(a) Valuing your privacy and safeguarding your personal data.
At Westmond, we respect your privacy and adhere to applicable data protection and privacy laws and relevant e-commerce laws globally. We strive to consistently exceed our clients’ expectations regarding the products and services that we offer to our contract logistics and freight management customers. We create experiences that our customers value by responsibly using information with which you entrusted us.
This Privacy Notice describes the way we treat all the personal data you provide or that we have obtained through our Westmond Websites .
(b) Applicability and links to other third party applications and/or websites
This Privacy Notice applies to all visitors and anyone who accesses or uses our products and services of twestmiond.com
The Westmond Website may contain links to and from the applications and/or websites of our partner networks, advertisers, third parties and affiliates. They are merely for informational purposes. If you follow a link to any of these applications and/or websites, please bear in mind that they have their own privacy policies and that we assume no responsibility or liability arising whatsoever nor endorse any practices from their policies.
BY ACCESSING WESTMOND.COM AND ACCEPTING THE STATEMENT WITH THE LINK OK, I AGREE AND CONTINUING TO ACCESS WESTMOND.COM, YOU ACCEPT THE TERMS AND THE PROCESSING OF PERSONAL DATA DESCRIBED IN THE PRIVACY NOTICE. IF YOU DO NOT AGREE, PLEASE REFRAIN FROM ACCESSING WESTMOND.COM.
YOU MAY WITHDRAW YOUR CONSENT AT ANY TIME. WE WILL THEN REFRAIN FROM FURTHER PROCESSING YOUR PERSONAL DATA, EXCEPT TO THE EXTENT THE PROCESSING OF YOUR PERSONAL DATA IS LAWFUL FOR OTHER REASONS EVEN WITHOUT YOUR CONSENT, SUCH AS LAWFUL PURPOSES AS FULFILLING THE CONTRACTUAL OBLIGATIONS OR COMPLIANCE WITH LAW OR TO PROTECT OUR OR THIRD PARTIES LEGITIMATE INTERESTS (SUCH AS THE UNINTERRUPTED AVAILABILITY OF OUR WEBSITE OR ENFORCEMENT OF VIOLATIONS OF LAW).
2. SOURCES OF PERSONAL DATA AND WHAT PERSONAL INFORMATION ABOUT CUSTOMERS DO WESTMOND.COM COLLECT?
(a) Controller and Processors of Personal Data
Westmond Logistics is the data controller of the personal data you (data subject) provide us or we received in our Websites.
(b) Types of Personal Data collected and Sources of Personal Data
We collect personal data directly from our customers through Westmond.com. We obtain, use, disclose and otherwise process personal data about customers to (i) process transactions they request, including online purchases and transactions, (ii) improve Westmond Website, quality of service and customers on line experience, (iii) send communications about our products, services, campaigns, promotions, and customer satisfaction surveys, (iv) prevent and detect fraud and abuse, (v) process information or claims in connection with incidents at our facilities, (vi) enable service providers to perform certain activities on Westmond’s behalf, (vii) protect the log in details of the subscribers and system integrity of the Westmond Website, (viii) comply with legal obligations, policies and procedures and for internal administrative and analytics purposes,(ix) allow valid customers to access their accounts and receive tracking confirmation as to where their products are currently located, (x) allow customers to monitor the assembly processes of all or part of their supply chain management solutions, and (xi) to commence, protect or defend Westmond in actual or threatened legal proceedings.
We collect the following types of personal data about you from the following sources:
Information that you provide to us:
We receive and store any information you enter on Westmond.com or give us in any other way such as during registration, accessing your account or profile, submitting queries or as part of a survey or competition or utilising customer support or communicate with us or requesting quotation for services or purchasing or using our products or services.
Due to such actions, you supply us with your (i) name, postal address, email address, phone numbers, (ii) data necessary to process your payment (including the credit card/payment instrument information and personal security code associated with your credit card) for on line purchases or to make requests for a quotation for our services and purchases, to apply for a refund, or to communicate with customer services regarding a refund to the credit card/payment instrument, (iii) name and contact information for the sender and addressee, their delivery address for the subscriber or make purchases of our products and services. Demographical data such as your age, gender, country, preferred language, passport number and citizenship, date of birth and country of residence are also collected. Such information is collected to meet our contractual obligations to our landlords and airport and port authorities and legal obligations towards customs and other regulatory authorities.
When you register for membership, subscribe for services or the newsletter or other marketing communications including blogs or customer comments or use the Westmond Websites or purchases online or at our facilities, we collect log in details, passwords, any password questions and hints, similar security information used for authentication and account access is also collected for the access into your personal account and profile and to utilise the customer services and resources elements of Westmond Websites.
