EU/UK ADDENDUM
Unless provided otherwise in this EU/UK Addendum, all relevant terms shall be interpreted and defined on the basis of the European General Data Protection Regulation (EU) 2016/679 or the UK GDPR (altogether “GDPR”), as relevant. Where the GDPR applies, the term “personal information” in the General Privacy Policy shall be understood as “personal data”, as defined under the GDPR.
THIS EU/UK ADDENDUM APPLIES TO ALL PERSONAL INFORMATION, AS DEFINED IN THE GENERAL PRIVACY POLICY ABOVE, ABOUT YOU THAT WE COLLECT, HOLD, USE AND DISCLOSE, REGARDLESS OF THE WAY IN WHICH WE COLLECT IT (I.E. WHETHER THROUGH A SITE OR OTHERWISE) WHERE THE GDPR APPLIES TO SUCH PROCESSING OF YOUR PERSONAL INFORMATION, IN PARTICULAR WHEN YOU ARE BASED IN THE EUROPEAN UNION OR IN THE UK.
This EU/UK Addendum does not apply to employees. JBT Marel employees based in a member state of the European Union, within the European Economic Area, or the United Kingdom should review the JBT Marel Employee Privacy Policy.
Collection of Personal Information
We collect personal information, described in the General Privacy Policy, from our Site, as well as through correspondence, faxes, e-mails, telephone inquiries, web forms, and other means of communication when we market and provide products and services to you or for other lawful purposes described in the General Privacy Policy and as detailed below in this EU/UK Addendum.
How We Use Your Personal Information
As a general matter, we collect personal information primarily to provide services to our customers, for administrative or management requirements, and to enhance our relationship with customers. In this section, in addition to the information provided in our General Privacy Policy, you will find more information about the purposes for which we process your personal information, as well as the legal basis on which we rely for such processing.
You are not obliged to share your personal information with us. However, if you do not share your personal information with us, we might not be able to offer all of our services to you.
Answering customer or technical support requests
For the purposes of answering any request you may make in relation to customer or technical support, we process the following personal information:
- Contact information;
- Transaction information;
- Credentials.
The legal basis for processing this personal information for the above mentioned purposes is the performance of a contract that you or your company has with us (Art. 6(1)(b) GDPR).
Ensuring the security of our Site
For the purposes of detecting security incidents and protecting us against malicious, deceptive, fraudulent or illegal activity, we process the following personal information:
- Device information and identifiers;
- Contact information;
- Credentials;
- Internet or other electronic activity.
The legal basis for processing this personal information for the above-mentioned purposes is our legitimate interests (Art. 6(1)(f) GDPR).
Analytic purposes
For the purposes of analyzing the statistics of our site, we process the following personal information:
- Internet or other electronic activity;
- Commercial information;
The legal basis for processing this personal information for the above mentioned purposes is our legitimate interests (Art. 6(1)(f) GDPR).
Marketing analytic purposes
For the purposes of measuring the interest and engagement in our Site and services in order to improve our Site and services as well as to provide you with better services and content, we process the following personal information:
- Device information and identifiers;
- Internet or other electronic activity;
The legal basis for processing this personal information for the above mentioned purposes is your consent (Art. 6(1)(a) GDPR) where such consent is required and obtained, or otherwise our legitimate interests (Art. 6(1)(f) GDPR) where your consent is not required.
Marketing
For the purposes of sending you marketing materials, such as newsletters, personalized and relevant marketing communications and other information that may be of interest to you, we process the following personal information:
- Contact information;
- Internet or other electronic activity;
- Commercial information;
If you are a customer of JBT Marel, we base the processing of your personal information for marketing purposes on our legitimate interest of maintaining a close relationship with our customers and sending you information about our products and services. If you are not a customer of JBT Marel, the legal basis for processing this personal information for the above mentioned purposes is your consent (Art. 6(1)(a) GDPR) where such consent is required and obtained, or otherwise our legitimate interests (Art. 6(1)(f) GDPR) where your consent is not required.
Surveys
For the purpose of carrying out surveys to conduct research about your opinion of current products or services or of potential new products or services that may be offered, we process the following personal information:
- Contact information;
- Device information and identifiers.
The legal basis processing this personal information for the above mentioned purpose is your consent (Art. 6(1)(a) GDPR) where such consent is required and obtained, or otherwise our legitimate interests (Art. 6(1)(f) GDPR) where your consent is not required.
