1. Who DOES this GDPR privacy statement apply to?

1.1 Eutracking Group (“EuTracking” or “We”) is an international port-infrastructure company that develops, operates, and manages global maritime supply-chain solutions for international customers in target industry sectors.

Eutracking operates and manages a network of port terminals in strategic locations across Europe and Asia. Our group consists of several companies (“the Eutracking Companies”) that process personal data.

1.2 This GDPR Privacy Statement applies to the processing of personal data:

• by all Eutracking companies established in the European Union, regardless of whether the processing takes place in the Union or not;
• by all Eutracking companies established outside the European Union, insofar as they process personal data of data subjects who are in the Union in the framework of:
  • the offering of goods or services to such data subjects in the Union;
  • the monitoring of their behaviour as far as their behaviour takes place within the Union.

1.3 All Eutracking Companies are separate and independent legal entities. Depending on the processing activity in the context of which your personal data are processed, they may be qualified as a separate data controller or a joint controller with one or more of the other Eutracking Companies. None of the Eutracking companies have any liability for the other Eutracking Companies’ acts or omissions.

1.4 We want to be a great company. To achieve that goal, we are committed to working in the right way. We are committed to protecting your privacy and processing your personal data openly and transparently, in particular concerning the General Data Protection Regulation 2016/679 of 27 April 2016 (“GDPR”).

1.5 Please follow the links below for further information. Where relevant, we have made a distinction between:

• website visitors;
• (contact persons) of suppliers, customers, prospects, or any other individuals whose data are processed in the framework of our business activities.

2. What is covered by this GDPR Privacy STATEMENT?

2.1 With this GDPR Privacy Statement we would like to inform you about why and how we process your personal data when we perform our business activities or when you use our website (“the Site”) and any of the services we offer through the Sites, who we give that information to, what your rights are and who you can contact for more information or queries.

2.2 When we refer to “the Site”, we mean the webpages with a URL commencing https://www.eu-tracking.com/. However, by way of derogation, this GDPR Privacy Statement does not apply to webpages on the “Careers” section of the Site allowing you to apply for job openings (Vacancies). These webpages are subject to our separate Privacy Notice for job applicants.

2.3 The Site may link to other sites provided by other affiliated entities or by third parties. Whilst we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content or the privacy practices of other websites.

When linking to any such sites, we strongly recommend you review the GDPR Privacy Statements on these sites, before disclosing any personal information.

3. Why do we use your data

3.1 I AM A WEBSITE VISITOR

3.1.1 We only process your personal data for legitimate business reasons. These purposes include, but are not limited to:

• dealing with inquiries, requests, and complaints sent via the online contact form;
• gathering statistics about the use of the Site (“web audience measuring”);
• improving the Site’s performance and design.

3.2 I AM (A CONTACT PERSON OF) A SUPPLIER, A CUSTOMER OR A PROSPECT, OR ANY OTHER INDIVIDUAL WHOSE PERSONAL DATA ARE PROCESSED (E.G. A VISITOR, A BUSINESS CONTACT ETC.)

3.2.1 We only process your personal data for legitimate business reasons. These purposes include, but are not limited to:

• respecting our legal obligations;
• customer and supplier management;
• visitor management;
• order and supply management;
• invoicing and accounting;
• the provision of information on our company, services, and activities;
• the good organisation of our services (such as day-to-day business communication);
• marketing and sales;
• dealing with inquiries, requests, and complaints;
• dispute management;
• public relations and press contacts;
• statistics and market research;
• access control;
• security;
• health and safety (QHSE).

4. The legal grounds for processing your data

4.1 I AM A WEBSITE VISITOR

4.1.1 When you send a message via the online contact form, your personal data will in principle be processed for the purposes of our legitimate interests (namely the interest to handle all inquiries, requests, and complaints sent via this form in the best possible way).

In this respect, we will always determine case by case whether our interests are not overridden by your interests, fundamental rights, and freedoms.

