via our security and video surveillance systems;
- (vi) via our license plate recognition system;
- (vii) through the company where you work or from one of your colleagues;
- (viii) when you visit our website or agroportal;
- (ix) when you participate or register in surveys, promotions, contests and/or company visits; or
- (x) when you subscribe to our newsletter or fill in the contact form.
If necessary, we supplement your personal data with information from public sources, namely the Belgian Official Gazette and the Crossroads Bank for Enterprises.
When we ask you directly for your information (for example, via a form), we will always tell you if you are required to provide us with this data and what the consequences will be if you fail to do so.
To ensure that the personal data we hold about you is accurate and up to date, we may ask you to review and confirm or, if necessary, update it from time to time.
4. Why is personal data collected and used?
Your personal data is always processed for a specific and well-defined purpose, and only the data necessary to achieve that purpose is used.
4.1 General purposes
We process the personal data (of representatives and employees) of our customers and suppliers, and visitors to our premises and websites for the following general purposes:
- (i) to monitor our activities (measure and compile statistics on our sales, purchases, payments, numbers of customers, etc.);
- (ii) to manage our information system, including infrastructure management and business continuity;
- (iii) to improve the quality of our products and services;
- (iv) to protect our economic interests,
- (v) to manage our archiving systems;
- (vi) to defend ourselves in legal proceedings, including in responses to requests from public authorities or courts;
- (vii) to comply with statutory obligations;
- (viii) for statistical purposes;
- (ix) to follow up requests and complaints;
- (x) for mergers and acquisitions; and
- (xi) to ensure the safety of our plants and subsidiaries, including security controls and fraud prevention.
We process the personal data (of representatives and employees) of our customers and suppliers:
- (i) to prepare and execute contracts;
- (ii) for purchasing, procurement, invoicing and accounting;
- (iii) to manage fees and complaints;
- (iv) for logistical assistance;
- (v) to manage relationships with customers, suppliers and partnership programmes, end-of-year gifts;
- (vi) to send regular newsletters and promotional emails concerning our products and services, as well as interesting information;
- (vii) to organise promotions, actions and competitions;
- (viii) for quality controls on delivered products; and
- (ix) to monitor activities on our premises, including compliance with applicable policies and health and safety rules.
We also process individuals' personal data:
- (i) to send regular newsletters and promotional emails concerning our products and services, as well as interesting information;
- (ii) to manage relationships with customers who purchase our products from large or small retailers;
- (iii) to answer questions; and
- (iv) to organise promotions, special offers and competitions.
4.4 Visitors to our premises
We process our visitors' personal data:
- (i) to keep a record of visitors and manage access controls;
- (ii) to operate the automatic license plate recognition system (this applies only to visitors to our subsidiaries in Longchamps and Wanze);
- (iii) for the organisation of visits by companies and schools; and
- (iv) to monitor activities on our premises, including compliance with applicable policies and health and safety rules.
4.5 Visitors to our websites
We also process the personal data of visitors to our websites and agroportal:
- (i) to manage and improve our websites (for example, through the diagnosis of server problems, data traffic optimisation, web page integration and optimisation);
- (ii) to measure the use of our websites (for example, by compiling statistics on data traffic or collecting information on visitor behaviour and the pages they view);
- (iv) to analyse the effectiveness of our email campaigns and improve email delivery and thus communication; and
- (v) to monitor and prevent fraud and other risks of misuse of our website.
5. Legal basis for the collection and use of personal data
Personal data may not be processed without a valid legal basis. Consequently, we will only process your personal data in the following cases:
- (i) where we have received your free, specific and unambiguous consent to process your personal data for a specific purpose or purposes; or
- (ii) where the processing is necessary to fulfil our contractual obligations to you or to take pre-contractual measures at your request; or
- (iii) where the processing is necessary to comply with an obligation to which we are subject under any law, decree or regulation; or
- (iv) where the processing is necessary to protect your vital interests or those of another person; or
- (v) where the processing is necessary for our legitimate interests and does not unduly prejudice your interests or fundamental rights and freedoms. Please note that when we process your personal data on this basis we always seek to strike a balance between our legitimate interests and the protection of your privacy. Our legitimate interests include: providing cost-effective services, supplying our products and services to our customers, preventing fraud, ensuring the security of our computer systems and networks, and achieving our corporate and social responsibility objectives.
In most cases we will process your personal data because it is necessary in the context of our current and future contractual relations. If you would like more information on the exact legal basis underpinning the processing of specific personal data, please do not hesitate to contact us as indicated in point 7.
