TATA STEEL NEDERLAND – PRIVACY STATEMENT
Introduction
This privacy statement is intended to explain in a simple and clear way which personal data we collect from you and how we process it. In this privacy statement, "Tata Steel Netherlands", "we", "us" or "our" means Tata Steel Nederland B.V. and all its affiliated subsidiaries.
We retain and process data of various individuals, including our customers, potential customers, individuals who have contacted us with a query or complaint, visitors to our website, individuals who receive our emails and visitors to our premises ("you" or "your"). We take your right to privacy and our statutory obligations in this regard seriously. Your personal data will be kept secure and confidential and will only be processed as set out in this privacy statement.
This privacy statement describes the categories of personal data we process, how your personal data will be processed and how your privacy will be safeguarded during our relationship with you. This statement is only intended to inform you about how Tata Steel Netherlands processes your personal data and does not form part of any agreement with us.
The Tata Steel Netherlands company responsible for processing your personal data is the Tata Steel Netherlands company with whom you have entered into a contract, with whom you are in contact or who you visit, from whom you receive a newsletter or who is responsible for the website you visit. If you have a question about which Tata Steel Netherlands company is responsible for processing your personal data, please send an email to: dataprivacytsn@tatasteeleurope.com.
What personal data does Tata Steel collect?
With a view to providing our products and services, we process various categories of personal data, including:
Contact details. Your name, address, email address and other contact details that you provide to us, for example at events, at trade fairs, when you download or otherwise wish to receive marketing and other information from us (including newsletters) or when you lodge a complaint with us or ask us a question, for example in relation to the environment;
Data about your profession and position (including the industry in which you operate);
Data about your transactions with us (through our websites or otherwise), including data about products or services you purchase from us;
Data about your business or personal interests, as well as questions and complaints and other topics you share with us;
Financial data provided to us (on request or voluntarily) that can be linked to you as a customer, employee or individual, such as bank details or billing information;
Data about your use of our products and services. We collect data relating to your use of our products and services, such as the purchases you make (either online or as part of the sales process), purchase details (type of purchase, method of payment, etc.);
Video footage and visit data. When you enter our premises, we record your visit and use surveillance cameras (CCTV). Video footage may also be taken of you during events and exhibitions we attend and where we make video recordings;
Automatically collected data. While visiting our websites, we automatically collect data through your browser or your device by using cookies and other technologies to track visitors on the website and to collect information about your use of our website. Read our cookie policy if you would like to know more about this;
Other personal data. This includes any personal data that you provide to us in the course of your (contractual) relationship with us, which is both given up voluntarily and on request (including data on satisfaction surveys), as well as personal data that we process in the context of any claims and demands.
If necessary and to the extent permitted by law, we may collect additional data.
Special categories of personal data
We only process special categories of personal data in very exceptional cases, such as unsolicited information you give us about your health.
To the extent permitted by law, we process a limited amount of data relating to criminal offences and proceedings, information on accusations and suspicions of criminal offences, or fraudulent and unlawful acts that we identify (e.g. on our premises or when making a purchase).
How do we collect this data?
We collect and process personal data originating from various sources, but mainly directly from you. This is data that you specifically provide to us, for example when you purchase a product from us, subscribe or unsubscribe to a newsletter by email or provide us with your contact details during an event or trade fair, or, for example, when you contact us by email with questions.
We will inform you when providing your personal data is mandatory and when we need specific data from you in connection with an agreement, the conclusion of an agreement or otherwise. We will also inform you of the consequences of not providing the required data: for example, failure to provide contact details means that we cannot contact you (e.g. to answer your questions) and without your payment details we cannot conduct transactions with you.
In addition to personal data about yourself, you may also provide us with personal data about others, for example alternative contacts within your organisation. Before you provide such personal data to us, you must inform those individuals of the data you intend to provide to us and of the processing of that data by us, as explained in this privacy statement.
What is the purpose and legal basis of data processing?
Your personal data are collected and processed in accordance with applicable laws, such as privacy laws, for various business purposes.
We process your personal data only in accordance with one of the following codified justifications.
The processing is necessary for the performance of an agreement to which you are a party or to take steps at your request to enter into such an agreement. Based on this basis, we process personal data for the following purposes:
Purchase of products/services. When you purchase products or services from us, we process your personal data (such as contact details, details of products and services purchased and financial data) in order to financially or otherwise process your order and deliver the products and perform services, to check creditworthiness, to report the status of your order and to contact you about the transaction.
Answering questions, etc. We may process your personal data to answer your questions and fulfil your requests, when you contact us or otherwise (for example, when you send us questions, suggestions, compliments or complaints, to provide customer support, or when you request other information about our products and services). In doing so, we may process your name, title (business or private), contact details (including your email address, telephone number, name of your company) and any other information you provide to us.
