Privacy Statement Bapacho – your local baker online – an initiative of the Royal Zeelandia Group

- Zeelandia respects the privacy of all users of her websites and handles your personal data carefully –

1. INTRODUCTION

This is the Bapacho Privacy Statement for consumer and customer data, where this information relates to an individual. This Privacy Statement provides information on the processing of personal data by the Royal Zeelandia Group BV and its group companies, hereafter ‘Zeelandia’, ‘we’ or ‘us’. Zeelandia is the company behind Bapacho.

In this Privacy Statement we describe who we are, how and for which purposes we process your personal data, how you can exercise your privacy rights and all other information that may be relevant to you.

We did our best to provide you with all information in a clear and readable format. However, if you have any questions about our use of your personal data after reading this Privacy Statement, you can of course always contact us through the contact details provided below.

This Privacy Statement may be changed over time. The most up-to-date Privacy Statement is published on our website. This Privacy Statement applies since Bapacho was launched, in June 2020. The last modifications to this Privacy Statement were made on June 8th 2020.

2. WHEN DOES THIS PRIVACY STATEMENT APPLY?

This Privacy Statement is applicable to the processing by Zeelandia of all personal data of consumers and customers and other individuals through Bapacho, where you can order products at your local shop. Zeelandia runs this platform to support local Bakeries, Pastry shops and Chocolate shops, leading to the name Bapacho. When you order a product via Bapacho, you are ordering directly at your local shop. Therefore, the local shop holder (the ‘merchant’) will also process your personal data to handle your order. This Privacy Statement does not cover that process with the merchant but covers the processing of the personal data by Zeelandia to run this platform. Zeelandia does not sell your data
Finally, this Privacy Statement does not address the processing of personal data of applicants or employees in the context of their employment relationship with Zeelandia.

3. WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA?

Zeelandia is the controller of the processing of all personal data that fall within the scope of this Privacy Statement. This Privacy Statement indicates what personal data are collected and used (so called ‘processed’) by Zeelandia and for what purpose, and to which persons or entities the data will or may be provided. If you have any questions about how we process your personal data, do not hesitate to contact us. We value your privacy and your personal data is safe with Zeelandia.

4. FOR WHICH PURPOSES DO WE PROCESS YOUR PERSONAL DATA?

(a) For the conclusion and execution of agreements When you have purchased a product from our merchants as a customer we process your personal data for administrative purposes, to make sure the merchant can send invoices and you can make a payment. We also use your personal data in order to enable the merchant to deliver or receive and administer it products.

For this purpose, we process your contact details such as your address and email address, personal details such as your name and date of birth, payment and credit information, order history and other data stored in our customer database.

For this purpose we process your data on the basis of article 6(1)(b) GDPR, since the processing is necessary for the performance of a contract. Without providing the information it is not possible to place orders via Bapacho.

(b) For relationship management and marketing We use the information stored in our customer database to send you suitable offers and newsletters (if you signed up for our newsletter), as well as to perform account management. We also use your personal data for the development, execution and analysis of market surveys and marketing strategies, in order to help our merchants to improve their online services to you. We never sell your data to a third party and all personal data processed for this purpose will be only used for marketing activities by Zeelandia and for the benefit of the merchants.

For this purpose, we process your contact details such as your address and email address, personal details such as your name and date of birth, payment information and order history.

For this purpose we process your personal data on the basis of article 6(1)(f) GDPR, the legitimate interest of Zeelandia and the merchants that sell their products via our platform. Also, we may ask your consent, article 6(1)(a) GDPR, for marketing purposes, for example to sign-up for a newsletter.

(c) For organisational analysis, improving the platform and development and reporting At Zeelandia, we process your personal data in the preparation and performance of management reporting and analysis. We use aggregated personal data to create management reports and to analyse the business running through the platform, in order to provide our merchants with valuable insights on how the platform is being used. Next to that, we may conduct customer surveys to learn more about your views and opinions. We also process your personal data for management reporting purposes in the context of mergers, acquisitions and divestitures and in order to manage such transactions.

