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Privacy statement for direct marketing

 

With the following privacy statement, Kloeckner Metals ODS Nederland (here in after also referred to as ‚Klöckner‘, ‚we‘ or ‚us‘) makes information available to you about the way in which your personal data is processed in the context of direct marketing. Personal data relates to your personal or business circumstances (e.g. your first and last name, address, telephone number or e-mail address), in so far as we can trace this data back to you.
In the following, we will let you know what personal data we process about you, for what purposes we use it and what rights you have.

 

I. Processing manager

Within the meaning of Article 4 No 7 of the General Data Protection Regulation (AVG), the controller shall be

 

Kloeckner Metals ODS Nederland
Donk 6 – 2991 LE Barendrecht
Postbus 69 – 2990 AB Barendrecht
Tel: +31 (0) 180 640 911
Fax: +31 (0) 180 640 275

Email: ODS.info@kloeckner.com

II.   Data Protection Officer

You can contact our data protection officer as follows:

 

Dhr. Willem in ‘t Veld

Tel: +31(0)180 640 116

Email: Willem.intVeld@kloeckner.com

III. Processing of your personal data for direct marketing

1.   Processing of your personal data for direct marketing purposes based on consent

a)Categories of data concerned, processing purposes:

If you have given us permission for direct marketing, we process the following personal data to inform you about special offers, special events, fairs, products and services via personal e-mail:

Personal data

Salutation; first and last name; e-mail address; age; marital status; income; profession; company name, address, customer number, branch classification and classification of my company based on analysis [3]; my function and department within my company; information about creditworthiness, method of payment and competitive behaviour of my company within the market and between different suppliers; first contact with Kloeckner Metals ODS Netherlands; number of the contact person assigned to me; my language preference; my purchase behaviour and order history (online/offline), previous contact moments and services activated for me; personal communication and interaction regarding advertising, requests, orders and the use of services, including movements within the online shop, click behavior, visited home, source, and destination pages, IP addresses used, length of visit and bounce rate during internet visits, number of visits, status as a new or existing customer, average load and visit times; my reactions and movements within marketing channels; chat and customer service logs; my communication history and recordings and result logs of telephone and personal conversations; the results of customer satisfaction surveys; information about my account manager and the sales organization at Kloeckner Metals ODS Netherlands.

For the purposes of individualisation, the personal data referred to above are analysed as follows for the composition and allocation of target groups:

Composition and allocation of target groups

For each e-mail campaign, subgroups are defined and clustered to be written about offers, events, fairs, products and services. The target group is then allocated. In accordance with the procedure described in point [3], an individual analysis of the personal data referred to in point [1] will be carried out. On the basis of this analysis, it will be decided for each e-mail campaign to which target group I will be assigned and which offers, in particular events, fairs, products and services will be offered to me.

Analysis

During the analysis, Kloeckner Metals ODS Netherlands creates a profile of me and my company that examines and evaluates the personal information referred to in clause [1] with respect to my behavior as a customer and the behavior of me and my company in the past. In this way, product preferences, time of purchase and other relevant information regarding purchasing behavior can be derived. Taking into account other statistical information, Kloeckner Metals ODS Netherlands draws conclusions about my future purchasing behavior and calculates the probability of my affinity for certain offers, in particular events and fairs, products and services.

b) Legal grounds and retention period:

The processing of your personal data takes place on the basis of your consent, in accordance with article 6 paragraph 1 a) of the GTC. For this purpose, we will in principle process your data until such time as you withdraw your consent as stated above (see „Withdrawal of your consent“); if we are not permitted to process the personal data mentioned above on another legal basis, these data will be deleted immediately.

 

c) Necessity of your cooperation in data collection/consequences in case of refusal:

You are not legally or contractually obliged to make your personal data available for the purpose of direct marketing or to give permission for this. If you do not give your consent, this will have no consequences, except that you will not receive any direct marketing information.

 

2. Processing of your personal data for direct marketing based on balancing of interests

a) Categories of data concerned, processing purposes:

Without your consent to receive personal messages according to point 1, we will process your e-mail address and location for the purpose of direct marketing on the basis of balancing interests. In this way, you will only receive general, non-personal information.

 

b) Legal grounds, legitimate interests and retention period:

Processing in these cases takes place on the basis of balancing interests in accordance with Article 6(1)(f) of the AVG. In doing so, we weigh up your and our interests in order to inform you in general about our own products and services. For this purpose, we will in principle process your data until such time as you object (see „The right to object at any time to the processing of your personal data for direct marketing purposes on the basis of a weighing of interests“); if we are not permitted to process the personal data referred to above on another legal basis, these data will be deleted immediately.

 

c) Necessity of your cooperation in data collection/consequences in case of refusal:

You are not legally or contractually obliged to make your personal data available for direct marketing purposes on the basis of balancing interests. If you withdraw your consent, this will have no consequences, except that you will not receive any further direct marketing information afterwards.

 

IV. Your rights as data subject

In the following we inform you about the rights you have as a person concerned according to articles 15-21 and 77 paragraph 1 of the AVG.

