Privacy Statement Sana Commerce

Most recent update of this Privacy Statement: 4th of November 2022

This document is the Privacy Statement applicable to the website of Sana Commerce EMEA B.V. in the Netherlands (“Sana Commerce” or “we” or “us”). We process your personal data when you use our service(s) and/or website (www.sana-commerce.com). As Sana Commerce is strongly committed to protecting your privacy, we conform to the European General Data Protection Regulation (the “GDPR”).

Summary of our Privacy Statement

In compliance with the privacy laws in relation to the processing of personal data, we:

• clearly specify our purposes in this Privacy Statement before we process your personal data;
• minimize the amount of personal data stored and only those data that are necessary for our purposes;
• ask your explicit consent for processing your personal data if consent is obligatory;
• take the necessary security measures to protect your personal data. We furthermore impose these obligations to parties processing personal data on our behalf;
• respect your rights, such as the right to access, the right to rectification of, or the right to erasure of your personal data.

For which purposes do we use your personal data?

By using our website, you provide us with various personal data. The data obtained from you, the purpose(s) for which we process these data, and the duration of data storage are clearly indicated for each purpose. If you have any questions or would like to know which of your records we keep on file, please contact Sana Commerce. Our contact details are given at the bottom of this Privacy Statement.

Contact

If you fill in the online contact form, send us an email message, approach us by telephone, or contact us in any other way, you agree to our offer to contact us. Processing of these data is necessary for the performance of the agreement. In other cases, we will request your specific consent.

We process the following personal data for this purpose:

• Name
• Contact details (email address and telephone number)
• Any personal data you provide as content of a message

We store your data for as long as necessary for the performance of the contract in question or up to a maximum period of two years following our most recent contact date, because we intend to ensure we have dealt with your question or complaint properly.

Commercial communications

Sana Commerce may send you commercial communications in the form of digital newsletters. You can subscribe to our commercial communications via our website. If we approach you as an existing customer with offers of in-house and similar products and/or services, we will do so on the basis of justified interest. If you are not an existing customer, or if the commercial communications do not relate to in-house and similar products and/or services, we will not send you these communications unless we have your consent.

We process the following personal data for this purpose:

• Name
• Contact details (email address and telephone number)

We keep your personal data on record until you unsubscribe from our commercial communications. You can do this at any time, for example via the unsubscribe link in every newsletter.

Free demo

You can request a free demo via our website. Sana Commerce will then contact you to discuss the various options of the free demo with you. To be able to contact you and present a suitable demo proposal, Sana Commerce needs you to provide various personal data. Filling in your personal data on an online or other form is required for us to contact you about the free demo, which is why data processing is necessary for the performance of the agreement.

We process the following personal data for this purpose:

• Name
• Contact details (email address and telephone number)
• Company name (if this falls under personal data)
• Seniority/job title

We keep your personal data on file for a maximum period of 5 years. We retain certain data for a longer period if we are required by law to do so, for example by virtue of the 7-year obligation to retain data for tax purposes.

Assessment meeting

You can book an assessment meeting via our website, in which we can answer your e-commerce questions. To be able to contact you and plan a meeting with you, Sana Commerce needs you to provide various personal data. Filling in your personal data on an online or other form is required for us to contact you about the assessment meeting, which is why data processing is necessary for the performance of the agreement.

We process the following personal data for this purpose:

• Name
• Contact details (email address and telephone number)
• Company name (if this qualifies as personal data)
• Seniority/job title

We keep your personal data on file for a maximum period of 5 years. We retain certain data for a longer period if we are required by law to do so, for example by virtue of the 7-year obligation to retain data for tax purposes.

Job application

Did you respond to one of our job vacancies or did you send us a speculative letter? Then we process your personal data for handling your job application and for possibly preparing an employment contract.

We process the following personal data for this purpose:

• Name and address
• Contact details (email address and telephone number)
• Curriculum Vitae/Résumé
• Cover letter
• Salary indication
• Referees
• Any other information you provide as part of your job application

We keep your application details on file for a maximum period of 6 weeks after the vacancy is filled. We retain these data so that we can contact you in case the job opening becomes available after the probationary period. If we cannot make you a job offer, with your consent we can keep your application details on file for an additional year. You can withdraw your consent at any time by sending us an email accordingly. By contrast, if you take up employment with Sana Commerce, we will keep your application details in your personnel file. This file will be store for as long as required.

The application procedure may comprise a social media and internet survey. It is crucial for safeguarding our solid reputation when taking on new employees, and is therefore carried out on the basis of our justified interest. This entails using your name to search Google, and any profiles to search various social media. This clearly applies to publicly accessible profiles only. We will not ask you to grant us access to any blocked social media pages or to create a link with us. The results of such survey will be discussed with you. If you object to this procedure, please notify us accordingly via email together with your job application.

When can we share your personal data with third parties?

Sana Commerce may share your data with third parties if permitted under applicable legislation. We may share your personal data with any third party for the following reasons:

• We engaged this third party to process certain data.
• There is a statutory basis for us to share data.
• We have a statutory obligation to share data, for example if law enforcement has grounds to suspect a serious offence has been committed.

The following parties may process personal data on our or your instructions:

• IT suppliers and IT service providers
• Hosting parties.
• Marketing companies

Sana Commerce may share your personal data with parties outside the European Economic Area (EEA) for the purpose of providing such services. It will do so only if an adequate level of protection of personal data processing applies.

Social media buttons

We use social media buttons on our website, which take you to the applicable social media platform. This enables you to follow us and to share content within the network, and presents advertisements on your social media page(s). Functioning of the buttons is facilitated by codes originating from the social media networks. For any information on how the social media platforms use your personal data, please read the applicable privacy statement:

• Facebook (privacy statement)
• Twitter (privacy statement)
• LinkedIn (privacy statement)
• Instagram (privacy statement)

Protecting your personal data

Sana Commerce takes adequate technical and organisational measures concerning the processing of personal data, to prevent loss, or to prevent any form of unlawful processing (such as unlawful access, interference, alteration, or unauthorised disclosure of the personal data