Privacy Policy
LDC.com Global Privacy Policy
A. General
This Privacy Policy is issued by Louis Dreyfus Company B.V. 92, Rotterdam 3012, The Netherlands, on behalf of itself and each of the companies in the Louis Dreyfus Company Group of companies (“LDC” or “We”).
We have developed this policy because we want you to feel confident about the privacy and security of your Personal Data held by us. It explains how LDC collects Personal Data from you or about you on our websites (the “Website”), or via written or verbal communications with us, mobile applications, social networking presence or from other sources. It also explains how we use and disclose such Personal Data. While this Privacy Policy broadly describes the practices we have adopted across the LDC Group globally, local laws vary and some jurisdictions may place restrictions on our processing activities.
Please read the following carefully to understand our practices regarding your Personal Data and how we will treat it. It is important that you read this Privacy Policy together with any other privacy policy that we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
“GDPR” means Regulation EU 2016/679 (GDPR) or a privacy law with the same requirements applies to you
“Personal Data” means any information relating to you that would allow a party to identify you as an individual or to contact you, including, for example, your full name, address, telephone number, or email address.
LDC will be the data controller and our nominated representative in relation to this Privacy Policy will be Louis Dreyfus Company Suisse S.A., GVA Centre -29, Rte de l’aéroport – case postale 236 – 1215 Geneva 15/ Switzerland.
The business contact information of our Singapore data protection officers is as follows: [email protected].
B. Information for Website Users
Personal Data we collect and how we use it
Below you will find information about how LDC collects and uses your Personal Data if you are a Website User. LDC is the operator of this Website which is hosted in the Netherlands.
We may collect and process the following Personal Data about you:
- Applications for jobs: First Name, Last Name, Email address, Phone number, Nationality, Country – residence, Languages, Level spoken, Years of experience, Current company, Current position, Current function, Current professional area, Previous Company, Previous position, Previous professional area, Previous function, Uploaded resume, CV or cover letter.
- Investment proposal: Title, First Name, Last Name, Company, Address, City, Country, Postal Code, Phone, Email.
- Supplier Opportunities: Title, First Name, Last Name, Company, Address, City, Country, Postal Code, Phone, Email.
- Quote request for commodities: Title, First Name, Last Name, Company, Address, City, Country, Postal Code, Phone, Email.
- Sustainability Inquiries: Title, First Name, Last Name, Company, Address, City, Country, Postal Code, Phone, Email.
- Investor Relations: Title, First Name, Last Name, Company, Address, City, Country, Postal Code, Phone, Email, Status.
- Media Inquiries: Title, First Name, Last Name, Media outlet of affiliation, Contact type, Email, Country.
- A request to download an LDC brochure or other marketing information: email address.
- Participation in games or activities on the LDC Galleries virtual museum: name, email address, location.
- Where we have a contract with you, we will also hold any personal contact details contained in that contract, which may include payment information and invoice information.
- Connection information (last login date, IP address) and mobile device information (device ID, manufacturer, platform, version).
- Information about how you use our website, including technical information (such as type of browser and operating system) and log information (your visits to and use of the site). This includes information gathered by the use of cookies in your web browser.
- If you contact us, we keep a record of that correspondence.
- Any other information uploaded by you onto our site.
Lawful basis for processing
We are able to lawfully process your personal data where you have explicitly consented to this.
We are also permitted to process your personal information where (i) the processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you, (ii) where the processing is necessary for compliance with a legal obligation that we have, or (iii) for the purposes of our overriding legitimate interests.
Our legitimate interests might be: to prevent fraud, to provide you with a safe, efficient and customised experience on our Website and to provide the services you have requested. We consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
We will use your Personal Data:
- For client and contract management in order to contact you and for electronic signature of contracts.
- To provide information and services you request.
- For security or fraud prevention purposes.
- To provide you with effective customer service.
- To provide you with a good user experience when you use our site.
- To improve the content, functionality and usability of our site.
- To improve our products and services.
- Where you have consented explicitly, we may contact you with marketing offers.
- To improve our marketing and promotional efforts.