For this purpose, we de-identify your personal data, such as how you use the platform, what you order and what you think of the platform and the products, for example based on the information you provide when responding to our surveys. Next to that, we use aggregated personal data to analyse customer behaviour and to adjust the platform, to ensure that it is relevant to the customers of our merchants. This means that we analyse how often you read our newsletters, how often you visit Bapacho, which pages you click on and what goods you purchase through Bapacho.

For this purpose, we may process your contact details, such as your address and email address, personal details such as your name and date of birth, payment and credit information, and correspondence with us. In addition, we process the personal data you entered into the platform or that were generated by the functionalities you used in the platform and the technical data from your device such as its IP-address, the pages you visited on Bapacho, your click- and surf behaviour and the length of your session.

For this purpose we process your personal data on the basis of article 6(1)(f), the legitimate interest of Zeelandia and the merchants that sell their products via our platform, so we can further improve Bapacho and the products that are being sold on it.

(d) To deliver you our website functionalities and for their technical and functional management If you use our platform, we process technical data to offer you our platform functionalities and to allow our platform administrators to manage and improve our platform performance. If you enter data in our platform, for example by creating an account or leaving behind information to receive relevant information, we process these data to provide you with the requested information.

Further, we process your personal data to allow you to save your data (such as subscriptions of freshly baked products).

For this purpose, we process the personal data you have entered into our platform or that is generated by the functionalities you have used in our platform and the technical data from your device such as its IP address, the internet browser you use, the pages you have visited on our platform, your click- and surf behaviour and the length of your session.

For this purpose we process your personal data on the basis of article 6(1)(f) GDPR, the legitimate interest of Zeelandia and the merchants that sell their products via our platform, so we can further improve the functionalities of our platform.

(e) If you open a Bapacho account with us, to administer the account and to ensure confidentiality and security of your purchases When you choose to register with us, you need to provide personal data so that we can create a personal account for you. Upon creating your account, we will send you your personal login information. These personal data enable us to administer your account and enable us to ensure the confidentiality and to maintain the security of your purchases. We are, for instance, able to change your password for you. We are, however, not able to view your password.

To create an account we only need your e-mail address. After that it is up to you which information you would like to share, for example your address, title, telephone number, gender and date of birth, address, any other information you have added to your account, your login data (including your password), display name, your role, the details of your purchases and your payment details].

For this purpose we process your personal data on the basis of article 6(1)(a) GDPR, your consent and article 6(1)(f) GDPR, the legitimate interest of Zeelandia and you to keep the platform secure and prevent malicious behaviour.

(f) To allow you to connect with us (e.g. via social media) We are active on social media platforms like Facebook, Twitter, LinkedIn, YouTube and Instagram. When you contact us via social media, we process your personal data in order to answer your questions and to respond to your messages.

We provide you with our email address, for you to send us your feedback and suggested improvements, as well as our social media details. When you click one of the corresponding icons (Twitter, YouTube, LinkedIn, Facebook, Instagram) on our platform, we will refer you to the website or app of the applicable external party.

For this, we process the communication channel you have chosen to use to connect with us and the personal data you supply to us. This includes your (user) name, address, email address, and the personal data you have included in your message. In addition, when you click one of the buttons displayed, the relevant third party might place cookies on your device. Read the cookie statement of that third party to find more information.

For this purpose we process your personal data on the basis of article 6(1)(f) GDPR, the legitimate interest of Zeelandia to connect with the users of the platform and other individuals that want to connect with Zeelandia.

(g) To answer all your questions about Bapacho If you get in touch with us via info@zeelandia.com or via the contact form on the platform, we will use your personal data in order to reply to and answer your question about Bapacho. For this purpose, we process your name, contact details, your correspondence with us your question and all other personal data which are necessary to answer your question.

If you have contacted us via the contact form on our support page, then your data will be deleted from our systems after two years after having the last contact. If you have contacted us via info@zeelandia.com, then your data will be retained for two years after having the last contact.

For this purpose we process your personal data on the basis of article 6(1)(f) GDPR, the legitimate interest of Zeelandia and the users of Bapacho to have all their questions answered timely.

(h) To comply with the law In some cases, we process your personal data to comply with laws and regulations. This could, for example, be the case where tax or business conduct related obligations apply. In order to comply with relevant laws and regulations, we may need to disclose your personal data to government institutions or supervisory authorities.