You can choose not to provide certain information, but then you might not be able to utilise many of the features of the Westmond Websites .
See What Are My Choices section below.
INFORMATION COLLECTED AUTOMATICALLY THROUGH INTERACTION WITH US:
We receive and store information where you interact with us through using our products and services, including online technologies (ie Cookies) and receiving error reports or usage data from software applications on your devices online.
We collect and analyse device, connectivity and configuration data including the Internet protocol (IP) address used to connect your computer or device to the internet, computer and connection information such as browser type, version, time zone and other computer software installed on the device, browser plug in types and versions, operating system, shopping preferences, wish list, purchase history, the features you use and pages accessed and web sites visited.
We also collect the Uniform Resource Locator (URL) clickstream to and from our Westmond Websites , including date and time, cookie number, products and services viewed and searched for and the phone number used to contact our customer support teams. We collect technical information to help us identify your device for fraud prevention and diagnostic purposes such as any problems to the product and settings, error reports including data as to the type and severity of the problem, details of software and hardware related to an error, contents of files you were using when an error occurred and data about other software on the device.
We collect browser data including persistent and session cookies and other online technologies as set out below in the Online Technologies section below. We utilise Google Analytics to assist with software tools to measure and collect the performance data on Westmond Websites including download error or performance issues caused. Further information can be found under Google Analytics Terms of Service & Privacy.
Most browsers allow you to opt out of cookies or turn on do not track. For more information, see What are My Choices section below.
Information from other Sources:
We receive information about you from other sources and add it to our account information. The third party sources include:
- Updated delivery and contact address data from third parties which are used to update our records and deliver your next purchase more easily;
- Social networks when you grant permission to Westmond Websites to access your data on one or more networks;
- Service providers that help us determine a location based on your IP address to allow customisation of certain products to your location;
- Publicly-available sources from open government databases or other data in the public domain;
- Credit history information from credit bureaus, which we use to help prevent and detect fraud;
3. LAWFUL PURPOSES FOR PROCESSING AND USING YOUR PERSONAL DATA
(a) Lawful purposes
Your personal data is processed by the Group on the basis of a lawful “justification” for such processing, to the extent required by or permissible under applicable law. The processing of special categories of personal data (including data relating to health, sexual preferences racial or ethnic origin, religious beliefs) is always justified on an additional basis as set out below.
In the majority of cases, the processing of your personal data will be justified on one of the following bases:
(a) It is provided for in your contract of providing products and services requested by you to be provided by us;
(b) It is necessary for us to comply with a legal obligation; or
(c) It is in our legitimate interests as a business and as your supplier of contractually requested goods, and our interests are not overridden by your interests, fundamental rights or freedoms including legitimate interests as set out below.
The processing of special categories of personal data will be justified by one of the above conditions and normally by one of the following special conditions:
(a) It is necessary for the purposes of carrying out legal obligations;
(b) It is carried out subject to your explicit consent;
(c) It is necessary for the establishment, exercise or defence of legal claims; or
(d) In exceptional circumstances, it is necessary to protect your vital interests and you are incapable of giving consent;
(e) Purposes of processing personal data
We obtain, use, disclose and otherwise process personal data about customers to:
- (i) process transactions they request, including e- commerce and mobile transactions,
- (ii) process information from customer to verify the identity of the customer to enable us to provide access to all areas of the customer accessible sections within programmescontained in Westmond Websites .
- (iii) review and collect data from the customer contact name, contact details, delivery address, destination and holder of the valid bill of lading or delivery tracking goods to allow Westmond to provide the deliverable goods under the terms of the contractual agreement;
- (iv) provide the contact details for the transportation of goods, declarations of dangerous goods, customs declarations for deliveries of goods, clearance of border and custom controls and cargo monitoring and surveillance;
- (v) provide information to the customer on the status of their delivery or monitor the processes of contractual logistics and assembly of all or part of a customers’ supply chain in a specific location or on a regional basis;
- (vi) provide payment services including credit cards for online purchases and online payments;
- (vii) provide goods and services to the customers that they have requested (i.e. provided an email address to allow the regular newsletter to be provided to the customer)
- (viii) to maintain our business relationship and communicate with you, where you are a customer, user or subscriber of our Westmond Websites ,
- (ix) to answer your enquiries and provide customer services support to you;
- (x) to answer your requests for a quote for requested services and Westmond products and solutions;
- (xi) improve Westmond Websites , quality of service and customers on line experience,
- (xii) send communications about our products, services, campaigns, promotions, and customer satisfaction surveys
- (xiii) prevent and detect fraud and abuse,
- (xiv) process information or claims in connection with incidents at Westmond facilities or during the transit to a new location by Westmond;
- (xv) enable service providers to perform certain activities on Westmond’s behalf,
- (xvi) protect the log in details of the subscribers and system integrity of the Westmond Websites ,
- (xvii) comply with legal obligations, policies and procedures and for internal administrative and analytics purposes, and
- (xviii) to commence, protect or defend Westmond in actual or threatened legal proceedings.
