PRIVACY POLICY
Updated August 2, 2023

1. Parties and Purpose

Disgrobel Foods & Beverages Partners BV SRL (hereinafter " Disgrobel " or the " Data Controller ")
Oude Lindestraat 21. 1800 Vilvoorde
BCE / VAT: BE0819390078
Mail: admin@disgrobel.com
Telephone: +32(0)2 318 13 07.

Disgrobel Foods & Beverages Partners has established this Privacy Policy in order to transparently inform Users of the website hosted at the following address: www.disgrobel.shop, (hereinafter the " Site "), of the manner in which personal data is collected and processed by Disgrobel Foods & Beverages Partners.

The term " User " refers to any individual or legal entity who visits or interacts in any way with the Site.

As such, Disgrobel Foods & Beverages Partners determines all the technical, legal and organizational means and purposes of processing Users' personal data. To this end, Disgrobel Foods & Beverages Partners undertakes to take all necessary measures to ensure that personal data is processed in accordance with the Law of July 30, 2018, on the protection of individuals with regard to the processing of personal data (hereinafter, "the Law" ) and the European Regulation of April 26, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter, "the Regulation " ).

Disgrobel Foods & Beverages Partners is free to choose any individual or legal entity that processes users' personal data at its request and on its behalf (hereinafter the " Processor"). Where applicable, Disgrobel Foods & Beverages Partners undertakes to select a Subcontractor offering sufficient guarantees with regard to technical and organizational security measures for the processing of personal data, in compliance with the Law and the Regulation.

2. Personal data processing

The use of the Site by Users may entail the communication of personal data. The processing of such data by Disgrobel Foods & Beverages Partners , in its capacity as Data Controller, or by service providers acting in the name and on behalf of Disgrobel Foods & Beverages Partners , will comply with the Law and the Regulation.

Personal data will be processed by Disgrobel Foods & Beverages Partners, in accordance with the purposes set out below, via :

Contact form; e-mail, commercial prospecting.

3. Purpose of personal data processing

In accordance with Article 13 of the Regulation, the purposes for which personal data is processed are communicated to the User and are as follows:

Handle requests related to Human Resources activities (CVs, cover letters, candidate information). Respond to commercial activities (requests for quotes, company support, etc.). Organize requests from subcontractors or suppliers.

4. Personal data likely to be processed

By visiting and using the Site, the User consents to Disgrobel Foods & Beverages Partners collecting and processing the following personal data in accordance with the terms and principles described in this Privacy Policy:

Contact details recorded in the search form. Anonymized information on site navigation and geolocation.

5. Consent

By accessing and using the Site, the User declares that he/she is aware of and gives his/her free, specific, informed and unequivocal consent to the processing of his/her personal data. This agreement covers the content of the present Privacy Policy.

Consent is given by the positive act by which the User has checked the box proposing the Privacy Policy as a hyperlink. This consent is an indispensable condition for carrying out certain operations on the Site or for allowing the User to enter into a contractual relationship with Disgrobel Foods & Beverages Partners. Any contract between Disgrobel Foods & Beverages Partners and a User concerning the services and goods offered on the Site is subject to the User's acceptance of the Privacy Policy.

The User consents to the processing and collection by the Data Controller, in accordance with the terms and principles set forth in this Privacy Policy, of the personal data that the User communicates on the Site or in connection with the services offered by Disgrobel Foods & Beverages Partners , for the purposes indicated above.

The User has the right to withdraw consent at any time. Withdrawal of consent does not compromise the lawfulness of processing based on consent previously given.

6. Retention period for Users' personal data

In accordance with article 13 §2 of the Regulation and the Law, the Data Controller only keeps personal data for as long as is reasonably necessary to achieve the purposes for which it is processed.

This period is in all cases less than: maximum 3 years

7. Data recipients and disclosure to third parties

Personal data may be passed on to Disgrobel Foods & Beverages Partners' employees, collaborators, subcontractors or suppliers who offer adequate data security guarantees, and who collaborate with Disgrobel Foods & Beverages Partners in the marketing of products or the provision of services. They act under the direct authority of Disgrobel, and are in particular responsible for collecting, processing or subcontracting such data.

In all cases, the recipients of the data and those to whom the data has been disclosed comply with the contents of this Privacy Policy. Disgrobel Foods & Beverages Partners assures you that they will process your data only for the purposes intended, in a discreet and secure manner.

In the event that data is disclosed to third parties for direct marketing or prospecting purposes, the User will be informed in advance so that he/she may express his/her consent to the use of such personal data.

