Privacy statement

1. Privacy Policy 
This Privacy Policy explains which personal data Logistiek Centrum Gorinchem BV (“LCG”) and its associated companies collect from you through our interaction with you and through our services and products as well as the manner in which this takes place, how the personal data is used by us, how long we retain the personal data, how you can gain insight into and adjust the personal data we hold and how your personal data is protected with us.

1.1 Our company details are:
Logistiek Centrum Gorinchem BV
Ambonstraat 2
4202 ML Gorinchem
The Netherlands
Telephone: +31 (0)183 - 22 90 00
Mail: info@lcgterminal.nl
KvK (Netherlands Chamber of Commerce): 24354019                       

1.2 Questions
Should you have any questions about our Privacy Policy and exercising your rights or have any requests regarding transparency, you can contact us by mail and telephone through the contact information posted above or through the personal communication channels you have with LCG.

2. Applicability of the General Data Protection Regulation
When processing data, the General Data Protection Regulation (GDPR) or its Dutch equivalent - Algemene Verordening Gegevensbescherming or AVG - may be applicable. Hereinafter, this will be referred to as the AVG. The AVG is applicable to situations in which personal data is processed in a fully or partially automated manner, but also to the manual processing of personal data contained in a file or intended to be included in this.

We process your personal data in accordance with the purpose for which said data was provided. These goals and types of personal data are described in this Privacy Policy:

  1. Processing of your personal data is solely limited to only that data which is minimally required for the purposes for which it is processed;
  2. Requesting your explicit consent if we require this for the processing of your personal data;
  3. Having appropriate technological and organisational measures in place to ensure that your personal data is protected;
  4. Not passing on personal data to other parties, unless this is necessary for the execution of the purposes for which said data is provided;
  5. Informing you of the rights you have with regard to the processing of your personal data.

3. Which personal data do we process?
We process the personal data that you have provided to us, for example in the context of the supply of products and/or services to you, or that has been obtained by us because you have made use of our digital services, our website, have filled out a contact form or have subscribed to our newsletter or have indicated a preference for the kinds of information which you would like to receive from us.
The personal data which we process about you may include the following:

  1. Your name

  2. Your (company) address

  3. The position you hold within the company

  4. Your contact details such as telephone number, address, email address, details of your social media

  5. Date and place of birth

  6. The IP address of the computer you use to visit our website

  7. Bank account numbers

  8. Details of identity documents (passport photo and Citizen Service Number)

4. Processing purposes: For which reasons do we process personal data?
LCG uses the data that is processed for:

  1. Its business operations
  2. Recruitment
  3. Supply of products and services
  4. Improvement of products and services
  5. The organisation of events

4.1 Business operations
Under Article 28 of the Dutch Wage Tax Act, LCG as an employer is obliged to include a copy or scan of the identity document of its employees in the payroll administration. A copy or scan of the identity document is made the moment an employee joins LCG. This enables us to demonstrate later that our employees have properly identified themselves and were legally in the Netherlands. In addition, the copies of the identity documents processed by us are used for inspections in the workplace by, for example, the Inspectorate SZW of the Ministry of Social Affairs and Employment.

4.2 Supply and improvement of products and services
Furthermore, LCG is a business-to-business company and therefore supplies products and services to companies rather than to consumers. We gather (personal) data that you have provided to us in the context of the supply of those products and services in order to inform you about and offer these products and services to you in the best possible manner. Furthermore, your personal data may also be used in the communication with customers and users of our digital services, for example for providing information about user accounts, security updates and product information.

4.3 Recruitment for LCG
We use personal data for recruitment on behalf of LCG and its group companies.
We may provide these items of personal data to these companies.

5. How is personal data stored with us?
These are some of the databases used by LCG to store personal data:

  • Unit 4
  • Modality
  • Microsoft Office 365 products
  • People inc.
  • Yealink telephones
  • MAS 24

This list of most important databases is based on an inventory performed on the date on which this Privacy Policy was drawn up and is subject to change.

6. With whom may your data be shared?
Personal data can be shared with:

  • Other LCG companies and companies in which LCG has a majority interest.
  • Customers for whom we perform services or management functions
  • Social media
  • Clients, suppliers or subcontractors, government agencies and other business relations.

6.1 Basis for provision of personal data
We do not provide data to the above-mentioned parties “just like that”. There must be a basis for the provision of data. Data is provided on the basis of:

  1. A legitimate interest
  2. Legal obligation and/or
  3. To implement the agreement in accordance with the aforementioned goals
  4. Permission
  5. LCG has included the applicable basis for provision in its processing register.

LCG considers the following activities as the granting of consent:

  • Exchange of business cards
  • Request for information
  • Request for quotation
  • Execution of an order
  • Permission to use data by email /Mailchimp

7. Processing of personal data
We enter into a processor agreement with processors of personal data. We record this processing agreement in a processing register.
The following items are included in this processing register:

  • The name and contact details of the responsible party;
  • The purposes for which the data is processed;
  • The categories of data (such as name and address details, contact details, payment details);
  • The categories of data subjects (for example: customers, employees, suppliers);
  • The categories of recipients (to whom is the data provided?);
  • Information about any transfer of data to countries outside the EU;
  • The retention periods of the data;
  • The manners in which data is secured (for example: encryption, access control, etc.)

7.1 Processing register
Since LCG has no obligation to appoint a data protection officer, this has not been included in the processing register. Instead, LCG has included the roles of process owner and application manager in the processing register. In this respect, it is stipulated that the owner can never be the same person as an application manager, thus realising the “four eyes” principle. LCG has translated the purposes for which the personal data is processed into the process for which the personal data in question is used. This processing register also includes the retainment period and the location where the data is hosted: Netherlands (NL), EU or outside the EU.

8. Rights of data subjects
By law, every person can exercise certain rights with regard to his or her personal data. For example, you have the right to see, correct and delete personal data. You can also object to the use of your data or request that this use be restricted. In some cases, you can even request your data and transfer it to another party. Please contact us via by phone or at info@lcgterminal.nl with any questions you may have in this respect.

9. Retention periods
We will retain your personal data for as long as this is necessary for the purpose for which we obtained the data, unless a legal retention period is in effect.

10. Complaints?
Should you have complaints about the manner in which we handle your personal data, then you can contact us by sending an email to info@lcgterminal.nl or by calling us. We are happy to work with you to find a solution. Should this still not yield a satisfactory result, then you can always contact the Dutch Data Protection Authority. Your trust is our top priority. Therefore, we will always treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.