Privacy Policy

With respect to personal data of ‘external contacts’

1. Introduction

Pursuing the goals of Refresco requires the processing of personal data. When processing such data, we are required to comply with the applicable laws and regulations. That goes for personal data pertaining to ‘you’ as our (potential) customer, consumer, prospect, job applicant, visitor of our plant(s) and business partner (supplier, agent or advisor). In the context of this Privacy Policy you and other natural persons of which we process personal data will be referred to as ‘external contacts’.


This Privacy Policy describes the personal data that Refresco collects from or about you, and how we use and to whom we disclose that personal data. 

2. Application and scope of this Privacy Policy

This Privacy Policy applies to the personal data of all of our external contacts. 

3. Organizations covered by this Privacy Policy

This Privacy Policy applies to Refresco, its parent company and its subsidiaries and other affiliated entities. All references in this Privacy Policy to Refresco", "we", "us", "our" and like terms should be interpreted accordingly. 

It is Refresco’s policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and / or an individual's right to privacy are different from one jurisdiction to another. If you are unsure if or how this Privacy Policy applies to you, please contact the office of our [name department and/or contact person].

4. What is personal data?

Personal data is any information about an identifiable individual, other than the person's business title or business contact information when used or disclosed for the purpose of business communications. Personal information does not include anonymous or non-personal information (i.e., information that cannot be associated with or tracked back to a specific individual).

5. What personal data do we process?

In our business operation we process different types of personal data of our external contacts, including, but not limited to, the personal data contained in:

  • completed contact forms;
  • submitted complaints;
  • communications, via post, e-mail, phone, websites or social media platforms;
  • job application letters;
  • the books in which names and signatures of visitors of our factories are recorded;
  • public sources (such as the Commercial Trade Registers);
  • databases from third parties.

In addition to the examples listed above, personal data also includes information such as gender, date of birth, education and/or training details, bank details and any other information necessary to achieve Refresco’s business purposes, which is disclosed in the context of having contact or doing business with, or applying for a job at, Refresco.

As a general rule, Refresco processes personal data directly provided by external contacts. From time to time, we may utilize the services of third parties in our business and may also receive personal data collected by those third parties in the course of the performance of their services for us or otherwise. Where this is applicable, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose the personal data of external contacts to us. 

Where permitted or required by applicable law or regulatory requirements, we may process information about external contacts without their knowledge or consent.

6. Why do we collect personal data? 

Refresco processes personal data of external contacts for its business purposes only. We can inter alia process personal data of external contacts for the following purposes: 

  • the entering and execution of an agreement in respect of the products and/or services we deliver;
  • the entering and execution of an agreement in respect of the products and/or services external contacts deliver;
  • to offer products and/or services from us and to adapt them to the needs and wishes of external contacts;
  • to be able to review the products and services that we obtain from you so that we may work with you and so that you may understand our requirements for such products and services;
  • to be able to contact external contacts via applicable media;
  • to be able to handle complaints;
  • to be able to handle job application letters; 
  • to be able to guarantee the safety of visitors and employees of our factories; 
  • to protect us against error, fraud, theft and damage to our goods and property, including to verify your identity;
  • in case the external contact has given unambiguous consent: to send press releases (with information about our company organization;
  • in case the external contact has given unambiguous consent: to show ads (e.g. on social media);
  • to send the external contact user information and service messages;
  • to analyze, maintain, secure and optimize our websites and associated technologies;
  • for compiling user statics of our websites;
  • to comply with relevant laws and regulations; 
  • such other purposes as are reasonably required by Refresco.

Please note that personal data of external contacts may be exchanged with, or made available to our subsidiaries for the aforementioned purposes.

7. Recruitment 

In connection with your application for work with us, we will use the personal data we collect about you to:

  • assess your skills, qualification, 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 process;
  • comply with legal or regulatory requirements. 

We also need to process your personal data to decide whether to enter into a contract of employment with you. Having received you CV, covering letter or your application form and the results from the test, which you took, if applicable, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. 

If we decide to call you for an interview, we will use the information you provide to us at the interview, to decide whether to offer you the role. 

If we decide the offer you the role, we might than take up references before confirming your appointment. 

If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis. 

If you fail to provide information when requested, which is necessary for us to consider your application, we will not be able to process your application successfully. 

8. How do we use your personal data?

We may use your personal data:

  • for the purposes described in this Privacy Policy; or
  • for any additional purposes that we advise you of and where your consent is required by law and have obtained your consent in respect of the use or disclosure of your personal data.

We may use your personal data without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

9. When do we disclose your personal data

As a principle, we do not disclose personal data to third parties. However, disclosing personal data of external contacts to third parties might be necessary in the performance of an agreement between Refresco and the external contact. At all times, any third party must act on the instructions of Refresco and ensure personal data is adequately protected. 

10. How is personal data protected?

Refresco will take all reasonable precautions to keep your personal information secure, appropriate to our business and the amount of personal data that we own or maintain and identified risks. 

11. How long is personal data retained?

Except as otherwise permitted or required by applicable law or regulatory requirements, Refresco endeavors to retain personal data of external contacts only for as long as it believes is necessary to fulfill the purposes for which the personal information was collected (including, for the purpose of meeting any legal, accounting or other reporting requirements or obligations). 

We may, instead of destroying or erasing personal data of the external contact(s) make it anonymous such that it cannot be associated with or tracked back to the external contact(s).

12. Links to third party websites

Our website(s) may contain hyperlinks to third party websites and social media platforms. Once you have used these links to leave our site, you should note that we do not have any control over that other website or social media platform. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Policy. 

You should exercise caution and look at the privacy statement applicable to the website in question. Moreover, we are not responsible nor liable for the content of third party websites or platforms.

13. Access to your personal data 

It is important that all personal data in our records is both accurate and up-to-date. You can exercise your rights with respect to your personal data, such as the right of access, rectification, erasure and objection. Please use the contact information provided below. We strive to respond to your request within four (4) weeks. Occasionally it may takes us longer than four (4) weeks 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.

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. 

14. Other Refresco privacy policies

Besides this Privacy Policy, specific campaigns or promotions may be governed by additional privacy terms. Please take a moment to familiarize yourself with such terms before participating in any such campaigns or promotions. 

15. Inquiries or concerns?

If you have any questions about this Privacy Policy or concerns about how we process and manage personal data of our external contacts, please contact [name department and/or contact person], in writing or by e-mail. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. 

We have appointed [name department and/or contact] to oversee compliance with this Privacy Policy. The contact information is as follows:

[contact information]

16. Revisions to this Privacy Policy

Refresco may from time to time make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with the personal data of external contacts. We will communicate any revised version of this Privacy Policy via our website(s). Any changes to this Privacy Policy will be effective from the time they are communicated. This Privacy Policy was last reviewed on 15 May 2018. 

17. Interpretation of this Privacy Policy

Any interpretation associated with this Privacy Policy will be made in accordance with Dutch law. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word 'including' is used, it shall mean 'including without limitation. This Privacy Policy does not create or confer upon any individual any rights, or impose upon Refresco any rights or obligations outside of, or in addition to, any rights or obligations imposed by the privacy laws applicable to such individual's personal data. Should there be, in a specific case, any inconsistency between this Privacy Policy and such privacy laws, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.