IP addresses and use of “cookies”
We collect information about your computer, including where available your internet protocol (“IP”) address, operating system and browser type, for system administration. An IP address is a number that is automatically assigned to your computer when you use the internet. We use IP addresses to help diagnose problems with our server, administer our site, analyse trends, track users’ activity within the application, and gather broad demographic information for aggregate use in order for us to improve our site.
We do use cookies that are vital for the basic functionality of the website. A cookie is a small data file that our server sends to your browser when you visit the site. Cookies will only be stored to improve the performance of the site in order to retrieve data in the most effective way and notify the user of previous activities. You can delete cookies at any time or you can set your browser to reject or disable cookies. If you are unsure how to do this, follow this link where you will find instructions for many of the most popular web browsers: http://www.allaboutcookies.org/manage-cookies/stop-cookies-installed.html.
Where we store your Personal Data
The Personal Data that we collect from you may be transferred to, and stored at, a destination outside Switzerland and the European Economic Area (“EEA”). Such destination countries may have different levels of privacy protection than in your country of residence.
Your Personal Data are processed by staff operating outside Switzerland and the EEA who work for us or for one of our group companies, affiliates or suppliers. These staff are engaged in the provision of support services. By submitting your Personal Data via our site, you agree to any such transfers, storage or other processing. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy.
These steps include imposing contractual obligations on the recipients of your Personal Data to protect that Personal Data, using standard contractual clauses approved by the European Commission. We may alternatively require approved codes of conduct or certification mechanisms to be in place.
Please contact our data protection team at the address in the Contact Us section to obtain more information about our contractual clauses imposed on third party recipients of your Data.
We store your Personal Data carefully. We have implemented, and follow, industry standard measures to protect against unauthorized access to, and unlawful interception or processing of, Personal Data. Once we have received your Personal Information, we will use strict procedures and security features to prevent unauthorized access.
Disclosure of Personal Data
We may disclose your Personal Data to any member of our group, which means our subsidiaries, our ultimate holding parent company and its subsidiaries and/or affiliates. Furthermore, we disclose your Personal Data to our business partners (DocuSign and Certisign for electronic signature, Plivo for SMS communication, Microsoft for hosting, Google for web analytics) insofar and for as long as it is necessary to perform our services. We oblige our business partners to assume and apply the same rights and obligations regarding your Personal Data as described in this Privacy Policy.
Other than previously specified in this Privacy Policy, we may also disclose your Personal Data to third parties in the following circumstances:
- If we become part of another organization, such organization will possess the Personal Data collected by us, and it will apply and assume the same rights and obligations regarding your Personal Data as described in this Privacy Policy.
- If we are under a duty to disclose or share your Personal Data, or part of it, in order to comply with any applicable legal or regulatory obligation, or in order to enforce or apply our Terms of Use and other agreements; or to protect the rights, property, or safety of us, our customers, or others.
International Transfers
LDC is a global organization that does business in many countries. Some of the parties, identified above, with whom we share your data may be located in countries outside of your own. Although the data protection laws of these various countries may differ from those in your own country, we have put in place appropriate safeguards (such as contractual commitments) to ensure that your personal information is handled as described in this Privacy Policy and in accordance with the law. For transfers of data outside of the European Union, this includes standard contractual clauses approved by the European Commission. For more information on the appropriate safeguards in place, please contact us via the contact information provided in the Contact Us section at the end of this Privacy Policy.
Retention of Personal Data
The time period for which we shall retain and keep Personal Data varies according to various statutes and what the information is used for. In some cases, there are legal requirements to keep data for a minimum period of time. Unless there is a specific legal requirement for us to retain and keep the information, we will retain and keep it only insofar and as long as it is necessary for the purposes for which the data was collected or for which it is to be further processed.
Non-personal information
Non-personal information is information that does not identify you individually. We collect non-personal information from your computer, such as your Web browser, the date and time of your Web site visit, the Web address from which you accessed our site, the number of visitors to the site, the pages viewed, and the length of time on the Web site.
Marketing
We collect data to analyse the website in general, to gain insights into how to improve our services and to target our marketing measures to your identifiable needs. You have the right to ask us not to process your Personal Data for our marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for our own marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your Personal Data. You can also exercise the right at any time by contacting us at the address in the Contact Us section. If you consent to the use of your Personal Data for marketing purposes, you can change your mind and opt-out of this at any time. You can do this by selecting ‘unsubscribe’ at the bottom of any marketing email you receive from us, or at any time by contacting us at the address in the Contact Us section.
