PRIVACY POLICY
CONTACT DETAILS
If you have any questions about this privacy policy or our privacy practices, please contact our Global Data Protection Officer in the following way:
Email address: info@roastrading.nl
Address: Roas Trading B.V., Keizersgracht 442, Amsterdam, The Netherlands
You have the right to make a complaint at any time to your country’s supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so, please contact us in the first instance.
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
Roas Trading B.V. ("we", "us" or "our") keep our privacy policy under regular review to ensure it is up to date with the latest industry standards and laws. The last update to our policy was on December 20, 2022. If you wish to view previous versions of our policy, please contact us.
It is crucial that the personal data we collect and store about you is accurate and current. We kindly ask that you inform us of any changes to your personal data during your relationship with our agency.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, refers to any information that can be used to identify an individual. This does not include anonymous data.
At Roas Trading B.V., we may collect, use, store, and transfer various types of personal data about you, which we have grouped as follows:
Identity Data: This includes your first and last name, email address, company, country, username or similar identifier, title, date of birth, gender, image (static or moving), and voice (collectively, your "image").
Contact Data: This includes your billing and delivery addresses, email address, and telephone number.
Financial Data: This includes your bank account numbers.
Transaction Data: This includes information about payments to and from you and details of products and services you have purchased from us.
Technical Data: This includes your IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, and platform, and other technology on the devices you use to access our website.
Profile Data: This includes your username and password, profile ID, ad account ID, Business Manager ID, FB Page ID, campaign results, test results, orders made by you, your interests, preferences, feedback, and survey responses, and any other Meta-related information you share with us while using our chat feature.
Usage Data: This includes information about how you use our website and services. This information is used to resolve our clients' issues/restrictions and improve their advertising on Meta platforms through us.
Marketing and Communication Data: This includes your preferences for receiving marketing from us and our third parties and your communication preferences.
We may also collect, use, and share Aggregated Data, such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data, but it is not considered personal data under the law as it does not reveal your identity directly or indirectly. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data and will use it in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data, such as information about race or ethnicity, religious or philosophical beliefs, sexual life, sexual orientation, political opinions, trade union membership, health, or genetic and biometric data. We also do not collect any information about criminal convictions and offenses.
IF YOU FAIL TO PROVIDE PERSONAL DATA
In cases where we are required by law or under the terms of a contract with you to collect personal data and you fail to provide it when requested, we may not be able to fulfill the contract we have or are trying to enter into with you (for example, providing you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
HOW IS YOUR PERSONAL DATA COLLECTED?
Roas Trading B.V. ("we", "us" or "our") uses various methods to collect data from and about you, including:
· Direct interactions: You may provide us with your Personal Data by filling in forms or by communicating with us through chat, post, phone, email, participation in synchronous live meetings or other means. This includes personal data you provide when you:
· Apply for our products or services.
· Create an account on our website.
· Subscribe to our service or publications.
· Contact us through any means of communication (for example, using our chat feature).
· Automated technologies or interactions: As you interact with our website, we automatically collect Technical Data about your equipment, browsing actions, and patterns by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites that employ our cookies.
· Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources, such as:
· Technical Data from analytics providers, such as D&B, local reports.
· Advertising networks.
· Search information providers.
· Contact, Financial, and Transaction Data from providers of technical and payment services, such as COFACE.
· Identity and Contact Data from publicly available sources.
· Social media interactions with any of our channels.
It is important to note that, we take measures to ensure that we only collect data that is necessary and relevant to our services or products.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
Roas Trading B.V. ("we", "us" or "our") has outlined the different ways in which we plan to use your personal data, as well as the legal bases we rely on to do so. We have also identified our legitimate interests, where appropriate. It's important to note that we may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. If you require more information about the specific legal ground we are relying on to process your personal data, where more than one ground has been set out in the table below, please contact us.