For this, we process your contact details such as your address and email address, personal details such as your name and date of birth, payment information, payment and order history, and your chamber of commerce and VAT details and tax details.

5. COOKIES

We also collect information through the use of cookies. Cookies are small files of information which save and retrieve information about your visit to this website. We use cookies to further improve our platform and to make sure everything works properly. At Zeelandia we care about your privacy. Therefore, we do not use so called ‘tracking’ cookies, which process your personal data. The only cookies we use are functional cookies and analytical cookies, which we limited to aggregated data, purely used for the statistical purposes of Zeelandia and our merchants. Therefore, we do not use analytical cookies to retrieve your personal data.

6. WHO HAS ACCESS TO YOUR PERSONAL DATA?

6.1 Access to your personal data within Zeelandia

As a global organisation, data we collect may be transferred internationally throughout our worldwide organisation. Your personal data may be exchanged within the Zeelandia group. We exchange your data for administrative purposes and so that we can have a complete overview of your contacts with the Zeelandia group. We may also exchange your data in order to offer you a complete package of services and products.

Our employees are authorised to access personal data only to the extent necessary to serve the applicable purpose and to perform their jobs.

6.2 Access to your personal data by third parties

The following third parties have access to your personal data, where relevant, for the provisioning of their products or services to us:

• Your local merchant, in order to process your order. • TransIP, which is our website service provider.

When third parties are given access to your personal data, we will take the required contractual, technical and organisational measures to ensure that your personal data are only processed to the extent that such processing is necessary. The third parties will only process your personal data in accordance with applicable law.

If your personal data are transferred to a recipient in a country that does not provide an adequate level of protection for personal data, we will take measures to ensure that your personal data are adequately protected, such as entering into EU Standard Contractual Clauses with these recipients.

In other cases, your personal data will not be supplied to third parties, except where required by law.

6.3 The use of your personal data by data processors

When a third party processes your personal data solely following Zeelandia’s instructions, it acts as a data processor. We enter into an agreement with such a data processor for the processing of personal data. In this agreement we include obligations to ensure that your personal data are processed by the data processor solely to provide services to us.

7. HOW ARE YOUR PERSONAL DATA SECURED?

Zeelandia has taken adequate safeguards to ensure the confidentiality and security of your personal data. We have implemented appropriate technical, physical and organisational measures to protect personal data against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorised disclosure or access as well as all other forms of unlawful processing (including, but not limited to, unnecessary collection) or further processing. Examples are IT security policies, staff training and secure servers. Your personal data are stored within the European Economic Area.

8. HOW LONG ARE YOUR PERSONAL DATA RETAINED?

Your personal data will be removed or made anonymous when your personal data is no longer necessary for the purposes for which these personal data are processed. As long as you have an active account, the information connected to your account will be stored in our database. Your order information will be stored with a maximum of two years after placing an order. Data which are explicitly used during a promotion or sweepstake will be deleted after the promotion or sweepstake period.

9. HOW CAN YOU EXERCISE YOUR PRIVACY RIGHTS?

You have the right to request access of an overview of your personal data, and under certain conditions, rectification and/or erasure of personal data. In addition, you may also have the right of restriction of processing concerning your personal data, the right to object to processing as well as the right to data portability.

To invoke your right of access, rectification, and/or erasure of personal data, your right of restriction of processing, and/or your right to object to processing as well as to invoke your right to data portability, please contact us by using the contact details at the bottom of this Privacy Statement. Please keep in mind that we may ask for additional information to verify your identity.

If you have given your consent to a certain purpose, you can withdraw your consent at any time. Please keep in mind that withdrawal does not have retrospective effect. You can contact us by using the contact details at the bottom of this Privacy Statement, or, in case of newsletters, by unsubscribing with the button in every email.

10. DO YOU HAVE QUESTIONS OR COMPLAINTS?

If you have any further questions about the way we process your personal data, please contact our privacy team through privacy@zeelandia.com first. Your question or complaint will then, if necessary to process it, be directed to the local office of Zeelandia in your country or region. For questions about your ordered products, please contact your local shop.

Should you still be of the opinion that your request or complaint was not handled satisfactorily by us, you have the right to lodge a complaint with your local data protection supervisory authority. Please contact your local data protection supervisory authority through the contact details on their website.