Privacy Policy

Last updated May 2018

Peleman Group Privacy Statement
May, 2018

Peleman Group is dedicated to protecting the confidentiality and privacy of information entrusted to the group. As part of this fundamental obligation, Peleman Group is committed to the appropriate protection and use of personal data (also referred to as “personal information”).

The company’s intent is to collect only the personal data that is provided to us so that we can offer information and/or services and share information about employment opportunities. Please review this privacy statement (“Privacy Statement”) to learn more about how we collect, use, share, protect and process personal data.

1. Collection and use of personal information

1.1 What type of data do we collect

1.2 Legal grounds to use your personal data

1.3 Purposes for which your personal data will be processed

1.4 Automatic collection of personal information

1.4.1 IP addresses

1.4.2 Cookies

1.4.3 Web beacons

1.4.4 Third Parties

1.4.5 Location-based tools

1.5 Social media widgets and applications

1.6 Children

2. Sharing and transfer of personal data

2.1 Transfers to third parties

3. Choices

4. Your rights

5. Data security and integrity

6. Links to other sites

7. Changes to this statement

8. Who is responsible for the processing of your personal data

9. Who to contact in case of questions

10. Statement questions and enforcement

1.   Collection and use of personal data
1.1  What type of data do we collect
We obtain personal data about you if you choose to share it with us – for example, to contact mailboxes, participate in offers or register for certain services. In some cases, you may have previously provided your personal data to group companies of Peleman Group (if, for example, you are a former employee or customer or partner of any of our subsidiaries).
By registering and/or submitting personal data to Peleman Group, you are giving your consent to us so that Peleman Group may use this data in accordance with this Privacy Statement. Your personal data is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards. For example, if you subscribe to our services or participate in any of our offers and provide information about your preferences, we will use this information to personalise your user experience. If you subscribe to receive direct marketing (i.e. newsletters, insights, events etc.) we may use your personal data in order to send you such messaging. If you send us a resume or curriculum vitae (CV) to apply online for a position at any of the subsidiaries of Peleman Group, we will use the information that you provide to match you with available job opportunities at the Group.

1.2 Legal grounds to use personal data
Peleman Group generally collects only the personal data necessary to fulfill your request. Where additional data is sought, you will be notified of this at the point of collection.
The applicable legislation allows us to process personal data, so long as we have a processing ground under the law to do so. It also requires us to tell you what those grounds are. As a result, when we process your personal data, we will rely on one of the following legal grounds for processing:

• Performance of a contract: this is when the processing of your personal data is necessary in order to perform our obligations under a contract or the intention to enter into a contract;
• Legal obligation: this is when we are required to process your personal data in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency;
• Legitimate interests: we may process data about you where it is in our legitimate interest in running a lawful business to do so in order to further that business, so long as it doesn’t outweigh your interests; or
• Your consent: we may occasionally ask you for specific permission to process some of your personal data, and we will only process your personal data in this way if you agree to us doing so. You may withdraw your consent at any time by contacting Peleman Group at  

1.3 Purposes for which your personal data will be processed
We will only process your personal data for specified, explicit and legitimate purposes and we will not process your personal data further in a way that is incompatible with those purposes.
This purpose can be the execution of an engagement, the improvement of your visit on our website or portals, the improvement of our products and services more generally, the offering of services or applications, marketing communications and actions, web personalisation, direct marketing and web analytics among others.
The purpose of each processing of your personal data will be clearly defined in the privacy notice. This privacy notice will be accessible, for example, on a website or portal, on an application, in an electronic newsletter and all other communications.

1.4 Automatic collection of personal data
In some instances, Peleman Group and its service providers use cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online, as well as through emails that we may exchange. The collection of this information allows us to customise your online experience, improve the performance, usability and effectiveness of Peleman Group and its subsidiaries’ online presence, and to measure the effectiveness of our marketing activities.

1.4.1 IP addresses
An IP address is a number assigned to your computer or Internet enabled device whenever you access the Internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct website trend and performance analysis.

1.4.2 Cookies
A ‘Cookie’ is a small piece of text that a website places in the browser or Cookies may be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes.
On some of our websites, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or Internet-enabled device will not be tracked for marketing-related activities. A secondary type of cookie referred to as “user-input” cookies may still be required for necessary functionality. Such cookies will not be blocked through the use of this notification banner. Your selection will be saved in a cookie and is valid for a period of 90 days. If you wish to revoke your selection, you may do so by clearing your browser’s cookies.
Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser’s settings. You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of the features offered on our websites.
Further information about managing cookies can be found in your browser’s help file or through related online sites.

