Privacy policy

1. INTRODUCTION AND SCOPE

Rotterdam World Gateway B.V., a company registered in the Netherlands with company number 24420010 and whose registered office is located at Amoerweg 50, 3199 KD Maasvlakte Rotterdam (the “Company”) are committed to protecting and respecting the personal data of all those whose data we are handling and to working within the guidelines set out by the Data Protection Law of the Netherlands.

This privacy policy describes how we use your personal data when you use our website www.rwg.nl, rwgservices.rwg.nl (“Our Website”), any apps we provide (as applicable) or when we provide products or services to you. We have provided this policy to ensure that you understand what personal data we may collect and hold about you, what we may use it for and how we keep it safe. You have legal rights to access the personal data that we hold about you and to control how we use it which are also explained.

You can read, print and save this whole policy. We use sub-headings to help you find specific information that you may be looking for more easily.  

 

2. DATA CONTROLLER

This website is operated under the legal jurisdiction of the Netherlands. For the purpose of the General Data Protection Regulation (Regulation [EU] 2016/679 of the European Parliament and of the Council) (the “GDPR”), the data controller is Rotterdam World Gateway B.V.

 

3. INFORMATION GOVERNANCE AND DATA PROTECTION OFFICER

We have appointed a Data Protection Officer who is responsible for helping us to comply with our legal obligations set out in the GDPR. The DPO monitors our data protection compliance and provides advice and guidance as to how we can improve our data handling practices.  The contact details of our DPO are:

 

Ms. R.S. Fontein

Corporate Lawyer

Rotterdam World Gateway B.V.

legal@RWG.nl

 

4. INFORMATION WE COLLECT FROM OR ABOUT YOU

We collect and process the following types of personal data via Our Website:

a)    Personal identifiers such as name, address, employer, job title, telephone number which you provide to us through our registration, enquiry or contact forms or if you correspond with us via email and which we use:  a) to fulfil any request you make (e.g. submitting a query on Our Website, subscribing to a communications service, fulfilling requests for information etc.);  b) to create a database of people who have expressed interest in our companies, products or services; and c) to allow you to participate in any interactive features of our service, when you choose to do so.
d) To create and maintain a mailing list of people who have expressed an interest in receiving electronic marketing communications from us.

b)    Feedback and opinions which you provide to us through our enquiry or contact forms is processed to allow us to answer queries and complaints you may have and to help us evaluate the quality and consistency of our services.

c)     Details of your visits to Our Website including your IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from Our Website (including date and time), products or services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number which we collect from your browser to enable us to monitor the performance and relevance of Our Website and our ad words campaigns, to ensure that content from Our Website is presented in the most effective manner for you and for your computer, and to keep Our Website safe and secure.

d)    Our Website uses cookies to distinguish you from other users of Our Website.  This helps us to provide you with a good experience when you browse Our Website and also allows us to improve it.  For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy [INSERT AS HYPER LINK TO THE COMPANY’S COOKIE POLICY].

We may also undertake additional data processing activities but will ensure they are compatible with the purposes above. 

Whilst we always want you to be aware of how we are using your personal data, this does not necessarily mean that we are required to ask for your consent before we can use it. In the day to day running of our business we may use your personal data without asking for your consent because:

a)    we are entering into and carrying out our obligations under a contract with you;

b)    we need to use your personal data for our own legitimate purposes (such as the administration and management of our business and the improvement of our services) and our doing so will not interfere with your privacy rights;

c)     we need to use your personal data in order to comply with a legal obligation to which the Company is subject.

If we choose to process your personal data for any purpose incompatible with those described in this section, we will provide you with appropriate information at the point where you come across those additional purposes in order to obtain your consent (where required) and prior to commencing any such additional processing activities. You are not required to give consent just because we ask for it.  If you do give consent you can change your mind and withdraw it at a later date. 

Optional additional purposes include, without limitation:

a)    to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

b)    to consider you for any job vacancy within our Company.

You are not under a legal obligation to provide us with any of your personal data but please note that if you elect not to provide us with your personal data we may be unable to provide our products or services to you.

 

5. RELATED WEBSITES

Our Website also provides the possibility to access social media through (for example) embedded videos placed on Our Website, such as Youtube and Vimeo, and you may find links to other websites, such as charities we support. These sites have been selected with care, however we cannot be held liable regarding the handling of your data by these sites. We kindly refer you to the privacy statements of the websites you visit through Our Website.

 

6. LEGAL BASIS FOR PROCESSING

The legal basis for processing personal data described above is the pursuit of our legitimate interests of seeking to promote, develop and grow our businesses through the sale of products and services and to provide excellent customer services. 

