Privacy Notice

ACT Commodities

This is the Privacy Statement of ACT Commodities Group B.V., established at Strawinsklylaan 3127 (1077 ZX) in Amsterdam, the Netherlands. ACT Commodities Group B.V. is also the controller in respect of the processing of personal data by its affiliates and subsidiaries, which are also established at the above address. The companies are hereinafter jointly referred to as: “ACT Commodities”; personal data is shared between these group companies. This Privacy Statement sets out how we handle personal data, which we do with all possible care. This Privacy Notice applies to the processing of personal data of our clients, prospective clients, applicants, and other people who visit our website or contact us. If, after reading this Privacy Notice, you have any questions about how we handle your personal data, or if you wish to exercise your rights under the General Data Protection Regulation (“GDPR”) mentioned in this Privacy Statement, or under any other data protection legislation, or if you wish to make a complaint about our use of your personal data, you may contact us at telephone number +31(0)20-2199268 or by email at HStrikwerda@actcommodities.com. If you are not satisfied with the way we have handled your complaint, or if you prefer not to make your complaint to us, you may also submit a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens), via the website autoriteitpersoonsgegevens.nl. Which personal data do we process, for what purpose and on what legal basis? Personal data of (contacts at) clients We process the contact details (name, company name, phone number, email) of our contacts at our clients to execute orders for our clients, and to contact these people in the context thereof. We also use these details to bill our activities. The legal basis for this is that the data are necessary to perform the contract concluded with the client. We also use the clients’ contact details in connection with relationship management, for instance, to send Christmas cards or birthday wishes. For this purpose, we may also process the date of birth of our clients’ contact persons. This processing is necessary in view of ACT Commodities’ legitimate interest to maintain a good relationship with its clients. Finally, we use the clients’ contact details to conduct customer satisfaction surveys from time to time. Naturally, clients are not obliged to participate in such surveys. This processing is necessary in view of ACT Commodities’ legitimate interest to improve its services. Recording conversations in the trading room We record telephone conversations made in the trading room and made by the operations team of our Fuels department with contacts of clients in order to register proof of trades and to improve our services. This processing is necessary in view of ACT Commodities’ legitimate interest to be able to prove that an order was given for the transaction and to ensure the transparency of our communication with the clients. Personal data of prospects We process the contact details (name, company name, telephone number, email) of contacts at prospective and former clients to contact them in order to offer our services to them, and to send them holiday wishes. We process this personal data in view of our legitimate interest to perform our activities and to obtain new orders. We do not send unsolicited commercial communications by email without the explicit consent of the intended recipient. Contact If we are contacted via the contact form on our website, by email, social media or telephone, we process the data that is provided to us. This typically includes the name, email and telephone number and the content of the contact (e.g. a question). We use this information, where relevant, to contact the person concerned, for instance to answer a question. We may add this data to our prospects’ files (please see above). We process this personal data in view of our legitimate interest to perform our activities and to obtain new orders. Recruitment and application procedures We process the personal data provided to us by prospective employees or obtained from a recruitment agency or via Linkedin. This may include name, address, email, telephone number, CV and all information it contains (including information about education and previous experience) and information posted on Linkedin. If an applicant is invited for an interview, we process, in addition to the information mentioned above, all other information the applicant provides us with. This may include information about education, work experience and references. For the purpose of the second round of the application procedure we may process data from a personality test, and data concerning motivation, talent and competences in order to decide whether the applicant would fit in with the organization. During the final phase of the application procedure, we may instruct an external agency to screen the applicant within the context of an integrity review. Obtaining a Certificate of Conduct (Verklaring Omtrent het Gedrag) is part of this screening. We only conduct the screening if this is necessary for the position concerned. The screening is highly secure and is conducted with all possible care and consideration. The legal basis for processing personal data within the context of recruitment and application procedures is that this processing is a necessary step to enter into an agreement, and in view of ACT Commodities’ legitimate interest to recruit and hire new staff. Visitors of the website Finally, we process information about the visitors of our website (or rather about their computer), by