Privacy Policy Triferto

In this Privacy Policy you can read how Triferto BV handles the personal data of customers and of others involved in the use of our websites, TrifertoWeb, and/or other services.

We are aware that you place your trust in us. Knowledge, skills, expertise and trust are important pillars for Triferto BV. We therefore see it as our responsibility to protect your privacy and to inform you about that. On this page you can read which data we collect when you use the website and/or services of Triferto BV, and why we collect those data. We respect the privacy of all users of our website and our services, and we see to it that the personal data you provide are treated confidentially. We act in accordance with the General Data Protection Regulation (GDPR).

1. Who is Triferto and to whom does this Privacy Policy apply?

Triferto is a private company with limited liability, having its registered office and its principal business
office in Doetinchem, the Netherlands, and registered in the Trade Register of the Chamber of
Commerce under number 09126552. With regard to this Privacy Policy you can reach us by telephone
via the numbers +31 314 374045 and +31 314 374014, and by e-mail via avg@triferto.eu.
This Privacy Policy applies to:

• Customers/relations of Triferto;
• potential customers/relations with whom Triferto has made or had, or wants to make or wants
  to have contact;
• visitors of any of our websites;
• recipients of our news items and e-mails;
• any other persons who contact Triferto or whose personal data are processed by Triferto
  (except our employees).

2. Which Personal Data does Triferto BV collect and process?

On our websites www.triferto.eu and in TrifertoWeb www.trifertoweb.eu you can see which services
and products we offer, and you can register for/purchase an appropriate service/product. You can also
place a message on our contact page, request a (blend) offer or an IBC return notification. If you
register for one or more of our services or products, we can ask you to provide the following (personal)
data:

Your data:

• name and address details;
• salutation or gender;
• telephone number;
• e-mail address

Your company details:

• legal form;
• company name;
• Chamber of Commerce number;
• postal code and city;
• e-mail address;
• delivery address details
• billing address details;
• if applicable: UBO statement (“Ultimate Beneficial Owner”)

Payment details:

• IBAN and ascription.

If you send e-mail or other messages to us, for example via a form on our website, we keep those
messages. Sometimes we ask you for your personal details that are relevant for the situation in
question. This makes it possible for us to process your questions and answer your requests. The data
are stored on an own secure server and on a server of a third party (with which party a processor
agreement has been concluded).

We process personal data that you have provided to us, personal data generated during your visit to
our website and while reading news items, and personal data that we have derived from other sources.
Personal data provided by you:

• contact details and other personal data needed to execute an agreement;
• contact details and other personal data entered on contact forms or other web forms or via email;
• contact details provided during introductory meetings, events, courses, seminars, etc., such as
  information stated on business cards.

Personal data obtained via or generated by our website, electronic news reports, e-mails and related
technologies:

• IP number;
• your surfing behaviour on the website, such as data about the first visit, previous visit and
  current visit, the pages viewed and how you navigate through the website;
• whether you open a news item or an e-mail, and on which parts thereof you click.

Personal data obtained from other sources:

• personal data available on public business social media platforms such as Facebook and
  LinkedIn;
• personal data obtained from the Trade Register of the Chamber of Commerce and from the
  Land Registry;
• personal data available on public business websites.

Our website contains hyperlinks to websites of other parties and social media buttons. We are not
responsible for the content of those websites or the services of those social media platforms. Nor are
we responsible for the privacy policies and the use of cookies on those websites and social media
platforms.

Automatically generated data:

In order to let our website work optimally, automatically generated information about your use of the
website is collected and processed. The optimization of the services includes technical adjustments,
for example the proper display of pages and securing the website. The information that is collected
consists of the type of device (including computer, mobile, tablet) that you use, your IP address
(number of your device that makes it possible to recognize your device), the type of browser, the
operating system you use, and the pages you visit on the website and the items you view.

3. For what purposes and on the basis of which legal grounds are the collected date used?

Your information will be used for the following purposes and on the basis of the following legal
grounds:

• The use is necessary for the performance of an agreement to which you are a party;
• Compliance with legal obligations;
• The processing is necessary for looking after the legitimate interests of Triferto:
• to send you information about our own products and services (marketing
  purposes);
• to respond to any questions and/or complaints you may have, and to secure, adapt
  and improve the website.

You have given permission for the use and/or processing of data. This is necessary in order to comply
with legal obligations resting on Triferto, such as:

• to provide information about you to third parties if you have given permission for that, or on
  the basis of laws and/or regulations.

