Effective date : 15/09/2022
1. Introduction
The aim of this privacy policy is to introduce the rules related to the protection of personal data that OriginFood ltd. (hereinafter « OriginFood ») commits to respect as data controller and data processor. These rules were drafted following the application of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation, hereinafter « GDPR ») on the protection of individuals with regards to processing of personal data and on the free movement of such data, and repealing Directive 95/46/CE.
This document is likely to evolve, where necessary in order to implement the obligations imposed by the legislation on personal data protection.
The notions concerning personal data protection used in this document have the meaning given in the GDPR, notably in accordance with Article 4 of the GDPR.
2. General principles on personal data protection
When OriginFood acts as data controller
According to Article 5 of the GDPR, OriginFood ensures that personal data are:
- processed fairly and lawfully
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes
- adequate, relevant and not excessive in relation to the purposes for which they are collected and processed
- accurate and, where necessary, kept up to date
- kept for no longer than is necessary for the purposes for which the data were collected
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.
When OriginFood acts as data processor
According to Article 28 of the GDPR, OriginFood ensures that:
- the purposes of the processing of data are described in the contract signed between OriginFood and the client
- the client’s personal data are processed for the purpose for which they were originally collected and is solely acting on its instructions in accordance with the terms of the contract
- the deletion of personal data is carried on under the conditions laid down in the contract, unless the applicable law requires the preservation of personal data
3. Purpose and legal basis of personal data processing
When OriginFood acts as data controller
For internal needs, OriginFood collects personal data for purposes such as:
- management of customer and prospects contact (i.e. send marketing or product information, respond to customer requests, assess the needs of your business to determine suitable products)
- management of commercial contracts (i.e. fulfill order, billing, debt covering)
- management of OriginFood’s staff, recruitment and careers (i.e. evaluate and contact the candidate)
- creation and administration of user accounts
- development and management of services to which the client subscribed (records of call(s) to support service)
Depending on these different purposes, OriginFood ensures that at least one of the following applies:
- the data subject has given consent to the processing of his or her personal data for one or more specific purposes
- processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering a contract
- processing is necessary for compliance with a legal obligation to which OriginFood is subject
- processing is necessary in order to protect the vital interests of a natural person
- processing is necessary for the purposes of the legitimate interests pursued by OriginFood except where such interests are overridden by the interests for fundamental rights and freedoms of the data subject
When OriginFood acts as data processor
It may be necessary for OriginFood to access and process personal data provided by its clients within the framework of completion of offers and services to which the customer subscribes.
The access and processing are organized by a contract containing specific clauses for data protection signed between OriginFood and the client. OriginFood processes personal data only on behalf of the client in accordance with the provisions of the contract.
4. Contact
If you have any inquiries regarding this privacy policy, please send us a message using the contact form