Introduction

In this Privacy Statement for customer, supplier and business partner data, COBBS Industries B.V., COBBS Belux B.V. and their group companies (“COBBS Industries”, “we” or “us”), provide information on the processing of personal data.

This Privacy Statement may be changed over time. This document was last changed in May 2021. You can find the most recent Privacy Statement on our website www.cobbsindustries.com.

When does this privacy statement apply?

This Privacy Statement applies to the processing by COBBS Industries of all personal data of (prospective) customers, suppliers and business partners and individuals that visit www.cobbsindustries.com or contact us. COBBS Industries processes all personal data that falls within the scope of this Privacy Statement as a data controller within the meaning of the General Data Protection Regulation (“GDPR”).

Under the GDPR, ‘personal data’ means any information relating to an identified or identifiable natural person (called a ‘data subject’). Examples are name, address, place of work, location data and other data that directly or indirectly specifies the identity of a person. You can find information about which personal data we process in the paragraph below.

What personal data do we collect and when?

When you act as a contract person for your employer or business when purchasing one of our products or services, communicate with us or supply us with products or services, we collect your personal data. Please see the paragraph ‘Why and how do we process your personal data?’ for more information on different purposes for which we collect personal data. Depending on the purpose, the personal data we collect may include your:

◦ contact details: name, email and telephone number

◦ login and account information, including hashed password and unique user ID

◦ social media username

◦ purchase history

◦ marketing and cookie preferences, in accordance with our Cookie Policy

When you use our website, certain data may be collected from your device or web browser. You can find more information about the collection of this data in our Cookie Policy below.

Why and how do we process your personal data?

When you contact us (online or offline)

When you contact us by phone, regular mail, email, or on LinkedIn, we will use your personal data to reply to your message and/or answer your question.

When you use our website

When you use our website, we process technical data to deliver you our website’s functionalities and for their technical and functional management. You can find more information in our Cookie Policy below [insert hyperlink to paragraph ‘Cookie Policy’].

When you purchase our products and services

We use your personal data to process your order and for customer service and relationship management. This includes services like reporting you on the status of your order and keeping your purchase history. Because of our strict safety policy procedures, COBBS Industries will only provide confidential product information to persons acting on behalf of an official government body. When you request confidential product information, we process your name and email address to verify this.

Newsletters and marketing

Only if you have given your consent, COBBS Industries uses your name and email address stored in its database to send you newsletters containing information about products, promotions and invitations to participate in events. We also use your personal data for the development, execution and analysis of market surveys and marketing strategies.

For the development and improvement of products and services

We process your personal data about your recent visits to our website and how you use our website for analytics purposes, so we can learn how people use our website and make it more intuitive and practical where possible. With your consent, we keep a record of the pages you have clicked on and use that information to target advertising relevant to your interests, based on the articles that you have read.

Provided you have given your consent if this is necessary, we use aggregated personal data to analyse how often you read our newsletters so we can improve the contents and format of our newsletter.

When entering into or performing an agreement

When you work together with us as a supplier or a business partner, we process your personal data for administrative purposes such as making payments, sending invoices and delivering or receiving our or your products or services.

When you use our online Order Portal

COBBS Industries offers contact persons of customers and suppliers a secure online order portal that can be accessed via our website (the Order Portal). When you are the contact person of your organization, we process your name and email address to send you an email that allows you to activate an account for the Order Portal. If you choose to activate your account, we process your personal account login information to administer your account and make sure your account is confidential and secure. For example, we can change your password for you. We note that we are not able to view your password.

To protect our or others’ rights, property or safety or to comply with the law

In rare situations, COBBS Industries may use your personal data to protect our or others’ rights, property or safety or to comply with laws and regulations. For example, we may need to disclose your personal data to government institutions or supervisory authorities if this is required by law.

Other purposes

If we want to use your personal data in other way than described in this Privacy Statement, we will provide specific notice at the time of collection and obtain your consent where necessary.

Legal grounds

We rely on different legal grounds to process your personal data, depending on how you interact with us. When you are our contact person of your employer or business in relation to the purchase COBBS Industries products or if you supply us with goods or services, we require your personal data to fulfil our contract with you or your employer. In other instances, we process your personal data based on your consent, for instance when you have activated an Order Portal account with us, if you have chosen to receive our newsletter and if you have consented to our use of cookies on our website. You can withdraw your consent at any time, without this affecting the lawfulness of processing based on consent before your withdrawal.

