INTRODUCTION

2. Who is responsible for your personal data? 

3.1. Global dairy Trade will process your personal data based on:

• The performance of a contract you have with us, or to enter into a contract and to act on your requests. For example, when you register to use our services, provide us with contact details for a contract, or when we are fulfilling our delivery and payment obligations.
• Global Dairy Trade’s legitimate business interests, for example, fraud prevention, maintaining the security of our data and systems, marketing, and the improvement of our services. Whenever we rely on this lawful basis to process your data, we assess our business interests to make sure they do not override your rights. Additionally, in some cases, you have the right to object to this processing. For more information, visit the ‘How can you exercise your privacy rights?’ section of this policy.
• Compliance with mandatory legal obligations, including for example accounting and tax requirements.
• Consent you provide where Global Dairy Trade does not rely on another legal basis. Consent may be withdrawn at any time. When you give your consent, you will be given details on how to change your mind. For more information, visit the ‘How can you exercise your privacy rights?’ section of this policy.

3.2. We collect your personal data, for example:

3.2.1. When you do business with us:

a) For the assessment and acceptance of a customer, supplier or business partner;

When you get in contact with us, either via our website, telephone, offline or otherwise, we may process your personal data for assessment and acceptance purposes, for example, to confirm and verify your identity. We may further process your personal data for other administrative purposes such as due diligence and screening against the publicly available government and/or law enforcement agency sanctions lists.

b) For the conclusion, execution and performance of agreements:

When you have subscribed to our services as a customer, either online, via telephone or offline, or when you work together with us as a vendor, supplier or business partner, we may process your personal data for administrative purposes such as sending invoices and making payments. We also use your personal data to deliver or receive and administer our or your products or services. We process your personal data to further execute our agreement, including for the delivery of customer services.

c) For relationship management and marketing

We may use the information stored in our customer database to send you suitable offers and newsletters, to invite you to take part in competitions, as well as to provide customer services, perform account management and communicate important messages about our services. We may also use your personal data for the development, execution and analysis of market surveys and marketing strategies.

d) For business process execution and internal management

We process your personal data in the performance and organisation of our business. This includes general management, order management and management of our assets. We have central processing facilities which conduct audits and investigations, implement business controls, and manage and use customers vendors, business partners and other stakeholder’s directories. Also, we process your personal data for finance and accounting, archiving and insurance purposes, legal and business consulting and in the context of dispute resolution.

e) For organisational analysis and development, management reporting and acquisition and divestitures

At Global Dairy Trade, we process your personal data in the preparation and performance of management reporting and analysis. We use aggregated and anonymised personal data to create management reports and to analyse our business and report on certain metrics, either to comply with reporting regulations or to improve our processes and services. We may conduct customer, supplier and business partner surveys to learn more about your views and opinions in preparation of our management reporting.

f) To monitor and investigate compliance and fraud within Global Dairy Trade

We monitor our IT systems to check for compliance with regulations and laws, fraud, and compliance with our policies. During compliance and monitoring activities, personal data we hold about you may be accessed and viewed for this purpose. The personal data that are accessed and viewed for this purpose will not be stored following such checking unless we need them to further investigate potential non-compliant behaviour.

3.2.2. When you use our Websites or Apps:

g) To deliver you our websites’ or apps' functionalities and for their technical and functional management

If you use our websites or apps (digital channels), we process technical data to offer you our digital channels’ functionalities and to allow our administrators to manage and improve the performance of these services. If you enter data in our digital channels, such as a product preference, a photo or your location to receive relevant information or functionalities, we process this data to provide you with the requested information or functionalities. Further, we process your personal data to allow you to save your data (such as preferences and products) to your saved items and to allow you to share these with others using the sharing options you have configured on your device. Global Dairy Trade also uses cookies to ensure you can retrieve information from our Digital Channels quickly and easily. Read our cookies policy by visiting https://www.globaldairytrade.info/en/generic-pages/cookies-statement/

h) If you open a user account with us, to administer the account and to ensure the confidentiality and security of your transactions

When you choose to register with one of Global Dairy Trade’s websites, apps or online portals, 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 confidentiality and to maintain the security of your transactions or use of the account. We are, for instance, able to assist you in changing your password. We are, however, not able to view your password.

i) To allow you to connect with us (e.g. via social media)

We may use social media platforms like WeChat Twitter and Linked In. When you contact us via social media, we process your personal data to answer your questions, to respond to your messages, and to provide customer services support.

3.2.3. When you interact with Global Dairy Trade (online or offline):

If you get in touch with us via our customer services centres, corporate email addresses, phone numbers, physical address or via a contact form on a Global Dairy Trade website, we will use your personal data to reply to and answer your question or to provide other customer services or commercial support. For this purpose, we process your name, contact details, your correspondence with us, your question and all other personal data which are necessary to respond to your communication.

j) For the development and improvement of products and/or services

We process your personal data to assess, analyse and improve our products and services for our customers and consumers. We use aggregated personal data to analyse consumer and customer behaviour and to adjust our products and services accordingly. When you use a website, app, or online portal, enter or search data through this website or app, we also process your personal data to compile analytics reports. We use aggregated personal data to analyse customer behaviour and to adjust our products and services accordingly, to ensure that it is relevant to our customers. This means that we may analyse how often you read our newsletters, how often you visit our website, apps or portals, which pages you click on and what transactions you make. We may purchase supplementary data from public sources to complement our database for the above purposes.

k) To protect health, safety, security and to ensure integrity

At Global Dairy Trade, we value your health, safety, security and integrity highly. We process your personal data to safeguard our employees, customers, suppliers and business partners. As such, we authenticate your access rights to our premises. We also process your personal data to protect Global Dairy Trade and employee and customer assets.

l) 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. To comply with relevant laws and regulations, we may need to disclose your personal data to government institutions or supervisory authorities.

