Privacy Statement PION Document Centre

1. What this statement covers

This privacy statement describes how PION Kunststoffen B.V., trading as PION Cable Protection (hereinafter: “PION”), processes personal data in the PION Document Centre at documents.pioncableprotection.com (hereinafter: “Portal”). The Portal is a closed environment in which PION's distributors and their employees consult product documentation, imagery, the CrossCube configurator and reference projects.

This statement applies to the Portal only. PION's public website has its own privacy statement, published there. Use of the Portal is additionally governed by the User Agreement, available through the Portal.

2. Who is responsible

PION is the controller for the personal data processed in the Portal.

PION Kunststoffen B.V. trading as PION Cable Protection Stadsring 147 3817 BA Amersfoort, Netherlands Phone: +31 (0)33 253 8630 Email: info@pioncableprotection.com Chamber of Commerce (KvK): 32098281

3. Whose data we process

We process data of:

• • employees of distributors who hold an account in the Portal (hereinafter: “users”);
• • contact persons of distributors with whom PION communicates about the Portal;
• • PION employees who administer the Portal;
• • persons who appear in reference projects submitted by distributors, for example in photographs or as a project contact.

4. Which data we process

Account data. Your name, your business email address, the distributor you work for, your role in the Portal (user or administrator), the status of your account (active or blocked) and your language preference. We receive this data from your employer or from you when the account is created.

Sign-in data. Your password (stored in encrypted form only), sign-in codes sent by email, invitation links and the details of your sign-in session.

Security data. The time and outcome of sign-in attempts and the IP address from which the sign-in is made. We use this data to limit the number of sign-in attempts and to recognise misuse.

Confirmations. When you confirm the User Agreement and this privacy statement, we record who did so, when, which version of the document it concerned (with a checksum of the text), and the IP address and browser details with which the confirmation was given, so that we can demonstrate the confirmation later.

Administration data. When a PION administrator creates, blocks or deletes an account, or changes a distributor's access, we record which administrator did so and when.

Submitted content. When you submit a reference project, we process the texts, photographs and location details you provide, and we record which user and which distributor submitted the project.

Settings. Whether you have viewed the CrossCube configurator walkthrough, and your choice not to see it again.

Correspondence. Emails and telephone contact with PION about the Portal, for example a request to block an account.

We do not process special categories of personal data or data of persons under the age of 16.

5. What we use your data for and on which legal basis

We use your data solely for the following purposes:

• • creating, managing and securing your account and arranging your access to the content released to your distributor (legal basis: performance of the User Agreement);
• • sending invitations, sign-in codes, password resets and service messages about the Portal by email (legal basis: performance of the User Agreement);
• • securing the Portal, including limiting sign-in attempts, investigating incidents and keeping a record of administrative actions (legal basis: PION's legitimate interest in a secure and well-managed Portal);
• • demonstrating that the User Agreement and this statement have been confirmed (legal basis: legitimate interest and, where applicable, legal obligation);
• • reviewing, editing and publishing submitted reference projects (legal basis: performance of the User Agreement);
• • handling your questions and requests (legal basis: legitimate interest or legal obligation).

We do not use your data for any purpose other than those listed above.

6. What we do not do

• • We use no advertising or tracking cookies and no third-party analytics services in the Portal.
• • We do not keep track per user of which documents you view or download.
• • We do not use your data for marketing and send no newsletters from the Portal.
• • We do not sell your data and do not share it with third parties for their own purposes.
• • We make no decisions about you based solely on automated processing.

7. Cookies

The Portal uses only functional cookies and similar browser storage that are necessary for it to work:

• • a session cookie that keeps you signed in;
• • a cookie holding your language choice (Dutch or English);
• • a local browser setting that remembers which sign-in method you used last.

These cookies do not require consent, which is why the Portal shows no cookie banner. You can delete cookies through your browser settings; you will then be asked to sign in again.

