Business Activities, Marketing Activities, Customer Service and Support
In addition to this Policy, please note that privacy statements, terms or notices might be provided to you, and shall be deemed as part of this Policy.
This Policy was last updated on 4 November 2020.
Type of information we collect
Depending on the Service (as defined below) we provide, we may collect the following information about you:
- Personal details and contact details: contact details (such as your first name, maiden name, last name, email address, postal address, phone number), account login credentials (such as user names and passwords, password hints and similar security information or other identifiers), footage of you or your vehicle when you visit us (for example, if you are recorded on CCTV while visiting our offices or production sites, or you give us the registration details of your vehicle).
- Work related information: such as your employer and/or department, your job function, your connection to us (e.g. customer, dealership, supplier), work address, work telephone number and work email address.
- Financial data: payment information (such as billing address, postal address, bank account, credit or debit card number and other payment method details, including details about payments to and from you and other details connected to the Services (as defined herein) you have received from us);
- User profile data: comments, feedback and other information you provide to us, or that we obtain in relation with Marketing Activities and/or Customer Service and Support (as defined hereunder), including when you use our Communication Technologies (as defined hereunder). This kind of information may include details of ANA products purchased by you or for you, machinery details (such as baler make and model), date of baling and the like.
- Communications preferences: your preferences in receiving marketing information from us and your communication preferences (including preferred language). This may include information about events to which you are invited by us or would like to be invited, to the extent that this information is relevant to organizing and managing those events.
- Automatically collected information: including information about (i) Internet protocol (IP) address used to connect your device to the Internet, (ii) your login information, browser type and version, time zone setting, operating system and platform; (iii) your visit to our Communication Technologies (as defined below), including the full URL, clickstream to, through and from our Websites’ (including date and time), services viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from a page.
When using ANA’s mobile applications, we may collect location information which provides your real-time location in order to deliver content or other Services that are dependent on knowing where you are. Delivery of location services will involve the coordinates (latitude/longitude) of your device location.
How we collect the information
We may collect your Personal Data (either obtained directly from you or from somewhere else as described hereafter), if and while:
- you visit or use ANA’s Websites (“Websites“), ANA’s mobile applications (“Apps“), social media accounts (such as but not limited to, ANA’s Facebook page, YouTube channel, Instagram account, LinkedIn page, etc.) (“Social Media“), or other technologies providing information in relation with ANA, suggesting services or enabling communication with ANA (“Communication Technologies“).
- you enquire about a Service, place a service request or purchase order, enter or participate a survey and/or field experiment, or contact us to report a problem and/or receive any Service in connection with our products, including through any of the Communication Technologies (“Customer Service and Support“);
- you or the organization you are employed by or affiliated with (as consultant, service provider, sub-contractor or otherwise) is engaged in any kind of business activity or relation with ANA (“Business Activities“).
Each of the above shall be defined together and separately under this Policy as “Service”.
Personal Data which is not collected directly from you, may be collected from:
- Your organization or an organization you are affiliated with regarding work related information (as described above).
- Other sources, such as third parties with whom we work closely, including but not limited to business partners (such as OEM’s and OEM dealers), sub-contractors that provide ANA with technical, payment/collection/insurance or delivery/transportation services, analytics providers and search information providers;
- Governmental bodies, regulators, courts or any other similar establishments;
- Communication Technologies operated by us which you use, including Websites or Apps;
- Social Media when you grant permission to the Service to access your data on one or more networks including via plugins such as YouTube, Google+, Pinterest and the Facebook, Inc. Like-Button to make our service more attractive for you.
For further information about social plugins please click here.
- When you use our App, service providers that help us determine a location in order to customize certain products to your location;
ANA owns or administers the Service and is the primary controller of the Personal Data provided by you or on behalf of you, or collected by ANA or anyone on its behalf for the Service, as the term “controller” is defined within the meaning of data protection laws.
How We use your information:
The Personal Data is processed for the following purposes and legal grounds basis for processing. Where applicable, we will point out, at the time of the data collection, if the provision of the Personal Data is a statutory or contractual requirement and whether you are obliged to provide the Personal Data and the possible consequences of failure to provide such data:
Lawful basis for processing
Customer Service and Support, which also includes providing requested products and Service such as product delivery, maintenance, customer and product support (including warranty service), and use of our Communication Technologies.
(1) Performance of a contract with you, or to take steps prior to entering into a contract with us; (2) Comply with a legal or statutory obligation applicable to us (e.g., product safety; recalls); (3) processing is necessary for the purposes of ANA legitimate interests in providing you with customer service, providing product and customer support, identifying and detecting issues with existing products and services, understanding how our products and services are used, analyzing advertising effectiveness, conducting research, improving products and services, developing new products and services, providing training and other educational events, and communicating relevant information about product updates and improvements (to the extent that such legitimate interests are not overridden by your interests or fundamental rights and freedoms); or (4) processing is with your consent.
Marketing Activities and specifically communications and offers of products and/or services by ANA, including offers based on your interests, personal and business characteristics, and location. We may provide these communications via email, postal mail, online (including providing advertising and content personalized to you), Social Media platforms, text message, push notifications, and other means.
