AGRIMATCO GROUP
PRIVACY NOTICE
Last updated 30/04/2024
INTRODUCTION
1.This Privacy Notice describes and governs how the Agrimatco Group of Companies (“we”, “us, “our”, “Agrimatco” or the “Group”) collects, uses, processes, and discloses information, including personal information (the “Personal Data”) of our customers, potential customers, job applicants and/or visitors or users of our website (hereinafter the “Website”).
2.We undertake to meet our legal obligations and handle such personal data in accordance with applicable data protection legislation and good business practices.
3.This Privacy Notice applies to all Companies in the Agrimatco Group of Companies.
4.You may read this Privacy Notice, in order to determine whether you wish to provide your Personal Data, or those of third parties, to Agrimatco.
5.For the purposes of this Policy and in addition to other definitions found herein, the following definitions shall apply:
A “Data Controller” determines the purposes for which and the means by which Personal Data is processed.
A “Data Processor” processes Personal Data on behalf of the Data Controller, for the purposes and using the means specified by the Data Controller, in accordance with applicable legislation.
“Personal Data” is information relating to natural persons who can be identified or are identifiable, directly from the information in question or who can be indirectly identified from that information in combination with other information.
6.Depending on the exact circumstances of each case and for the purposes of this Policy, a member of the Agrimatco Group may act as a Data Controller and/or as a Data Processor of your data. If you wish to find out which member(s) of the Group act(s) as the Data Controller and/or the Data Processor in relation to your Personal Data in a specific situation, please contact our Data Protection Officer.
7.Our Data Protection Officer is Volodymyr Synytsia (the “DPO”). You may contact our DPO at dpo@agrimatco.com.
WHAT PERSONAL DATA DO WE COLLECT?
Website Visitors
8.When you visit the Website, we do not automatically collect information from your computer, tablet, phone or other electronic device used to access the Website without your intervention.
9.Irrespective of the above, we may collect your information (such as your name, email address and phone number) when you submit an enquiry or feedback through our Website.
10.We may collect Personal Data from Third Parties, including technical data from analytics providers such as Google LLC.
Websites Visitors & Withdrawal of Consent
11.With the use of the Website and/or by contacting us through the Contact Forms on the Website, you consent to this Privacy Notice. To revoke such consent, you may refrain from using our website. If you do not wish to use our website and need to contact us, you may do so via phone or email, found in our contact page.
12.In the event that you withdraw your consent, the legality of the processing carried out prior to the withdrawal of your consent will not be affected.
Communication with Us
13.When you communicate with us via email or telephone, or in any other way interact with us, we may collect any of the following data, depending on the case:
i.Name and Surname
ii.Email Address
iii.Telephone Number
iv.Any other Personal Data which you may voluntarily share with us
14.Personal Data shared with us while communicating with us, will be used to facilitate the communication with you and to respond to your enquiries.
Provision of Goods or Services to You
15.When you transact with us, you will be required to provide us with information in connection with the following:
i.Identifying information such as your name, telephone number and email address.
ii.Buying or selling information you provide during a transaction, or other transaction-based information generated or is connected to you as a result of a transaction you are involved in.
iii.Financial and billing information (such as credit card or bank account details),
iv.Your information when you correspond with us.
16.We may be unable and we reserve the right to refuse to fulfil any orders, enter into any agreements, respond to any requests and/or provide any goods or services if you fail or refuse to provide us with necessary personal information for the above purposes.
Provision of Deferred Payment Terms
17.To provide Deferred Payment Terms to you, we may request the following additional information to assess you credit worthiness:
i.Copies of ID Card, Passport or other identification document
ii.Residential Address
iii.Date of Birth
iv.Education and Professional Background
v.Marital Status
vi.Loan and Credit Status
Job Applicants
18.When you apply for a position in the Agrimatco Group, we may collect the following information to examine your job application and decide whether to conclude an Employment Agreement with you:
i.Name & Surname
ii.Gender
iii.Date & Place of Birth
iv.Nationality
v.Phone Number
vi.Email Address
vii.Residential Address
viii.Education
ix.Prior Work Experience
19.If we conclude an Employment Agreement with you, we will maintain the Personal Data collected as part of your job application and additional data that we may request, in accordance with our Staff Privacy Notice which will be communicated to you at the time of your hiring.
20.You are not obliged to provide us with the Personal Data mentioned above, however, if you choose not to share such Data, we may not be able to examine your application or notify you for future job vacancies with Agrimatco.