How to disable cookies?
If you would like to block cookies, you can do so for the browser you use.
When you disable cookies, remember that some graphics may not appear correctly, or that you may be unable to use certain applications or online services.
If you wish to delete the placed cookies, you may do so by clearing your browser’s cookies.

Types of Cookies
“Session” Cookies are stored in the device’s memory only during a user’s browsing session and are automatically deleted from the user’s device when the browser is closed.
“Persistent” Cookies are stored on the user’s device and are not deleted when the browser is closed, unless deleted by you. Permanent cookies can retain user preferences for a particular website, allowing those preferences to be used in future browsing sessions.
Below is a list of the types of cookies used on our web sites:

Other third party tools and widgets may be used on our individual webpages to provide additional functionality. Use of these tools or widgets may place a cookie on your device to make their service easier to use, and ensure your interaction is displayed on our webpages properly.
Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our web sites and geographic origin of visitor trends, and not to identify individual visitors. By navigating on our websites or entering you log-in details to access areas reserved for registered users, you agree that we can place these cookies on your computer or Internet enabled device.

1.4.3 Web beacons
A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. Peleman only uses web beacons in accordance with applicable laws.
Peleman or its service providers may use web beacons to track the effectiveness of third party web sites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.
You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address but cookie information will not be recorded.
In some of our newsletters and other communications, we may monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences.

1.4.4 Third Parties

Hotjar
We use Hotjar in order to better understand our users’ needs and to optimise this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click on, what are our users’ preferences, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices (in particular device’s IP address), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website etc.). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link.
You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.

Lead Forensics
For marketing and optimisation purposes, our website uses products and services of the company Lead Forensics, Communication House 26 York Street, London, W1U 6PZ, United Kingdom. Lead Forensics determines details of your organisation, such as phone number, website address, SIC code, and a business description. In so doing, Lead Forensics shows the actual process of your visit to this website, including all pages visited and viewed by you, and the time spent on our website. The data will never be used for the personal identification of an individual visitor. Any collected IP addresses are anonymised immediately after collection. On behalf of Hanse Orga, Lead Forensics will use the collected information to evaluate your visit to this website, to compile reports on website activity, and to provide other website and Internet-related services to Hanse Orga.
If you do not agree to this, you can object to the collection, processing, and storage of the data at any time with effect for the future by clicking on the following link: “Deactivate Lead Forensics“
Further information on the terms of use and data privacy at Lead Forensics is available at http://www.leadforensics.com/privacy-and-cookies/.

Google analytics and Google Tag Manager
We rely on Google Analytics and Google Tag Manager, two services provided by Google, Inc. (“Google”), to analyse your use of the website. The information generated by Google Analytics is subject to Google’s privacy policy and will be transferred to and stored by Google on servers in the USA. Prior to the transfer, it will be anonymised by removing the last octet of your IP address. Google will then process it on our behalf in order to evaluate your use of the website, to compile reports on website activity and to provide other services related to Internet usage. Google will not link your IP address with any other data held by Google. You may refuse the use of cookies for the aforesaid purposes by setting your browser accordingly; however, in that case, you may not be able to use the full functionality of the website. You may further opt-out of the collection of your usage data (including your IP address) and its processing by downloading and installing the add-on for your current web browser at http://tools.google.com/dlpage/gaoptout?hl=en. For more information about the use of your data by Google, please see http://www.google.com/analytics/learn/privacy.html.

1.4.5 Location-based tools
Peleman Group may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based communications and services.

1.5 Social media widgets and applications
Peleman Group websites may include functionality to enable sharing via third party social media applications, such as the Facebook Like button and Twitter or Instagram widget. These social media applications may collect and use information regarding your use of  websites related to group companies of Peleman Group. Any personal data that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.
In addition, Peleman Group websites may host blogs, crowd-sourcing and other applications or services (collectively “social media features”). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal data that you provide on any Peleman Group social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.

1.6 Children
Peleman Group (and all subsidiaries) understands the importance of protecting children’s privacy, especially in an online environment. In particular, our sites are not intentionally designed for or directed at children.