We want to keep you informed of developments of our products and services. If, for example, there is
an expansion of the possibilities with the services and/or products, we can let you know that. We can
also keep you informed of news items.

If you do not want to receive e-mails from Triferto, you can indicate this by sending an e-mail to
avg@triferto.eu. You can unsubscribe at all times for such e-mails that we send you, by means of an
unsubscribe link.

Use by third parties
If you provide us with personal data in connection with our services, those personal data will not be
shared with third parties, except and insofar as this appears from this Privacy Policy.
We may provide your information to third parties insofar as you have explicitly indicated in relation to
a certain third party that you have given permission for this, and this is required in the context of your
use of our services/products and/or insofar as these data cannot be traced back to you personally
(such as automatically generated information).

We can for instance engage third parties to outsource activities. These third parties process your
personal data exclusively on instruction and for and on behalf of (the purposes of) Triferto. In some
incidental cases the information can be shared internally if it has beneficial consequences for the
provision of services to the customer. The employees of Triferto are obliged to observe the
confidentiality of your data.

Finally, we can provide your personal data to third parties if Triferto is required to do so on the basis
of specific laws and/or regulations.

Hyperlinks from third parties
Our websites may contain hyperlinks by which you leave the environment of Triferto and end up on
the website of another party. Triferto has no control over third-party services and/or websites to which
you may be linked to. It may therefore be the case that a different privacy policy applies to those
services and/or websites of third parties. The present Privacy Policy only applies to (personal) data that
are processed by us. Triferto accepts no responsibility or liability for (the operation and/or content of)
services and/or websites of third parties.

4. How long does Triferto store personal data?

Your personal data are stored carefully and no longer than is necessary for the purpose for which they
were obtained. Unless Triferto is obliged to keep your data longer on the basis of legislation, we use
the statutory retention periods.

5. Where are your personal data stored?

Your data are stored on Triferto’s own secured servers, as well as on secured servers of a third party.
We may use service providers (“processors”) for the processing of your personal data, who only
process personal data on our behalf. With these processors we conclude processor agreements that
meet the requirements set by the General Data Protection Regulation (GDPR). For example, we work
with service providers who offer software and/or provide hosting services. Furthermore, there are ICT
service providers who offer us support in keeping our systems safe and stable. We also use third-party
services for sending newsletters and commercial e-mails. These are examples of parties that can be
qualified as processors as referred to in the General Data Protection Regulation (GDPR).

6. How are your personal data protected?

We have taken appropriate technical and organizational measures to protect your personal data
against loss or against any form of unlawful processing. For example, our websites are adequately
protected (with certificates / among other things, https). For more information on how we have
organized this security concretely, contact us at avg@triferto.eu.

7. Cookies

Triferto can use cookies through our websites. This saves information in the form of a text file on the
hard disk of your device. Cookies are used to deliver the website in a user-friendly manner, or to obtain
information about the quality and effectiveness of the website.

8. Inspection, improvement and portability of your data

If you want to inspect the data that have been recorded about you, you can request access to it. This
request can be sent to avg@triferto.eu. Triferto will respond to your access request within four (4)
weeks. If you want to make changes to the data you have seen as a result of your access request, you
can submit a request for that via the e-mail address mentioned hereinabove. You can request that
Triferto changes, corrects, supplements, erases or shields off your data. We will respond to your
request within four (4) weeks. If Triferto rejects your request, it will indicate in its reply why the request
to change the data has been rejected.
You also have the right to obtain and transfer the personal data you have provided in a conventional,
structured and readable form. This request can be sent to avg@triferto.eu.

9. Can this Privacy Policy be changed?

This Privacy Policy can be changed. Developments go fast, and as a result, there may sometimes also
be changes in the personal data we request from you, and the way in which we use your personal data.
These changes will be announced on our website, and the last mentioned change date will be stated.
We therefore advise you to consult this Privacy Policy on a regular basis.

10. Where can you go with a complaint?

If you have a complaint about the use of your personal data, please do not hesitate to contact us. We
will endeavour to find a joint solution. If we do not find a solution together, you can also submit your
complaint to the courts or to the Dutch Data Protection Authority.

11. Questions and feedback

If you have any questions about this Privacy Policy, please contact us at avg@triferto.eu or send a
letter to Triferto: t.a.v. Personeelszaken, Postbus 462, NL-7000 AL Doetinchem, the Netherlands,
stating “Confidential”.