Purpose/Activity
Type of Data
Lawful Basis for Processing
To register you as a new customer
Identity, Profile
Performance of a contract with you, Necessary to comply with a legal obligation, Necessary for our legitimate interests (to conduct a background check)
To process and deliver your order
Identity, Financial, Transaction, Marketing and Communications
Performance of a contract, Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you
Identity, Profile
Performance of a contract with you, Necessary to comply with a legal obligation, Necessary for our legitimate interests (to keep our records updated)
To administer and protect our business and website
Identity, Technical
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization exercise), Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationship experience
Technical, Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
Identity, Contact, Technical, Usage, Profile, Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
MARKETING:
We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing).
You may receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
THIRD-PARTY MARKETING:
We will obtain your express opt-in consent before we share your personal data with any third party for marketing purposes.
OPTING OUT:
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service experience or other transactions.
COOKIES:
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
At Roas Trading B.V., we may use cookies to gather information about your browsing activity and preferences when you visit our website or view our advertisements. These small text files are placed on your computer and are commonly used to improve website functionality and to provide information to website owners. Cookies also allow us to better target relevant advertisements to you based on your location and browsing habits.
We use Google Analytics cookies to improve user experience on our website and to understand how our users interact with it. You can choose to decline or remove cookies via your browser settings, however, this may affect the functionality of our website and services. If you would like to manage your cookie settings, you can do so by following the instructions provided in your browser settings.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table “Purposes for which we will use your personal data” above.
Internal Third Parties [see Glossary]
External Third Parties [see Glossary].
Specific Third Parties, such as our Partners, for the purpose of direct communications or quality assessments.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
TRANSFERRING DATA OF EU VISITORS
In some specific cases we will have to transfer personal data of an EU visitor also outside the EU.
Also some of our external third parties are based outside the EU so their processing of your personal data will involve a transfer of data outside the EU.
Whenever we transfer your personal data out of the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we use certain service providers, we may use specific contracts approved for use in the EU which give personal data the same protection it has in the EU.
Using also Standard Contractual Clauses.
DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
DATA PROTECTION POLICY
1.1. Organization
1.1.1. Roas Trading B.V., a limited liability company incorporated under the laws of the Netherlands, with its main establishment and registered office at Keizersgracht 442, 1016GD, Amsterdam, The Netherlands, registration number 78044073 and tax identification number NL861243833B01, is responsible as the data controller of your personal data.
1.1.2. This Data Protection Policy (‘policy’) applies to Roas Trading B.V. and any of its subsidiary and affiliated enterprises. The reference to Roas Trading B.V., also referred to as ‘we’ or ‘us’, may mean reference to the group of undertakings or an individual enterprise within this group being responsible as the data controller of your personal data as the case may be.
1.1.3. Roas Trading B.V. cooperates with service providers, such as advertisers, publishers and other partners, accounting and IT services providers, wherein within this business cooperation certain personal data could be collected, transferred and processed by such service providers. Roas Trading B.V. cooperates only with service providers, which are in compliance with the General Data Protection Regulation.
1.1.4. This policy applies to information we collect when you access or use Roas Trading B.V.'s website(s), or otherwise interact with us as described below. We are compliant with applicable legislation in the countries in which we operate. By using our services or interacting with us as described below, you confirm that you are aware of this policy.
1.1.5. We may update this policy from time to time to reflect changes in legislation or our internal policies and practices. If we make changes, we will notify you by revising the date of this policy, and in some circumstances, we may provide you with additional notice, such as by posting a notice on our website or sending you an email notification. We encourage you to review the policy regularly to stay informed about our data practices and your privacy rights and choices.
1.1.6. This policy was prepared by the Roas Trading B.V. team and approved on the current date by the Director of the company.
2. INTRODUCTION
2.1. Definitions
2.1.1. ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
2.1.2. ‘processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
2.1.3. ‘controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
2.1.4. ‘processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
2.1.5. ‘third party’ means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data;
2.1.6. ‘consent’ of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
2.1.7. ‘data concerning health’ means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status;
2.1.8. 'Enterprise' means a natural or legal person engaged in an economic activity, regardless of its legal form, including partnerships or associations regularly engaged in an economic activity.