2. Sharing and transfer of personal data

2.1 Transfers to third parties

We do not share personal data with unaffiliated third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards.  In addition, Peleman Group may transfer certain personal data across geographical borders to other group companies or outside companies working with us or on our behalf. Pelemen Group may also store personal data in a jurisdiction other than where you are based. Transfer of personal data by Peleman Group takes place in accordance with the applicable European Union data protection legislation

• Peleman Group may also disclose personal data to our service providers: Peleman Group works with reputable partners, service providers or agencies so they can process your personal data on our behalf. Peleman Group and its subsidiaries will only transfer personal data to them when they meet our strict standards on the processing of data and security. We only share personal data that allows them to provide their services.
• Audits: disclosures of personal data may also be needed for data privacy or security audits and/or to investigate or respond to a complaint or security threat.

In addition, Peleman Group may transfer certain personal data outside of the EEA to outside companies working with us or on our behalf for the purposes described in this Privacy Statement. Peleman Group may also store personal data outside of the EEA. If we do this your personal data will continue to be protected by means of contracts we have in place with those organisations outside the EEA, which are in a form approved by the European Commission. By providing personal data online, visitors are consenting to this transfer and/or storage of their personal data across borders.
Peleman Group will not transfer the personal data you provide to any third parties for their own direct marketing use.

3. Choices
In general, you are not required to submit any personal data to Peleman Group, but we may require you to provide certain personal data in order for you to receive additional information about our services and events. Peleman Group may also ask for your permission for certain uses of your personal data, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.
As described in “Cookies” above, if you wish to prevent cookies from tracking you as you navigate our sites, you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our sites may not work properly if you elect to refuse cookies.

4. Your rights
If you have submitted personal data to Peleman Group, you have the following rights:

• Access and correction: you have the right to access to that data. This is sometimes called a ‘Subject Access Request’. If we agree that we are obliged to provide personal data to you, we will provide it to you free of charge. Before providing personal data to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal data. If the information we hold about you is incorrect, you may ask us to correct any inaccuracies in the personal data.
• Object to processing: you have the right to object to us processing your personal data if we are not entitled to use it any more, to have your data deleted if we are keeping it too long or have its processing restricted in certain circumstances.
• Right to restriction of processing: you have the right to request a restriction on the processing of your personal data (for example, while the accuracy of your personal data is being checked).
• Right to erasure: you have the right to the erasure of any data concerning you (except in some cases, for example, to prove a transaction or when required by law).
• Right to data portability: under certain conditions, you have the right to receive your personal data, which you have provided to us, in a commonly used, structured machine readable format and to transmit your personal data to any third party of your choice.

You can make a request or exercise these rights by contacting Peleman Group at   and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

5. Data security and integrity
Peleman Group has reasonable security policies and procedures in place to protect personal data from unauthorized loss, misuse, alteration, or destruction. Despite Peleman Group’s best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal data is limited to those who have a need to know. Those individuals who have access to the personal data are required to maintain the confidentiality of such information.
We also make reasonable efforts to retain personal data only for so long as the data is necessary to comply with an individual’s request or with the applicable legislation.

6. Links to other sites
Please be aware that Peleman Group websites may contain links to other sites, including sites maintained by other subsidiaries that are not governed by this Privacy Statement but by other privacy statements that may differ somewhat. We encourage users to review the privacy policy of each website visited before disclosing any personal data.
By visiting any website managed by subsidiaries of Peleman Group and then navigating to another Peleman Group website, you agree to the use of your personal data in accordance with the privacy statement of the Peleman Group website you are visiting.

7. Changes to this statement
Peleman Group may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the “updated” date at the top of this page. We encourage you to periodically review this Privacy Statement to be informed about how Peleman Group and its subsidiaries are protecting your data.
If we make any significant changes in the way we treat your personal data we will make this clear via our website.

8. Who is responsible for the processing of your personal data from www.peleman.com?
Unibind Manufacturing Ltd
13 Ayiou Procopiou
2406 Engomi
Lefkosia, Cyprus

9. Who to contact in case of questions?
We have appointed a data protection officer who will handle your questions or requests relating to this Privacy Statement, any specific privacy notice or your personal data (and its processing).
For any questions or requests or complaints concerning the application of this Privacy Statement or to exercise your rights, as described in this this Privacy Statement, you may contact us at

10. Statement questions and enforcement
Peleman Group is committed to protecting the online privacy of your personal data. If you have questions or comments about our administration of your personal data, please contact us at . You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement.