NewCold Coöperatief UA and its affiliated companies (together: "NewCold" or "we") have created this Privacy Policy to demonstrate our commitment to the individual's right to data protection and privacy.

This privacy policy applies to the processing of personal data in the context of our global business activities. This includes the processing of personal data via our website www.newcold.com. This Privacy Policy contains information about the categories of personal data we collect, why we collect it, what we do with it, how we protect it and your individual rights.

NewCold is the so-called controller within the meaning of the General Data Protection Regulation ("GDPR"). This Privacy Policy explains in general terms how we seek to comply with data protection laws and regulations, including, but not limited to, the European General Data Protection Regulation ("GDPR") and national laws implementing the GDPR, as well as state security breach laws and privacy laws in the United States and applicable privacy laws in other countries, such as Australia.

If you have any questions after reading our privacy policy or would like to contact us in general, you can do so using the contact details at the end of this document.

Collection and processing of your personal data

We process personal data of (contact persons at) our customers, suppliers and other business partners, students and job applicants and visitors to our websites. We obtain personal data i) from you, ii) from third parties (such as customers, suppliers and chain partners) or iii) from public sources, such as the trade register of the Chamber of Commerce.

Personal data that we can process are:

• basic information such as first and last name, title, gender;
• Contact details such as your e-mail address, postal address, telephone number, the company you work for and your position;
• Financial data such as IBAN/bank account number;
• IP address and statistical data about your use of our websites;
• personal data that you provide to us when you apply for a job with us, e.g. a letter of application, a CV, your date of birth, information about your education and profession;
• any other personal data that we receive from you or about you and that we use for the purposes set out below.

We do not always process all of the above data, this depends on the nature of the relationship, the service concerned and (if applicable) the consent you have given.

Purposes of the processing of personal data

We process your personal data for one or more of the following purposes (depending on our relationship with you):

Marketing and acquisition purposes
We use your personal data to send you newsletters, invitations to our events and other marketing communications that are relevant to you, as well as in the context of (registering for) one of our marketing events. If you have attended one of our events, we may also ask you for feedback.

Execution of a contract
We process your personal data insofar as this is necessary in connection with the products or services we offer, including the exchange of personal data for offers, the execution and processing (including invoicing) of an order, a service request or an order.

Compliance with legal obligations
We process your personal data insofar as this is necessary to fulfill legal obligations. This includes, for example, the collection and storage of data and the provision of information to the tax authorities and supervisory authorities.

Job applications and recruitment
The data that you provide to us when you apply for a job with us (by email/post, via the application form on our website or via social media), or that we receive via recruitment agencies, will be processed by us in order to contact you for the purposes of our application procedures and to process your application. We may also process your personal data in connection with an internship at one of our branches (an application for an internship).

Access control and security
We keep a list of visitors to our business premises for security purposes (evacuation in the event of accidents). These lists are destroyed at the end of the day. We also use camera surveillance to protect the property and safety of our employees and visitors. For more information on camera surveillance, please refer to our CCTV policy, which is available at the reception of each site and applies to all NewCold sites.

Use and improvement of our website
We process statistical data about your visit to and use of our website. We do this to analyze and improve the content, layout and use of our website.

Other processing
We may also process your data to carry out customer satisfaction surveys or to process questions or complaints.

Principles of data processing

We process your personal data on the basis of one or more of the following legal bases:

• The performance of a contract with you or the taking of steps prior to entering into a contract;
• a legitimate interest;
• Your consent;
• our compliance with legal obligations.

Disclosure of your personal data

In some cases, we may share your personal data with third parties. We will only do this if we deem it necessary. We will only share your data with trusted parties and will ensure that any transfer of your personal data is subject to appropriate safeguards. We may share your personal data with:

• State institutions such as tax authorities and supervisory authorities.
• Companies, customers, suppliers and subcontractors associated with NewCold;
• Chain partners and other service providers such as banks, insurers, bailiffs, auditors, tax consultants and other advisors;
• External suppliers such as IT service providers, hosting and cloud service providers or other suppliers to whom we outsource support services.

If the third party to whom your personal data is passed on is designated as a processor within the meaning of the GDPR, we also conclude a data processing contract with this third party.

Storage of personal data

We retain your personal data in accordance with applicable data protection laws and certain prescribed retention periods. The data will not be kept for longer than is necessary to achieve the purpose for which it was collected and to comply with legal obligations.

Your right to privacy

Under the General Data Protection Regulation, you have the following rights:

You have the right to request access to, rectification, erasure, restriction of processing and transfer of your personal data. You also have the right to object to the processing of your personal data. If you wish to exercise your rights, please submit a request by e-mail. Our contact information can be found at the end of this privacy policy.

Please note that the rights of individuals under the General Data Protection Regulation are subject to certain restrictions and cannot always be granted. A request may be denied in whole or in part due to these restrictions, such as legal obligations, the rights of third parties and the legitimate interests of NewCold. If we are unable to grant a particular request, we will inform you of this, stating the reasons.

If the processing of your personal data is based on consent, you have the right to withdraw this consent at any time. The withdrawal of your consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Within the EU, EU citizens have the right to lodge a complaint with a data protection authority. A list of all EU supervisory authorities can be found on the website of the European Data Protection Board: https://edpb.europa.eu/about-edpb/board/members_en. In the Netherlands, this is the "Autoriteit Persoonsgegevens" ("AP"). You can find more information on the AP website (https://autoriteitpersoonsgegevens.nl/). We would appreciate it if you would contact us first so that we can find an amicable solution.

Data security

We take appropriate security measures to limit the misuse of and unauthorized access to personal data. For example, we ensure that only authorized persons have access to the data, that access to the data and its transmission are protected by appropriate security measures such as secure connections and firewalls, and that our security measures are regularly evaluated and updated.

Transfer of personal data outside the EEA

Any information you provide to us via our websites will be stored on servers in the European Economic Area (EEA). If necessary, we may share information with our affiliates inside and outside the EEA.

When we transfer or store personal data outside the EEA, appropriate safeguards are put in place.

Cookies

We use cookies to personalize content and ads, to provide social media features and to analyze our traffic. We also share information about your use of our website with our social media, advertising and analytics partners, who may combine it with other information that you have provided to them or that they have collected from your use of their services.

Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. You can also customize the cookie settings on our websites via the pop-up notice. If you choose to refuse certain cookies, you may not be able to access all or parts of our websites.

Children

We do not knowingly collect personal data from children. If you become aware that a child has provided us with personal data, please contact us.

Changes to this privacy policy

We may change this privacy policy from time to time. The changes will be published on our websites. It is therefore advisable to consult our websites regularly to keep up to date with any changes.

Contact information

NewCold welcomes your comments on this privacy policy. If you have any questions or requests regarding the processing of your personal data, please contact us using the contact details below.

privacy@newcold.com
NewCold Coöperatief UA

P.O. Box 1893
4801 BW Breda
The Netherlands

This privacy policy was last updated and published on June 20, 2024.