Aggregated data
For the purpose of providing our authorized service providers in certain cases with aggregated statistics about our customers, sales, traffic patterns, usage and related information, we process the following personal information:
- Device information and identifiers;
- Internet or other electronic activity;
- Commercial information;
The legal basis for processing this personal information for the above mentioned purpose is your consent (Art. 6(1)(a) GDPR) where we have obtained your consent.
Complying with legal obligations
For the purpose of complying with any legal obligations, such as compliance activities and cooperating with law enforcement or tax authorities, we process the following personal information:
The legal basis for processing this personal information for the above mentioned purposes is the necessity to comply with our legal obligations (Art. 6(1)(c) GDPR).
Transferring your personal information
For the purpose of transferring your personal information to the services providers, affiliates and advertising partners for the purposes explicitly mentioned in this General Privacy Policy as well as to carry out corporate transactions or to comply with legal obligations, we process the following personal information:
- Contact information;
- Device information and identifiers;
- Internet or other electronic activity;
- Commercial information;
The legal basis for processing this personal information for the above mentioned purpose is your consent (Art. 6(1)(a) GDPR) where such consent is required and obtained, or otherwise our legitimate interests (Art. 6(1)(f) GDPR) where your consent is not required. For the sake of clarity, we do not sell, rent or lease our customer lists to third parties.
Obtaining Consent
Except when otherwise permitted by law and indicated in this Policy, we obtain the requisite consent prior to collecting and, in any case, prior to using or disclosing your personal information for any purpose not previously communicated to you. You may provide your consent to us orally, in writing, by electronic communication, or any other means reasonably capable of conveying your consent. We will obtain your explicit consent if we collect, use or disclose sensitive data. We also disclose information to third parties partners for whom you have given us consent, where obtaining your consent is necessary for such disclosure. Your consent may also be intrinsic to the circumstances such as in the case where you have provided our representatives with your phone number so that we can contact you.
Third parties
We remain responsible for all personal information communicated to third parties for processing. As such, we ensure that third parties that are engaged to provide products or services on our behalf and are provided with personal information are required to observe the intent of this Policy by having comparable levels of data security protection or, when required, by assuring us that they will not use or disclose the personal information for any purpose other than the purpose for which the personal information was disclosed.
International Transfer of your Personal Information
We are based out of the United States and thus must transfer your personal information across borders, specifically to members of our group of companies in connection with the above purposes. We have taken appropriate safeguards to ensure your personal information is protected in accordance with this General Privacy Policy through implementing additional safeguards. In particular, when transferring personal information outside of the EEA and the UK, we will:
- include the standard contractual clauses approved by the European Commission or UK Government for transferring personal information outside the EEA or the UK into our contracts with third parties.
- ensure that the country in which your personal information is transferred has been deemed as providing an adequate level of protection of personal information by the European Commission or the UK Government under Art. 45 GDPR.
You may request a copy of the above mentioned standard contractual clauses by sending us a corresponding request.
You can find out further information about the rules on data transfers outside the EEA and the UK, including the mechanisms that we rely upon, on the websites of the European Commission, as well as the Information Commissioner’s Office.
Limitations
We only collect the personal information necessary to fulfil the purposes identified to you prior to or at the time of collection, or any other reasonable and legitimate purposes or as required by law.
We do not use or disclose your personal information, except for the purposes for which it was collected, or new purposes to which you have consented, or as required or otherwise permitted by applicable law.
We do not, as a condition of providing services to you or on your behalf, or as an administrative or management requirement, require consent to the collection, use or disclosure of personal information beyond that reasonably required for such purposes, or to comply with our obligations under applicable law.
Retention of Personal Information
We keep a record of your personal information, including correspondence or comments.
Where we process personal information for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period of 30 days after this to allow us to implement your requests. We also keep a record of the fact that you have asked us no to send you direct marketing or to process your personal information indefinitely so that we can respect your request in the future.
Where we process personal information for site security purposes, we retain it for 12 months.
Where we process personal information in connection with performing a contract, we keep the data for 8 years from your last interaction with us, or longer if required by applicable laws.
Rights over Personal Information
If you are located in the European Economic Area or United Kingdom you have the rights of access, rectification, erasure, restriction, objection or portability with regards to your personal information and the right to lodge a complaint with your Data Protection Authority. Please use the form in the “Contact” section below to exercise these rights. To lodge a complaint, please contact your local data protection authority – contact information may be found here. If you are located in the UK, you can contact the Information Commissioner’s Office.