2.1.9. 'Group of undertakings' means a controlling undertaking and its controlled undertakings.
2.1.10. 'General Data Protection Regulation' means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.
2.2. Purpose of policy
2.2.1. The purpose of this policy is to give you information about what personal data we collect and why we do it, how we collect, use and disclose that personal data, the legal grounds for processing, and your rights in respect to your personal information.
2.2.2. Roas Trading B.V. has adopted this policy in order to ensure the protection of your rights in relation to the processing of your personal data as your fundamental right, to further design the processing of personal data to serve both you, Roas Trading B.V.'s clients, workers and employees and other individuals, as well as to protect Roas Trading B.V..
2.2.3. Roas Trading B.V. notably strives to further design this policy in order to approved it as binding corporate rules in accordance with Article 47 of the General Data Protection Regulation.
2.3. Business activities
2.3.1. Roas Trading B.V. provides marketing services to its clients. Upon opening an account with us, you provide us with contact and business management data. Clients use our services to reach their target audience and we in return provide the services to help them achieve their marketing goals. Thus, within its business activities, Roas Trading B.V. processes only a limited scope of personal data, notably end user data, wherein the majority of the information we receive when providing services to our clients is considered to be data of enterprises, notably business management data.
2.4.1. Roas Trading B.V. processes the following categories of personal data:
2.4.1.1. Contact Data: personal name, company name, telephone number, and email address, in order to respond to you when you contact us.
2.4.1.2. Client Data: data collected from our clients, including their contact information, company information, and details about the services they have requested from us. This data is used to provide our services and manage our business relationships.
2.4.1.3. Employee Data: personal data of our employees, including information about their work permit, employment contract, and compensation. This data is used to comply with legal requirements and manage our human resources.
2.4.1.4. Candidate Data: personal data of candidates for employment, including their resume and cover letter. This data is used to process job applications and make hiring decisions.
2.4.1.5. Marketing Data: data collected through interactions with our marketing materials, including email addresses and information about engagement with our content. This data is used to improve our marketing efforts and communicate with potential clients.
2.4.1.6. Information on Management of Premises: personal data of individuals maintained regarding entries and exits from the premises, namely the personal name, number and type of personal document, address of residence, employment, type and registration number of the vehicle and date, time and reason for entry to or exit from the premises, all in order to ensure the safety and security of our business premise;
2.4.1.7. Sensitive Information: information of employees and workers in relation to medical examination with an assessment of the worker’s compliance with specific health requirements for a particular work in the workplace, health checks of individual groups of workers with a list of examined workers and an assessment of the fulfilment of specific health requirements for a particular work in the work environment, health status of a group of examined workers, established occupational diseases, sickness-related illnesses or suspicion of an occupational disease, information on the fact and level of intoxication, information whether the worker was under the influence of illicit drugs and other psychoactive substances or not in case testing for illicit drugs and other psychoactive substances, accidents at work, collective casualties, dangerous occurrences, established occupational diseases and work-related illnesses and their causes; all only in order for us to comply with regulatory statutory provisions and to the extent as permitted by law;
2.4.1.8. We ask that you avoid submitting us special categories of personal data including sensitive information and data concerning health, unless such information is legally required and/or Roas Trading B.V. requests you to submit such information.
2.4.1.9. Roas Trading B.V. has adopted every reasonable step to ensure that personal data are accurate and kept up to date, as well as that inaccurate personal data are erased or rectified without delay, however, it cannot assume liability should your information provided to us not be true, incomplete and/or misleading.
2.5. Legal basis for processing
2.5.1. Roas Trading B.V. processes personal data only when permitted to do so by the General Data Protection Regulation.
2.5.2. Most commonly, Roas Trading B.V. processes personal data when it is necessary for compliance with a legal obligation to which the agency is subject. Special categories of personal data are processed only on this legal basis and Roas Trading B.V. does not process any such data on any other legal basis.
2.5.3. Furthermore, Roas Trading B.V. processes some personal data when it is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.
2.5.4. Roas Trading B.V. also processes personal data when it is necessary for the legitimate interests pursued by the agency and your interests and fundamental rights do not override these interests. For example, Roas Trading B.V. has a legitimate interest in processing and transferring personal data within its group of undertakings for internal business purposes, including centralization of data processing activities and making business processes more efficient and cost-effective.
2.5.5. Roas Trading B.V. may also process your personal data when you have given consent to the processing of your personal data for one or more specific purposes. Roas Trading B.V. strives to obtain consents that are given freely, specific, informed and present an unambiguous indication of your wishes by a statement or by a clear affirmative action, signifying agreement to the processing of your personal data.
2.5.6. Where Roas Trading B.V. relies on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
2.6. Use of Data
2.6.1. Roas Trading B.V. processes personal data for the following purposes:
2.6.1.1. Managing of workforce notably with respect to Human Resource Data, Candidate Management Data and Sensitive Information;
2.6.1.2. Communications: enabling response and facilitating communication with you regarding Contact Data;
2.6.1.3. Complying with legal requirements, such as record-keeping and reporting obligations, conducting audits, compliance with government inspections and other requests from government or other public authorities, responding to legal process such as subpoenas, pursuing legal rights and remedies, defending litigation and managing any internal complaints or claims, conducting investigations and complying with internal rules, policies and procedures.
2.6.1.4. Services: Roas Trading B.V. processes Business Management and End User Data in order to provide services to clients.
2.6.2. There may be more than one purpose that justifies our use of your personal data in any particular circumstance.
2.6.3. We shall only use your personal data for the purposes for which we collected it. Should we reasonably require to use your personal data for an unrelated purpose, we will notify you thereof and explain the legal obligation or that such processing is compatible with the original purpose, which allows us to use it for another reason.
If your consent was granted for a specific purpose, which may contain one or more processing activities, we shall not process your personal data for another purpose other than the purpose for which it was originally collected. Where we intend to perform processing for another purpose on the basis of your initial consent, we shall process your personal data only on the basis of a new consent.
2.6.4. Managing of workforce and complying
2.6.4.1. Roas Trading B.V. manages your Business Management, Human Resource, Candidate Management Data and Sensitive Information within its customer relations management software. The software is designed on a need-to-know basis. Furthermore, our internal privacy and security rules are communicated to all of our employees and workers, instructing them to process personal data in accordance with the respective legislation, internal rules and under highest security processing standards when managing workforce or complying with statutory provisions.
2.6.5. Use of Data
2.6.5.1. Roas Trading B.V. uses your data to operate lawfully, effectively and provide the best experience with our services.
2.6.5.2. We use your data to enable access to our Ad Platform, to provide customer, technical, and operational support, to manage your account(s), to send you technical notices, updates, security alerts and support and administrative messages and to resolve disputes and enforcing of our rights, to detect and protect against errors, fraud, or other criminal or illegal activities and to enforce our client agreements. This may also include analyzing, customizing, and improving the Ad Platform, to provide information and analytics to clients about the use of the Ad Platform, to help our clients create or enhance their services with respect to marketing or analytics.
2.6.5.3. You may access to the Ad Platform by submitting the identification form (Join us form), wherein for certain services it is necessary to create a user account, enabling the user to use certain applications. In these cases, you are required to submit data including Business Management Data. This information is needed to provide services to clients, including access to the application, display of customized content and advertising, communications, transfer of profit deriving from digital advertising, ensuring the technical functioning of the network, research and analysis in order to maintain and protect our services.
2.6.5.4. We also use your data to create interferences about end users geographically categorized in order to enable our agency to help clients place advertisement in the respective geographical region. For example, if the End User Data indicates that an end user is located in a certain geographical region or country, the Ad Platform enables the client to place advertisements in such region or country. After this process is done, the internet protocol number of the end user is anonymized in order to prevent our agency and other partners from accessing or retrieving the internet protocol number of the end user. This process also includes anonymizing internet protocol numbers for statistical purposes.
2.6.5.5. We may also use your data when the AdPlatform interacts with social media sites, plug-ins, or other applications provided by advertisers, publishers, or other partners. For example, if a worker or an employee of a client intends to advertise on Facebook through the AdPlatform, they must link their personal Facebook account with the AdPlatform, as Facebook does not allow for corporate Facebook accounts. Once the connection is established, we save their personal name, Facebook identification number, and a list of all Facebook advertisement accounts that individual has access to, which we consider Business Management Data since the individual has opened the AdPlatform account for the client (enterprise), in order to invoice the services provided by the AdPlatform. If the individual then revokes their AdPlatform access through their Facebook account, we still store their data as necessary until the agreement with our client is fulfilled.
2.6.6. Cookies
2.6.6.1. When an end-user visits a website or views an advertisement linked to the AdPlatform, we may deploy online cookies to end-users in order to better or more accurately target relevant advertisements to end-users with respect to their geolocation and frequency of the advertisements. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site. They are typically stored on your computer’s hard drive.
2.6.6.2. Cookies include those strictly necessary for the normal website functions, which cannot be switched off because the website wouldn’t work properly anymore, nor do they store any personal data.
2.6.6.3. In order to deliver as relevant advertisements as feasible, Roas Trading B.V. collects data across its Ad Network. This enables it to identify likely consumer interest segments. All the data, however, is on a completely aggregate basis. We use cookies to improve the quality of our services by storing user preferences and tracking users’ trends, thus providing the most relevant advertisements. Cookies are also used to help advertisers and publishers serve and manage advertisements across the web. We use Google Analytics cookies that enable us to improve user experience on our websites. They help us understand how our users use the website and decide on the functional and material adjustments in order to show as much useful content as possible.
2.6.6.4. You are free to decline most of our cookies if your browser or browser add-on permits it, but choosing to remove or disable our cookies may interfere with your use and functionality of Roas Trading B.V.’s services. You may amend our cookies settings by clicking on the following link: cookie settings.
2.6.6.5. You may delete other cookies as follows:
2.6.6.5.1. To clear cookies on Google Chrome, navigate to the settings by clicking on the menu icon. Scroll down to the bottom of the page and click on "Advanced." In the "Privacy and Security" panel, click on "Content settings" and then "Cookies." Alternatively, you can type "chrome://settings/content/cookies" in the browser's address bar.
2.6.6.5.2. To clear cookies on Mozilla Firefox, click on the "Menu" hamburger icon and navigate to preferences. In the "Privacy & Security" tab, go to the history section and click on the "remove individual cookies" link.
2.6.6.5.3. To clear cookies on Safari, navigate to the "Privacy" menu and select the option to "Block all cookies" or remove them all. You can also click "Details" to remove individual cookies.
2.6.6.5.4. To clear cookies on Edge, click on the 3 dot icon and select "Settings." Next, select the arrow keys next to "Advanced settings" at the top. You will see an option to "clear browsing data," which will allow you to clear cookies.
2.6.7. Communications:
2.6.7.1. Roas Trading B.V. uses your Contact Data primarily to respond to you when you have contacted us.
2.6.7.2. In addition, we may use your Contact Data and/or Business Management Data in order to send you promotional communications or newsletters from us through e-mails where you have given consent. You may choose to sign-up for marketing or other communications from Roas Trading B.V. on our website.
2.6.7.3. You may opt out of receiving promotional communications and/or newsletters from us by following the instructions in those communications (unsubscribe button at the bottom of each email). If you opt out of receiving promotional communications and/or newsletters, we may still send you transactional or relationship messages, such as those about your account or our ongoing business relations for as long as the business relationship exists.