3.3. The types of information we may collect, and process are, where applicable:

• Your contact details such as your address, phone number and email address, and contact preferences, personal details such as your title, name, and date of birth, payment and credit information, tax and GST or VAT details.

• Your correspondence with us, such as a note or recording of a call you make to a customer service centre, or with any of our employees, a live chat log, an email or letter sent, or other records of any contact or correspondence with us.

• Where you have a personal account with us, your account information such as order history, payment history, account numbers, login data, correspondence with us, account management information or other information that you have added to your account.

• Credential information – we’ll collect passwords, hints and similar security information used for authentication and access to any accounts and services.

• Your preferences for particular products, services and activities when you tell us what they are (for example by completing a survey), or we assume what they are, based on how you use any of our products and services.

• Data generated during the performance of the agreement(s) between you and Global Dairy Trade, and other data stored in our customer, supplier and business partner databases.

• We process the personal data you have entered into our websites, apps or online portals or that is generated by the functionalities you have used in these forums and the technical data from your device such as its IP address, the internet browser you use, the pages you have visited on our websites, portals or apps, your click and surf behaviour and the length of your session. We process the communication channel you may have chosen to use to connect with us (such as Facebook or Twitter) and the personal data you supply to us.

• See the 'Cookies' section for details on what we collect using cookies and visit www.globaldairytrade.info/en/generic-pages/cookies-statement/ for our full Cookies Statement.

• Your location data. This may be precise such as where you enable location-based services or features on our websites, apps or online portals, or less precise where, for example, a location is derived from your IP address or data such as an address.

• If you physically visit our premises, we may also collect information about you on CCTV as part of our security and crime prevention measures, we may also collect your name and contact details for security and health and safety purposes, and your visiting history to our premises, and to provide to facilities such as wifi.

• Information we obtain from other sources, such as credit agencies, fraud-prevention agencies, and from other data providers that may relate to your interactions with us.

4. Cookies

To assist with the performance of the website, cookies may be installed on your computer. Cookies are small text files that are placed on your computer by websites that you visit. Cookies are useful because they allow a website to recognise a user’s device. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

Most cookies we use on this website collect information about how visitors use the website, for instance, which pages visitors go to most often. These cookies do not collect information that identifies a visitor. All information collected by these cookies is aggregated and therefore anonymous.

This website also uses cookies to ensure that users of the website are taken to their local version of the website each time they visit. The information these cookie collect may be anonymised, and they cannot track your browsing activity on other websites.

Most internet browsers give you the option to reject all cookies, accept all cookies, erase cookies stored on your computer or be notified before a cookie is stored on your computer. However, if you reject or erase the cookies referred to above some our Site features or services will not function properly or may not be fully available. Please refer to your internet browser instructions if you want to find out more about rejecting or erasing cookies.

Please visit https://www.globaldairytrade.info/en/generic-pages/cookies-statement/ for our full Cookies Statement.

5. Who has access to your personal data?

5.1. Transferring your personal data

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

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

5.2. Access to your personal data by external parties

Our employees are authorised to access personal data only to the extent necessary to serve the applicable purpose and to perform their jobs. Global Dairy Trade holds its own Privacy Policy and Standards which Global Dairy Trade personnel must comply with as a condition of their employment (or contractual obligations where they are a contractor).

The following types of external parties may have access to your personal data, where relevant:

• Partners, suppliers or agents involved in delivering the products and services you’ve subscribed to through our platforms;

• Companies who are engaged to perform services for, or on behalf of Global Dairy Trade

• Debt-recovery organisations, credit reference, fraud-prevention or business-scoring agencies, or other credit scoring agencies;

• Third parties for joint promotions with that third party. They’ll be responsible for their own compliance with applicable privacy laws;

• Third parties that we use for marketing, for example, approved media agencies, and third parties that we advertise with.

When external 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 external parties will only process your personal data in accordance with applicable law.

We will provide your personal data to regulatory bodies, tax authorities and/or investigating authorities only if Global Dairy Trade is obliged to do so by law or regulation, or if you have provided instructions to Global Dairy Trade to allow this information to be disclosed.

5.3. The use of your personal data by data processors:

When a third party processes your personal data solely following Global Dairy Trade 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 protected and processed by the data processor solely to provide services to us.

6. How are your personal data secured?

We make all reasonable efforts to secure our systems 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 specialised security teams, IT security policies, staff training and secure servers.

7. How long is your personal data retained?

We will keep your personal data for as long as it is required for the purpose for which it was collected, considering our need to answer queries or resolve problems, provide improved and new services, and comply with legal requirements.

This means that we may retain your personal data for a reasonable period after your last interaction with us. When the personal data that we collect is no longer required or is not required to be retained by law, we destroy, delete or permanently anonymise it.

If you would like to know specific retention periods for a certain type of information we collect, please contact us. For data retention periods of any other companies, please check their privacy statement on their website.

8. 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 to data portability.

To invoke any of these rights, 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.

It is important to us that your personal data held by us is accurate, complete and current. If you are a registered user of a Global Dairy Trade website account, you may log in to your account and (functionality permitting) update your personal data or request an update.

9. Do you have a complaint?

If you want to contact us about any of your rights or complain about how we use your information, you can contact us on the details set out below. We’ll do our best to help, but if you are still not satisfied, you can lodge a complaint with your local data protection supervisory authority.

10. How can you contact us?

If you have any questions about the way we process your personal data or want to request access to, deletion of, or correction of your personal data held by us, please contact us by email: privacy.officer@globaldairytrade.info