Version Date: February 2024
Introduction
This Privacy Notice explains how particular companies in the CSafe Group collect, use and disclose your personal data, and your rights in relation to the personal data it holds.
This Privacy Notice applies to the processing activities of the following CSafe Group companies:
- CSafe Global Coöperatief U.A., a private company with limited liability organized and existing under the laws of the Netherlands, having its registered address at Parkstraat 83, 2ndfloor, 2514 JG, The Hague, the Netherlands;
- Softbox Systems Limited, organized and existing under the laws of England and Wales and having its registered address at Units 1-2 Ridgeway, Drakes Drive, Long Crendon, Buckinghamshire, HP18 9BF, UK;
- Kalibox SA, simplified joint-stock company organized and existing under the laws of France, having its registered address at Route de Neuilly sous Clermont, 60290 Rantigny, France;
- Tempack Packaging Solutions S.L., company organized and existing under the laws of Spain, having its registered address at de la Verge de Montserrat 2, 08820, Prat de Llobregat, Barcelona, Spain, and their affiliates,
Each of which is the data controller of your personal data and is subject to the EU / UK General Data Protection Regulation and the national implementation laws thereof (hereafter jointly referenced to as the “GDPR”). The named companies shall hereinafter also be referred to as ‘us’, ‘we’ or ‘our’ and/or ‘CSafe’.
How we collect your data
We may collect your personal data in a number of ways:
- From the information you provide to us when you meet us or when you visit our website, or when you request information from our website or from the information to be included in the distribution of our corporate newsletter;
- From information about you provided to us by your company or an intermediary;
- When you communicate with us by telephone, fax, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
- When you complete any type of forms, execute agreements with us and apply for our services, including (but not limited by) when you apply for leasing of containers, acquisition of boxes or Track & Trace Services access;
- When you apply for a job within the CSafe Group;
- From other companies in the CSafe Group;
- From your agents, advisers, intermediaries, and custodians of your assets;
- From publicly available sources or from third parties, most commonly where we need to conduct background checks about you.
The categories of personal data we collect
We may collect the following categories of personal data about you:
- Your contact details, which may include name, business or home address, email address, telephone number, gender, titles (where relevant);
- Personal identification information, which may confirm your identity including your date/country of birth, tax identification number and your passport number, driving license or national identity card details, your national identification number (based on a legal obligation), country of domicile your nationality, (electronical) signature and/or your language preferences (where relevant);
- Imagery, such as photos and video footage taken at our seminars or events depicting participants of such seminars and events;
- Information relating to your financial situation, such as income, expenditure, assets and liabilities, sources of wealth, creditworthiness, payment behavior as well as your bank account details, credit card information, billing account number (where relevant);
- Information about your employment, resume, education, your (criminal) background or personal circumstances, and interests (where relevant);
- For customer due diligence, KYC or AML checks, personal identification information and other background check information to assess whether you may represent a politically exposed person or carry any money laundering risk (where relevant).
Cookies
Please see our Cookies Policy for more information about our use of Cookies.
How we use your personal data and whom we share it with
(i) Customers management, administration and performance of a contract with you
We process your personal data because it is necessary for the performance of a contract to which you are a party to or in order to take steps upon your request prior to entering into a contract. In this respect, we use your personal data for the following purposes:
- To deal with any complaints or feedback you may have;
- To provide you with the information about the goods we are delivering and services we are providing;
- To inform you about the recent up-dates in our services;
- To draft a proposal for you regarding the services we offer and goods we deliver;
- KYC purposes (when applicable);
- For any other purpose for which you provide us with your personal data.
In this respect, we may share your personal data with, or transfer it to, the following:
- Your agents, advisers, intermediaries, and custodians of your assets who you tell us about;
- Third parties whom we engage to assist in delivering the services to you, including other companies in the CSafe Group;
- Our professional advisers where it is necessary for us to obtain their advice or assistance, including lawyers, accountants, IT or public relations advisers;
- Other third parties such as intermediaries who we introduce to you. We will wherever possible tell you who they are before we introduce you; and
- Our data storage providers.
(ii) Supplies management
We may process your personal data for prospecting for potential supplies and for their assessment; in order for us to perform the supplies administration and control the supplies payments.
(iii) Legitimate interests
We also process your personal data because it is necessary for our legitimate interests, or sometimes necessary for the legitimate interests of another person.
In this respect, we use your personal data for the following purposes:
- For marketing activities (including social media activities);
- In order to assess and evaluate your job application and to assess your suitability for a position with us;
- In order to contact you in case of suitable vacancies and job opportunities within CSafe Group;
- For the administration and management of our business, including recovering money you owe to us, and archiving or statistical analysis;
- Seeking advice on our rights and obligations, such as where we require our own legal advice;
- Handling legal claims and proceedings; and
- For the safety and integrity of CSafe Group and its employees and visitors.