4.1.2 Before using Google Analytics cookies to gather statistics about the visits to the Site, we will always ask for your explicit consent.

4.2 I AM (A CONTACT PERSON OF) A SUPPLIER, A CUSTOMER OR A PROSPECT, OR ANY OTHER INDIVIDUAL WHOSE PERSONAL DATA ARE PROCESSED (E.G. A VISITOR, A BUSINESS CONTACT ETC.)

4.3 We process your personal data for the purposes mentioned above:

• when necessary for the performance of contracts to which you are a party or to take steps at your request before entering into a contract;
• when necessary for compliance with our legal obligations;
• for the purposes of the legitimate interests of the Company and/or of a third party, including (but not limited to) our business activities, customer and supplier management, etc. In this respect, we will always determine case by case whether our interests are not overridden by your interests, fundamental rights, and freedoms.

4.3.1 If we have the legal obligation to obtain your free, informed, specific and unambiguous consent to process your personal data for certain purposes (e.g. specific direct marketing or market research activities), we will only process your data for such purposes to the extent that we have obtained such consent from you.

5. Your Rights

5.1 You have several rights concerning the information we hold about you. We would like to inform you that you have the right to:

• obtain confirmation that we are processing your personal data and request a copy of the personal data we hold about you;
• ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete;
• ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data;
• withdraw consent to our processing of your personal data (to the extent such processing is based on consent);
• receive a copy of the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format, and transmit such data to another party (to the extent the processing is based on consent or a contract);
• object to our processing of your personal data for which we use legitimate interest as a legal basis, in which case we will cease the processing unless we have compelling legitimate grounds for the processing.
• You have also the right to object at any time to the processing of personal data for direct marketing. If you do not want to continue receiving any direct marketing from us, you can contact us (see below) or click on the unsubscribe function in any such communication. In that event, the personal data shall no longer be processed for such purposes.

5.2 To exercise any of your rights, you can send us a request, indicating the right you wish to exercise:

• by using the contact form on our website; or
• by addressing your query to Eutracking Belgium HQ, Privacy Office, Land van Waaslaan 5, Haven 1205, 9130 Kallo, BE.

You may also use these contact details if you wish to make a complaint to us relating to your privacy.

5.3 If you are unhappy with the way we have handled your personal data or any privacy query or request that you have raised with us, you have a right to complain to the Data Protection Authority (“DPA”) in your jurisdiction. If you would like to be directed to the appropriate DPA, please contact us.

Contact Information

If you have any questions about this GDPR Privacy Statement, your rights, or any other data protection queries, please contact us:

6. How we obtain DATA

6.1 I AM A WEBSITE VISITOR

6.1.1 We may obtain your personal data when you use the Site and its services. This may be for instance the case when you fill in the contact form on the Site.

6.1.2 With your consent, the Site also uses cookies to gather statistics about the visits to the Site to improve its performance and design. For more information about the cookies we use and how you can control them, please consult the cookie section.

6.2 I AM (A CONTACT PERSON OF) A SUPPLIER, A CUSTOMER OR A PROSPECT, OR ANY OTHER INDIVIDUAL WHOSE PERSONAL DATA ARE PROCESSED (E.G. A VISITOR, A BUSINESS CONTACT ETC.)

6.2.1 We may obtain your personal data in the framework of the execution of our business activities.

6.2.2 We may obtain such personal data because you give them to us (e.g. by contacting us, by completing online forms, …), because others give them to us (e.g. your employer or third-party service providers that we use in the framework of our business activities) or because they are publicly available.

6.3 When we obtain personal data from external parties, we make reasonable efforts to enter into contractual clauses with these parties obliging them to respect the data protection legislation. This can be done by obliging this party to provide you with all necessary information or – if necessary – to obtain your consent for processing the personal data as described in this GDPR Privacy Statement.

7. Data we collect

7.1 I AM A WEBSITE VISITOR

7.1.1 The main personal data we collect through this Site are the data that you have to fill in when contacting us through the online contact form. The following data are collected through this form: name, company (optional), phone number, email, subject, and the content of your message.