Other websites
Our website contains links to other websites such as Docusign, Certisign, etc. Please note that when you click on one of these links, you are entering another website over which we have no control and will bear no responsibility. Often these sites require you to enter your Personal Data. We encourage you to read the privacy policies on all such websites as their policies may differ from ours.
C. Information for Suppliers, Customers, Logistics Partners and the Public
Personal Data we collect and how we use it
Below you will find information about how LDC collects and uses your Personal Data if you are one of our Suppliers, Customers, Logistics Partners or a member of the public. We may collect and process the following Personal Data about you:
- Investment proposal: Title, First Name, Last Name, Company, Address, City, Country, Postal Code, Phone, Email.
- Supplier Opportunities: Title, First Name, Last Name, Company, Address, City, Country, Postal Code, Phone, Email.Supplier Data: we may collect additional personal data in connection with our transparency and traceability programme and as required by our accredited certifications: gender, national ID number, date of birth, household size, income, location of farms/supplier premises including GPS co-ordinates, photos, videos, voice recordings, quotes from speech or text provided by you.
- Quote request for commodities: Title, First Name, Last Name, Company, Address, City, Country, Postal Code, Phone, Email.
- Sustainability Inquiries: Title, First Name, Last Name, Company, Address, City, Country, Postal Code, Phone, Email.
- Investor Relations: Title, First Name, Last Name, Company, Address, City, Country, Postal Code, Phone, Email, Status.
- Media Inquiries: Title, First Name, Last Name, Media outlet of affiliation, Contact type, Email, Country.
- Where we have a contract with you, we will also hold any personal contact details contained in that contract, which may include payment information and invoice information.
- If you contact us, we keep a record of that correspondence.
We use your Personal Data:
- For client and contract management in order to contact you and for electronic signature of contracts.
- To provide any information and services that you request.
- For security or fraud prevention purposes.
- To provide you with effective customer service.
- To improve our products and services.
- Where you have consented explicitly, we may contact you with marketing offers.
- To improve our marketing and promotional efforts.
- In connection with the sustainability objectives and obligations of LDC and its customers.
Lawful basis for processing
We are able to lawfully process your personal data where you have explicitly consented to this.
We are also permitted to process your personal information where (i) the processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you, (ii) where the processing is necessary for compliance with a legal obligation that we have, or (iii) for the purposes of our overriding legitimate interests.
Our legitimate interests might be: to comply with our corporate due diligence and sustainability obligations/objectives and those of our customers, to prevent fraud, to provide you with a safe, efficient and customized experience on our Website and to provide the services you have requested. We consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Where we store your Personal Data
The Personal Data that we collect from you may be transferred to, and stored at, a destination outside Switzerland and the European Economic Area (“EEA”). Such destination countries may have different levels of privacy protection than in your country of residence.
Your Personal Data are processed by staff operating outside Switzerland and the EEA who work for us or for one of our group companies, affiliates or suppliers. These staff are engaged in the provision of support services. By providing your personal data, you agree to any such transfers, storage or other processing. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy.
These steps include imposing contractual obligations on the recipients of your Personal Data to protect that Personal Data, using standard contractual clauses approved by the European Commission. We may alternatively require approved codes of conduct or certification mechanisms to be in place.
Please contact our data protection team at the address in the Contact Us section to obtain more information about our contractual clauses imposed on third party recipients of your Data.
We store your Personal Data carefully. We have implemented, and follow, industry standard measures to protect against unauthorized access to, and unlawful interception or processing of, Personal Data. Once we have received your Personal Information, we will use strict procedures and security features to prevent unauthorized access.
Disclosure of Personal Data
We may disclose your Personal Data to any member of our group, which means our subsidiaries, our ultimate holding parent company and its subsidiaries and/or affiliates. Furthermore, we disclose your Personal Data to our business partners (DocuSign and Certisign for electronic signature, Plivo for SMS communication, Microsoft for hosting, Google for web analytics) and to certification schemes and control bodies, insofar and for as long as it is necessary to perform our services. We oblige our business partners to assume and apply the same rights and obligations regarding your Personal Data as described in this Privacy Policy.
