CBA-Europe is an IT service provider that focuses on different market segments under different product labels. Under the CtrlBase label, CBA-Europe offers IT solutions for the trade in piece goods. CtrlBase develops its own software for Retail and wholesale and is a supplier of all possible equipment for shop automation. CtrlMice provides all possible IT facilities during temporary conferences and events. CtrlOffice advises and provides all possible IT facilities for office automation within the SME. More information about CBA-Europe can be found on the website www.cbaeurope.eu and more information about the product labels can be found at www.ctrlbase.eu, www.ctrlmice.eu and www.ctrloffice.eu.

This Privacy Statement describes how we process the corporate and personal data of prospects and current and former customers of CBA-Europe. If after reading this Privacy Statement you still have questions about the way in which we process your personal data or about the content of this Privacy Statement, you can of course contact us.

If information goes directly about someone, such as a name, or can be traced back to this person, as is the case with a telephone number or the combination of a postcode and house number, then that information is personal data.

Company data is not personal data. This Privacy Statement therefore applies only to the information about your company, if you have a sole proprietorship or general partnership. The products and services you purchase from CBA-Europe are also not personal data because you purchase them for business purposes. These purchases therefore say nothing about you as a person.

The word ‘process’ includes all actions that CBA-Europe can carry out with personal data, such as collecting, recording, organizing, structuring, storing, updating or modifying, retrieving, consulting, using, forwarding, distributing, making available, bringing together, with each other associate, protect, delete and destroy personal data. So this is a very broad concept.

CBA-Europe B.V. is responsible for the processing of your company and personal data described in this Privacy Statement. We are located in Mijdrecht (the Netherlands) at the Constructieweg 96M and registered in the Commercial Register of the Chamber of Commerce under number 34374506.

CBA-Europe can process the following business and / or personal data of you and your company:

The company details of your company, as recorded in the Trade Register of the Chamber of Commerce;

• Financial details of your company, such as the VAT number and the bank account number;
• The contact details of contacts within your company (gender, first name, last name, e-mail address and telephone number and if you have an account in our webshop or cloud solutions: your personal details (gender, first name, last name and your telephone number), your login details (e- e-mail address and password), your authorization (administrator or user) and other information about your account, such as your job;
• Our communication with you, such as messages and other correspondence, contact with our Customer Service, Support department or other employees, and the information that you fill in via a contact form on one of our websites.
• Possible information that we collect when you visit one of our websites, such as your IP address, referring website, surfing habits, cookies and similar technologies;
• Possible information that we receive from the provider of social media (including Facebook, YouTube, Instagram, LinkedIn, Pinterest), depending on your personal settings for social media. For more information about the personal data we receive from a provider and about changing your settings, we refer you to the website and / or privacy policy of the provider of the relevant social network;
• Your location data, provided you have given permission to use it;

• Other information that you share with us, such as interests and preferences you share with us, a response to social media or participation in a customer survey or action;

We strive for an optimal service, where the interests of our customers are paramount. This is also the starting point for the processing of your company and personal data. In order to provide you with the best possible service and to improve our services, it is essential that we process your company and personal data. We do this in order to implement the agreement that we have entered into with your company, because we have a legitimate interest in our marketing activities and the research and analyzes we do to comply with legal obligations that rest on CBA-Europe. or because you gave us permission to do so. We will inform you about the way in which we process your company and personal data in this chapter.

Prospects:

If you have registered your company in the Trade Register of the Chamber of Commerce, we can receive the details of your business from the Chamber of Commerce. The Chamber of Commerce informs us whether your company has activated the Non-Mailing Indicator. If you have not activated the Non-Mailing Indicator, we may use the business data that we receive from the Chamber of Commerce to send information about CBA-Europe to the business address by post. We can also contact your company by telephone with the question whether your company wants to become a CBA-Europe customer, unless you have a sole proprietorship or partnership and have indicated in the do- not -cal me register that has given it no price.

If your company has activated the Non-Mailing Indicator, we will not approach your company by post, but we can contact you by telephone with the question whether your company wants to become a CBA-Europe customer, unless you are a sole proprietorship or has a partnership and has given the Bel-me-niet-register no price for it. We can also obtain your business data in a different way than via the Chamber of Commerce, because your company details are public. In that case, we can not guarantee that we will not approach your company despite your company having activated the Non-Mailing Indicator. Of course we only do business with reputable parties, from whom we expect, that they respect your preference.

If you request a quotation from us about our products or services, we need your company and contact details to be of service to you.

Customers

Implementing an agreement that CBA-Europe has with its customers: We need your business and personal data to ensure that we can deliver our products or services correctly, that you can place orders via the online order platform of CBA-Europe and that orders can be delivered, that we can invoice the purchased products to you and that we can contact your company if necessary.

Customers who are registered by our business partners: Business partners of CBA-Europe have the opportunity to register for our online software services as part of their own services. Within this service you have authorized our business partner to share your company and personal data with us. Your data is necessary for activating an online software account. We will inform you about the data provided for this purpose, supplemented with your personal login details. As soon as you use these log-in data for the first time, you must agree with the Software User Agreement, with which you are regarded as a customer of CBA-Europe.