(1) ANA legitimate interests in conducting marketing, prospecting, and obtaining new customers, getting to know preferences to better personalize offers, and to offer products and services that meet a (prospective) customer’s needs (to the extent that such legitimate interests is not overridden by your interests or fundamental rights and freedoms); or (2) processing is with your consent.
Marketing Activities and specifically administering contests and/or campaigns, and other promotional events for which you sign up or enter, such as scheduling and arranging tours to ANA’s facilities, or participating in product introductions and trade shows.
(1) Performance of a contract with you, or taking steps prior to entering into a contract with us; (2) processing is necessary for the purposes of ANA’s legitimate interests in providing marketing, prospecting, and servicing and obtaining (prospective) customers (to the extent that such legitimate interests is not overridden by your interests or fundamental rights and freedoms); or (3) processing is with your consent.
Marketing Activities and specifically providing you with other information that may be of interest, such as announcements, reminders, product improvement and technical service bulletins; news about ANA; Crop Packaging Association (“CPA”) magazines or newsletters; and product catalogs;
(1) Performance of a contract with you, or to take steps prior to entering into a contract with us; (2) processing is necessary for the purposes of ANA legitimate interests in marketing, prospecting, obtaining new customers, and servicing and communicating news to (prospective) customers such as product updates and improvements and other information about products and services (to the extent that such legitimate interests is not overridden by your interests or fundamental rights and freedoms); or (3) processing is with your consent.
Business Operations by means of managing the day-to-day operations of ANA, for data analysis to report on business performance, and for corporate governance (including audit(s), compliance controls and other risk management activities, including procurement of insurance).
(1) legal obligations applicable to us; or (2) it is necessary for purposes of ANA’s legitimate interests to manage and operate the day-to-day operation of ANA, manage financial affairs of ANA, manage risks to which ANA is exposed, and as part of a corporate transaction, such as a transfer of assets to or an acquisition by or merger with another company.
Legal compliance and/or proceedings in order to comply with applicable laws and regulations; and establishing, exercising, and defending legal rights.
1) comply with legal obligations applicable to us; or (2) it is necessary for purposes of ANA’s legitimate interests to manage and operate the day-to-day operation of the business, manage financial affairs of our business, to manage risks to which our business is exposed, corporate and information governance, and compliance with non-EU laws and laws of other countries in which ANA may operate (to the extent that such legitimate interest is not overridden by your interests or fundamental rights and freedoms).
Sharing of your information
We may share your Personal Data with:
- Our Group Companies: Any member of our Group companies who support our processing of Personal Data under this Policy.
- We might disclose your Personal Data if we have a good faith belief that such disclosure is necessary to meet any applicable law including any obligation or need to prevent fraud or other crime, or if we believe such action is necessary to protect and defend the rights, property or safety of ANA, our users, employees or others.
We will only retain your Personal Data for as long as necessary to fulfil the purpose for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your Personal Data can be requested from us using our contact details below.
In some circumstances we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without notifying you.
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used, altered, disclosed or accessed in an unauthorized way. For example, all information you provide to us is stored on secure servers.
In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to access your data. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Apps, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Please note that the transmission of information via the internet is never completely secure. Although we will do our best to protect your Personal Data, We cannot guarantee the security of your data transmitted to our Websites or Apps any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
- Children’s Privacy: We do not knowingly collect information from and of children.
- Your Rights:
Referring to your Personal Data, you are entitled, under certain circumstances, to the following rights:
- Access: be provided with a copy of your Personal Data held by us. For information on, corrections or the deletion of the Personal Data or part of it;
- Rectification: request the rectification or erasure of your Personal Data held by us, and object to the further processing of your Personal Data, including the right to object to Marketing Activities or any of them;
- Restriction: request that we restrict the processing of your Personal Data or part of it;
- Portability: request that provided Personal Data be moved to a specific third party.
- Erasure: You may opt out at any time from allowing us access to your location data by checking or un-checking (as directed) the relevant box, by using the “opt-out” mechanisms such as “unsubscribe” or other means provided within the communications that you receive, or by contacting us. We reserve the right to notify you of changes or updates to the Service whenever necessary.
- Withdraw consent: Where the processing of your Personal Data by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us. You can also change your marketing preferences at any time.
You can exercise the rights listed above, all of them and each one of them, at any time by contacting us at firstname.lastname@example.org.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If your request or concern is not satisfactorily resolved by us, please also note you have the right to lodge a complaint with a supervisory authority. In particular, the supervisory authority of the member state of your residence, place of employment, or the location where the issue that is the subject of the complaint occurred.
Objection: You have the right to object to the processing of Personal Data about you for compelling and legitimate reasons relating to your particular situation, except in cases where legal provisions expressly provide for that processing. In addition, you have the right to object if data about you is processed for direct marketing purposes.
Where do we store your information?
The Personal Data that we process in relation to you may be transferred to, and stored at, a destination outside of your country’s borders and for European residents outside the European Economic Area (“EEA“) that may not be subject to equivalent data protection laws. It may also be processed by staff situated outside the EEA who works for us or for a third party providing services to us.