Other than previously specified in this Privacy Policy, we may also disclose your Personal Data to third parties in the following circumstances:
- If we become part of another organization, such organization will possess the Personal Data collected by us, and it will apply and assume the same rights and obligations regarding your Personal Data as described in this Privacy Policy.
- If we are under a duty to disclose or share your Personal Data, or part of it, in order to comply with any applicable legal or regulatory obligation, or in order to enforce or apply our Terms of Use and other agreements; or to protect the rights, property, or safety of us, our customers, or others.
International Transfers
LDC is a global organization that does business in many countries. Some of the parties, identified above, with whom we share your data may be located in countries outside of your own. Although the data protection laws of these various countries may differ from those in your own country, we have put in place appropriate safeguards (such as contractual commitments) to ensure that your personal information is handled as described in this Privacy Policy and in accordance with the law. For transfers of data outside of the European Union, this includes standard contractual clauses approved by the European Commission. For more information on the appropriate safeguards in place, please contact us via the contact information provided in the Contact Us section at the end of this Privacy Policy.
Retention of Personal Data
The time period for which we shall retain and keep Personal Data varies according to various statutes and what the information is used for. In some cases, there are legal requirements to keep data for a minimum period of time. Unless there is a specific legal requirement for us to retain and keep the information, we will retain and keep it only insofar and as long as it is necessary for the purposes for which the data was collected or for which it is to be further processed.
Marketing
We may collect data in order to gain insights into how to improve our services and to target our marketing measures to your identifiable needs. You have the right to ask us not to process your Personal Data for our marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for our own marketing purposes. You can also exercise the right at any time by contacting us at the address in the Contact Us section. If you consent to the use of your Personal Data for marketing purposes, you can change your mind and opt-out of this at any time by contacting us at the address in the Contact Us section.
D. Information for Job Applicants
Personal Data we collect and how we use it
During the recruitment process, LDC will generally only collect personal data that is necessary to assess you for the position for which you have applied. This includes:
- Application information: Information that tells us who you are and helps us assess your suitability for the position. This may include: first name, last name, contact information, nationality, country of residence, academic experience and grades, languages and level spoken, years of experience, current and previous professional experience, current and previous company/employers, current position, current function, current professional area, previous position, previous professional area, previous function, uploaded resume, any other information that you provide in your application, including in your CV or cover letter, such as professional qualifications and personal interests;
- Information contained in your social media accounts (e.g. LinkedIn and Twitter);
- Recruitment process information: Information collected as a result of the recruitment process, such as assessment and interview results and information provided by your referees;
- Future opportunities information: Information that allows us to notify you about future job opportunities at LDC, such as your name, email, location, field of expertise and the kind of role you are interested in;
- We may also collect, store and use the following types of more sensitive personal information:Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions. This will only be sought where relevant (e.g. for equal opportunities monitoring) and permitted by applicable law.Where we have not requested sensitive personal information but you provide it anyway, we will treat it in accordance with applicable data privacy law and LDC’s policies.
LDC generally receives this information either (a) directly from you (for instance when you provide information as part of your application or during the recruitment process) or (b) from third parties such as recruitment agencies, recruitment technology providers and your referees. LDC will indicate whether the information requested is mandatory or optional. If you fail to provide mandatory information, in some circumstances this may mean the LDC is unable to take your application further.
We use your Personal Data to:
- Assess your skills, qualifications, and suitability for the role.
- Carry out background and reference checks, where applicable.
- Communicate with you about the recruitment process.
- Keep records related to our hiring processes.
- Comply with legal or regulatory requirements.
- Improve our recruitment process.
- Prevent fraud and manage security.
Lawful basis for processing
We are able to lawfully process your personal data where you have explicitly consented to the processing.
We are also permitted to process your personal information where (i) the processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you, such as a contract of employment, (ii) where the processing is necessary for compliance with a legal obligation that we have, or (iii) for the purposes of our overriding legitimate interests.