We rely on our legitimate interests as a business for the processing of personal data for the purpose of:

• verification that you are acting on behalf of an official government body

• securing our business and data

• combatting fraud and cyberattacks

• improving our products and services as described in this Privacy Statement

• sending you offers within the context of an existing business relationship

If we are required by law to process personal data, this is based on the legal ground ‘comply with a legal obligation’. In rare circumstances, we process personal data to protect your or someone else’s vital interests.

How long do we keep your personal data?

Your personal data will only be retained for as long as is necessary to carry out the purposes described this Privacy Statement. In some cases, for instance in relation to product purchases, applicable law may require us to store your data for a longer time period. Generally, we will keep your personal data relating to your COBBS Industries Order Portal account until you ask us to delete the account, inform us of a change in contact person or until the agreement with your employer has terminated or expired. If you have signed up for our newsletter, we will keep your name and email address until you unsubscribe.

Who has access to your personal data?

COBBS Industries is a European organization with several group companies. Data we collect may be transferred within our organization. Our employees are only authorized to access personal data if this serves the applicable purpose, to perform their jobs and are bound by contractual confidentiality obligations.

Access to your personal data by third parties

Third parties may process personal data on our behalf, for example to process payments, shipping and deliveries, host, manage and service our data and distribute newsletters. When using third party service providers, COBBS Industries ensures that appropriate contractual, technical and organizational measures are taken to ensure that your personal data is processed in accordance with the law and only to the extent necessary.

COBBS Industries will only transfer your personal data to a country outside of the European Economic Area if an appropriate transfer mechanism is in place. If personal data is transferred to a country that does not have an adequate level of protection for personal data, we take appropriate measures to ensure that your personal data are adequately protected, such as entering into so-called Standard Contractual Clauses approved by the European Commission. In other cases, your personal data will not be supplied to third parties, except where required by applicable law.

Security of your personal data

COBBS Industries takes the security of your personal data seriously. We have implemented appropriate technical, physical and organizational measures to maintain the safety of your personal data, such as two-factor authentication, access control restrictions and physical security measures.

Requests for access, correction and removal

You can request access, correction, restriction, portability or removal of the personal data that COBBS Industries processes about you (including the personal data in your Order Portal account) at any time by sending a request to: intel@cobbsindustries.com.

Questions and complaints

If you feel that we do not comply with applicable privacy laws you have the right to lodge a complaint with your Data Protection Authority.

If you have any questions regarding the processing of your personal data, please contact: intel@cobbsindustries.com.

COOKIE POLICY

COBBS INDUSTRIES

What are cookies?

A cookie is a small text file stored on your computer or mobile device when visiting our website www.cobbsindustries.com. Cookies can be used for different purposes, for instance for improving our website, monitoring of sessions or storing information about your interaction with our website such as purchases and indicated preferences.

What cookies do we use?

COBBS Industries uses session cookies and permanent cookies. A session cookie can track usage, for example the webpages you visit and what options you use. When you close your internet browser, the session is ended and the cookie is deleted. A permanent cookie enables our website to recognize you at a subsequent visit. An example is a permanent cookie that remembers the items placed in your shopping basket.

Necessary cookies

COBBS Industries stores cookies that are essential in providing the functionalities of our website. You can set your browser to refuse cookies altogether if you do not want to receive any cookies. In that case you may no longer be able to use all the functionalities of our website.

Non-strictly necessary cookies

Provided that you have first given consent, COBBS Industries places cookies that are not strictly necessary for providing the functionalities of our website. COBBS Industries uses these cookies we collect information about your use of the website, for instance which pages you visited and the length of a user session. We use this information to improve your user experience of our website. If you have not given your consent to cookie being placed, these cookies will be blocked.

Please see below an overview the non-strictly necessary cookies that our website uses.

Google Analytics

Our website www.cobbsindustries.com uses Google Analytics’ cookies. Google Analytics is a web analysis service that is offered by Google Inc. (“Google”). Google Analytics uses cookies only to analyse the usage of our website by its users. Google uses aggregated statistical data to give COBBS Industries an insight in the way users use our website. COBBS Industries has concluded a data processing agreement with Google to ensure proper protection of your personal data. COBBS Industries does not make use of any other Google services related to Google Analytics. To the extent allowed by the Google Analytics functionalities, COBBS Industries has opted out from sharing your information with Google. Google will remove the last three digits of your IP address. Google may only provide related data to third parties if Google is required to do so by law, or to the extent third parties process these data on behalf of Google. For more information on Google Analytics, please visit https://support.google.com/analytics/answer/6004245.

How to manage cookies

You can accept, refuse, manage or delete cookies at any time by selecting your desired setting on your browser. However, this may prevent you from properly use certain features on our website.