6. Who has access to your personal data?
6.1 At Raffinerie Tirlemontoise
Raffinerie Tirlemontoise stores your personal data on its computer systems but only employees who need to access your data as part OF their duties at Raffinerie Tirlemontoise (and, if necessary, its parent and sister companies, Südzucker AG group, BioWanze, Beneo) will have access to it, and only for the purposes set out in point 4.
These employees are required to comply with our internal rules and procedures relating to security, confidentiality and the protection of personal data. They must also comply with the technical and organisational measures we have put in place to protect your personal data. These security measures have been designed to take account of the latest technology, the costs of implementation, the risks presented by the processing and nature of personal data, the volume and risks related to the processing of personal data.
6.2 Outside Raffinerie Tirlemontoise
Some of your personal data will also be transmitted to certain categories of recipients outside Raffinerie Tirlemontoise for the purposes mentioned above, but only when the information is actually required. In particular, this applies to:
- (i) our service providers, such as consultants, IT service providers, security companies, insurance companies and financial institutions;
- (ii) our business partners, such as distributors and agents;
- (iii) any judicial, law enforcement, regulator or market authority, or the courts (whether national or international) to which we are required to transmit information under applicable laws or regulations, or at the request of one of these bodies;
- (iv) third parties who advise or assist us, such as external consultants, accountants, bailiffs and lawyers, for example, in connection with the transfer or acquisition of part or all of the business; and
- (v) third parties involved in investigating possible cases of fraud or other illegalities.
In this context, we remain responsible for processing your personal data. Except in the case of an authority, these recipients may only process your data on the basis of our specific instructions and for no other purpose, unless we have informed you in advance and obtained your consent, where necessary. We also impose specific contractual obligations on them to ensure the protection of your personal data.
6.3 Outside the European Economic Area
The recipients may sometimes be located in countries outside the European Economic Area ("EEA"), which may not guarantee an adequate level of protection of personal data. The legislation applicable to the transfer of personal data to these countries requires us to implement appropriate measures to ensure the protection of personal data (such as contractual provisions that require recipients to protect your personal data). You can obtain further information and an explanation in this regard, as well as a copy of these measures, by exercising your rights as indicated in point 7.
7. What are your rights and how can you exercise them?
You have the right to request access to your personal data processed by Raffinerie Tirlemontoise at any time, and to request its correction if it is inaccurate or incomplete. In some cases you may also object to the processing of this data, request that the
processing be limited or for certain data be deleted. Finally, you are also entitled, in certain circumstances, to request that some of your personal data be returned to you or transferred to a third party.
When you have given your consent for a certain type of processing you can also withdraw it at any time. However, please be aware that, in such cases, you may not be able to take full advantage of all our services. The withdrawal of consent does not affect the
lawfulness of processing of your data prior to your withdrawal of consent. Furthermore, you may always object, at no cost, to the use of your personal data for direct marketing purposes.
If you wish to exercise any of the rights above, please send a letter to Raffinerie Tirlemontoise, for the attention of the Legal Department, Aandorenstraat 1, 3300 Tienen, or send an email to email@example.com, attaching a copy of your identity card.
Raffinerie Tirlemontoise takes any comments about the processing of your personal data very seriously and handles them quickly. Please feel free to contact us if you have any comments.
If you are not satisfied with the way we process your personal data, you have the right to file a complaint with the supervisory authority responsible for the protection of personal data in Belgium, namely the Data Protection Authority (DPA).
8. How long is your data kept?
The exact storage period depends on the purposes for which the personal data is processed.
In principle, Raffinerie Tirlemontoise uses the following criteria for the storage of personal data: personal data is stored (i) for as long as necessary to achieve the purposes for which it was collected and (ii) always in compliance with legal and regulatory provisions and related internal requirements.
More precisely, your personal data that we hold in our database and that is not linked to a specific contract is deleted 12 months after your last interaction with us.
For personal data related to a contract that you (or the company for which you work) have signed with us, the storage period is equal to the duration of that contract plus the limitation period under which a request may be made pursuant to that contract, except where mandatory statutory provisions or regulations provide for a longer or shorter storage period. After this period has expired your personal data will be deleted from our systems.
Images from the video surveillance cameras are kept for a maximum of 1 month.
Personal data collected and processed as part of a dispute will be deleted (i) as soon as an amicable agreement has been reached, (ii) as soon as a final decision has been taken and can no longer be appealed or (iii) when the requests are time-barred.
9. Modification of the policy
10. Contact us for more information
For general enquiries you can contact us by sending an email to firstname.lastname@example.org, or a letter to Tiense Suikerraffinaderij NV / Raffinerie Tirlemontoise SA, Avenue de Tervuren 182, B-1150 Brussels. For questions relating to the protection of your privacy and/or to exercise your rights, please contact the contact person mentioned in point 7. We will be happy to assist you.