  1. The right to information

According to article 15 of the GTC, you have the right to obtain a decision from us as to which personal data will or will not be processed. The right to information includes the following points;

  • the categories of personal data concerned that are processed;
  • the processing purposes;
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed;
  • that you have the right to request us to rectify or delete your personal data, or to limit the processing of your personal data, as well as the right to object to such processing, and
  • that you have the right to complain to a supervisory authority.

If applicable and to the extent possible, you are also entitled to information about the following:

  • the period for which personal data are expected to be stored or, if that is not possible, the criteria for determining that period;
  • where the personal data has not been collected from you, any available information as to the source of that data, and
  • the existence of automated decision making, including profiling, and, at least in those cases, useful information about the underlying logic, as well as the importance and expected consequences of that processing for you.

We are also obliged to provide you with a copy of all personal data processed by us as the responsible party if you request it from us. The data will be provided in the form and to the extent available to us at the time of your request.

  1. Right of rectification

Pursuant to Article 16 of the GTC, you have the right to demand rectification or completion of personal data from us if they are incorrect or incomplete. For example, you can have data that is incorrect in content (e.g. due to typing errors/indistinct handwriting) corrected.

  1. The right to oblivion

Pursuant to Article 17 of the GTC, you have the right to request us to delete your personal data if

  • they are no longer necessary for the purposes for which they were processed;
  • you have withdrawn your consent on which the processing is based;
  • you have objected to the processing of your personal data, and there are no overriding compelling legitimate grounds for processing;
  • the personal data have been unlawfully processed, or
  • personal data must be deleted in order to comply with a legal obligation laid down in Union or Member State law.
  1. The right to limit processing

Pursuant to Article 18 of the GTC, you have the right to request us to limit the processing of your personal data if

  • you have disputed the accuracy of the personal data;
  • the processing of your personal data is unlawful and you oppose the deletion of the personal data;
  • you need the personal data that we no longer need for the institution, exercise or substantiation of a legal claim, or
  • after you have objected to the processing of your personal data, it has not yet been established whether our legitimate grounds for further processing outweigh yours.

If the processing is limited, we may only continue to process your personal data in exceptional cases laid down by law. If the restriction on the processing of your personal data is lifted, we will inform you of this in advance.

  1. The right to transfer data

Pursuant to Article 20 of the GTC, you have the right to obtain the personal data relating to you, which you have provided to us, in a structured, common and machine-readable form.

This right does not extend to personal data which

  • have been made available to us by third parties or have been sent to us;
  • concern passwords, salary details or biometric data;
  • relate to your technical settings of the services you use;
  • display the result of a correlation established by us on the basis of your personal data or any other calculation carried out by us (e.g. credit scores, profiling results).

The right to transfer data shall also lapse if

  • the processing is lawful and this lawfulness is not based on your consent within the meaning of Article 6(1)(a) of the AVG or the performance of a contract within the meaning of Article 6(1)(b) of the AVG, or
  • the transfer would prejudice the rights and freedoms of others.

In some cases, you also have the right, if technically possible, to have your personal data transferred directly from us to another data controller.

  1. Individual right of objection

Pursuant to Article 21 of the GTC, you have the right to object to the processing of your personal data by us, insofar as this objection is legally based on the fact that

  • the processing is necessary for the performance of a task in the public interest (compare Article 6(1)(e) or 1 AVG),
  • the processing is necessary for the exercise of the public authority vested in us (see Article 6 paragraph 1 (e) or 2 of the AVG), or
  • the processing is necessary for the protection of our legitimate interests (compare article 6 paragraph 1 (f) AVG).

You must give reasons for your objection in all cases, insofar as you have to explain what reasons there are in your specific situation to challenge the admissibility of the processing.

The right to object at any time to the processing of your personal data for direct marketing purposes on the basis of balancing of interests

If personal data is processed for direct marketing purposes on the basis of balancing interests, you have the right to object at any time to the processing of your e-mail address and location for direct marketing purposes. To do so, you can click on the unsubscribe link or the link for the Preference Center in each newsletter, or send an e-mail to shop-nl@kloeckner.com. You can also send a letter to Kloeckner Metals ODS Netherlands, Donk 6, 2991LE Barendrecht. If you invoke the right of objection, you will only be charged a transfer fee at a basic rate (e.g. postage, sending by e-mail).

7. Lawfulness of withdrawing your consent

If you have given us your consent for the processing of your personal data, you may revoke this consent free of charge at any time in full or only in respect of specific processing purposes. Please note that lawful processing of your personal data as it was carried out prior to the withdrawal of your consent does not become unlawful with retroactive effect.

8. Filing a complaint with a supervisory authority

Finally, pursuant to Article 77(1) of the AVG, you have the right to lodge a complaint with a supervisory authority if you consider that the processing of your personal data infringes data protection provisions. In particular, you may lodge such a complaint with a supervisory authority in the Member State where you have your habitual residence, your place of work or where the alleged breach has been committed. In addition, you will have the possibility to seek law or redress under the applicable law (e.g. before the court or authorities).

Versie: april 2018