This privacy policy (“Policy”) sets out how Corbion Trading (Shanghai) Co., Ltd. (“Corbion China”, with its registered address at Room 2816, 2817, 2818, No. 2, Lane 166, Minhong Road, Minhang District, Shanghai, China and e-mail address of privacy.china@corbion.com and Corbion NV (Address: Piet Heinkade 127, 1019 GM Amsterdam, Netherlands; E-mail Address: privacy@corbion.com) (collectively, “Corbion”, “we” or “us”) collect, store, use, process, transfer, provide, disclose and protect any Personal Information (as defined below) of individual residing in the Peoples’ Republic of China (“PRC” or “China”, which, for the purpose of this Policy only, refers to mainland China) that you or your company provide to Corbion when visiting our website, correspond with us and/or interact in the course of our businesses or in connection with our products and services. Corbion NV is the personal information processor for the purpose of our website, and Corbion China is the personal information processor for the purpose of any other applicable interactions as specified below.
Failure to provide certain Personal Information may result in us not being able to perform certain processing activities described in this Policy, and as a consequence, we may not be able to meet all our obligations to you, or we cannot comply with other legal obligations.
If you provide us with Personal Information about other persons such as, Personal Information of contact persons, board members, directors, shareholders, representatives, or other persons who have executive power in your company, or you ask us to disclose their Personal Information you provided to us to third parties, you are responsible for notifying those other persons of the details of this Policy and obtaining any required consent from them for the provision of their Personal Information to us as well as the processing of their Personal Information by us.
“Personal Information” means all kinds of information, whether recorded in electronic or another format, that relates to an identified or identifiable natural person, excluding anonymized information.
• Corbion website, Dedicated websites, Subscription and Customer Portal
Corbion NV may collect your Personal Information from use of Corbion website, Dedicated websites, Subscription, Customer Portal, and your interactions with us through these channels in the manner and for the purposes described below.
1. Contact us: When you visit our website www.corbion.com, you can contact us via the Contact button by filling out the form. Through this form, Corbion NV may collect all the Personal Information that you fill out, including your name, company, e-mail address, phone number, country, your enquiry and any other Personal Information you decide to enter into the form. Corbion NV may then allocate your enquiries to Corbion China and share your Personal Information with Corbion China (as applicable).
You can also contact us via e-mail and using the contact details listed on various parts of our website. If you contact us, we will collect your name, company and phone number, and any other Personal Information you provide us which we need to be of further assistance and communicate with you.
2. Customer Portal: If you make use of our Customer Portal, Corbion NV may collect the Personal Information you have filled out in the registration form or otherwise provided, including your name, company, e-mail address, phone number, job title and username and password. We also register relevant queries and the pages and products our customers view in the Customer Portal.
3. Registration for our dedicated websites: If you make an account in one of our dedicated websites (e.g. product calculators), Corbion NV may collect the Personal Information you inform on the registration form, including your name, salutation, company, e-mail address, phone number, job title and username and password. We register when you login the website and when you require a copy of the calculations in pdf format. In certain cases, and with your prior consent, we will also receive a copy of the pdf you have downloaded with the calculations.
4. Subscription: If you use the “Subscribe” button to subscribe to our newsletters and updates on our products and services, special offers, Corbion NV may collect the Personal Information you fill out in the form, including your e-mail address, the topics for which you wish to receive updates or further Personal Information and other Personal Information you decide to provide us in the subscription form, such as your name, company and position. If you do not wish to receive such communications, please send an e-mail to privacy.china@corbion.com, reach out to your respective Corbion contact or unsubscribe directly via the links provided in our e-mails.
5. Improving our products and services: For market research to improve our products and services and to be able to offer our customers and prospects tailored products and services, Corbion NV may collect and process your certain Personal Information. This may include following up with our customers and prospects in relation to the products that they have viewed on the Customer Portal to see how we may be of further service and whether they are interested in particular Corbion products and services.
6. Cookies: We also collect Personal Information on the use of our website via cookies, including your IP address and other identifiers, and webpage browsing data. We may use such Personal Information for data analytical purposes. Please view the section “How do we use cookies?” below and the Cookie Policy for more information.