2.6.7.4. In case of performing direct marketing upon the first communication at latest, we shall communicate to you our identity and contact details, the details of our data protection officer, the purposes of the processing for which the personal data are intended as well as the legal basis for the processing, categories of personal data, the recipients or categories of recipients of the personal data and other information provided in Article 14 of the General Data Protection Regulation. If we shall process personal data for direct marketing purposes, we shall do so in accordance with Article 21 of the General Data Protection Regulation, wherein you may exercise your rights to rectification, to object and to request from us to permanently or temporarily cease to use or otherwise process your personal data for the purpose of direct marketing. We shall not disclose this personal data to other users.
2.7. Disclosure of data
2.7.1. In order to provide our services, we may share your personal data with third parties, including:
2.7.1.2. Social media integrations with platforms such as Facebook, Twitter, Snapchat, and LinkedIn for campaign settings, advertisement group targeting settings, and for importing campaign statistics;
2.7.1.3. Other service providers such as advertisers, publishers and other partners, accounting and IT services providers;
2.7.1.4. Public and Governmental Authorities: entities that regulate or have jurisdiction over ROAS such as regulatory authorities, public bodies, and judicial bodies, including to meet national security or law enforcement requirements.
2.8. Transfer of personal data
2.8.1. In order to fulfill the purposes outlined in this policy, ROAS may transfer personal data to a third country or an international organization. These transfers will be made in compliance with the General Data Protection Regulation, including obtaining appropriate safeguards or obtaining consent when necessary.
2.9. Data retention
2.9.1. Generally, Roas Trading B.V. retains personal data for as long as necessary to fulfill the purposes described in this policy, subject to our own legal and regulatory obligations.
2.9.2. Our employees and workers processing personal data are instructed to verify the respective national statutory provisions regarding data retention when processing data.
2.9.3. When personal data is no longer needed, we either irreversibly anonymize the data (and we may further retain and use the anonymized information) or securely destroy the data.
2.10. Your rights
2.10.1. Roas Trading B.V. enables you to exercise the following rights as determined under the General Data Protection Law and respective national jurisdiction:
2.10.1.1. Right to access: you may obtain confirmation from Roas Trading B.V. to whether or not your personal data is being processed, and where that is the case, access to personal data and information;
2.10.1.2. Right to correct: you may request from Roas Trading B.V. to rectify inaccurate personal data and complete incomplete personal data;
2.10.1.3. Right to erasure: you may obtain erasure of your personal data that we hold as a data controller;
2.10.1.4. Right to restriction of processing: you may obtain from Roas Trading B.V. the restriction of processing;
2.10.1.5. Right of information: we shall communicate any rectification or erasure of personal data or restriction of
processing to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. We shall inform you about those recipients if you request it.
2.10.1.6. Right to data portability: you may request from Roas Trading B.V. to receive personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and may also request us to transmit those data to another controller without our hindrance.
2.10.1.7. Right to object: you have the right to object to the processing of your personal data based on our legitimate interests. If you exercise this right, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms.
2.10.1.8. Right to object to direct marketing: you have the right to object to the processing of your personal data for marketing purposes at any time. If you exercise this right, we will no longer process your personal data for marketing purposes.
2.10.1.9. Right not to be subject to automated decision-making: We guarantee your right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
2.10.1.10. Right to be informed of a breach: We shall notify you in the event of a data breach that poses a high risk to your rights and freedoms.
2.10.1.11. Right to file a complaint: You have the right to lodge a complaint with a supervisory authority if you have any concerns or complaints about the way we handle your personal data. However, we encourage you to contact us first so that we can work with you to resolve any issues.
2.10.2. You can exercise your rights by emailing info@roastrading.nl. You can also contact this email to obtain details of the supervisory authorities of the respective Roas Trading B.V. enterprise or to be directed to the respective privacy officer of the Roas Trading B.V. group enterprise.