In this respect we will share your personal data with:
- Our advisers or agents where it is necessary for us to obtain their advice or assistance;
- Third parties and their advisers where those third parties are acquiring, or considering acquiring, all or part of our business;
- Other companies in the CSafe Group.
(iv) Legal obligations
We also process your personal data for our compliance with a legal obligation that applies to us.
In this respect, we will use your personal data for the following purposes:
- To meet our compliance and regulatory obligations, such as compliance with anti-money laundering laws which may include the fact that we conduct a (criminal) background check (when applicable) as well as screening vs sanction lists;
- As required by tax authorities or any competent court or legal authority.
In this respect, we will share your personal data with:
- Our advisers where it is necessary for us to obtain their advice or assistance;
- Our auditors where it is necessary as part of their auditing functions;
- Third parties who assist us in conducting background checks;
- Relevant regulators or law enforcement agencies where we are required to do so.
Your rights
Under the GDPR, under certain circumstances, you have the following rights. You can exercise you rights by sending your request to: data-protection-team@csafeglobal.com – for further detail see also the ‘Contact us’ section below. We reserve the right to ask for information verifying your identity prior to disclosing any information to you. Should we ask for verification, the information you provide to verify your identify will be used only for that purpose, and all copies of this information in our possession will be destroyed when the process is complete.
- Right of access – to obtain access to, and copies of, the personal data that we hold about you;
- Right to rectification – to require us to correct the personal data we hold about you if it is incorrect.
- Right to erasure – to require us to erase your personal data;
- Right to restriction – to require us to restrict our data processing activities in relation to your personal data;
- Right to portability – to receive from us, or transferring it to another controller, the personal data we hold about you which you have provided to us.
- Right to object – to object to the processing of your personal data, including requiring us not to send you direct marketing communications.
Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply. If you are not satisfied with how we are processing your personal data, you have also the right to file a complaint with the your competent Data Protection Authority (see for EEA contact details here and for the UK, please contact the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom).
If you have given your consent to the processing of your personal data, you have the right to withdraw it at any time, please send an email to data-protection-team@csafeglobal.com or by opting out via the “unsubscribe” button in any direct marketing message you receive from us.
Transfer and processing of your personal data outside the European Union
When sharing your personal data with third parties as set out in this Privacy Notice, it may be transferred outside the European Union. In these circumstances, your personal data will only be transferred on one of the following bases:
- the country that we send the personal data to is approved by the European Commission as providing an adequate level of protection for personal data;
- the recipient has entered into European Commission standard contractual clauses with us; or
- you have explicitly consented to the same.
To find out more about transfers by us of your personal data outside the European Union and the countries concerned, or to receive copies of the transfer mechanisms that we have put in place, please send an email to data-protection-team@csafeglobal.com.
Children
CSafe does not offer its services or promote its website to, nor does it intentionally collect or retain personal information from, children who are younger than 16 years of age. Visitors to the website are cautioned, however, that the collection of personal information submitted in an e-mail or through the website will be treated as though it was submitted by an adult, and may, unless exempted from access by law, be subject to public access. If you believe your child may have submitted information to CSafe Global without indicating their actual age and would like it removed, please contact us at data-protection-team@csafeglobal.com and we will delete it immediately.
Security
The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it, and to guard that information against loss, misuse or alteration. When you enter sensitive and/or personal data on our registration or order forms, we encrypt that information using secure socket layer technology (SSL).
Please note, however, that no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, while we use appropriate means to protect your personal data, we cannot guarantee its absolute security.
Retention of your data
We retain your personal data for no longer than is necessary for its processing purposes. The applicable retention period depends on the purpose for which personal data was obtained and on specific data retention obligations arising from applicable laws that may require the data to be held for a certain period of time.
Third-party websites
From time to time, our website may link you to other sites (“Linked Sites”) that are not owned by CSafe. We do not control the collection or use of any information, including personally-identifying information, which occurs during your visit to the Linked Sites. Further, we make no representations about the privacy policies or practices of the Linked Sites, and CSafe is not responsible for the privacy practices of these Linked Sites.
Be careful of disclosing any of your personal data when leaving our website. We encourage you to be aware when you leave our website and to read the privacy statements of each and every website that collects personal data.
Contact us
If you have any further questions about how we process your personal information or if you want to exercise one of your rights, you can contact us at the office address Parkstraat 83, 2nd floor, 2514 JG, The Hague, the Netherlands, by via email address: data-protection-team@csafeglobal.com or by phone: +31 0 70 353 8249.
Version control
This version of the Privacy Notice is effective per 1 February 2024. This notice supersedes any previous Privacy Notice or equivalent which you may have been provided with or seen prior to the effective date stated above. From time to time we may update this Privacy Notice. When making changes to this notice, we will add a new date to this Privacy Notice.