There is a possibility to place orders via the online ordering platform of CBA-Europe. We process your company and personal data as far as necessary for the processing of the order. Every user receives their own account within the online ordering platform. The main account is created by CBA-Europe. Based on the surfing and clicking behavior (depending on your cookie settings) and the transaction behavior of your account, we can draw your attention to alternative or relevant products.

Use of contact information We use your contact details to contact you if necessary in connection with the proper execution of the agreement we have with your company and the obligations arising there for CBA-Europe, for example in connection with your placement. order, planned delivery or if a product can not be delivered. We also use your contact information to inform you if that is in your interest for another reason. If you have indicated that you wish to be informed by e-mail about product renewals or offers, we will use your e-mail address to send you this information. You can unsubscribe from these e-mails via the link in those e-mails or by contacting CBA-Europe.

Improving CBA-Europe services We have a legitimate interest in processing your company and personal data for marketing activities and analyzes, research and reporting to improve our services, to offer our customers more relevant offers and a better product range and to inform, inspire, to improve our customer contacts and to improve the design and content of our websites and our online ordering platform. For these purposes, we analyze the purchase data of customers and / or accounts for the online ordering platform of CBA-Europe and compare this information, as well as your company and personal data with company and personal data of other customers. Preventing fraud We have a legitimate interest in using your company and personal data to detect and prevent fraud. Meeting legal obligations We process your corporate and personal data for internal business purposes, such as conducting an administration and complying with our legal and tax obligations.

Cloud services We work closely with carefully selected and specialized cloud service providers. If it is necessary for the execution of the agreement that CBA-Europe has with your company, then we will share your company and personal data with one or more of our suppliers. The Cloud Service providers may only use the corporate and personal data that CBA-Europe provides to them for the purpose for which CBA-Europe provided the data to them. They are obliged to protect all company and personal data against unlawful use and loss and must take appropriate technical and organizational measures.

Other Commercial partners and service providers

We can use commercial partners and service providers to deliver our services. These third parties may only use the corporate and personal data that CBA-Europe provides to them for the purpose for which CBA-Europe provided the data to them. They are obliged to protect all company and personal data against unlawful use and loss and must take appropriate technical and organizational measures.

Government agencies

We may be forced by law to share corporate or personal data or data about your company’s purchases with public authorities or government organizations.

Third party websites

The CBA-Europe websites may contain links to third-party websites. If you follow these links, you will leave the website (s) of CBA-Europe. This Privacy Statement does not apply to third party websites. CBA-Europe accepts no liability for the use of your personal data by these third parties. The use of these websites is at your own risk. More information about how these third parties deal with your personal data can be found in the privacy policy on these websites (if available).

We keep your company and personal data as long as necessary for the purposes described in this Privacy Statement or to the extent necessary to comply with laws and regulations and resolve disputes. After the retention period has expired, CBA-Europe will remove or anonymize the company and personal data if we want to use the data for statistical research.

The retention period of the information of prospects is unlimited, unless a prospect becomes a CBA-Europe customer or no longer wishes to be regarded as a prospect. In that case we will delete the data immediately. The processing of the removal can take several weeks, so it is possible that your company is still being approached, even after the data has been deleted.

The retention period of the customer data is no more than one year after a customer has been given the ‘expired status’, unless the data must be retained in connection with a fiscal retention period or stored in an anonymised manner in order to remain available for analysis and research.

We keep your company and personal data as long as necessary for the purposes described in this Privacy Statement or to the extent necessary to comply with laws and regulations and resolve disputes. After the retention period has expired, CBA-Europe will remove or anonymize the company and personal data if we want to use the data for statistical research.

The retention period of the information of prospects is unlimited, unless a prospect becomes a CBA-Europe customer or no longer wishes to be regarded as a prospect. In that case we will delete the data immediately. The processing of the removal can take several weeks, so it is possible that your company is still being approached, even after the data has been deleted.

The retention period of the customer data is no more than one year after a customer has been given the ‘expired status’, unless the data must be retained in connection with a fiscal retention period or stored in an anonymised manner in order to remain available for analysis and research.

• What (s) right (s) your request relates to
• The reason for your request (if you wish to make this known to us)
• Your customer number (if you are already a CBA-Europe customer)
• The number under which your company is registered in the Trade Register

The AVG obliges CBA-Europe to determine your identity. If we are unable to establish your identity, CBA-Europe may ask you for additional information that is necessary to confirm your identity. If CBA-Europe can not confirm your identity, we can not process your request.

If you have a complaint about the way in which we process or have processed your personal data, you can submit this complaint to the management of CBA-Europe B.V.

You do not first have to notify CBA-Europe of your complaint, but you can also submit it directly to the Dutch Data Protection Authority. Of course we would appreciate it if you first submit your complaint to CBA-Europe, so that we are given the opportunity to solve your problem.

This version of the Privacy Statement was entered into on 1 July 2018. If there is reason to do so, we will adjust this Privacy Statement. We will inform you about this.