USE OF PERSONAL DATA
21.We will only use your Personal Data for the purposes for which it was collected, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose of collection. If we need to use any Personal Data for an unrelated purpose, we will notify you to explain the legal basis for such use and where required, ask for your consent.
SPECIAL CATEGORY PERSONAL DATA
22.Except as provided herein, we do not collect any Special Category Personal Data about you (such as details about your race or ethnicity, religious or philosophical beliefs, political opinions, information about your health and genetic and biometric data, or any information about criminal convictions and offences).
PURPOSES & LEGAL BASIS FOR PROCESSING
23.Depending on how you interact with us, we will collect and process your Personal Data:
i.To provide our products and services to you. This includes completing orders, providing support, updating, improving, securing and personalising our Services.
ii.To contact you about any products or services provided to you and provide you with customer service.
iii.To comply with our legal obligations and applicable legal and compliance requirements.
iv.Prevent, detect, mitigate, and investigate fraudulent or illegal activities.
v.To conclude an Employment Agreement with you.
24.When processing your Personal Data, we may rely on one or more of the following Legal Bases:
i.Processing is necessary for the provision of our products and services. If your Personal Data are not provided or not provided accurately, we may be unable to fulfil any orders, provide support and/or provide our products and services.
ii.For the safeguarding of our legitimate interests.
iii.You have consented to the processing of your Personal Data for the specific purpose.
SHARING OF PERSONAL DATA
25.Under specific circumstances, we are legally obliged to share your Personal Data. We share your Personal Data with third parties, including government agencies and external auditors. We may also be legally required to share your Personal Data under a court order.
26.We may disclose your Personal Data to third parties as follows:
i.Disclosure to companies in the Agrimatco Group, Agrimatco affiliates and subsidiaries or to third parties, where such disclosure is necessary for the performance of the intended purposes (such as to meet our contractual obligations to you). Data recipients include, among others, our Accountants, our Suppliers, our Lawyers, and the IT service providers who have access to our systems. Such receiving parties are bound by appropriate confidentiality agreements.
ii.Disclosure is necessary to assert, exercise or defend legal claims and there is no reason to assume that you have a predominantly legitimate interest in not disclosing your data.
iii.You have expressly consented to this.
iv.We are legally required to disclose such data.
27.When disclosure of your Personal Data is required, we try to restrict the Personal Data disclosed to what is directly relevant and necessary for the accomplishment of the specified purpose.
DATA RETENTION
28.We will retain your Personal Data for as long as it is necessary and relevant for our operations and for the purposes for which this was collected (the “Data Retention Period”).
29.When you visit our Website, we will retain any Personal Data collected for a period of 6 months from the date of each Website visit to monitor our Website performance and traffic.
30.When you communicate with us, we will retain any Personal Data shared with us for a period of 6 months from the date of such communication, to be able to follow up on your enquiry.
31.Where we transact with you for the provision of goods or services, we will retain your Personal Data for as long as we provide or receive goods or services from or to you or for as long as there is a legal basis for retention and processing.
32.Where the business relationship or transaction between you and a member of the Agrimatco Group has terminated or lapsed, we will retain any Personal Data collected for this purpose for a period not exceeding 7 years, to comply with national laws (such as applicable statutes of limitation), prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation and take other actions permitted or required by applicable laws.
33.Irrespective of the above, where we provide Deferred Payment Terms to you, we will retain Personal Data collected for this purpose until the payment obligations have been fully settled and for a period not exceeding 7 years thereafter, to comply with national laws (such as applicable statutes of limitation), prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation and take other actions permitted or required by applicable national laws.
34.Where a transaction between you and a member of the Agrimatco Group is completed, we will maintain any accounting records and any relevant Personal Data for a period not exceeding 7 years to comply with applicable legislation, and in particular to comply with relevant record-keeping obligations.
35.If you apply to work with Agrimatco and your application is unsuccessful, we will retain the Personal Data collected for this purpose for a period of 3 months from the date of filling of the position you have applied for, to notify you of any job vacancies of similar positions with Agrimatco within this period. If you have explicitly consented to this, we will retain the Personal Data collected as part of your job application for a period of 2 years, to notify you of any job vacancies of similar positions with Agrimatco within this period.
36.You may at any time withdraw your consent to being notified for future job vacancies with Agrimatco by sending a relevant request to the DPO via email. We will stop the processing of your Personal Data and delete any copies maintained. The lawfulness of any processing of your Personal Data performed by Agrimatco prior to the withdrawal of your consent will not be affected.