The processing is necessary for the protection of our legitimate interests, unless your interests or fundamental rights and freedoms for which personal data must be protected outweigh our interests. On this basis, we process personal data for the following purposes:
Marketing/surveys. If you are an existing customer, and have not objected to this, we process personal data to approach you for marketing purposes and to keep you informed about our products, services, events, trade shows, etc. We may also ask you to participate in customer satisfaction surveys.
Improving products, services and customer relationship. We may use your personal data to analyse and improve the quality of our products and services, as well as to assist and better understand you as a customer (customer relationship optimisation). We assess what may be of interest to you, measure and rate the effectiveness of ads we show to you and others, which enables us to place and send relevant advertisements. In addition, based on your historical use of our products and services, we send you targeted offers, advertisements or other marketing materials tailored to your personal preferences and experiences.
Security. We process personal data using cameras on our premises (CCTV), as well as by monitoring transaction data, all to protect our rights, privacy, security or property, and/or those of you or others (including our employees).
Business operations. We may process personal data to conduct business transactions, such as a merger, sale, reorganisation or transfer of any of the Tata Steel Netherlands companies (or assets thereof), as well as acquisitions, bankruptcies or similar events.
Establishing, exercising or substantiating a legal claim. We process your data if you submit a claim to us. It may also be the case that we want to file a claim with you. In that case too, we process your data. We do not keep this data longer than necessary (until the claim is settled).
Other purposes. We may process personal data for other legitimate, business purposes permitted in accordance with applicable law.
Processing takes place on the basis of your consent. On this basis, we process personal data for the following purpose:
We may use your personal data to send you marketing communications (such as newsletters, offers, news about products and services) by email or other electronic means, by telephone or by post (such as leaflets). We do so when you have given us your consent to do so. You can withdraw your consent at any time (see below "Your rights").
The processing is necessary to comply with a legal obligation. On this basis, we process personal data for the following purposes:
Personal data may be used by us to comply with legal obligations, such as keeping accurate business records, complying with lawful requests from government bodies and public authorities, as well as complying with applicable laws, regulations and other legal obligations.
The protection is necessary to protect the vital interests of you or other natural persons. On this basis, we process personal data for the following purposes:
We process your data if it is essential for your life or health or that of another person, for example for urgent medical reasons. We will only process your data for the vital interests of another natural person if we cannot base it on any of the other stated purposes.
Retention of personal data
We aim to update personal data as much as possible and delete or anonymise unnecessary data as soon as reasonably possible. However, some personal data may be retained to comply with statutory requirements or for other business interests.
We will not retain your personal data for longer than necessary for the purposes for which it was collected. This will usually be for the duration of your relationship with us, plus the length of a statutory defined period after the end of that relationship. However, some data may need to be retained longer. For example, we retain certain specific data, such as transaction data and product warranties, for different periods as prescribed by applicable law.
We apply a data retention policy. If your personal data is no longer needed, we will ensure that it is securely deleted or anonymised.
Access to data
We will ensure that our employees, suppliers and subcontractors only have access to your data when it is part of their duties, and then only for the purposes described in this privacy statement.
Within Tata Steel Netherlands, your personal data, as described in this privacy statement, will be shared between the responsible Tata Steel Netherlands companies for internal administrative purposes, management purposes, analytical purposes and other business-related purposes.
Your personal data are also accessible by third parties with whom we work, as well as their affiliated companies and subcontractors. They provide us with services such as hosting, support and maintenance of overarching information systems. Personal data is also exchanged with certain interconnected systems, such as content management systems for websites. Data contained in such systems may be accessible by the providers of those systems, their affiliated companies and subcontractors.
Other examples of third parties with whom your data is shared include Tata Steel Netherlands' insurers, IT administrators, lawyers, accountants, investors, consultants and other professional advisers, and service providers such as our email service providers and web analytics companies. Tata Steel Netherlands expects such third parties to process any data provided to them in accordance with applicable privacy law, including the security and confidentiality prescribed therein, and other contractual arrangements agreed with us.
Where a third party acts as a "data processor" (e.g., our email service provider), it will perform tasks on our behalf and in accordance with our instructions in relation to the purposes set out in this privacy statement. Your personal data will be shared with these parties only to the extent necessary for the relevant service and will not be used by these parties for their own purposes.
In addition, your personal data may be shared with third parties:
to the extent required by law (e.g. to the Tax and Customs Administration or regulators);
in connection with possible or already ongoing legal proceedings, in order to establish, exercise or substantiate our statutory rights;
in connection with the possible or actual sale of companies or assets. In that case, your data will be shared with the potential or actual buyer and relevant professional advisers; or
with your explicit consent.
Data protection
Tata Steel Netherlands is responsible for the security of the personal data you provide to us. We have taken technical, physical and organisational measures to ensure an appropriate level of security.
