Protecting your privacy is very important to Viterra Limited and its affiliates ("Viterra", "our", "us"or "we"). This privacy notice details how we collect, use and manage personal data about individual directors, officers, employees and beneficial owners of our prospective and existing customers and counerparties who are themselves individuals. When we refer to "you" or "your" in this privacy notice, we are referring to you ( as a prospective or actual customer or counterparty) and/or your associated individuals.
What personal data do we process?
“Personal data” is information that relates to an identified or identifiable individual. Data, which identifies an individual, can simply be a name or a number or could include other identifiers such as an IP address or a cookie identifier, or other factors.
“Processing” or “process” 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.
As a prospective or existing customer or counterparty of Viterra, we may collect and process Personal data about you, your directors, officers, employees, beneficial owners and other associated individuals. This includes names, current and previous addresses, date of birth, telephone number and email address, job title / role with / shareholding in your organization, information about your business, and information relevant for money laundering, sanctions, anti-bribery and corruption compliance checking purposes.
In some circumstances, we may also collect and process identification information about you or your directors, officers, employees, beneficial owners or other associated individuals in order to verify your or their identity, such as driver’s license and passport information. We collect this information where it is reasonably necessary to comply with the law or if it is required to administer aspects of the relationship between you and us.
You may need the consent of your associated individuals if you disclose their personal data to us. You must provide them with a copy of (or link to) this privacy notice before you give us their Personal data.
We may also collect details of the interactions that you have with us, together with any other information that you choose to give us.
Why do we process personal data?
We may collect your and your associated individuals' personal data for a range of different purposes as a prospective or existing customer or counterparty, including:
- to support our procurement and onboarding processes, including complying with our internal policies (particularly policies designed to prevent money laundering and sanctions violations);
- to provide our products and services to you, or to provide you with a quote or offer for our products and services;
- to communicate with you about a potential or existing engagement with Viterra;
- to answer your enquiries and provide any information or documents you ask for;
- for administrative, planning, product or service development and delivery purposes; and
- to update our records and keep your contact details up to date.
If you choose not to provide your personal data to us, we may not be able to engage in a business relationship with you, either partly or at all.
What are the legal bases for our processing of your personal data?
The legal bases on which we process Personal data are:
- The processing is necessary for compliance with a legal obligation; or
- The processing is necessary in connection with any contract that you (as an individual) may enter into with us, or to take steps prior to entering into a contract with us; or
- We have a legitimate interest in carrying out the processing in order to further our business interests or for the purposes of compliance with our policies, in particular in relation to money laundering and sanctions violations (to the extent such legitimate interest is not overridden by your interests or fundamental rights and freedoms).
How do we collect your personal data?
We will collect your personal data in a number of ways, including:
- directly from you (where it is practicable to do so);
- from third parties including employers, authorized representatives, agents or third parties who are authorized to share personal data, and publicly available sources of information, such as address validation software and telephone directories; and
- from third parties (some of whom may be our agents) who have identified you as someone who may wish to purchase our products or provide services to Viterra.
To whom do we disclose your personal data?
We may share your personal data with Viterra affiliates and disclose your personal data to third parties during the course of business, including:
- our authorized representatives (agents, consultants, intermediaries);
- financial institutions (for payment processing);
- government and regulatory authorities (where required or authorized by law);
- our service providers, such as information technology suppliers, contractors, debt collection agencies and our professional advisors, such as accountants, auditors and lawyers;
- third parties that provide screening and due diligence solutions for background screening purposes.
Where appropriate, we ask that these third parties hold, use and disclose your personal data in accordance with any applicable data protection laws.
International transfers of your personal data
Viterra is an international group of companies and we have affiliates and service providers, and relationships with counterparties and governmental authorities, in many countries. As a result, Viterra might transfer your personal data to third parties located in or outside of European Economic Area (EEA) which are not regarded by the European Commission (or the equivalent authorities in other jurisdictions) as ensuring an adequate level of data protection, but Viterra takes appropriate steps to ensure that the transfers comply with the applicable data protection laws.
Note in particular that, if you are located in EEA, transfer of your personal data to any country outside the EEA may only take place under below conditions:
- The third country provides an adequate level of protection for the personal data as determined by the European Commission;
- In the absence of the adequate level of protection, a party wishing to transfer the personal data requires to ensure appropriate safeguards which provides enforceable data subject rights and effective legal remedies for data subjects;
- In the absence of an adequate level of protection or of appropriate safeguards, a transfer or a set of transfers of personal data is line with the one of the derogations for specific situations covered by the General Data Protection Regulation.
Please contact email@example.com for more information about the mechanisms used by Viterra when transferring data outside of EEA.
How long do we keep your personal data?
We will keep your personal data for as long as we need to keep it for legal, compliance or business purposes. Please contact firstname.lastname@example.org for more information about our record retention practices.
Your rights in relation to personal data
We take reasonable steps to ensure the personal data we collect, use and disclose about you is correct, complete and relevant for the purposes for which we collect it. In any event, as a data subject;
- You have a right to request access to your personal data that Viterra holds about you.
- You have a right to rectification of inaccurate personal data about you.
- Under certain circumstances, you can request, in writing, to have your personal data to be erased or you can object to our processing of your personal data and/or request that we limit the purposes for which we continue to process your data.
To protect your personal data we will always confirm your identity with you before giving you access to any information or making any changes.
You can send an e-mail to email@example.com to make a request or to be informed further about your rights as a data subject.
If you have a complaint about how we have dealt with your personal data, please contact us at firstname.lastname@example.org using the details below. We will investigate your complaint and provide you with a formal response, usually within 30 days. If the circumstances of your complaint are complex and we need additional information or time to provide you with a formal response, we will contact you to let you know.
If you are not satisfied with our response, then you may file a report at https://autoriteitpersoonsgegevens.nl/nl/zelf-doen/gebruik-uw-privacyrechten/klacht-melden-bij-de-ap or lodge a formal complaint with your local data protection authority.
If you have any comments, questions or would like to receive further information about the international data transfer agreements that we have in place, please contact your regular Viterra contact or email us at email@example.com