Our legitimate interests might be: to understand applicants in sufficient detail in order to operate an effective recruitment process. We consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Where we store your Personal Data
The Personal Data that we collect from you may be transferred to, and stored at, a destination outside Switzerland and the European Economic Area (“EEA”). Such destination countries may have different levels of privacy protection than in your country of residence.
Your Personal Data are processed by staff operating outside Switzerland and the EEA who work for us or for one of our group companies, affiliates or suppliers. These staff are engaged in the provision of support services. By providing your personal data, you agree to any such transfers, storage or other processing. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy.
These steps include imposing contractual obligations on the recipients of your Personal Data to protect that Personal Data, using standard contractual clauses approved by the European Commission. We may alternatively require approved codes of conduct or certification mechanisms to be in place.
Please contact our data protection team at the address in the Contact Us section to obtain more information about our contractual clauses imposed on third party recipients of your Data.
We store your Personal Data carefully. We have implemented, and follow, industry standard measures to protect against unauthorized access to, and unlawful interception or processing of, Personal Data. Once we have received your Personal Information, we will use strict procedures and security features to prevent unauthorized access.
Disclosure of Personal Data
In connection with your application we may disclose your Personal Data to the following parties: any member of our group, which means our subsidiaries, our ultimate holding parent company and its subsidiaries and/or affiliates;[our business partners (DocuSign and Certisign for electronic signature, Plivo for SMS communication, Microsoft for hosting, Google for web analytics) and to certification schemes and control bodies, insofar and for as long as it is necessary to perform our services], and third parties such as recruitment agencies, background check providers etc. We oblige our group companies and third parties to assume and apply the same rights and obligations regarding your Personal Data as described in this Privacy Policy.
Other than previously specified in this Privacy Policy, we may also disclose your Personal Data to third parties in the following circumstances:
- If we become part of another organization, such organization will possess the Personal Data collected by us, and it will apply and assume the same rights and obligations regarding your Personal Data as described in this Privacy Policy.
- If we are under a duty to disclose or share your Personal Data, or part of it, in order to comply with any applicable legal or regulatory obligation, or in order to enforce or apply our Terms of Use and other agreements; or to protect the rights, property, or safety of us, our customers, or others.
International Transfers
LDC is a global organization that does business in many countries. Some of the parties, identified above, with whom we share your data may be located in countries outside of your own. Although the data protection laws of these various countries may differ from those in your own country, we have put in place appropriate safeguards (such as contractual commitments) to ensure that your personal information is handled as described in this Privacy Policy and in accordance with the law. For transfers of data outside of the European Union, this includes standard contractual clauses approved by the European Commission. For more information on the appropriate safeguards in place, please contact us via the contact information provided in the Contact Us section at the end of this Privacy Policy.
Retention of Personal Data
We retain job candidate Personal Data for 24 months so that we are able to contact you if another job opportunity arises.
Marketing
We may collect data in order to gain insights into how to improve our services and to target our marketing measures to your identifiable needs. You have the right to ask us not to process your Personal Data for our marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for our own marketing purposes. You can also exercise the right at any time by contacting us at the address in the Contact Us section. If you consent to the use of your Personal Data for marketing purposes, you can change your mind and opt-out of this at any time by contacting us at the address in the Contact Us section.
Your rights
You may have the following rights in respect of your personal data.
Right of Access
The right to access and receive a copy of your Personal Data held by us.
The right to demand that we correct incorrect information.
Right to Erasure
The right to request the erasure of your Personal Data at any time, if you consider that we do not have the right to hold it. We may retain certain information about you as required by law and for legitimate business purposes permitted by law.
Right to Restrict Processing
The right to ask us to suspend the processing of your Personal Data in several scenarios, including if you want us to verify the accuracy of the data, and where our use of the data is unlawful but you do not want us to erase it.
Right to Data Portability
The right to request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. This right only applies to information which you initially provided consent for us to use, where we used the information to perform a contract with you or where the processing of your Personal Data is carried out by automated means.
Right to Object
The right to object to your Personal Data being processed for a particular purpose or to request that we stop using your Personal Data.