2.11. Security
2.11.1. We have implemented reasonable and effective technical and organisational measures and procedures designed to implement data-protection principles, such as data minimisation, and integrated necessary safeguards into the processing in order to meet the requirements of the General Data Protection Regulations.
2.11.2. We protect your information by using reasonable physical, technical and administrative security measures, including limiting access to your information to employees and workers on a need-to-know basis. To make sure your personal data is secured, we communicate our internal privacy and security rules to all of our employees and workers, strictly enforce privacy safeguards within Roas Trading B.V. and have also designed our internal software in order to meet our high security processing standards.
2.11.3. We advise you to protect your AdPlatform account details including your username and password and not to share this information with any other individual.
2.12. Contact
2.12.1. Should you have any questions or concerns regarding this policy, our use of cookies, or our policies regarding the collection, use, processing, retention and/or disclosure of your personal data, you may contact us or our privacy officer as indicated below:
Roas Trading B.V.
Keizersgracht 442
1018HG, Amsterdam
The Netherlands
E-Mail: info@roastrading.nl
YOUR LEGAL RIGHTS
IF YOU ARE A VISITOR FROM EU
As a visitor from the EU, you have certain rights under data protection laws in relation to your personal data. These rights include:
· The right to request access to your personal data
· The right to request correction of your personal data
· The right to request erasure of your personal data
· The right to object to the processing of your personal data
· The right to request restriction of processing your personal data
· The right to request transfer of your personal data
· The right to withdraw consent
If you wish to exercise any of these rights, please contact us at: info@roastrading.nl.
LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION
We can only process your personal information if we have a legal basis for doing so. These legal bases include:
· Your consent for the relevant processing activities
· Compliance with a legal or regulatory obligation that applies to us
· Carrying out public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments
· Studies conducted by research entities, preferably carried out on anonymized personal information
· Carrying out a contract and its preliminary procedures, in cases where you are a party to the contract
· Exercising our rights in judicial, administrative or arbitration procedures
· Protection or physical safety of yourself or a third party
· Protection of health in procedures carried out by health entities or professionals
· Our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests
· Credit protection
For more information on the legal bases for processing your personal information, please contact us at any time using the contact details provided in this document.
CATEGORIES OF PERSONAL INFORMATION PROCESSED
To find out what categories of your personal information are processed, you can read the section titled “The Data We Collect About You” within this document.
WHY WE PROCESS YOUR PERSONAL INFORMATION
To find out why we process your personal information, you can read the sections titled “Purposes for which we will use your personal data” within this document.
HOW TO FILE YOUR REQUEST
You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.
HOW AND WHEN WE WILL RESPOND TO YOUR REQUEST
At Roas Trading B.V., we are committed to promptly responding to any requests related to your personal data. However, if for any reason we are unable to fulfill your request, we will communicate the factual or legal reasons that prevent us from doing so. If we are not responsible for processing your personal data, we will provide you with the information of the physical or legal person to whom you should direct your request, if possible.
If you request access to or confirmation of your personal data, please specify whether you prefer to receive it in electronic or printed form. Additionally, please let us know if you require an immediate simplified response or a more detailed response within 15 days.
In the event that you request rectification, deletion, anonymization, or blocking of your personal data, we will promptly communicate your request to any third parties with whom we have shared your data, in order to ensure compliance, except in cases where doing so is impossible or would require disproportionate effort.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests as soon as possible and at least within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
YOU EXPRESSLY ACKNOWLEDGE THAT YOU HAVE READ THIS PRIVACY POLICY AND YOU UNDERSTAND THE RIGHTS, OBLIGATIONS, TERMS AND CONDITIONS SET FORTH HEREIN AND BY USING OUR WEBSITE YOU EXPRESSLY CONSENT TO BE BOUND BY THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND GRANT US THE RIGHTS SET FORTH HEREIN.
GLOSSARY
EXTERNAL THIRD PARTIES
Service providers acting as processors who provide IT and system administration services
Professional advisers acting as processor or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
Regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restrictions of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data´s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