7.1.2 With your consent, this Site also uses cookies to gather statistics about the visits to the Site to improve its performance and design. For more information about the cookies we use and how you can control them, please consult the cookie section.

7.2 I AM (A CONTACT PERSON OF) A SUPPLIER, A CUSTOMER OR A PROSPECT, OR ANY OTHER INDIVIDUAL WHOSE PERSONAL DATA ARE PROCESSED (E.G. A VISITOR, A BUSINESS CONTACT ETC.)

7.2.1 The personal data that we collect or obtain may, among other things, include:

• Identification data (e.g. name, address (private / work), phone number (private / work), e-mail address (private / work), country of residence), national identification number, passports etc.
• Electronic identification data (e.g. IP addresses, browser type, cookie identifiers, …);
• Personal characteristics (e.g. age, gender, date of birth, place of birth, nationality, language, family composition, hobbies, etc.);
• Financial specifics (e.g. bank account number, creditworthiness…);
• Lifestyle and social circumstances;
• Family circumstances (e.g. marital status);
• Employment and educational data (e.g. organization you work for, job title, current responsibilities, projects, qualifications, training, work scheme…);
• Data about which products and services you order;
• Camera surveillance records;
• Data about how you interact with us (e.g. when you contact us) and other similar information.

8. Disclosures

8.1 We may disclose your personal data to affiliated companies, third parties that provide services to us that reasonably require access to personal data relating to you for one or more of the purposes outlined in the “Why we use your data” section above. The following external parties may for instance be involved:

• External service providers, we rely on for various business services;
• Law enforcement authorities under the relevant legislation;
• External professional advisors (e.g. attorneys or consultants of the company).

If our business enters into a joint venture with or is sold to or merged with another business entity, your information may be disclosed to our new business partners or owners.

8.2 Please note that some of the recipients of your personal data referenced above may be based in countries outside of the European Economic Area whose laws may not provide the same level of data protection.

Should this be the case appropriate safeguards to process your personal data under the data protection legislation have been taken.

8.3 In general, we will take all steps reasonably necessary to ensure that your data is treated securely and under this GDPR Privacy Statement.

We reserve the right to disclose your personal information as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator or any other legal process served on us.

9. Cookies

9.1 This Site uses Cookies. Cookies are small text files that are stored by your browser onto your computer or mobile device when you visit this Site.

You can find more information about cookies by visiting the following website: www.allaboutcookies.org.

Your consent applies to the following domains: www.eu-tracking.com

[user_consent_state]

9.2 The only type of cookies we use on the Sites are:

[cookie_category]

The below list details the cookies used in our website.

[cookie_audit_category columns="cookie,description"]

9.2.1 How do we protect your privacy?

To protect your privacy and to comply with the applicable data protection legislation, we have taken the following measures:

• We have entered into a data processing agreement with Google. Under this agreement, Google will only act as a data processor concerning the data of website visitors. Consequently, Google will not use the data for its purposes.
• We have enabled IP masking. This means that the last octet of your IP address is removed before its use and storage (e.g. 123 987 XXX).
• We have specified in our Google Analytics settings that no data are shared for Google’s purposes such as benchmarking, the improvement of other products and services (as also stipulated in the data processing agreement).
• We have ensured that other services of Google will not be used in combination with the Google Analytics cookies and that no data can be used for advertising purposes.

For more information about Google Analytics cookie practices, please click on this link: Google Analytics

9.2.2 Rejection of Google Analytics

You can easily opt out and prevent your data from being used by Google Analytics. This can be done by installing the Google Analytics opt-out browser add-on. Alternatively, you can always adjust the corresponding settings in your browser software to prevent the use of Google Analytics cookies.

9.3 You can enable, disable and/or delete cookies as you wish. You can delete all cookies that are already on your device and you can set most browsers to prevent them from being placed.