8. Who has access to your data

PION employees. PION administrators see users' account data in order to manage accounts and access and to review submitted reference projects.

Your employer. Your distributor decides who is given access on the company's behalf and notifies PION when an account must be blocked or deleted. PION may inform your distributor's contact person about the status of the company's accounts. Your distributor has no access to your sign-in or security data.

Processors. To run the Portal we engage service providers that process data solely on our instructions. They fall into the following categories:

• • hosting of the application;
• • database, authentication and file storage;
• • sending of email from the Portal;
• • automatic translation of product texts and submitted project texts; only those texts, and never users' data, are sent for this purpose;
• • looking up project locations on the map; only the entered place name or address is sent for this purpose.

We have concluded data processing agreements with these providers where the law requires it. A current list of the providers we engage is available from us on request.

Other recipients. We disclose data to third parties where a legal obligation or a court order requires us to do so.

9. Where your data is stored

The Portal and its database and file storage are hosted within the European Union. Where a service provider processes data outside the European Economic Area, we ensure appropriate safeguards in accordance with Chapter V of the General Data Protection Regulation (GDPR), such as the European Commission's standard contractual clauses or a valid adequacy decision.

10. How long we keep your data

• • Account data: for as long as your account exists. When the account is deleted, this data is erased.
• • Pending invitations: 14 days, after which they expire automatically.
• • Sign-in and security data: a short, fixed period, for security purposes only, after which it is deleted automatically.
• • Administration data: a limited period, after which it is deleted automatically.
• • Confirmations of the User Agreement and this statement: for as long as your account exists.
• • Submitted reference projects: for as long as the project is shown in the Portal, or until your distributor asks for its removal.
• • Correspondence: for as long as needed to handle your request, and thereafter as long as the law requires.

Deleted data remains present in secured backups for a limited time until these are overwritten automatically.

11. How we protect your data

We take appropriate technical and organisational measures to protect your data against loss, misuse and unauthorised access. These include encrypted connections (TLS), access control per distributor enforced at database level, encrypted storage of passwords, short-lived single-use sign-in codes, limits on the number of sign-in attempts, logging of administrative actions, regular backups and periodic security reviews.

Your business mailbox gives access to sign-in codes and password resets. Please secure that mailbox well and tell your employer and PION immediately if you suspect that your sign-in details or your mailbox have been compromised.

12. Your rights

You have the right to access your personal data, to have it corrected or deleted, to have its processing restricted, to object to processing based on legitimate interest, and to receive your data in a commonly used format.

You can send a request to info@pioncableprotection.com. We respond within one month. To verify your identity we may ask you to make the request from the email address of your account. Deleting your account means you no longer have access to the Portal; your employer is informed of this.

If you have a complaint about the processing of your personal data, please contact us first. You also have the right to lodge a complaint with the Autoriteit Persoonsgegevens, the Dutch Data Protection Authority.

13. Your employer and the Portal

Your account exists because your employer, the distributor, arranged your access to the Portal. Your employer is itself responsible for the personal data it provides to PION and for notifying PION in good time when you should no longer have access, for example when you leave the company. Your employer should inform you about this processing; this statement is the basis for that.

If your company uses a shared mailbox as an account, your employer is responsible for who has access to it. In that case PION cannot see which individual employee used the account.

If you submit a reference project in which persons appear, your distributor ensures that those persons have given their consent.

14. Data breaches

Should a personal data breach occur that affects you, PION acts in accordance with the GDPR. We inform your distributor's contact person, report the breach to the Autoriteit Persoonsgegevens where required, and inform the persons concerned when the breach poses a high risk to them.

15. Changes

We may amend this privacy statement, for example when the Portal gains new features. The current version is always available in the Portal, with a version date. After a change we ask you to take note of the new version at your next sign-in.

16. Contact

Questions about this privacy statement or about the processing of your data in the Portal can be sent to info@pioncableprotection.com or asked by telephone on +31 (0)33 253 8630.