Mileway (“Company“, “we”, “us”) believes it is important that you understand how we collect, store, share and use information from and about our website visitors, customers and vendors. The purpose of this Privacy Notice (“Notice”) and our cookie notice is to clearly describe how we collect, use and disclose personal data collected through the website or in the course of our business activities conducted offline when we act as the Controller of that data and when its processing is governed by the EU General Data Protection Regulation (GDPR).
For the purposes of GDPR, Company is the controller of any personal data collected from you on the website or otherwise for the purpose of conducting or developing our business with you. We are a logistics real estate company located in The Netherlands and operating in other European territories and we can be contacted as follows:
- Address: Parnassusweg 723, 1077 DG Amsterdam, The Netherlands – Email: email@example.com.
- We have a data protection officer, who can be contacted at firstname.lastname@example.org.
For the purposes of this Notice, personal data means any information relating to an identified or identifiable person. Please read this Policy carefully as it provides important information about how we use personal data and explains your legal rights.
Information you provide
In order to access or use certain portions of the website or enjoy the full functionality of the website, or otherwise in conducting business with us or seeking to conduct business with us, you may be prompted to provide certain personal data to us in the following ways:
- by filling in forms (for example, a ‘Contact us’ form) on our website or anywhere else we conduct business;
- by subscribing to newsletters or other communications; or
- by corresponding with us by phone, e-mail or otherwise using our contact details.
The personal data you will be asked to provide includes name, business affiliation, business address, telephone number, and email address, and any personal details required to resolve any enquiries or complaints.
This personal data is required to enter into a contract with you (in anticipation of an agreement to provide services) or to perform a contract with you (such as to provide services at your request), and failure to provide any information may result in our inability to perform such contract.
Information we collect automatically
When you visit our website, our server automatically collects certain browser or device generated information, which may in some cases constitute personal data, including but not limited to:
- your domain;
- your IP address;
- your date, time and duration of your visit;
- your browser type;
- your operating system;
- your page visits;
- other information about your computer or device;
- Internet traffic.
Why and on what legal basis we use personal data
All processing and use of your personal data is justified.
The following is an overview of the justified legal grounds for processing personal data, and why we use your personal data:
- The processing is necessary to perform a contract with you or take steps to enter into a contract at your request:
- to provide you with documentation or communications which you have requested;
- to process and complete certain transactions involving the website, and more generally transactions involving our services;
- or to provide information you have requested;
- The processing is necessary for us to comply with a relevant legal or regulatory obligation:
- to keep accounting records and evidence of on-line sales;
- to comply with EU trade sanctions laws;
- The processing is in our legitimate interests, which are not overridden by your interests and fundamental rights:
- to evaluate transactions involving the website or our services;
- to operate, evaluate, maintain, improve and develop the website (including by monitoring and analyzing trends, access to, and use of the website for advertising and marketing);
- to evaluate, improve and develop our services;
- to engage you about events, promotions, the website and our similar services (unless consent is required by local law);
- to send you marketing communications;
- to protect and ensure safety of the website and our confidential and proprietary information;
- to manage, protect against and investigate fraud, risk exposure, claims and other liabilities, including but not limited to violation of our contract terms or laws or regulations;
- to share your personal data with third parties in connection with potential or actual sale of our company or any of our assets, or those of any affiliated company, in which case personal data held by us about our users may be one of the transferred assets;
- You have consented to the processing:
- to market to you where consent is required by local law.
When the justification for processing is our legitimate interests, those interests are to use supplier, customer and website user data to conduct and develop our business activities with them and with others, while limiting the use of their personal data to those purposes that strictly support the conduct and development of our business within the reasonable expectation of the individuals concerned.
We will always take steps to ensure that any international transfer of information is carefully managed to protect your rights and interests.
We will ensure that transfers outside your country are subject to additional safeguards required under local law – for example, the EU Model Clauses pursuant to Article 46(2) of the GDPR.
You have the right to ask us for more information about the safeguards we have put in place as mentioned above. Contact us as if you would like further information or to request a copy where the safeguard is documented (which may be redacted to ensure confidentiality).
