A. INTRODUCTION
1. Scope
We are committed to protecting the confidentiality, accuracy and integrity of any personal data you provide to us. We always safeguard such data from misappropriation, loss, misuse, unauthorized access, disclosure and/or alteration. We only collect personal data that is relevant for our described purposes.
This Online Privacy Notice (“Notice”) has been created for all digital application (“app”) users, in order to provide relevant information and demonstrate that your personal data is processed in a legal and responsible manner. Please note that some information is only applicable where Regulation EU 2016/679 (GDPR) applies to you. The GDPR applies to you where the processing of your personal data is done in the context of the activities of a relevant establishment in the Union, or where the offering of goods or services, or the monitoring of your behaviour, has occurred and you are in the Union.
2. Controller
The controller for your personal data is the entity responsible for the digital app that you use. You can find their details within the Legal Notice link in the website or mobile app. To contact our privacy team and Data Protection Officer, you can use the follow contact details: EU Data Protection Officer, c/o ADM Germany GmbH, Ferdinandstraße 5, 20095 Hamburg, Germany, Telephone: 0049 (0) 40 3013 774, Email: privacyeu@adm.com.
B. PURPOSE & LEGAL BASIS
Below you will find information about how we process your personal data, the purpose for our processing, and the legal basis according to the GDPR if applicable:
1. Use of digital app
We process your personal data in order to offer the digital app to you. The purpose of our processing is therefore the technical provision of the app (including log-in and authentication), understanding your interests, and supporting/furthering our business relationship. Personal data required for this is as follows:
Basic contact details: These may be private, but are generally only your professional details.
Technical data: Generated by your usage of the app.
App input: This is the information collected by us or input by you during your usage of the app. Please note that this can also include information collected from you with your permission from national agricultural services in order for us to properly offer the app to you. More information on this is provided where you are so affected.
Location data: For a small portion of our apps, you can use a map feature to see relevant locations (i.e., our closest shops). The app will prompt you to confirm that you really wish to share this if you are affected.
The legal basis for our processing is contract necessity (Art. 6(1)(b) GDPR) where a contractual arrangement exists between your business and us. We therefore provide the app on the basis of or in connection with our service provision or products that you have purchased.
Where no contract exists between your business and us, the legal basis for processing is our legitimate interests (Art. 6(1)(f) GDPR), our legitimate interests being the successful technical provision of our app, understanding your interests, and furthering our business relationship. This is because these apps are designed for existing or prospect customers in our industry and support/extend our products.
In some circumstances, the legal basis for our processing may be your consent (Art. 6(1)(a) GDPR). You will know that this applies where your consent is collected clearly and separately from this Notice.
2. Communication
Where you contact us through a provided contact form in the app, or through helpdesk contacts provided in the app, the purpose of the processing is to facilitate contact between you and us. The legal basis for this processing is our legitimate interests (Art. 6(1)(f) GDPR), as we have a legitimate interest in assisting you and responding to your queries.
3. Cookies & Tracking
We use a banner on our websites to allow you to manage your cookie or tracking preferences, and consent to such before they are activated. Please note that technically necessary cookies cannot be deactivated by this tool. You can access more information about cookies or tracking practices at our dedicated XXX Notice.
4. Marketing
We may use your personal data for our marketing activities. These marketing activities will involve us or our affiliates regularly contacting you about our or related services, products, competitions or events. The legal basis for this processing is your consent (Art. 6(1)(a) GDPR). This consent will be collected clearly and separately from this Notice. You can withdraw this consent at any time with future effect by contacting privacyeu@adm.com.
C. RECIPIENTS
Here you will find information about recipients of your personal data. We only share your personal data where it is necessary for the above stated purpose.
1. Internal & Affiliates
We will share your personal data internally and also with our affiliates where required. We only do this where we have a defined reason for doing so. This is generally where they help us with the service provision, or contact you in regards to marketing activities.