Right to Withdraw Consent
Where our processing of your Personal Data is based on your consent, you have the right to withdraw your consent at any time. If you do so we will stop processing your Personal Data unless there is another lawful basis we can rely on, if which case we will inform you of this.
Right to Reject Automated Individual Decision-Making
The right to request not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data;
Rights regarding Marketing Communications
The right to ask us to stop or to start sending marking messages at any time.
E. Modifications to this Privacy Policy
We reserve the right to change, alter or otherwise modify this Privacy Policy at any time by posting revisions on this web page. In the event of any change, you will be alerted.
F. Complaints
If you have any concerns about our processing of your Personal Data, you may of course contact us at the address and email address in the Contact Us section but you also have the right to complain to your local data protection regulator.
G. Contact Us
At: Chief Legal Officer, Louis Dreyfus Company Suisse S.A., GVA Centre – 29, Rte de l’aéroport – case postale 236 – 1215 Geneva 15 / Switzerland.
Or: email [email protected].
The business contact information of our Singapore data protection officers is as follows: [email protected]
Mainland China Addendum
This Mainland China Addendum to the Privacy Policy (this “Addendum”) applies to the processing of Personal Data of job applicants from mainland China by LDC. This Addendum supplements and constitutes an integral part of the Privacy Policy for North Asia. This Addendum is formulated in accordance with the applicable laws and regulations in the jurisdiction of the People’s Republic of China, including the Personal Information Protection Law, Data Security Law, Cybersecurity Law and other relevant laws, regulations, regulatory requirements, and national standards (“Applicable Legal Requirements”). The terms in this Addendum shall have the same meaning defined under the Privacy Policy unless otherwise clearly specified. For the purpose of this Addendum only, the term “Personal Data” refers to any kind of information related to an identified or identifiable natural person as electronically or otherwise recorded, excluding information that has been anonymized.
Personal Data we collect and how we use it
In addition to the types of Personal Data listed in Section D (Information for Job Applicants) of the Privacy Policy, we may also collect your Personal Data when you apply for jobs in our site, including expected working location, work eligibility, and salary expectations. Furthermore, certain information as listed in the “Non-personal information” in Section B (Information for Website Users) of the Privacy Policy may constitute Personal Data under Applicable Legal Requirements, such as your Web browser, the date and time of your Web site visit, the Web address from which you accessed our site, the pages viewed, and the length of time on the Website.
Lawful basis for processing
We only process your Personal Data when we have a legal basis for the processing. We may process your Personal Data on the basis of: (a) obtaining your consent for the purposes listed in the Privacy Policy, especially for recruitment purposes prescribed in “Personal Data we collect and how we use it” in Section D (Information for Job Applicants) of the Privacy Policy; (b) where it is necessary for the conclusion or performance of a contract to which you are a contracting party or where it is necessary for carrying out human resources management under an employment policy legally established or a collective contract legally concluded;; (c) where LDC is required to perform a statutory responsibility or obligation; and/or (d) where it is necessary for LDC to respond to a public health emergency, or for protecting the life, health or property safety of a natural person in the case of an emergency.
In addition to the above, we may process your Personal Data on other lawful bases for purposes that could be justified by such other bases according to Applicable Legal Requirements.
Sensitive Personal Data
It refers to Personal Data that, once leaked or illegally used, may easily cause infringement upon the human dignity or harm to the personal or property safety of a natural person, including biometric recognition, religious belief, specific identity, medical and health, financial account, personal whereabouts and other information of a natural person, as well as the Personal Data of minors under the age of 14. For achieving the purposes specified in this Privacy Policy, we may collect certain types of Sensitive Personal Data only when permitted or required by Applicable Legal Requirements. Where it is necessary to carry out the equal opportunities monitoring and permitted by Applicable Legal Requirements, we may collect your information of race or ethnicity, religious beliefs, sexual orientation and political opinions. Our Processing of your Sensitive Personal Data will strictly comply with Applicable Legal Requirements, including the enhanced protection measures and obtaining the separate consent you give us to such processing.
