With respect to personal data of ‘external contacts’
4. What is personal data?
Personal data is any information about an identifiable individual, other than the person's business title or business contact information when used or disclosed for the purpose of business communications. Personal information does not include anonymous or non-personal information (i.e., information that cannot be associated with or tracked back to a specific individual).
5. What personal data do we process?
In our business operation we process different types of personal data of our external contacts, including, but not limited to, the personal data contained in:
- completed contact forms;
- submitted complaints;
- communications, via post, e-mail, phone, websites or social media platforms;
- job application letters;
- the books in which names and signatures of visitors of our factories are recorded;
- public sources (such as the Commercial Trade Registers);
- databases from third parties.
In addition to the examples listed above, personal data also includes information such as gender, date of birth, education and/or training details, bank details and any other information necessary to achieve Refresco’s business purposes, which is disclosed in the context of having contact or doing business with, or applying for a job at, Refresco.
As a general rule, Refresco processes personal data directly provided by external contacts. From time to time, we may utilize the services of third parties in our business and may also receive personal data collected by those third parties in the course of the performance of their services for us or otherwise. Where this is applicable, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose the personal data of external contacts to us.
Where permitted or required by applicable law or regulatory requirements, we may process information about external contacts without their knowledge or consent.
6. Why do we collect personal data?
Refresco processes personal data of external contacts for its business purposes only. We can inter alia process personal data of external contacts for the following purposes:
- the entering and execution of an agreement in respect of the products and/or services we deliver;
- the entering and execution of an agreement in respect of the products and/or services external contacts deliver;
- to offer products and/or services from us and to adapt them to the needs and wishes of external contacts;
- to be able to review the products and services that we obtain from you so that we may work with you and so that you may understand our requirements for such products and services;
- to be able to contact external contacts via applicable media;
- to be able to handle complaints;
- to be able to handle job application letters;
- to be able to guarantee the safety of visitors and employees of our factories;
- to protect us against error, fraud, theft and damage to our goods and property, including to verify your identity;
- in case the external contact has given unambiguous consent: to send press releases (with information about our company organization;
- in case the external contact has given unambiguous consent: to show ads (e.g. on social media);
- to send the external contact user information and service messages;
- to analyze, maintain, secure and optimize our websites and associated technologies;
- for compiling user statics of our websites;
- to comply with relevant laws and regulations;
- such other purposes as are reasonably required by Refresco.
Please note that personal data of external contacts may be exchanged with, or made available to our subsidiaries for the aforementioned purposes.
In connection with your application for work with us, we will use the personal data we collect about you to:
- assess your skills, qualification, and suitability for the role;
- carry out background and reference checks, where applicable;
- communicate with you about the recruitment process;
- keep records related to our hiring process;
- comply with legal or regulatory requirements.
We also need to process your personal data to decide whether to enter into a contract of employment with you. Having received you CV, covering letter or your application form and the results from the test, which you took, if applicable, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role.
If we decide to call you for an interview, we will use the information you provide to us at the interview, to decide whether to offer you the role.
If we decide the offer you the role, we might than take up references before confirming your appointment.
If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.
If you fail to provide information when requested, which is necessary for us to consider your application, we will not be able to process your application successfully.
8. How do we use your personal data?
We may use your personal data:
- for any additional purposes that we advise you of and where your consent is required by law and have obtained your consent in respect of the use or disclosure of your personal data.
We may use your personal data without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
9. When do we disclose your personal data
As a principle, we do not disclose personal data to third parties. However, disclosing personal data of external contacts to third parties might be necessary in the performance of an agreement between Refresco and the external contact. At all times, any third party must act on the instructions of Refresco and ensure personal data is adequately protected.
10. How is personal data protected?
Refresco will take all reasonable precautions to keep your personal information secure, appropriate to our business and the amount of personal data that we own or maintain and identified risks.
11. How long is personal data retained?
Except as otherwise permitted or required by applicable law or regulatory requirements, Refresco endeavors to retain personal data of external contacts only for as long as it believes is necessary to fulfill the purposes for which the personal information was collected (including, for the purpose of meeting any legal, accounting or other reporting requirements or obligations).
We may, instead of destroying or erasing personal data of the external contact(s) make it anonymous such that it cannot be associated with or tracked back to the external contact(s).
12. Links to third party websites
You should exercise caution and look at the privacy statement applicable to the website in question. Moreover, we are not responsible nor liable for the content of third party websites or platforms.
13. Access to your personal data
It is important that all personal data in our records is both accurate and up-to-date. You can exercise your rights with respect to your personal data, such as the right of access, rectification, erasure and objection. Please use the contact information provided below. We strive to respond to your request within four (4) weeks. Occasionally it may takes us longer than four (4) weeks if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
14. Other Refresco privacy policies
15. Inquiries or concerns?