placing cookies every time they visit our website. The legal basis for this is the consent we ask each visitor upon their first visit to our website. You may withdraw this consent at any time. Please see our cookie statement for more information about the cookies we place. How long do we keep your personal data? Personal data of clients and their contacts As a rule, we keep the personal data of our contact persons at clients for two years after the final transaction with that client is completed. We keep our administration, including invoices and other documents that include the personal data of parties, for a period of seven years after the end of the financial year, in order to comply with our statutory retention obligation for tax purposes. Recordings of conversations in the trading room The recordings of conversations in the trading room are kept until the information is no longer required, usually once the trades are closed. Personal data of prospects The personal data of prospects is deleted at the request of the data subject, or ultimately one year after the final communication with the person concerned. Other contact details We keep other contact details for one year after the final contact, or until you submit a request to us to delete them. Recruitment and application procedures Information about applicants that are not hired are kept for a period of one year after the end of the application procedure. This term is necessary for us to evaluate the applicant’s application, to create a talent pool which is of great value to us and to possibly contact the applicant about future opportunities consistent with this policy and the expressed With whom do we share your data? We share personal data with other group companies. Where necessary, we may also share personal data with our sister company Act Commodities in New York. We have concluded a model agreement with our sister company based on the standard contract clauses approved by the European Commission in Commission Decision of 15 June 2001 (2001/497/EC). Personal data is stored electronically and may be included in emails we send or receive and is consequently stored (and processed) by our ICT providers. We have concluded data processing agreements with these providers that stipulate at least the same level of security and reliability that you may expect from ourselves. Our accountant may have access to the personal data of contact persons at clients. We may also share this data with firms that conduct customer satisfaction surveys for us. We may also share the data of contact persons at clients with third parties where this is necessary in order to execute your order. We may for instance share your data with sellers and regulators. Recruitment and application data is stored in our recruitment software from Greenhouse Software, Inc., a cloud services provider located in the United States of America and engaged by ACT to help manage its recruitment and hiring process on ACT’s behalf. Accordingly, if the applicant is located outside of the United States, the personal data will be transferred to the United States. We have concluded a data processing agreement with that party. Because the European Union Commission has determined that United States data privacy laws do not ensure an adequate level of protection for personal data collected from EU data subjects, the transfer will be subject to appropriate additional safeguards under the standard contractual clauses. When an applicant proceeds to the next phase in the application procedure, his/her personal data may also be shared with an assessment agency and if necessary, and in consultation, with CV-OK, the agency that conducts screenings for us. CV-OK has a license from the Dutch Data Protection Authority. The data collected via cookies is processed by the providers of those cookies. Please see our cookie statement for more information. Apart from the situations mentioned above, we do not share personal data with third parties, unless we are obliged to provide certain data under the applicable laws or regulations, for instance to the police under a warrant. How is your data protected? We have adopted a strict security policy, including appropriate technical and organizational measurements, to protect your personal data against loss, abuse and unauthorised access by third parties. We apply strict access authorisation, both offline and online, and our servers are regularly backed up, and our connections are secure. Our servers are installed in the Netherlands. What are your rights? You have the following rights: - the right to access your personal data and to receive a copy thereof. - the right to have your personal data rectified if they are incorrect or incomplete. - the right to object to the processing and/or (in certain circumstances) to restrict the processing of your personal data. - in certain circumstances, the right to have your personal data erased (‘right to be forgotten’). - the right to receive your personal data in a structured, commonly used and machine-readable form and to transmit that data to another controller. For more information about these rights and when you may exercise them, see Articles 15 – 20 of the GDPR. You may exercise your rights by contacting us via the email or telephone number mentioned at the beginning of this Privacy Statement. Changes Sometimes changes may occur in the personal data we process or in the applicable legislation. In that event we may amend this Privacy Notice. In the event of major changes, we will post an announcement on the website or inform you of those changes by email. Version January 2022