Right to Withdraw Your Consent
When the processing is based on consent, which has been obtained, you can withdraw consent at any time by sending an e-mail to privacy@jbtc.com or global-dataprotection@marel.com. This withdrawal of your consent will not affect the lawfulness of the processing which has already taken place based on your consent before such withdrawal.
Please note that the withdrawal of your consent may adversely affect our ability to provide products and services to you or to maintain our relationship with you.
Opt-Out & Unsubscribe
We respect your privacy and give you an opportunity to opt-out of receiving communications from JBT Marel by contacting us at privacy@jbtc.com or global-dataprotection@marel.com. You may also follow the instructions in any promotional message you get from us. If you opt out of getting marketing messages, you will continue to receive messages from us about your relationship with us where permitted by law.
Objection to the Processing of Your Personal Information
You have the right to object to the processing of your personal information by use, in certain circumstances, if we process your personal information on the basis of the performance of a task in the public interest (Art. 6(1)(e) GDPR) or on the basis of our legitimate interests (Art. 6(1)(f) GDPR) or if we process your personal information for direct marketing purposes (Art. 21 GDPR). Your objection to the processing of your personal information will be upheld, and we will cease processing your personal information, unless the processing is based on compelling legitimate grounds or is needed for the exercise or defense of legal claims that may be brought by or against.
Access to Your Personal Information
In accordance with Art. 15 GDPR , subject to the exceptions provided by applicable law, we will make available to you personal information about you that we have collected, utilized or disclosed, upon your written request. If requested, we will make such information available to you in a form that is generally understandable, including explaining any abbreviations or codes and using an alternative format, if required. Simply send your request for access us using the information in the section “Contact Us” at the end of this EU/UK Addendum.
Accuracy
We will use reasonable efforts to ensure that your personal information is kept accurate and complete. We will not routinely update your personal information, unless such a process is necessary or you request us to do so. In order to help us maintain and ensure that your personal information is accurate and up to date, you must inform us of changes to the personal information you provided to us.
In accordance with Art. 16 GDPR, you can at any time inform us about any inaccurate, incomplete or outdated personal information we have about you and request the corresponding correction of your personal information. In such case, we will amend the personal information as required. Where appropriate, we will transmit the amended information to third parties to whom we have communicated your personal information.
Deletion, Anonymization or Blocking of Your Personal Information
You have the right to request the deletion, anonymization or blocking of your personal information when the processing of your personal information is based on your consent or when such processing is unnecessary, excessive or noncompliant, in accordance with Art. 17 GDPR.
Restriction of the Processing of Your Personal Information
You have the right to request the restriction of the processing of your personal information under certain circumstances, in accordance with Art. 18 GDPR.
Portability of Your Personal Information
You have the right to request the portability of the personal information you have provided to us where the processing of your personal information is based on your consent and is carried out by automated means, pursuant to Art. 20 GDPR. To this end, we will provide you or a third party of your choice with the personal information we have about you in a structured, commonly used and machine readable format, where technically feasible.
Response Times
We will make every reasonable effort to respond to each of your written requests not later than 30 days after receipt of such requests. When applicable, we will advise you in writing if we cannot meet your requests within this time limit. When applicable, you have the right to make a complaint to the appropriate Data Protection Authority with respect to this time limit.
Costs
We expect to provide access without charge as a general matter. However, we reserve the right to collect a reasonable charge when your request for the transcription, reproduction, or transmission of such information is unfounded or excessive. We will notify you, following your request of the appropriate amount that will be charged. You will then have the opportunity to maintain or withdraw your request prior to incurring the charge.
Identifying You in Connection with Requests
We may require you to provide us with sufficient information to identify yourself before we provide information about the existence, use, or disclosure of your personal information in our possession. Any such information shall be used only for this purpose.
Security of Your Personal Information
We use physical, technical, and procedural security safeguards appropriate to the sensitivity of personal information to protect it from loss or theft, as well as unauthorized access, disclosure, copying, use or modification. These safeguards include physical measures, such as restricted access to offices and equipment, organizational measures, such as security clearances, and publishing this policy to appropriate personnel with instructions to act in accordance with its principles (for example, limiting access on a “need to know” basis), and technological measures, such as the use of passwords and/or encryption.
Contact
We welcome your data requests under this EU/UK Addendum or questions as to how we process your personal informational Data. Please complete our request form and e-mail it to privacy@jbtc.com or global-dataprotection@marel.com so that we can address your request in a timely fashion. In addition, you may contact our global data privacy office using the following contact information: JBT Europe B.V., ATTN: Data Privacy Counsel, Deccaweg 32, 1042AD Amsterdam, The Netherlands.