8. User rights

At any time, the User may exercise his rights by sending a message by e-mail to the following address: admin@disgrobel.com, or a letter by post addressed, enclosing a copy of his identity card to the following address: Oude Lindestraat 21. 1800 Vilvoorde

8.1. Right of access

In accordance with Article 15 of the Regulation, Disgrobel Foods & Beverages Partners guarantees the User's right of access to his/her personal data. The User has the right to obtain access to said personal data as well as the following information:

• Purposes of processing ;
• Categories of personal data concerned ;
• The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients established in third countries or international organizations;
• Where possible, the intended retention period for personal data or, where this is not possible, the criteria used to determine this period;
• The existence of automated decision-making, including profiling, as referred to in Article 22(1) and (4) of the Regulation, and, at least in such cases, useful information regarding the underlying logic, as well as the significance and intended consequences of such processing for the data subject

The Data Controller may charge a reasonable fee based on administrative costs for any additional copies requested by the User.

Where the User submits such a request electronically (via e-mail address, for example), the information is provided in a commonly used electronic form, unless the User requests otherwise.

The User will be sent a copy of his or her data no later than one month after receipt of the request.

8.2. Right of rectification

Disgrobel Foods & Beverages Partners guarantees the user the right to rectify and delete personal data.

In accordance with Article 16 of the Regulation, incorrect, inaccurate or irrelevant data may be corrected or deleted at any time. The User shall first make the necessary changes himself/herself from his/her user/other account, unless they cannot be made autonomously, in which case the request may be made to Disgrobel Foods & Beverages Partners .

In accordance with Article 19 of the Regulation, the Data Controller shall notify each recipient to whom personal data has been communicated of any rectification of personal data, unless such communication proves impossible or would require disproportionate effort. The Data Controller shall provide the data subject with information about such recipients if the data subject so requests.

8.3. Right to erasure

The User has the right to obtain the deletion of his personal data as soon as possible in the cases listed in Article 17 of the Regulation.

Where the Controller has made the personal data public and is required to erase it pursuant to the preceding paragraph, the Controller shall, taking into account available technology and implementation costs, take reasonable steps, including technical steps, to inform other controllers who process such personal data that the data subject has requested the erasure by such controllers of any links to, or copies or reproductions of, such personal data.

The two preceding paragraphs do not apply insofar as such processing is necessary:

• the exercise of the right to freedom of expression and information;
• to comply with a legal obligation to process that is laid down by Union law or by the law of the Member State to which the controller is subject, or to perform a task carried out in the public interest or in the exercise of official authority vested in the controller;
• the establishment, exercise or defense of legal claims.

In accordance with Article 19 of the Regulation, the Controller shall notify each recipient to whom personal data has been communicated of any erasure of personal data or restriction of processing carried out, unless such communication proves impossible or requires disproportionate efforts. The data controller shall provide the data subject with information on these recipients upon request.

8.4. Right to limit processing

The User has the right to obtain the limitation of the processing of his/her personal data in the cases listed in Article 19 of the Regulation.

In accordance with Article 19 of the Regulation, the Data Controller shall notify each recipient to whom personal data has been communicated of any restriction on the processing carried out, unless such communication proves impossible or requires disproportionate efforts. The Data Controller shall provide the data subject with information about such recipients if the data subject so requests.

8.5. Right to data portability

In accordance with Article 20 of the Regulation, Users have the right to receive from Disgrobel Foods & Beverages Partners personal data concerning them in a structured, commonly used and machine-readable format. Users have the right to transfer this data to another data controller without Disgrobel Foods & Beverages Partners being able to prevent this in the cases provided for by the Regulation.

Where the User exercises her right to data portability pursuant to the preceding paragraph, she has the right to obtain that personal data be transmitted directly from one data controller to another, where technically possible.

The exercise of the right to data portability is without prejudice to the right to erasure. This right does not apply to processing that is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

The right to data portability does not affect the rights and freedoms of third parties.

8.6. Right to object and automated individual decision-making

The User has the right at any time to object to the processing of his/her personal data due to his/her particular situation, including the automation of data carried out by Disgrobel Foods & Beverages Partners . In accordance with Article 21 of the Regulation, Disgrobel Foods & Beverages Partner will no longer process personal data unless there are compelling legitimate grounds for the processing which override the interests and rights and freedoms of the User, or for the establishment, exercise or defence of legal claims.

Where personal data is processed for canvassing purposes, the User has the right to object at any time to the processing of his/her personal data for such canvassing purposes, including profiling insofar as it is linked to such canvassing.

If the data subject objects to the processing for canvassing purposes, the personal data will no longer be processed for these purposes.

8.7. Right of complaint

The User has the right to lodge a complaint concerning the processing of his/her personal data by Disgrobel Foods & Beverages Partners with the Belgian Data Protection Authority. Further information can be found on the website: https://www.autoriteprotectiondonnees.be.

Complaints can be submitted to the following addresses:

Data Protection Authority
Rue de la Presse 35, 1000 Brussels
Tel. + 32 2 274 48 00
Fax. + 32 2 274 48 35
E-mail: contact@apd-gba.be

The User may also lodge a complaint with the court of first instance in his place of residence.