Privacy policy

1. Scope
We are delighted that you are visiting our website, and about your interest in our company and our
products. We are very stringent about the protection of your personal data and your private sphere
when processing personal data. [Nordzucker (Ireland) Ltd] processes the personal data collected
when our website is visited in accordance with the applicable data protection regulations.
This website is provided and controlled by [Nordzucker (Ireland) Ltd., Citywest Business Centre, 3013
Lake Drive, Citywest Dublin 24, PPT3 Ireland, Reg. No 423656 , (“Nordzucker”, “we”, “us”, “our”)].
This privacy and cookie policy ("Policy") explains what personal data we collect and process about
you during your visit to and in connection with this website. It includes a description of your data
subject rights, including your right to object to some of the processing which we carry out.
This website contains links to other sites. Nordic Sugar is not responsible for the privacy practices or the content of such other websites.
 
2. How do we process your personal data?
a. Personal data in connection with your visit of this website
When you visit our website, our web servers store as part of a standard procedure the IP address
assigned to you by your internet service provider, as well as the web page from which you have come to visit us, the areas that you visit on our website, the type and version of browser and operating system that you use, the host name of the accessing computer as well as the date and duration of the visit.
We process such personal data for the following purposes:
- To provide you with technical administration processes in connection with the website; and
- To implement and maintain IT security measures.
We delete personal data which we process in connection with your visit of this website after a
maximum period of 12 weeks.
 
b. Personal data in connection with “Aktientreff” (for Germany)
This section only applies to users of the German website.
 
On our website you can register for an account in order to access the separate website “Aktientreff”
and its additional functions. On “Aktientreff” you can buy and sell shares from/to shareholders and
accountholders. We only process your e-mail address, last name and username in order to create
and maintain your account for “Aktientreff” and to provide you with access to “Aktientreff”.
We do not process any information you share with shareholders and accountholders via “Aktientreff”,
in particular any details of your transactions regarding shares, unless you provide us with this
information via a separate form. We process your personal data, including your bank account
information and address, which you provide to us in connection with your transactions in order to
prepare the necessary paper work, transfer shares and maintain our share register.
 
c. Personal data in connection with your requests and inquiries
Our website’s contact form requires you to give us your name, your e-mail address and the topic and
content of your query. You are free to give us additional information, for example further contact
details (such as a phone number or postal address).
We process such personal data for the following purpose:
- To answer your questions or contact you in connection with your requests and inquiries, and
to provide you with services and products to accommodate your requests and inquiries; and
- For customer relationship management.
 
d. Personal data in connection with newsletters, news and publications
We collect and process your name and e-mail address in connection with subscriptions to our
newsletters, news and publications. We also process your postal address if you ask to receive our print publications by regular mail.
We process such personal data for the following purpose solely based on your consent:
- To provide you with our newsletters, news and publications;
- To ask you to participate in product surveys; and
- For other marketing purposes.
For certain newsletters, we use the services of the Rocket Sience Group LLC, 675 Ponce de Leon
Ave NE, Suite 5000 Atlanta, GA 30308, in particular the company MailChimp in connection with newsletters. MailChimp is certified under the US-EU "Privacy Shield" to comply with EU data protection regulations.
 
Where your register for a newsletter the following data will be stored on the servers of MailChimp in
the USA: your name, username, title, contact details (such as e-mail address, phone number) and IT
information (IP address, usage data, cookies data, online navigation data, location data, browser
data).
MailChimp processes this data to send and evaluate newsletters on our behalf. Furthermore,
MailChimp may also process this data to optimise or improve its services, e.g. to technically optimise
sending and presenting newsletters. MailChimp logs the subscriptions to our newsletters in order to be able to prove that the registration process is in accordance with the double opt-in procedure. The log contains the time of your registration and confirmation, as well as your IP address. MailChimp also logs changes to your personal data stored with MailChimp.
MailChimp carries out statistical surveys. These include, for example, determining whether
newsletters are opened, when they are opened and which links are clicked. For technical reasons,
this information can be assigned to the individual newsletter recipients. However, it is neither our
endeavour, nor that of MailChimp, to monitor individual users. The evaluations serve to recognise the reading habits of our users and to adapt our contents to them.
You can unsubscribe from our newsletter at any time by using the unsubscribe link contained in each e-mail. If you have not subscribed to any newsletters or e-mail services, no data will be transmitted.
The Rocket Science Group's privacy policy can be found at http://mailchimp.com/legal/privacy/.
 