37.After the Data Retention Period has elapsed or when we have no legal basis to process your data, we will delete all copies of your Personal Data in a secure manner in accordance with this policy.
INTERNATIONAL TRANSFERS
38.We may share your Personal Data with the Agrimatco Group Companies and/or other recipients outside the European Economic Area, if such a need arises and in accordance with the terms of this Policy.
39.We integrate the European Commission’s Standard Contractual Clauses in our agreements with data recipients outside the European Union. We also ensure that they are bound by contractual confidentiality obligations and that they have appropriate safeguards and procedures in place.
SECURITY MEASURES
40.We are committed at all times to process your Personal Data in a confidential manner and in accordance with applicable laws and regulations.
41.For this purpose, we adopt measures of a technical and organizational nature required to guarantee the security and integrity of your Personal Data, depending on the state of the technology, the nature of the stored data
, the medium of storage and the risk of data being accidentally lost, used or accessed in an unauthorised way.
42.We have appropriate security measures in place to prevent Personal Data from being accidentally lost or used or accessed in an unauthorised way. We limit access to your Personal Data to those who have a genuine business need to have access to it. Those processing your Personal Data will do so only in an authorised manner and are subject to a duty of confidentiality.
43.We also use firewalls and active Antivirus Software and Advance Threat Protection Subscriptions, data encryption, restrictions and controls on physical access to data stored in physical location(s). When possible and appropriate, we try to anonymize data and impose limitations on use.
44.We have procedures in place to deal with any suspected Personal Data security breach. We will notify you and any applicable regulator of a suspected Personal Data security breach where we are legally required to do so.
YOUR RIGHTS
45.You have the following rights as regards your Personal Data:
i.Request Access: You have the right to request access to your Personal Data.
ii.Request to Correct Personal Data: You may request that we correct any incomplete or inaccurate data we hold about you, though we may need to verify the accuracy of the new data you provide to us.
iii.Request the Erasure of Personal Data: You may request that we delete or remove any Personal Data where there is no valid legal basis for us continuing to process it.
iv.Object to Processing of Personal Data: Where there is something about your particular situation which makes you want to object to processing because it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your data.
v.Request Restriction of Processing: This enables you to ask us to suspend the processing of your Personal Data if you want us to establish the data’s accuracy or where the use of such data is unlawful but you do not want us to erase it, where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims, or where you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
vi.Request the Transfer of Personal Data: You may request that we provide you, or a third party of your choice, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used to perform a contract with you.
vii.Withdraw Consent: You may withdraw your consent to the processing of your Personal Data by emailing our DPO, at any time where we are relying on consent to process your Personal Data.
viii.Not to be subject to a Decision Based Solely on Automated Processing: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
HANDLING OF DATA SUBJECT REQUESTS AND COMPLAINTS
46.If you wish to exercise any of the rights set out above, contact our DPO via email.
47.We do not normally charge any fees for access to your Personal Data (or to exercise any of the above rights). We may charge a reasonable fee if a request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with a request in these circumstances.
48.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.
49.We try to respond to all legitimate requests within one (1) month of receipt. It may take us longer than a month 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.
50.We do not warrant, undertake and/or represent error-free performance under this Privacy Notice. We will use all reasonable efforts to comply with this Privacy Notice and shall take immediate rectification actions in the event of a breach of this Privacy Notice. We shall not be liable for any incidental, consequential or punitive damages relating to a breach of this Privacy Notice.
51.You have the right to file a complaint with a Data Protection Commissioner on any matter related to how we collect and process your personal data.
52.The relevant supervising authority in Cyprus is the Commissioner for Personal Data Protection. You can visit the Commissioner’s website for more information at their website /www.dataprotection.gov.cy/.
LINKS TO OTHER WEBSITES
53.The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies and/or procedures. When you leave our Website, we encourage you to read the privacy notice of every website you visit.
CHANGES TO THIS PRIVACY NOTICE
54.We may amend the information contained in this Privacy Notice when we consider this appropriate or as required due to changes in applicable legislation. Should we do so, we will update the Notice as published on our Website, but are not obliged to send you an email or in any other way inform you of the changes effected. You may assess such changes and, as the case may be, object or unsubscribe from any service or functionality.
55.We recommend that you review this Privacy Notice at frequent intervals to be kept up to date with any amendments introduced. We will update the “Last Updated” date at the beginning of this Privacy Notice. Any changes make to this Privacy Notice are effective as of this Last Updated date and replace any prior Privacy Notice versions.
56.In case you need any clarifications about the processing of your Personal Data, contact our DPO via email.