 

7. DISCLOSING, SHARING AND TRANSFERRING PERSONAL DATA

We may send you marketing and/or operational communications by email and/or push message through the RWG application. You can ask us to only send you marketing and/or communications about specific subjects or you may ask us not to send you any marketing and/or operational communications at all.

We may ask you to indicate your preferences when you first register an account on Our Website and/or app (as applicable). You can check and update your current marketing preferences at any time by logging into your account on Our Website and/or our app (as applicable), calling or emailing us using the details set out in section 11 below.

 

 

We may disclose your personal information to other third parties from time to time:

a)    if we are under a duty to disclose or share your personal data to comply with any legal obligation or if we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;

b)     to enforce or apply our terms of use and other agreements; 

c)     business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;

d)     analytics and search engine providers that assist us in the improvement and optimisation of Our Website;

We do not make use of automated decision making or profiling.

 

8.  DATA RETENTION

We will hold information about you in our data systems only for as long as we need to hold it which generally is as follows:

a)    We will retain and process information about you for as long as you continue to use or express an interest in our services, log into Our Website, use our interactive services, or for as long as we feel that our business, products and services may be of interest to you where you have not indicated otherwise. 

b)     we may anonymise your personal data or use it for statistical purposes.   We keep anonymised and statistical data indefinitely but we take care to ensure that such data can no longer identify or be connected to any individual.

9.  YOUR RIGHTS

Data protection law grants you certain rights (‘information rights’) which provide you with:

Your rightsDescription
Right of access and of data portability.You have the right of access to information we hold about or concerning you and/or to have it transferred to another data controller in some circumstances. If you would like to exercise this right you should contact us as outlined above.
Right of rectification or erasure.If you feel that any data that we hold about you is inaccurate you have the right to ask us to correct or rectify it. You also have a right to ask us to erase information about you where you can demonstrate that the data we hold is no longer needed by us, or if you withdraw the consent upon which our processing is based, or if you feel that we are unlawfully processing your data. Your right of rectification and erasure extends to anyone we have disclosed your personal information to and we will/shall take all reasonable steps to inform those with whom we have shared your data about your request for erasure.
Right to restriction of processing.You have a right to request that we refrain from processing your data where you contest its accuracy, or the processing is unlawful and you have opposed its erasure, or where we don’t need to hold your data anymore but you need us to in order to establish, exercise or defend any legal claims, or we are in dispute about the legality of our processing your personal data.
Right to object.You have a right to object to our processing of your personal data where the basis of the processing is our legitimate interests including but not limited to direct marketing and profiling.
Right to Withdraw Consent.You have the right to withdraw your consent for the processing of your personal data where the processing is based on consent. To withdraw consent please select the unsubscribe option in the most recent electronic marketing communication you have received or alternatively you can contact us by emailing legal@rwg.nl or telephone on +31107422000.
Right of Complaint.If you are unhappy with the way we have used or are handling your personal data you have the right to lodge a complaint with the Dutch Data Protection Authority.

You can find full details of your personal data rights on the Dutch Data Protection Authority website at www.autoriteitpersoonsgegevens.nl. 

 

10. HOW WE KEEP YOUR PERSONAL DATA SAFE 

We take every care to ensure that your personal data is kept secure.  The security measures we take include:

a)    only storing your personal data on our secure servers;

b)    encrypting any transactions made through our website and app;

c)     ensuring that our staff receive regular data security awareness training;

d)    keeping paper records to a minimum and ensuring that those we do have are stored in locked filing cabinets on our office premises;

e)    maintaining up to date firewalls and anti-virus software to minimise the risk of unauthorised access to our systems;

f)      Use of two-factor authentication technology for remote access

g)    Applying a strict update/patch policy.

h)    Use of strict hardware disposal policies.

Please remember that you are responsible for keeping your passwords secure. If we have given you (or you have chosen) a password which enables you to access certain parts of Our Website or app (as applicable), you are responsible for keeping this password confidential. Please do not to share your passwords with anyone.

Unfortunately, sending information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of personal data sent to Our Website; you send us personal data at your own risk. Once we have received your personal data, we will use strict procedures and security features (some of which are described above) to try to prevent unauthorised access.

 

11.  How we keep this policy up to date

We will review and update this privacy policy from time to time. This may be to reflect a change in the products or services we offer or to our internal procedures or it may be to reflect a change in the law. 

The easiest way to check for updates is by looking for the latest version of this policy on Our Website or you can contact us at Amoerweg 50, 3199 KD Maasvlakte Rotterdam or by emailing legal@rwg.nl. If you would like to speak to us please call +31107422000.

Each time we update our privacy policy we will update the policy version number shown at the end of the privacy policy and the date on which that version of the privacy policy came into force.

This is policy version is Version 1.0 dated 18 May 2018