Cookie Statement ACT Commodities

In this statement we tell you which cookies are placed via the website actcommodities.com. ACT Commodities Group B.V., established at Strawinsklylaan 3127 (1077 ZX) in Amsterdam, the Netherlands (“ACT Commodities”) is the party responsible for placing cookies.

What are cookies?

We make use of cookies on this website. A cookie is a small file that is transmitted together with the pages of this website and stored by your browser on your computer, telephone or other device. The information it contains may be sent back to our servers the next time you visit our website.

About cookie consent

We want to provide you, as visitor to our website, with the best possible user experience. For this purpose, we make use of cookies. Below we tell you which cookies these are. We always place essential cookies and cookies from Google Analytics. For all other cookies, we ask for your consent. If you do not want your data to be stored through these cookies, you may simply click on ‘no, rather not’ in the cookie banner.

Which cookies do we place?

We place the following cookies:

  • essential cookies: Google Tag Manager and Wordpress multilingual plugin

  • analytical cookies: Google Analytics, Hotjar, LinkedIn Analysis

  • ad/tracking cookies: LinkedIn Ads, Facebook Custom Audience, DoubleClick

  • social media cookies: Facebook Connect [youtube?]

Essential cookies

ACT Commodities makes use of essential cookies to remember your settings and preferences. These are Google Tag Manager and Wordpress multilingual plugin. We always place these cookies.

Analytical cookies

We use analytical cookies to monitor and analyse the use and performance of our website.

Google Analytics

We use Google Analytics cookies and anonymise the information measured by it. Your IP address is stored anonymously and the last octet of the IP-address is masked. We do not share data with Google and are not using other Google services in combination with the Google Analytics cookie. We always place this cookie.

Hotjar

We also make use of Hotjar cookies in order to know which sections of our website are accessed and which links are clicked. With the help of the information collected by these cookies we are able to analyse what takes place on the website. This helps us to improve the website. This cookie is placed during each visit to a page containing the Hotjar code. The cookie contains a unique identifier (UUID) that makes it possible to track the same visitor over several pages and sessions. For more information please see the Hotjar privacy statement. We only place this cookie if you have given your consent.

LinkedIn Analytics

We also make use of LinkedIn analytics to compile user statistics and to understand how visitors (either from LinkedIn or elsewhere) use our website.We only place this cookie if you have given your consent.

Social media cookies

Our website contains buttons with which web pages may be liked or shared on social media platforms like Facebook and LinkedIn. These buttons operate by means of tiny codes provided by Facebook and LinkedIn. Cookies are placed by means of these codes. Please see the privacy notices of Facebook and LinkedIn (which are subject to change) if you would like to know more about what they do with your (personal) data they process via these cookies. The collected information is made anonymous to all possible extent and transferred to and stored by Facebook and LinkedIn.

Ad/tracking cookies

With your consent, tracking cookies are placed by our website that are used for advertising purposes. These cookies collect information about your browsing activities. Based on this information a profile is compiled that allows personalised ads to be shown to you, based on your preferences. These cookies are provided by third parties, who thereby gain insight in the websites you have visited (or rather which websites are visited using your device). This information is not only collected on our website, but on other websites as well. The profile compiled on the basis of your browsing activities is not linked to your name, address or email but is solely used to adapt ads to your profile in order to make them as relevant to you as possible. The following tracking cookies are placed:

LinkedIn Ads

This cookie stores such information as which LinkedIn users visit the website, which pages they visit, etc. In addition, the behaviour of these users is tracked after they see or click on a LinkedIn ad. In this manner LinkedIn assesses the efficacy of its ads. The pixel allows us to show visitors to our website an ad on the LinkedIn platform.

For more information about what LinkedIn does with your (personal) data obtained via these cookies, please see the LinkedIn Privacy Notice (which is subject to change).

Facebook Custom Audience

The Facebook Custom Audience cookie allows us to show you personalised ads and show visitors to our website an ad on Facebook.For more information about what Facebook does with your (personal) data obtained via these cookies, please see the Facebook Privacy Notice (which is subject to change).

Double Click

Finally, we place Double Click cookies. Double Click is a cookie offered by Google that ensures that you do not repeatedly get to see the same ad. For more information about what happens with your (personal) data obtained via these cookies, please see the Google Privacy Notice (which is subject to change).

Deactivate or block cookies?

We always ask your consent before we place cookies (with the exception of essential cookies and the Google Analytics cookie, which we always place). If you wish to withdraw your consent, please check the help function of your browser, or read the explanation by clicking on the browser that you use below:

Pursuant to the General Data Protection Regulation you have several rights regarding your personal data that we collect. Please see our Privacy Statement for more information about your rights and how you may exercise them.