• Business Relations
If you or your company are one of our customers or their affiliates, business partners, suppliers, vendors, service providers, other persons who provide their products and services to us, other recipients of our products and services, and any other individuals about whom we obtain Personal Information in the course of our business relations, or prospects, Corbion China may process limited Personal Information via offline and online channels, for example:
1. physical documents (e.g. quotations, drawings, technical manuals), name cards, telephone calls, text messages;
2. electronic documents, e-mail address, communication application and platforms (e.g. WeChat, MS Teams, Zoom, and Skype) and other communications with us;
3. other Personal Information you provided to us during offline or online exhibitions, seminar or other events;
4. public information; and
5. we may also receive Personal Information from our Corbion group entities globally or other third party sources (e.g. your company, reference company, purchasing association and acquaintances in the market, other suppliers, or any other third parties involved in the course of our businesses).
Corbion China will collect your Personal Information in the manner and for the purposes described below. Where your Personal Information is collected from third parties, we will ask such third parties to advise on the source of Personal Information for verification and ensure that they have obtained your consent to the provision of such Personal Information to us as well as to the processing of such Personal Information by us (to the extent that such consent is required by law). Except as expressly permitted by law, we will not process such Personal Information until we receive confirmation that the relevant third parties have already obtained your consent. If the purposes for which we process the Personal Information are not covered under the scope of consent obtained by the third parties, we will seek or will ask such third parties to seek your consent before we process your Personal Information for such additional purposes.
1. Customer/supplier management: For management purposes, such as master data set up, Corbion China may collect the contact details of the contact persons of our customers, suppliers, vendors, service providers, or other entities who provide their products and services to us, including their names, company name, telephone numbers, email addresses, titles, signatures and WeChat accounts. We may collect further personal identification data, including the identification cards or passports to provide support on booking ticket and/or hotel for business trip. Your identification card or passport are your sensitive Personal Information.
2. Order processing and shipment: Corbion China may collect your name, telephone number and address to process the order and ship products/sample to you.
3. Communication: Corbion China may collect and use the Personal Information you provide us when you contact us, including the information regarding your enquires, orders, comments or complaints, and your contact details for responding to your enquires or informing you of information about our products and services (e.g. quality assurance, product testing).
4. Visitor management: If you wish to visit the office of Corbion China, we may collect your name, telephone number, identification card or passport, reason for visiting, arrival/departure time, your health data (e.g. information on fever, symptoms, and body temperature for the purpose of contagious disease screening) for visitor management purpose. Your identification card or passport, and your health data are your sensitive Personal Information. In connection with this, we may also share your Personal Information (including sensitive Personal Information) with our office building management company.
5. Marketing: If you wish to receive our newsletters and updates on our products and services, special offers, Corbion China may collect your name and contact details, including telephone number and e-mail address. If you do not wish to receive such communications, please send an e-mail to privacy.china@corbion.com, reach out to your respective Corbion contact or unsubscribe directly via the links provided in the communications.
• Security-related purpose: If necessary, we may collect and use your Personal Information for the purposes of personal safety, public security, crime prevention, potential legal prosecution or proceedings, including using CCTV for ensuring on-site activity security.
• Other legitimate purposes: If necessary, we may collect and use your Personal Information for compliance, regulatory, investigative purposes, or for the purposes of protecting our legal rights, solving disputes, detecting, preventing and investigating fraud, and establishing, exercising or defensing of legal claims.
You consent to our collection and use of your Personal Information (including sensitive Personal Information) for the purposes and in the manner as described above.
We will make sure that the processing of your sensitive Personal Information is for specific purposes as described in this Policy and is necessary. We will take strict security measures when processing the sensitive Personal Information and such processing will be conducted in a manner having the least impact on your personal rights and interests.
Apart from the above purposes where we may seek your consent, we may collect and use your Personal Information under the following circumstance:
1. where it is required to conclude and perform a contract to which you is a party (if applicable);
2. where it is required to perform our statutory obligations or legal duties;
3. where it is required to respond to public health emergencies, or protect the life, health and safety of property of natural persons in emergencies;
4. where your Personal Information is processed to a reasonable extent for the purposes of news report, public opinion supervision and other acts for public interest;
5. where your Personal Information has already been made public by yourself or through other legitimate channels, and processing of such Personal Information is conducted pursuant to the PRC Personal Information Protection Law, and to a reasonable extent; or
6. other circumstances provided in the laws and regulations.