We use personal data to carry out your contractual transactions with us and to provide our products and services to you as requested by you. This includes using your personal information to register or subscribe to any services provided thorough Westmond Websites .
Where we process your personal data on the basis of our legitimate interests, those will be our interests in:
- The conclusion of the specific processes listed above;
- Providing and improving the products we offer and perform essential business operations. This includes operating the products, maintaining and improving the performance of the products, developing new features, conducting research and providing customer support.
- Protecting the security and safety of our products and our customers, to detect and prevent fraud to confirm the validity of the subscriber logging into Westmond Websites ;
- Using personal data for statistical and analytical purposes. Whenever reasonably possible we will anonymize such information before using it for statistical or analytical purposes. Such information is processed in the legitimate interests of Westmond to maintain the efficiency, relevancy and availability of the Westmond Websites ;
- Effective management and operation of Westmond;
- Our engagement with and communications with our customers;
- Developing our business
- Increasing the efficiency of our processes and practices;
- Striving to ensure compliance with our policies and procedures and applicable laws and business norms;
- Ensuring the on-going stability and availability of the Westmond Websites ;
- Avoiding or mitigating harm to you, to our customer, to us and to third parties;
- Communications to maintain customers relationship and furtherance of legitimate interests;
We use personal data we collect to communicate with you and personalize our communications with you. i.e. respond to your queries, accommodate your preferences and registration for program membership. We communicate with you by email or phone or SMS to inform you about our services, how to keep your subscription or account active, to communicate regarding a refund or customer inquiry or assisting with web site or Westmond Websites access or technical queries or to participate in a customer survey or a competition or to receive a discount rebate from customer services for service irregularities or to invite you to attend an event sponsored by the Westmond Websites . These communications are to maintain our customer relationship with you and is in furtherance of our legitimate interests of Westmond.
4. SHARING YOUR PERSONAL DATA
Nevertheless, within our corporate group of Westmond, certain services are centralised to provide one or more affiliates for the entire group or a part of it.
We will not transfer or disclose your personal information outside Westmond other than as set out below:
(a) in connection with a joint venture or business combination where Westmond holds less than 50% ownership or does not have effective management control of such joint venture or business combination;
(b) to third party service providers (companies or individuals) that we employ to perform functions on our behalf such as fulfilling orders, delivering to requested locations, sending postal mail and email, removing repetitive information from customer lists, analysing data, providing marketing assistance, providing search results and links, processing credit card payments and providing customer service. These providers have access to personal information needed to perform their functions, but may not use it for other purposes and include the following categories of data recipients:
- (i) advertising and media consultants,
- (ii) market research consultants;
- (iii) providers of technical services;
- (iv) website designers and developers;
- (v) cloud computing service providers;
- (vi) electronic storage providers;
- (vii) customer services;
- (viii) recruitment agencies;
(c) in connection with the proposed merger, acquisition or sale or as a result of the actual sale of all or part of the assets of, or shares in Westmond or a business transfer of business activities of Westmond occurs other than without a sale or acquisition;
(e) to comply with legal or regulatory requirements or obligations in accordance with applicable law, a court order or a subpoena,
(f) with regulatory authorities, airport or port authorities, duty free trading zones, Westmond landlords and concession partners and customs and tax authorities to show the calculation of such customs or tax exemptions; or
(g) to data analytical firms, Google Analytics Inc. or;
(h) in an emergency, such as to safeguard the life, health, or property of an individual; or
(i) with your consent to proceed to share your personal information with third parties where required by applicable law.
(j) we may transfer all or some of our rights under our financial agreements with you or companies which you represent to third parties which will provide (or are involved in providing) funding to us. If such a transfer takes place, your personal data or personal data which you provide to us may be processed by the entities participating in such funding arrangement in order that such funding arrangements may be evaluated, monitored and administered (including, without limitation, providing certain information about the financial agreement(s) you or the companies you represent have with us to third parties when we obtain funding through a securitisation so that a third party can evaluate, monitor and administer the pool of financial agreements with respect to which funding is being provided to us) subject to such third party or parties agreeing to act in accordance with applicable law.