Disclosure of personal data
We are part of a global group, and from time to time it will be necessary to share your personal data with our affiliated businesses for the purposes described above. We also appoint third party service providers (who will operate under our instructions) to assist us in providing information, products or services to you, in conducting and managing our business, or in managing and improving our products, services or the website. We share your personal data with these affiliates and third parties to perform services, subject to appropriate contractual restrictions and security measures. We will further share your personal data with law enforcement, regulatory bodies or professional advisors if we believe it is reasonably necessary to prevent harm or loss or if we believe that the disclosure will further an investigation of suspected or actual illegal activities.
The website is not for use by children under the age of 16 years and we do not knowingly collect, store, share or use the personal data of children under 16 years. If you are under the age of 16 years, please do not provide any personal data, even if prompted by the website to do so. If you are under the age of 16 years and you have provided personal data, please ask your parent(s) or guardian(s) to notify us and we will delete all such personal data.
Subject to your consent where required by local laws, we may communicate with you by SMS and email to tell you about our services. If you wish to opt-out of receiving marketing communications, please use the ‘unsubscribe’ link provided in our emails or text the STOP number in our SMS, or otherwise contact us directly and we will stop sending you communications.
We do not engage in automated decisions about you in connection with the website, but we will notify you if this changes.
Retention of your personal data
We apply a general rule of keeping personal data only for as long as required to fulfil the purposes for which it was collected. In general, we retain your personal data for a period of time corresponding to a statute of limitation setting out the period during which legal claims may be filed in court. For example, we’ll retain your personal data during the statute of limitation period, to maintain an accurate record of your dealings with us and, as applicable, assert or defend against a legal claim. However, in some circumstances we may retain personal data for other periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required. With respect to marketing, we retain your personal data for 8 years after your last request for service or other contact you initiate.
The website may contain links to third party sites. As we are not control responsible for the privacy practices of those websites, we encourage you to review the privacy policies of these third party sites. This Notice applies solely to personal data collected by our websites or in the course of our business activities.
- Right to withdraw consent – where applicable, you have the right to withdraw your consent at any time. For example, if you wish to opt-out of receiving electronic marketing communications, you can change your settings in your account on the website, use the ‘unsubscribe’ link provided in our emails or text the STOP number in our SMS, or otherwise contact us directly and we will stop sending you communications.
- Right of access, rectification and erasure – you have the right to request access to and obtain a copy of any of your personal data that we may hold, to request correction of any inaccurate data relating to you and to request the deletion of your personal data under certain circumstances. [You can see and update most of this data yourself online, or by contacting us directly at email@example.com.
- Data portability – where we are relying (as the justification for processing) upon your consent, or the fact that the processing is necessary to perform a contract to which you are party or to take steps at your request prior to entering a contract, and the personal data is processed by automatic means, you have the right to receive all such personal data which you have provided us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.
- Right to restriction of processing – you have the right to restrict our processing of your personal data (that is, allow only its storage) where:
- you contest the accuracy of the personal data, until we have taken sufficient steps to correct or verify its accuracy;
- where the processing is unlawful but you do not want us to erase the personal data;
- where we no longer need your personal data for the purposes of the processing, but you require such personal data for the establishment, exercise or defense of legal claims; or
- where you have objected to processing justified on legitimate interest grounds (see below), pending verification as to whether we have compelling legitimate grounds to continue processing.
Where your personal data is subject to restriction we will only process it with your consent or for the establishment, exercise or defense of legal claims.
You also have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your personal data infringes applicable law. A list of data protection supervisory authorities is available here https://edpb.europa.eu/about-edpb/board/members_en.
- Right to object to processing (including profiling) based on legitimate interest grounds – where we are relying upon legitimate interests to process personal data, you have the right to object to that processing. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we need to process the personal data for the establishment, exercise or defense of legal claims. Where we rely upon legitimate interest as a basis for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.
- Right to object to direct marketing (including profiling) – you have the right to object to our use of your personal data (including profiling) for direct marketing purposes, such as when we use your personal data to invite you to our promotional events.
Please contact us at firstname.lastname@example.org if you wish to exercise any of your rights, or if you have any enquiries or complaints regarding the processing of your personal data.
Changes to this notice
We will changes to this Notice from time to time for example, to keep it up to date or to comply with legal requirements or changes in the way we operate our business. Any changes or updates we may make to this Notice will be posted on this page in advance so that you are aware of the impact to our data processing activities before you continue to engage. If we have your contact details on file we will notify you in advance of any significant changes to this Notice that are material or may impact you. For other changes, please check back frequently to see any updates or changes to this Notice.