Sharing of Personal Data
In addition to entrusting third-party service providers such as recruitment agencies, recruitment technology providers, and background check providers to process your Personal Data for the purpose of assisting us in providing relevant operation and service support and enabling us to perform the functions of our products and/or services, we may share and transfer your Personal Data to third parties, including to entities located within and outside the Mainland China, for the processing purposes as follows:
- Within LDC Group: Your Personal Data as described in the Privacy Policy may be shared with, or otherwise accessed by any member of LDC Group (defined in Appendix I), for the processing purposes as provided in the Privacy Policy.
- If we are under a duty to share your Personal Data, or part of it, in order to comply with any applicable legal or regulatory obligation, or to protect the rights, property, or safety of us, our customers, or others, we may share your Personal Data to public and governmental authorities.
Cross-border transfer of Personal Data
For achieving the purposes stated in “Personal Data we collect and how we use it” in Section D (Information for Job Applicants) of the Privacy Policy, your Personal Data we collect as listed in the Privacy Policy may be transferred to and stored outside the Mainland China. The overseas data recipients include Members of LDC Group as described in Appendix I, which may be located outside the Mainland China. You can contact us through the contact information described in the “Contact Us” section below to exercise personal information related rights against the overseas data recipients. We will comply with Applicable Legal Requirements before transferring your Personal Data overseas.
Individual Rights
In addition to the data subject rights listed in the Privacy Policy, you also have, in accordance with Applicable Legal Requirements, the right to request for an explanation on this Addendum, the Privacy Policy and other processing rules of LDC in relation to your Personal Data. If you are a close relative of a deceased user of our site, for your own legal and legitimate interests, you can contact us through the contact information described in the Contact Us section below to exercise personal information related rights regarding Personal Data about the deceased we hold, unless otherwise arranged by the deceased. In order to fully protect the personal information rights of deceased users, when you contact us, we may inform you of the specific application procedures and requirements, and you will need to proceed the application per our instruction.
Contact Us
If you have any questions about the processing of your Personal Data or would like to exercise any of your data subject rights, in addition to the ways described in the Privacy Policy and this Addendum, you may also contact us at [email protected].
Colombia Addendum
This Colombia Addendum to the Privacy Policy (this “Addendum”) applies to the processing of Personal Data of Colombian residents by LDC. This Addendum supplements and constitutes an integral part of this Privacy Policy and is formulated in accordance with the applicable laws and regulations in the jurisdiction of Colombia, mainly, Law 1581 of 2012 and Decree 1377 of 2013. The terms in this Addendum shall have the same meaning defined under this Privacy Policy unless otherwise clearly specified.
Processing of your Personal Data
We will collect, store, use, transfer, circulate, or delete your Personal Data for the purposes described in the main section of this Privacy Policy and we will rely on your prior, explicit, and informed consent as the primary lawful basis.
Your rights
For the case of Colombian residents/data subjects, you may exercise the following additional privacy rights:
Right to Consultation
You have the right to consult your Personal Data at any time and free of charge.
Right to Update
You have the right to update your Personal Data at any time.
Right to be Informed
You have the right to be informed about how we are using your Personal Data.
Inquiries and Complaints Procedures
In order to exercise the right to rectify, update or demand the deletion of your information, as Data Subject you are entitled to make complaints by sending an email to [email protected], which will be answered within 15 business days from the date of their receipt.
To exercise the right to consult your information, you are entitled to file any type of inquiries concerning the processing of your Personal Data by sending an email to [email protected], which will be answered within 10 business days from the date of their receipt.
California Privacy Notice Addendum
This California Privacy Notice Addendum (“California Addendum”) is adopted to comply with the California Consumer Privacy Act of 2018 and the California Privacy Rights Act of 2020, as each may be amended and modified, including all implementing regulations enacted thereunder (collectively, “CCPA”), and supplements and constitutes an integral part of the Privacy Policy. This California Addendum is only applicable to residents of California, USA. The terms in this California Addendum shall have the same meaning defined under the Privacy Policy unless otherwise clearly specified.
Collection, Use, and Disclosure of Your Personal Information
We may collect the following categories of personal information:
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
- Characteristics of protected classifications under California or federal law
- Commercial information
- Biometric information
- Internet or other similar network activity
- Age
- Ethnicity
- Financial Information
- Gender
- Geolocation Data
- Audio, electronic, visual, thermal, olfactory, or similar information
- Insurance Information
- Marital Status
- Medical Condition and other Health Information
- Military/Veteran Status
- Personal Identifiers
- Professional or Employment-Related Information
- Education information
- Signature
- Any other information that you either provide to us or that you consent to the provision of
We may collect the categories of personal information set forth in this California Addendum directly from you; through third party sources, including our business partners; or through any other communication between you and us.