5. STORING YOUR PERSONAL DATA
Your personal information you have provided to the controllers be located in a Westmond server located in Holland or another location within the European Union, unless the local data protection laws require that the local Westmond entity will be included in a file owned by the local Westmond entity, the purpose of which is to manage the business relationship with you, in accordance with the provisions of the local data protection laws. However, the customer relationship and the personal data if any is held with (the local Westmond entity) can be accessed or communicated to group or affiliated companies of Westmond.
Westmond and (local Westmond entity) will manage the customer relationship with you and any marketing materials can be provided, in accordance with your preferences, by Westmond as Controller or by the local Westmond entity as a processor on behalf of Westmond.
6. SECURITY OF PERSONAL DATA
Your personal data will be secured by taking security measures that are commensurate with the sensitivity of the personal data processed. To this end, Westmond and all Group entities maintain appropriate physical, technical, and administrative security measures with a view to protecting personal data against theft; accidental loss; unauthorised alteration; unauthorised or accidental access, processing, erasure, use, disclosure or copying; and/or accidental or unlawful destruction.
When we have provided (or you have chosen) a password allowing access to certain benefits of the Westmond Websites , you are responsible for safeguarding it and keeping it confidential and you undertake not to allow it to be used by third parties. Unfortunately, the transmission of information thorough the internet is not completely secure. Although we will take all reasonable commercial measures to protect your personal data, we cannot guarantee the security of any personal information or data you disclose on line. You accept the inherent security implications of using the internet and to the extent permitted by law, we will not be responsible for any breach of security, unless we have been acting with gross negligence and only within the limitations as set out in the terms and conditions of use for Westmond Websites .
7. TRANSFERS OF DATA OUTSIDE OF YOUR COUNTRY
Your personal data (as described above) may be transferred to other Group entities or to third parties described above, only to the extent required for Westmond and group companies to perform their obligations to you, or for you to access your Westmond Websites , or for the purposes described above in this Notice, provided such purposes are in accordance with applicable laws. In particular:
- Your profile and contact information contained in systems such as corporate communications systems, customer relationship management databases or directories will be accessible to all marketing, sales and customer support or customer care employees of Group companies worldwide.
- Your personal data may be transferred to or accessed by Group employees located inside or outside your country, and/or a person or company that is not part of the Group located in or outside your country, on a need-to-know basis. Transfers outside the EU may be made pursuant to the European Commission’s Standard Contractual Clauses (“SCC”), the EU-U.S. Privacy Shield certification or other legally acceptable mechanisms which ensure an adequate level of protection.
- Westmond may process your personal data as a controller in order to administer and provide you with products and services that you requested, to administer global sales and customer programs, promotional and marketing activities and surveys, competitions and coupon and gift promotions, communications with customers, advertising campaigns with us, to manage sales and customer relationships and to prepare sales and customer relationship management and customer support reporting, consistent with the terms of this Notice.
- Transfers may be made to respond to law enforcement requests or discovery procedures, or where required or permitted by applicable laws, court orders, government regulations, or government authorities (including tax and employment). Such transfers may entail access by courts or governmental authorities outside your country, after having ensured that only your minimal necessary data is disclosed and transferred, or that such data is de-identified or that, where possible, appropriate stipulative court orders have been issued.
A list of the countries located outside the EU to which your Personal Data may be transferred, and an indication of whether they have been determined by the European Commission to grant adequate protection to Personal Data, can be found at https://ec.europa.eu/info/strategy/justice-and-fundamental-rights/data-protection/data-transfers-outside-eu_en.
Transfers of Personal Data in accordance with this Section 7 are based on the same legal bases as applicable for the respective purposes of processing as set out above.
8. RETENTION OF PERSONAL DATA
Westmond data retention policy requires that personal data be retained for no longer than required to fulfil the purposes for which it was collected. In general, personal data, or records containing personal data, will be retained for periods of time required in accordance with applicable legal, tax, or accounting obligations. In specific circumstances, and in accordance with applicable law, Westmond may retain your personal data for longer periods of time (such as for the duration of the relevant statute of limitation) so that we have an accurate record of our dealings with you or to protect the legitimate interests of Westmond. In all cases, where your information is no longer required, Westmond will ensure it is disposed of in a secure manner.
Westmond Websites do not provide products and services to children. We do not knowingly collect personal information from children under the age of 18 years, without the consent of the child’s parent or guardian. Accordingly, the parent will need to complete and submit a fully completed and signed Parental Personal Data Consent Form (in the form provided by Westmond) along with evidence of the person’s identity, to the email address: privacy@WestmondLogistics.com.