• We may share your Personal Information with other Corbion group entities located outside of China. An overview of Corbion group entities can be found here.
1. When you contact us via Corbion website or Customer Portal, to better communicate with you and follow-up on your enquiries, Corbion NV may share the Personal Information you filled out or otherwise provided (including your name, contact details and your enquires) with Corbion China.
2. Purac Asia Pacific PTE Ltd. (in Singapore) provides customer/supplier management service for Corbion China and will create master data in our SAP system. In connection with this, Corbion China may provide Purac Asia Pacific PTE Ltd. with the Personal Information of contact persons of our customers, suppliers, vendors, service providers, or other entities who provide their products and services to us, including their names, company name, telephone numbers, email addresses, titles, and signatures.
• We may also share your Personal Information to third party service providers, for example e-mail and hosting providers, suppliers, marketing agencies and delivery services. Third party service providers will only process your Personal Information on behalf of Corbion for the purposes set out herein and in compliance with all applicable laws and regulations. When we share your Personal Information with these parties, we make sure that appropriate safeguards are taken to protect your Personal Information.
• For the purposes of global mobilization and management, and data storage and protection, Corbion may share your Personal Information in global systems which will involve cross-border transfer of Personal Information. For more information about these systems, please contact privacy.china@corbion.com
• We may also share your Personal Information to third parties connected with possible or substantive sale of our business or any of our assets, or those of any related company, particularly through acquirements or mergers, alteration in divestitures or control, or affiliation with bankruptcy. In such instances, Personal Information collected by us may be one of the reassigned equities and we will inform you of, or make available, the identities and the contact details of such third parties and other information required to be disclosed by law (if any), and will obtain your consent where required by laws and regulations. If such third parties change the original purposes or methods of the Personal Information processing activities, they will obtain your consent again.
• We may also share your Personal Information to government bodies, authorities and/or law enforcement officials, to the extent in compliance with applicable laws and regulations. We will further disclose to you the details of such sharing and will obtain your consent to the same (where such disclosure and consent are required).
You consent to our provision of your Personal Information to the overseas entities for the purposes and in the manner as described above. You may contact the overseas entities using the contact details listed above to exercise your rights for protection of Personal Information as provided by applicable laws and regulations in China.
We retain Personal Information about you only for the minimum period we need it for the purposes for which it was collected. However, we may retain Personal Information for a longer period where it is required by laws or regulations, such as where legal action or proceedings is initiated.
For example, if you are a customer or supplier of Corbion, Corbion will keep your Personal Information for the duration of the contractual relationship you or your company has with us and after the end of that relationship for a reasonable period necessary to perform the purposes set out above or to comply with legal obligations. Personal Information we collect for your subscription to our newsletter or updates will be stored until you decide to withdraw your subscription.
We are committed to ensuring that your Personal Information is secure. In order to prevent any accidental, unlawful or unauthorized loss, access, use, alteration, modification or disclosure, we have put in place administrative, technical and organizational measures to safeguard and secure the Personal Information we collect from you.
We have implemented measures on controlling access and use of devices for storing and processing Personal Information which are secured and suitable for our processing of Personal Information. We also have measures on restricting access to Personal Information and the use of storage and processing equipment by imposing users’ access rights, users’ permission rights to the authorized personnel, and users’ duties and responsibilities to prevent unauthorized access, disclosure, perception or unlawful duplication of Personal Information, or theft of device used to store and process Personal Information. This includes measures on the re-examination in relation to access, alteration, delete, or transfer of Personal Information which are in accordance with methods and channels used to collect, use or disclose Personal Information.
Subject to applicable laws and regulations, you have the following rights for protection of Personal Information:
1. Right to access and copy: You have the right to access and make a copy of your Personal Information held by us by sending an e-mail to privacy.china@corbion.com, except where we are required by applicable laws to keep such information confidential.