However, sending information via the Internet inevitably entails security risks. Therefore, we cannot guarantee its security in this respect.
Transfer of personal data
If the Tata Steel Netherlands company responsible for processing your personal data is based within the European Union, in most cases your personal data will be processed within the European Union. Keep in mind, however, that Tata Steel Netherlands also has companies and uses external service providers based outside the European Union. As a result, it may be necessary for us to process your personal data outside the European Union. In such cases, we will put in place adequate safeguards (and, where necessary, additional measures) to ensure that your personal data is afforded a level of protection equivalent to that guaranteed within the European Union, such as entering into European Commission-approved standard contractual clauses with the recipients of your data.
Where the Tata Steel Netherlands company responsible for processing your personal data is located outside the European Union, in all cases of international transfer of personal data, we will put in place adequate safeguards to comply with applicable laws of transfer and to ensure the security of your personal data.
Where documented, you may request the measures taken by us to protect your personal data and to ensure the correct transfer of your personal data by sending an email to dataprivacytsn@tatasteeleurope.com. However, certain details may have been omitted for confidentiality reasons.
Third-party websites
Occasionally, we post links to external websites that are relevant to our industry or that we believe are useful to the user. Although we select these links very carefully, they are provided solely for the convenience of the user, and we, or any other Tata Steel Netherlands Group company, do not guarantee the content and privacy policies of the relevant site, nor the products or services offered to that effect.
Your rights
Right to access, correct and delete your personal data
Tata Steel Netherlands aims to ensure that all personal data processed by us is correct. We therefore ask you to inform us if your personal data needs to be amended through your usual point of contact within Tata Steel Netherlands or via the contact details at the bottom of this privacy statement.
You have the right to access all personal data that Tata Steel Netherlands retains from you and you can request us to make a correction if your data is not correct or not correct any longer. In addition, you have the right to request us to delete unnecessary data that we retain from you.
In addition, you have the following rights:
Rights to data portability – if we use your consent or the fact that processing is necessary for the performance of an agreement as the legal basis for processing and if the personal data is processed by automated means, you have the right to request all the personal data you have provided to Tata Steel Netherlands in a structured, common and machine-readable form and also to request us to transfer this data to another data controller if this is technically possible.
Right to restrict processing – you have the right to restrict the processing of your personal data if:
you contest the accuracy of the personal data for a period that allows us to verify the accuracy of the data;
if the processing is unlawful, but you do not want us to delete the data;
if we no longer need the personal data, but you need them for the establishment, exercise or defence of legal claims; or
you have objected to processing based on the protection of our legitimate interests (see below) pending the answer to whether your objection is well-founded.
If personal data is subject to such restrictions, we will only process it with your consent, for the establishment, exercise or substantiation of a legal claim or to protect the rights of another (legal) person.
Right to withdraw your consent - if we use your consent as the legal basis for processing your data, you have the right to withdraw that consent at any time. You can do so by contacting us at the email address below, or in some cases by using a specific withdrawal mechanism, such as for deletion of cookies (see our cookie policy for more information).
Right to object to processing based on legitimate interests – if we use the pursuit of our legitimate interests as the legal basis for processing your data, you have the right to object to such processing. If you object, we must stop such processing unless we invoke compelling legitimate grounds for the processing which outweigh your interests, rights and freedoms, or if we need to process the data for the establishment, exercise or vindication of legal claims. If we use a legitimate interest as a ground for processing, we are satisfied that we can demonstrate such compelling justification for processing, but we will assess each case individually.
You also have the right to lodge a complaint with the supervisory authority if you believe that the processing of your personal data is not carried out in accordance with applicable privacy laws.
For more information regarding your rights, or if you wish to exercise them, contact us by sending an email to dataprivacytsn@tatasteeleurope.com.
Other privacy statements
We may process data to which a different privacy statement applies. In that case, we will inform you accordingly.
Changes
We may change or update this privacy statement at any time. In that case, we will place the new version on our website. You are therefore advised to consult this page regularly so you are always aware of the most recent changes.
This privacy statement was last updated and checked on 12 May 2023.
Contacting us
If you have any questions or complaints about this privacy statement or the way we handle your personal data, if you want to exercise your rights or if you request an overview of which Tata Steel Netherlands company is responsible for processing your personal data, please contact us. You can do so by post and email.
Post
You can write to:
Legal Compliance Department
Tata Steel Netherlands
Wenckebachstraat 1
1951 JZ Velsen-Noord
Email:
EN-Legal Notice-Sales and Purchasing Conditions TSE
Standard Terms and Conditions for Sales for Tata Steel Europe Limited
EN-Legal Notice-Entities TSE
Read more about details of certain entities within the Tata Steel Europe Limited group of companies