2. Unaffiliated third parties
We may share your personal data with unaffiliated third parties who perform administrative, marketing, professional, or technological support functions. This is especially the case where external third parties help us with authentication support, hosting, or where you log in to the app using a third party provider account. These parties are vetted and contracted with us to ensure your personal data is protected;
We may share your personal data with unaffiliated third parties with whom we enter into joint venture agreements, branding agreements or other strategic alliances, or in the event of a sale, merger, reorganization, liquidation or other similar event;
Where we engage external service providers to support us in promotional and/or advertising activities, your personal data will be shared accordingly.
Where it is necessary for the carrying out of a contractual relationship, we will share your data with partners, customers and suppliers.
3. Regulatory bodies / National services
For some apps, we may retrieve personal data about you or your business from agricultural services. This is done with your permission, or generally at least where have signed the corresponding form (including digitally) and provided this to us.
Additionally, we may be required to disclose personal data by law or legal process, for the administration of justice, for investigation of breaches, for interacting with governmental anti-fraud databases, to protect the security or integrity of our databases or this website, to protect and defend our rights or property, to protect the personal safety of our website users, to take precautions against legal liability, to protect your or our legal claims and interests, defend against litigation and to comply with a government organization. We reserve the right to contact appropriate authorities when activities that are illegal or violate our policies occur on our website.
D. INTERNATIONAL TRANSFERS
If you would like more information as to how we protect your personal data in these circumstances, please contact the Data Protection Officer with the contact details we provided above.
E. STORAGE
We only store your personal data for a period reasonable for our purposes of processing and/or for a period of time that is required of us by applicable laws. We do not process your data any longer than we need to. If you would like to delete your profile/account within the application, you can do so by contacting us through the page https://www.compliance.adm.com/contact/.
If you would like more information about our retention periods, please contact our Data Protection Officer with the contact details that we provided above.
F. YOUR RIGHTS
Some jurisdictions provide you with specific rights over your personal data. You can exercise these rights, per your specific situation/circumstances, by contacting us with the above details. These rights are: Where the GDPR applies, you have actions available to you in relation to our processing of your data. You may use the contact information below to request:
Access to your data (Art. 15 GDPR): You have the right to request information as to whether we are processing personal data concerning you, and subsequent access to this personal data.
Rectification of your data (Art. 16 GDPR): You have the right to the rectification of your personal data that is inaccurate or incomplete, this includes by means of a supplementary statement.
Erasure of your data (Art. 17 GDPR): You have the right to ask us for the erasure of your personal data, where no exemption for retaining the personal data applies.
Restriction of our processing of your data (Art. 18 GDPR):You have the right to request a restriction on the processing of your personal data in particular circumstances.
Data Portability (Art. 20 GDPR): In some circumstances, you may be entitled to request that your personal data be provided to you in machine readable format. This is applicable where the processing of your personal data is based on consent (Article 6(1)(a)), where special categories of personal data are being processed based on consent (Article 9(2)(a)), or where your personal data is processed on the basis of Article 6(1)(b). This right to data portability includes the right to have your personal data transferred directly to another controller.
| a. Objection to our processing of your data (Art: 21 GDPR): Where your personal data is processed for the purpose of performing tasks carried out in the public interest (Art. 6(1)(e)), for the purpose of legitimate interests of the controller (Art. 6(1)(f)), or for the purpose of direct marketing and profiling related to this (Art. 21(2)), you are able, based on the grounds relating to your particular situation, to object to the processing of your personal data. For direct marketing, you may object at any time without reasoning with future effect. |
Withdrawal of consent: Where processing is based on your consent, you have the right to withdraw your consent at any time with future effect. You can do this by contacting us with the contact details provided above.
Provision of personal data: Generally, your usage of the apps and therefore personal data input is optional and voluntary. However, without the personal data provision, specifically without full data provision as requested (aside from marketing), we cannot provide the apps to you in their full functionality.
G. COMPLAINTS
You may submit a complaint regarding your personal information to a supervisory authority regarding our processing of your personal data.
Last Update : February, 2021