The ability to enable, disable and/or delete cookies can be completed at the browser level. These settings are usually found in the “options” or “preferences” menu of your internet browser. To understand these settings, the following links may be helpful. Otherwise, you should use the “Help” option in your internet browser for more details:

• Cookie settings in Internet Explorer
• Cookie settings in Firefox
• Cookie settings in Chrome
• Cookie settings in Safari
• Cookies settings in Microsoft Edge

10. Security of your data

10.1 Your data are stored on local Eutracking’ owned servers. We employ strict technical and organizational (security) measures to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction, and damage both online and offline.

These measures include:

• Training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;
• Administrative and technical controls to restrict access to personal data on a “need to know” basis (passwords);
• Technological security measures, including firewalls, encryption, and anti-virus software;
• Login access blocks in case of loss or theft of devices;
• Physical security measures, such as staff security badges to access our premises.

10.2 Although we use appropriate security measures once we have received your personal data, the transmission of data – especially over the internet (including by e-mail) – is never completely secure. We endeavour to protect personal data, but we cannot guarantee the security of data transmitted to us or by us.

We limit access to your personal information to those who we believe reasonably need to come into contact with that information to carry out their jobs.

11. Data retention

11.1 I AM A WEBSITE VISITOR

11.1.1 Your personal data will not be retained longer than necessary for the purposes described above.

11.1.2 As a general rule, personal data obtained through the contact form on our website are stored for 5 years.

Depending on the specific situation and the applicable national legislation, we may however retain your personal data for a longer period. This will, in particular, be the case if any of the following periods is longer: (i) as long as is necessary for our daily business; (ii) any retention period that is required by law; or (iii) the end of the period in which litigation or investigations might arise.

11.1.3 For more information about the expiry dates of the cookies used on this Site, please consult the cookie section.

11.2 I AM (A CONTACT PERSON OF) A SUPPLIER, A CUSTOMER OR A PROSPECT, OR ANY OTHER INDIVIDUAL WHOSE PERSONAL DATA ARE PROCESSED (E.G. A VISITOR, A BUSINESS CONTACT ETC.)

11.2.1 Your personal data will not be retained longer than necessary for the purposes described above.

11.3 As a general rule, records in the framework of our business activities that may contain personal data (e.g. contracts, orders, correspondence, etc.) are stored for 10 years.

Personal data processed for direct marketing purposes are however stored for 3 years as from the last contact with the individual concerned. If you have become a customer during this period, we may however retain your data for a longer period, namely 10 years as from the delivery of the products or services, or as from the latest contact with Eutracking (if this contact would take place at a later date).

11.4 Depending on the specific situation and the applicable national legislation, we may however retain your personal data for a longer period. This will, in particular, be the case if any of the following periods is longer: (i) as long as is necessary for our daily business; (ii) any retention period that is required by law; or (iii) the end of the period in which litigation or investigations might arise.

12. Automated Decision-making

12.1 Automated decisions are defined as decisions about individuals that are based solely on the automated processing of data and that produce legal effects that significantly affect the individuals involved.

12.2 As a rule, your personal data will not be used for automated decision-making. We do not base any decisions about you solely on the automated processing of your personal data.

13. How to contact us?

13.1 We hope that this GDPR Privacy Statement helps you understand, and feel more confident about, the way we process your data. If you have any further queries about this GDPR Privacy Statement and this Site in general, please contact us:

• by using the contact form on our website; or
• by calling us at 00 32 2 374 45 55; or
• by addressing your query to: privacydata@eu-tracking.com

14. CHANGES TO this GDPR PRIVACY STATEMENT

14.1 We may modify or amend this GDPR Privacy Statement from time to time. Any changes we may make to this GDPR Privacy Statement in the future will be posted on this page. To let you know when we make changes to this GDPR Privacy Statement, we will amend the revision date at the top of this page. The new modified or amended GDPR Privacy Statement will apply from that revision date. Please check back periodically to see changes and additions.