Privacy Policy Statement

32Cup respects your privacy and your personal data in conformity with the General Data Protection Regulation.

This policy describes our policy regarding your personal information on how we collect, obtain, or use your personal information, how long we keep it, who we share it with and how we protect your information. Also, we are transparent in the transfer of your personal information, which is never done without your consent. We wish to safeguard your privacy of your personal information.

32cup refers to 32cup, its subsidiaries and other joint ventures, partnerships, undertakings and entities authorized to using the name 32cup. For more information on the entities that control and process personal data, see below under ‘data controllers and processors.

What personal information do we collect?

We may collect personal data for our business purposes to offer, promote and sell Green Coffee through direct marketing, project coordination, event management, marketing campaigns, promotional actions, or any other action in our relationship with our stakeholders in the green coffee industry, including inbound and outbound business development. Our policy to respect your privacy and to act in conformity with the general data protection regulation applies when you use our website, when you contact or request information or when you use our services as staff, clients, suppliers and stakeholders.

The personal information we process may include the following within our scope of business:
• your first name, surname, prefix, title, the company you represent and your relationship to our organization as a customer, supplier, staff or stakeholder
• Contact information, such as your (home) postal address, professional domicile(s), primary email address, and phone number(s)
• Financial information, such as payment-related information or shared pricing information
• Statistical information, including information from your visits to our website with your consent or applications we offer or use in our contractual working relationship with you
• Information you provide to us to deliver onsite or for our logistics services
• Identification, authentication and information required to provide green coffee or our logistics services
• Personal information required for operational or quality purposes in your capacity as supplier or customer such as reported non-conformities, quality reviews, customer requirements, legal requirements or any other requirement to supply green coffee and our corresponding services, which may include special categories of data e.g. for visa approval or other legal requirements.
• Any other information relating to you which you may provide to us with your consent

How we obtain your personal information

• We may collect personal information for our business processes about you and others as required for providing professional services to our customers
• We may collect personal information while monitoring our applications and services, including our websites and email communications sent to and from 32cup
• We gather information about you when you provide it to us, or interact with us directly, for instance engaging with our staff or registering on one of our digital platforms or applications
• We may legally collect or receive personal information from other sources, such as contact details to update your personal information in our company data or in other resources

How we use your personal data

32Cup obtains, collects, and processes personal information about you in several ways, including your use of our website and the provision of services by us or for us.
Purpose of obtaining, collecting or processing any personal information about you:
• Maintenance, population, monitoring, updating and improving our website and applications
• Provision and improvement of our green coffee sales or purchasing and corresponding services to you and to our customers
• Provision of information requested by you or by our customers to deliver our green coffee sales or purchasing and corresponding services
• Promotion and branding of our services, including updates, publications and event details
• Management and coordination of our relationship with clients, suppliers and stakeholders
• Meeting our legal, regulatory and risk management obligations, including legal claims
• Recruitment, dispatch, and contracting of services including rental of material supplies

32cup Website Policy

Our website includes web-based services including the provision and processing of personal data, such as qualification forms, customer requests, call-to-actions, requests for proposals, jobs or the use of cloud-based applications. The purpose of these services is to obtain and provide personal data required for the provision, availability, promotion and supply of green coffee sales or purchasing and corresponding services.

Our website uses web-based tracking, analysis and reporting tools such as Google Analytics and other web-based analytics to report, log, and improve the use of our website by our visitors. Google Analytics does this by placing text files called ‘cookies’ on your device. The information collected by these cookies, such as the number of visitors to the site, the pages visited, and the length of time spent on the site, is fully anonymous.

You may refuse the use of cookies or withdraw your consent at any time by selecting the appropriate settings on your browser. Please note that this may affect the use of our website. By continuing to use our website without changing your privacy settings, you agree with the use of cookies.

Marketing and Email

32Cup uses email and marketing campaign applications. These applications are in conformity with the Global Regulation on Data Privacy with a separate conformity agreement between the processing companies for such applications and their customers. These applications may use personal data for the sole purpose of analysis in reading and linking emails to marketing, branding or educational campaigns, such as clicks on links and other real-time or historical website information. We do this by using software that places a cookie on your device which tracks the activity of your recorded email address. Our website policy explains how to manage or remove these cookies.

We may also use customer relationship management applications, within the scope of the applicable legislation, to manage and improve the relationship between 32cup and its stakeholders: customers, suppliers or business partners.

If you receive marketing communications from us and no longer wish to receive these, you can unsubscribe at any time by using the unsubscribe link in campaigns or by emailing our company.

Onsite and online meetings

We will collect and process personal information about you in relation to the preparation, organization, management, coordination and supply of onsite and online meetings and events. We will only process and use personal information required for the provision or the supply of onsite or online meeting services, which includes account records and financial information to meet any other legal or regulatory obligations. We only share your information with service providers or business partners involved in organizing, coordinating or hosting the relevant meeting or event.