We may collect the above categories of personal information for the following business purposes:
- To comply with all applicable laws and regulations
- For business and contract negotiation
- For client and contract management
- To provide information and services you request
- For security or fraud prevention purposes
- To provide you with effective customer service
- To provide you with a good user experience when you use our site
- To improve the content, functionality and usability of our site
- To improve our products and services
- Where you have consented explicitly, we may contact you with marketing offers
- To improve our marketing and promotional efforts
- To recruit and evaluate job applicants and candidates for employment
- To conduct background checks
- As applicable, to manage your employment relationship with us, including for:
- onboarding processes;
- timekeeping, payroll, and expense report administration;
- employee benefits administration;
- employee training and development requirements;
- the creation, maintenance, and security of your online employee accounts;
- employee job performance, including goals and performance reviews, promotions, discipline, and termination; and
- any other human resources purposes permitted under applicable law
- To manage and monitor employee access to our facilities, equipment, and systems
- To conduct internal audits and workplace investigations
- To investigate and enforce compliance with and potential breaches of our policies and procedures
- To engage in corporate transactions such as for evaluating potential mergers and acquisitions
- To perform workforce analytics, data analytics, and benchmarking
- To administer and maintain our operations
- To exercise or defend the legal rights of LDC and its employees, affiliates, customers, contractors, and agents
- For any purpose that, under the circumstances, would be reasonably expected by you or otherwise pursuant to your consent
We may have disclosed the categories of personal information set forth in this California Addendum for one or more of the purposes set forth above, including disclosure to a service provider.
We do not sell or share (as both such terms are defined under CCPA) any personal information.
Collection, Use, and Disclosure of Your Sensitive Personal Information
We may have collected the following categories of sensitive personal information:
- Social security, driver’s license or state identification card
- Racial or ethnic origin
- Precise geolocation
Please note, we do not use your sensitive personal information for the purpose of inferring characteristics about you.
Retention of Your Personal Information
We will retain your personal information, including sensitive personal information, for no longer than is reasonably necessary for the purpose(s) for which it was collected. In certain cases, personal information may be kept for an extended period of time in order to comply with a legal obligation, or for the establishment, exercise, or defense of a legal claim, in accordance with CCPA.
Individual Rights
The CCPA may provide you with the following rights with respect to your personal information, subject to certain exceptions under the CCPA and applicable law:
Access: You may have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business purpose for collecting that personal information.
- The categories of third parties with whom we share that personal information for business purposes.
- The specific pieces of personal information we collected about you.
- If we disclosed your personal information for a business purpose, a list identifying the personal information categories that each category of recipient obtained.
You may only make two (2) such verifiable consumer requests within a 12-month period.
Deletion: You may have the limited right to request that we delete certain of your personal information we have retained. Once we receive and confirm your request, we will delete personal information we have retained on you.
Correction: You may have the right to request that we correct your inaccurate personal information we have on you.
Portability. You may have the right to request that we transmit your personal information to another entity in a portable, easily understandable, and to the extent technically feasible, in a structured, commonly used, machine-readable, and readily usable format.
Profiling. You may have the right to opt-out of processing of your information which constitutes profiling in furtherance of decisions that produce legal effects or similarly significant effects concerning you.
We will not discriminate against you for exercising any of your CCPA rights.
For Further Information
If you have questions regarding this California Addendum or would like to exercise your rights described in this California Addendum, you may contact us at 1 (844-539-2330) [[email protected]].
Appendix I
- Members of LDC Group Companies that may receive applicants’ Personal Data mean Louis Dreyfus Company B.V., any company or legal entity directly or indirectly controlled by Louis Dreyfus Company B.V., and other entities controlling Louis Dreyfus Company B.V. The address of Louis Dreyfus Company B.V. is Westblaak 92, 3012 Rotterdam, Netherlands.