2. Right of rectification and supplement: When you find that your Personal Information that our process is wrong, you have the right to request us to make rectifications or supplements through the channels set out in Section F.1 above. We will make such rectifications or supplements after we have verified the accuracy of your Personal Information.
3. Right of deletion: In the following circumstances, we will actively delete your Personal Information (and you also have the right to request us to delete your Personal Information through the channels set out in Section F.1 above):
o If our processing purpose has been achieved or is unachievable or your Personal Information is no longer necessary to achieve the processing purpose;
o If we cease to offer products or services to you or the retention period has expired;
o If you cease to use our products or services, or withdraw your consent;
o If we process your Personal Information in violation of the laws or regulations or in breach of this Policy; or
o Other circumstances provided for in laws or regulations.
If the retention period provided for in laws or regulations has not yet expired or the Personal Information would technically be difficult to delete, we will cease the processing except for storage and the taking of necessary security protection measures.
4. Change of Consent: You can request us to change the scope of your consent for us to collect your Personal Information through the channels set out in Section F.1 above. If you change your consent, we may no longer be able to provide you with the products or services, or certain function of the same corresponding to your consent that has been changed. The change of consent shall not affect the validity of the Personal Information processing activities conducted prior to such change on the basis of your consent.
5. Right to Transfer Personal Information: You may request us to transfer your Personal Information that we hold about you to another personal information processor that is designated by you. If you wish to make such request, please contact us through the channels set out in Section F.1 above. We will review your request, and if such request meets the applicable statutory or regulatory requirements, we will duly provide you with the channel for the transfer.
6. Right to Request for Explanation: You may request us to explain about our rules as to the processing of your Personal Information. If you wish to make such request, please contact us through the channels set out in Section F.1 above.
We hope that we can satisfy queries you may have about the above. If you have any concerns about how we process your Personal Information, you can get in touch with us at privacy.china@corbion.com.
Our website may contain links to other websites. However, once you have used these links to leave our site, you should note that we do not have any control over those other websites. Therefore, we cannot be responsible for the protection and privacy of any Personal Information which you provide whist visiting such sites and such sites are not governed by this Policy. You should exercise caution and look at the privacy policies applicable to such sites in question.
On our website we use the social media plug-ins from platforms such as LinkedIn. The plug-ins can be recognized by the social media buttons marked with the logos of these companies.
We have implemented these plug-ins using the so-called 2-click solution. This means that when you surf on our website, no Personal Information of you will initially be collected by the providers of these social media plug-ins. Only if you click on one of the plug-ins will your Personal Information be transmitted. By activating the plug-ins, Personal Information is automatically transmitted to the respective plug-in provider and stored by them. We do not have control over the collected Personal Information and Personal Information processing activities conducted by the providers of the plug-ins and are not aware of the full extent of Personal Information collection, the purposes or the retention periods. Therefore, we cannot be responsible for the protection and privacy of any Personal Information which you provide via the plug-ins and such Personal Information is not governed by this Policy.
Information on the purpose and scope of Personal Information collection and its processing by the providers of the plug-ins can be found in their respective privacy policies, where you will also find further information on your rights and options for Personal Information protection. You should exercise caution and look at the privacy policies of the plug-in providers.
Some of the features on this website require the use of “cookies” - small text files that are stored on your computer’s hard drive. We use cookies to measure which pages are being accessed, and which features are most frequently used. This enables us to continuously improve this website to meet the needs of our visitors.
For more information about our use of cookies, please view our Cookie Policy.
If you have any questions or requests with regard to this Policy or if you wish to exercise your rights as set out above, please contact us at:
Corbion China
Room 2816, 2817, 2818, No. 2, Lane 166, Minhong Road,
Minhang District, Shanghai, China
privacy.china@corbion.com
or
Corbion Global
Legal & Compliance Department – Data Protection Office
Piet Heinkade 127
1019 GM Amsterdam
The Netherlands
privacy@corbion.com
We may change this Policy from time to time by updating this page. This Policy was last updated in January 2021. Please review this Policy regularly for any updates. We will notify you or obtain your consent again if there are significant updates to this Policy, or if we are required to do so by applicable laws and regulations.
This Policy is governed and construed in accordance with the laws of the PRC.