Legal ground for using and processing personal information

We use and process your personal information on the following legal bases:
 To perform and provide any business service contract
 To comply with legal and regulatory obligations, such as keeping financial records
 For legitimate business purposes
 For identification purposes where this is required by law
 For safety or authentication purposes in onsite or online meeting planning

How long we keep your personal information

Your personal information will be retained in accordance with our data retention policy related to all personal information held by 32Cup or its partners within its business purpose. This data retention policy is recorded for all personal information processed or used with an appropriate retention period for each data category. These retention periods are based on data protection laws where applicable and for the sole purpose for the collection, use and disclosure of personal information for identification purposes required to perform a green coffee contract, taking into account the minimum period for the purpose of management of logistics, human and material resources, customer or supplier relationships, including the retention period for confidential and sensitive information required.

Who we share your personal information with

We are an international specialty coffee company. Personal information you provide to us to perform or to support a contract, or personal information obtained through one of our branding campaigns, may be shared with and processed by any of our business partners or associated suppliers if this is required to perform or support our services, including the use of that personal information to manage, offer or improve our services within the scope of business related services.
We may also use or share your personal information with certain trusted third parties if these entities are within the legal scope of contractual agreements and arrangements, including:
• Our professional advisers, external auditors, accountants or legal authorities
• Suppliers or subcontractors to whom we outsource services
• IT, marketing and videoconferencing providers to 32Cup or its business partners
• Third parties involved in hosting or organizing onsite or online meetings
• Where applicable, personal information may also be shared with regulatory authorities, courts, governments and law enforcement departments if this is required to perform a project (e.g. travel visa, customs) or to provide services
• Legal or regulatory requirements to disclose your information to comply with these requirements with your prior consent to do so unless we are legally restricted from doing so.

Transfer of personal information

In the event of a future transfer or re-organization all or part of our business, we may need to transfer your information to new 32Cup entities or to third parties through which the business of 32Cup will be carried out after a transfer, sales or re-organization of 32Cup.

Social media policy

32Cup uses social media sites such as Facebook, LinkedIn, Instagram, Twitter or other social media for company branding purposes. Please review their privacy policy regarding personal information if you make use of these social media in connection with our branded business.
We do not sell, rent or otherwise disclose personal information to any third party for commercial purposes outside the scope of our company objectives or business purposes without prior consent.

How we protect your personal information

We protect your personal information from unauthorized access, use, disclosure, modification, hacking or destruction in conformity with applicable international data protection laws.
32cup holds an internationally recognized quality standard ISO certification in respect of its document management, client property, confidential data and internal and external communication.

The information security policy of 32Cup and the measures taken to safeguard this policy are compliant with the requirements of international data privacy and the general data protection regulation with best practices in data protection, security, encryption and disaster recovery schemes.

Which countries we transfer your personal information to

To provide our related business services, we may need to transfer your personal information to locations outside the jurisdiction in which you provide it or where you are viewing this website for the purposes set out in this privacy policy. This may include a transfer of your information from a location within the European Union (the EU) to outside the EU, or from outside the EU to a location within the EU. Please consult ‘Who we share your personal information with’ for details on information sharing with 32Cup and third-party providers.

The level of information protection in countries outside the EU may be less than that offered within the EU. Where this is the case, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws. EU standard contractual clauses apply for all 32Cup entities or their business partners.

Where our third-party service providers process personal information outside the EU when providing services to us, our data processing agreement with them will include the purpose and legal ground to use or share such personal information within the scope of our contractual business relationship with these third-party service providers who will be recorded on the data processor list.

Your rights regarding your personal information

The European Union’s General Data Protection Regulation and other applicable data protection laws provide certain rights for owners or subjects of personal information and data.

You are entitled to request details of the information we hold about you and how we process it. Where permitted or not otherwise restricted by law, you are entitled to have your personal information modified or deleted, to restrict our processing of that information, or to prevent unauthorized transfers of your personal information to third parties.

You also have the right to file a complaint in relation to our processing of your personal information with a supervisory authority for data protection if we are unable to meet the legally required protection requirements of your personal information, despite our efforts and measures to do so.

If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that to meet our legal obligations.

Your objection or withdrawal of previously given consent could mean that we are unable to perform the actions necessary to achieve the purposes set out above to use your personal information to provide, support or supply related business services.

Please note that even after you have chosen to refrain from processing your personal information or to withdraw your prior consent we may be able to continue to process your personal information to the extent reasonably required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal, financial and regulatory obligations.

To ensure that your personal information is accurate and up to date, please advise us of any changes to your personal information by using our web based protected access or by simply emailing 32Cup with your updated personal information or any requests to change this information.

Data controller responsibility

Our services are provided by 32Cup’ s head office based in Belgium. The company’s central IT applications and servers are in Belgium and controlled by Sucafina SA. Depending on the location where our services are provided, another undertaking or entity within 32Cup’s business units or business partners may be the data controller or processor in relation to your personal data depending on the jurisdiction of the legal parties of a contract or business agreement. For details of the 32Cup and its business partners through which we provide related business services, please consult our website www.32cup.com

Antwerp, 05 October 2018