10. ONLINE TECHNOLOGIES INCLUDING COOKIES
A “cookie” is a small text file that identifies your mobile device and/or equipment on our server. None of the Cookies we use collect your personal information and they cannot be used to identify you, only the mobile device and/or equipment used. Unless stipulated otherwise, we will not pass personally identifiable data to third parties.
We use ‘persistent’ cookies. ‘Persistent’ cookies usually have a long shelf life because they are “collected” and “updated” every time a user visits an application and/or page where the same or a similar cookie is being used.
Information obtained through cookies is used by us and by third parties that we have hired in order to show you advertising related to your preferences. For a full list of the cookies that we use, please click here.
Cookies generally help us provide better Westmond Websites , which allows us to monitor which pages you find useful and those which are not. A cookie does not allow us to access any other data on your mobile device, equipment or to any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can modify your browser setting to decline cookies if you prefer. Cookies, including those which have already been set, can be deleted from your hard drive.
(b) Google Analytics
Google Analytics are used to help us understand how to make the best use of our content and find out how we can improve it. These cookies allow us to track your progress through our Westmond Websites , collect personal data at their origin, which applications and/or pages you visit, and the time you spend on the site. This data is then stored by Google in order to create reports.
11. WHAT ARE YOUR RIGHTS?
You have the right under applicable law to access, obtain a copy and correct personal data concerning you, subject to limited exceptions that may be prescribed by applicable laws. Where justified and mandated by applicable law, you may also require that your personal data be deleted or blocked, or you may be entitled to obtain information about the processing of your data, or object to further processing of your data.
In the event your personal data is processed on the basis of your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. You can do this by (i) in some cases deleting the relevant Personal Data from the relevant IT system (although note that in this case it may remain in back-ups and linked systems until it is deleted in accordance with our data retention policy) or (ii) contacting privacy@WestmondLogistics.com.
You also have the following additional rights:
- Data portability – where we are relying upon your consent or the fact that the processing is necessary for the performance of a contract to which you are party as the legal basis for processing, and that personal data is processed by automatic means, you have the right to receive all such personal data which you have provided to Westmond or the Group in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.
- Right to restriction of processing – you have the right to restrict our processing of your personal data where:
- you contest the accuracy of the personal data until we have taken sufficient steps to correct or verify its accuracy;
- where the processing is unlawful but you do not want us to erase the personal data;
- where we no longer need your personal data for the purposes of the processing, but you require such personal data for the establishment, exercise or defence of legal claims; or
- where you have objected to processing justified on legitimate interest grounds (see below) pending verification as to whether Westmond or the Group has compelling legitimate grounds to continue processing.
Where your personal data is subject to restriction in this way we will only process it with your consent or for the establishment, exercise or defence of legal claims.
- Right to object to processing justified on legitimate interest grounds – where we are relying upon legitimate interest to process personal data, then you have the right to object to that processing. If you object, we must stop that processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the personal data for the establishment, exercise or defence of legal claims. Where we rely upon legitimate interest as a basis for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.
- Right to object to processing for marketing purposes – you have the right to object to any processing of your data for marketing purposes (including profiling). Additionally, see your Choices section below.
Please contact us for a Data Subject Access Request Form in writing or by email to either of the addressees listed below.
Westmond has appointed a Global Data Protection Manager who may be contacted securely and confidentially at the following E – Mail address: privacy@WestmondLogistics.com. Alternatively, you can send your Data Subject Access Request Form, written comments, questions or concerns to:
Attention : Data Privacy Office,
Siriusdreef 20, 2132 WT
Hoofdorp, The Netherlands
12. WHAT ARE MY CHOICES?
Westmond Websites provide you with access to a range of information about your account and your interactions with us. To ensure that your personal data is accurate and up to date, we encourage you to regularly review and update your information as appropriate, if your communication preferences change or your contact details or address has changed. If you have subscribed to Westmond Websites , especially the customer services and resources sections of the Westmond Websites , then you can either access your profile and make the changes or request the changes are made by sending an email request along with evidence of your identity to privacy@WestmondLogistics.com.
13. CHANGES TO OUR PRIVACY NOTICE
Changes and amendment to the terms of this Privacy Notice can be made at any time and shall apply as soon as they are published on any Westmond Websites . Should you not agree to any changes or amendments, then you should refrain from continuing to use our services or products or access Westmond Websites . You can unsubscribe from receiving or using our products and services at any time by sending an email request to unsubscribe your profile to privacy@WestmondLogistics.com.
WHERE TO MAKE A DATA PROTECTION COMPLAINT
You have the right to lodge complaints pertaining to the processing of your personal data with the relevant data protection supervisory authority.
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