This data protection policy sets out the basis as to how CWT Europe B.V. and its EU-based affiliated companies (together ‘CWT Commodities’) will make use of any personal data. Please read the following carefully to understand our views and practices regarding your personal data, and how we will treat it. This policy is written to comply with the applicable provisions under data protection law, including the new EU General Data Protection Regulation (‘EU-GDPR’) in force since May 25, 2018. Further information regarding the EU-GDPR can be found at EUGDPR.org.
The following definitions should assist you in understanding this policy.
You may also contact our Data Protection Officers:
in The Netherlands for the Amsterdam business:
in The Netherlands for the Rotterdam business:
in the United Kingdom:
CWT Europe B.V. is the data controller for CWT Commodities.
CWT Commodities is subject to a wide range of additional legal obligations. To comply with these obligations, we process your data to the required extent and, if necessary, submit it to the responsible authorities in accordance with legal reporting requirements.
In the context of the business, CWT Commodities may process personal data for the following purposes:
For the aforementioned purposes, CWT Commodities may process the following categories of personal data:
Unless indicated otherwise, the legal basis for the processing of personal data is as follows:
or, if explicitly provided by business partner contacts:
CWT Commodities is a global company. Your personal data may be stored and processed in The Netherlands or any other country in which CWT Commodities or its associates and affiliates, maintain facilities. If necessary to meet the aforementioned purposes, your personal data will be forwarded to CWT Europe affiliated companies.
Your personal data may be transferred to, stored at, and may be processed outside the European Economic Area (‘EEA’). By indicating consent when submitting your personal data, you agree to this transfer, storing or processing.
If legally permitted to do so, CWT Commodities may transfer personal data to courts, law enforcement authorities, regulators, attorneys or insurers if necessary to comply with the law or for the establishment, exercise or defence of legal claims.
Should CWT Commodities need to transfer your personal data, CWT Commodities will take all reasonable measures to safeguard the transfer of your personal data to third parties in a manner that complies with the applicable provisions under the data protection laws, including the EU-GDPR.
We take your privacy seriously and we will never sell personal data or email addresses.
We store your personal data for only as long as it is required for the intended purpose. If data has been processed for multiple purposes, it will be deleted, or only stored in a form that cannot be directly traced back to you, when it is no longer needed for the ultimate specified purpose.
We also process personal data wherever there is a legal obligation to do so – i.e., where necessary to enable operation of IT systems, including the following activities:
No automated individual decision-making and profiling takes place at CWT Commodities.
The websites of CWT Commodities Pte Ltd contain no cookies (exception: embedded google maps).
CWT Commodities does not use any third-party analytical services.
The websites of CWT Commodities Pte Ltd may be simultaneously hosted at numerous third-party locations around the world for performance purposes. Your visit to our websites may be redirected to a particular location according to numerous factors, such as your location (GeoIP).
As the party affected by the processing of your data, you may claim certain rights under the EU-GDPR and other relevant data protection regulations. For future information about your rights, please consult EUGDPR.org. Under the EU-GDPR, you are entitled to claim the following specific rights vis-à-vis CWT Commodities as the data subject.
You have the right to request information from us at any time relating to the data we hold about you. This information includes, but is not limited to, the categories of data we process, the purposes for which it is processed, the source of the data if not collected directly from you, and, if applicable, the recipients with whom we have shared your data. You can obtain a copy of your data from us free of charge. If you require additional copies, we reserve the right to charge you for these copies.
You have the right to request that we rectify inaccurate data relating to you. We will take appropriate steps to keep the data we store and process on an ongoing basis accurate, complete and current, based on the most up-to-date information available.
You have the right to request that we erase your data, as long as the legal requirements for this are satisfied. This may be the case under Article 17 EU-GDPR if:
You have the right to restrict processing of your data if:
You have the right to object to the processing of your data at any time for reasons that arise from your particular situation, as long as data processing is based on your consent, on our legitimate interests or those of a third party. In this case, we will cease to process your data. This does not apply if we can show that there are compelling legitimate grounds for processing such data that outweigh your interests, or if we need your data for the establishment, exercise or defence of legal claims.
You have the right to request that we transfer your data – if technically possible – to another responsible party. However, you may only enforce this right if data processing is based on your consent or is necessary for the performance of a contract. Rather than receiving a copy of your data, you may also ask us to submit the data directly to another responsible party specified by you.
CWT Commodities takes your concerns and rights seriously. However, if you believe that we have not responded in an appropriate manner to your complaints or concerns, you have the right to lodge a complaint with your local data protection authority.
We make every effort to comply with all requests within a calendar month. However, this period may be extended for reasons relating to the specific right or complexity of your request.
In certain situations, due to legal requirements, we may be unable to provide you with information with regards to all of your data. If we are unable to fulfil your request for information in such a case, we will notify you of the reasons.
You have the right to withdraw your declaration of consent for data processing. Your revoking of consent does not affect lawfulness of the processing that has taken place because of the consent up to the time of withdrawal.
This Data Protection Policy of CWT Europe shall be governed by and construed in accordance with for:
CWT Europe BV, CWT Commodities (Amsterdam) BV, CWT Commodities Metals BV and/or CWT Commodities (Rotterdam) BV:
the laws of the Netherlands. Any legal action or proceeding arising out of or in connection with this data protection policy may solely be brought in the court in Amsterdam and the parties hereby irrevocably submit to the exclusive jurisdiction of such court in connection with any such legal action or proceedings.
CWT Commodities (UK) Ltd and/or CWT Commodities Properties (UK) Ltd:
the laws of England and Wales. Any legal action or proceeding arising out of or in connection with this data protection policy may solely be brought in the High Court in London and the parties hereby irrevocably submit to the exclusive jurisdiction of such court in connection with any such legal action or proceedings.
CWT Commodities (Antwerp) NV:
the Belgian laws. Any legal action or proceeding arising out of or in connection with this data protection policy may solely be brought in the court in Antwerp and the parties hereby irrevocably submit to the exclusive jurisdiction of such court in connection with any such legal action or proceedings.
© 2018 CWT Europe B.V.