e. Personal data in connection with your online application
We process for recruiting purposes information that you provide as part of your online application,
including your CV and other submitted documents, as well as during interviews. We use an e-recruiting software, HR Manager, for all applications to our Danish (Nordic Sugar A/S), Finnish (Sucros OY and Suomen Sokeri OY) and Swedish (Nordic Sugar AB) entities. Please see the separate privacy policy for applications via HR Manager for details. Our Human Resources
department and the relevant company department have access to your data once you have made an
application in direct response to a specific job vacancy.
We store your personal data provided in your application (including your pro-active application) after the end of the hiring process for the allowed statutory retention period, unless you have given us your consent to store your personal data for a longer time.
 
f. How long do we retain your personal data? 
We delete your personal data as set out in this section, unless explicitly set out in another section of this Policy.
We delete personal data which we process in connection your requests and inquiries once we have answered your request or inquiry or provided the corresponding services and/or products. We delete personal data which we process based on your consent, for example in connection you’re your subscription to newsletters, once you withdraw your consent.
As an exception, we will not delete your personal data where we still have a legitimate interest to use
your personal data. For example, we may still retain your personal data to resolve disputes, or comply with legal requirements. In any case, we will not retain or use your personal data longer than necessary for the purposes outlined in this Policy.
 
g. With whom do we share your personal data?
We disclose or transfer personal information to other parties as follows:
- with other legal entities of the Nordzucker Group if this is necessary for the purposes set
out in this Policy, for example if your request concerns another company of the
Nordzucker Group, or to the extent this is necessary for internal administrative purposes;
- to third party service providers that perform processing operations on our behalf in
relation to the website and the purposes set out in this Policy (for example, website
hosting and technical support, marketing email service providers, data analysts website
developers);
- if we are under a duty to disclose or share your personal data in order to comply with a
legal obligation, or in order to enforce, defend or protect the rights and property of
[Nordzucker (Ireland) Ltd) and other entities of the Nordzucker Group;
- to government authorities, and to other third parties when compelled to do so by
government and law enforcement authorities, or otherwise as required or permitted by
law, including but not limited to responses to court orders. We also disclose user information when we have reason to believe that someone is causing injury to or interference with our rights or property, other users of our site, or anyone else that could be harmed by such activities.
 
Other than set out above, personal data will not be shared with, sold or otherwise transferred to any
third party. We do not process or transfer your personal data processed under this Policy outside the European Economic Area (“EEA”).
 
3. Cookies
We use cookies and similar technologies, such as tagging to make our websites (including our mobile sites) work better and to distinguish you from other users.
Any data collected via cookies will be used only to enhance the quality and accessibility of content,
service and support to our visitors. The data may be made public from time to time, however only in
an aggregate, non-personally identifiable form, indicating for instance the total number of site visitors.
Please see our cookie policy below for details on which cookies we use for which purposes.
 
4. Your rights
Please send an email to our Data Protection Officer (see section “Contact” below for details) to invoke your rights which are set out below in detail.
You have the right to request information on your personal data, recipients of your personal data as
well as the data processing purposes for which your personal data is used at any time. We will correct inaccurate personal data upon your request. In certain circumstances, you can request that we
transfer personal information that you have provided to us as well as the deletion of your personal data.
Where we rely on your consent in order to process your personal data, you have the right to withdraw
such consent to our further use of your personal data at any time.
Where we have based a processing operation on legitimate interest, you may object to the processing of your personal data, for example to answer your requests or administrative purposes, on grounds relating to your particular situation. You may control the extent to which we market to you, and you have the right to request that we stop sending you marketing messages at any time.
We hope that we can satisfy queries you may have about the way we process your personal data.
However, if you have unresolved concerns you also have the right to complain to the data protection authorities. You can bring the complaint in your member state of residence, place of work or where an alleged infringement of data protection law has occurred.
 
5. Contact
Please contact the Nordzucker Group Data Protection Officer at [dataprotection@nordzucker.com] in
connection with your rights. Our Data Protection Officer is also at your disposal if you have any
complaints with respect to any data protection aspects. If you have any additional questions or
comments, please contact Nordzucker Ireland Ltd.