PRIVACY POLICY
INTRODUCTION
PURPOSE
The purpose of this policy is to explain how TriGranit handles your personal data, whether we pursue a relationship with you regularly or occasionally, provide you with a service or receive a service from you, or you are simply visiting our website.
This Privacy policy describes how we collect, use and process your personal data, and how we comply with our legal obligations towards you. Your privacy is important to us and we are committed to protecting and safeguarding your data privacy rights.
SCOPE
This policy applies to all operating units of the Company, in relevant countries throughout our international network. Each country may approach data privacy in slightly different ways, thus we have country-specific procedures connected to this policy. This allows us to ensure that we are compliant with all applicable data protection regulations, no matter where you are.
In scope of this Privacy policy are the personal data of our Clients, Suppliers and other Business Partners, as well as Website Users and Third Parties whom we may contact.
If you are a member of TriGranit Staff, you are out of scope of this policy and should refer to our internal Data protection and privacy policy, which is available in Employee Handbook.
GOVERNANCE
All decisions related to personal data protection and privacy activities belong to the exclusive powers of the Company’s management team, which has the discretion to change or amend this policy from time to time, with or without prior notice. Please visit this webpage to stay updated.
In case of any discrepancies between the provisions of this policy and national laws or other local regulations, the latter shall prevail.
If you are dissatisfied with any aspect of our data protection and privacy practices, you have the legal right to address your complaints as described later.
DEFINITIONS
Business partner: any commercial party, person or organization, with whom the Company has a business relationship as Client or Supplier
Client: any customer, person or organization, to whom the Company provides services in the course of its business
Company: all legal entities and operating units of TriGranit Group
Data subject: a natural person whose personal data are collected, stored or processed
Erasure: removal or deletion of personal data when there is no compelling reason for a business to continue processing that data
GDPR: General Data Protection Regulation of the European Union
Staff: employee, contractor, trainee, temporary, consultant, leased worker or any other member of the Company’s workforce, who are engaged directly in the business of TriGranit
Supplier: any commercial party, person or organization, who provides services to the Company in the course of its business
Third party: any individual who is not acting or otherwise performing any services for, or on behalf of, TriGranit, including applicants and requestors who voluntarily entrust us with their personal data
Website user: any individual who accesses any of the TriGranit websites
FREQUENTLY ASKED QUESTIONS ON PERSONAL DATA
WHAT KIND OF PERSONAL DATA DO WE COLLECT?
Several elements of the personal data we collect from you are required to enable us to fulfil our contractual duties to you or to others. Depending on the type of personal data in question and the grounds on which we may be processing it, should you decline to provide us with such data, we may not be able to fulfil our contractual requirements or, in extreme cases, may not be able to continue with our relationship.
Client data: If you are a TriGranit customer, we need to collect and use information about you or certain individuals at your organization, in the course of providing you with services and/or notifying you of content published by TriGranit which is likely to be relevant and useful to you.
To the extent that you access our website we will also collect certain data from you.
Supplier data: We do not collect much data about Suppliers, we simply need to make sure that our relationship runs smoothly. We may collect contact details within your organization, such as names, telephone numbers and email addresses.
To the extent that you access our website we will also collect certain data from you.
Website user data: We collect a limited amount of data from our Website users which we use to help us to improve your experience when using our website, as well as to help us manage the services we provide. Our website uses so-called cookies, which are small text files that are placed on your computer by our website. Cookies are used to help users of our website to navigate efficiently and perform certain functions. Cookies that are required for the website to operate properly are allowed to be set without your consent. All other cookies need to be approved before they can be set in the browser. If you want to control the cookies on your computer, you can select your browser settings so that you receive a notification when a website wants to store cookies. You can also block or delete cookies if they are already stored on your computer. If you would like to know more about these steps, please use the “Help”-feature in your browser. Please note that blocking or deleting cookies may affect your online experience and prevent you from fully using our website.
Third party data: We may collect the personal data that you provide when sending a request or inquiry or application to us. Depending on the matter in relation to which you get in contact with us, we may collect your contact details, such as name, telephone numbers and email addresses, communications sent in connection with your request, inquiry or application. If you send a job application to us, we may collect all personal data included in your CV and application documents.
To the extent that you access our website we will also collect certain data from you.
HOW DO WE COLLECT PERSONAL DATA?
Client data: We collect your personal data either directly from you or from limited external sources, e.g. online and offline media.
To the extent that you access our website or read or click on an email from us, we may also collect certain data automatically or through you providing it to us.
Supplier data: We collect your personal data during the course of our work with you.
To the extent that you access our website or read or click on an email from us, we may also collect certain data automatically or through you providing it to us.
Website user data: We collect your data automatically or upon your consent via cookies when you visit our website.
Third party data: We collect your personal data directly from you or from limited external sources, e.g. online and offline media.
To the extent that you access our website or read or click on an email from us, we may also collect certain data automatically or through you providing it to us.
HOW DO WE USE PERSONAL DATA?
Client data: The main reason for using information about Clients is to ensure that the contractual arrangements between us can properly be implemented.
Supplier data: The main reasons for using your personal data are to ensure that the contractual arrangements between us can properly be implemented.
Website user data: We use your data to help us to improve your experience of using our website.
Third party data: The main reasons for using your data in order to answer your request or inquiry or to evaluate your application.
PROTECTION OF PERSONAL DATA
We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold on you from misuse, loss or unauthorized access. We do this by having in place a range of appropriate technical and organizational measures to ensure the security and confidentiality of entrusted personal data.
If you know or suspect any misuse or loss or unauthorized access to your personal data, please let us know immediately.
RETENTION OF PERSONAL DATA
We store personal data for as short as possible and for nor longer than its purpose requires it to be. Retention periods are as follows:
Standard retention time for Client, Supplier and Website user data is up to two years. If we have not had any meaningful contact with you for two years, we will delete your personal data from our files and systems, as after this period your data will unlikely be relevant for the purposes for which it was collected.
In case of Applicants, Requestors and other third-party data, standard retention time is up to six months.
Standard retention time of personal data can be extended if:
· requested by relevant legislation
· requested by contractual obligation
· requested by police or other prosecution agencies
When we refer to “meaningful contact”, we mean communication between us, either verbal, written or personal. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you click-through or reply directly.
While we will endeavor to permanently erase your personal data once it reaches the end of its retention period or where we receive a valid request from you to do so, some of your data may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, this data has been put beyond use, meaning that while it still exists on an archive system, this cannot be readily accessed by any of our operational systems, processes or Staff.