1. General provisions

1. This Privacy Policy (hereinafter referred to as the “Policy”) applies to all information that X5 Retail Group N.V, registration number 33143036, registered at the address Zuidplein 196 (WTC Tower H, 24th floor), 1077 XV Amsterdam, The Netherlands (hereinafter referred to as the “Company”), may receive about a potential or current customer (hereinafter referred to as the “User”) during their use of the website at www.x5.com (hereinafter referred to as the “Site”).
2. Use of the Site indicates the User’s unconditional consent to this Policy and to the terms for processing the User’s personal information specified therein. If the User does not agree to these terms, they may not use the Site.
3. The Policy regulates the processing of the User’s personal information in connection with the User’s actions on the Site. This Policy does not govern the User’s actions on third-party sites that that User can access through links accessible on the Site.

2. Personal information received and processed by the Company

1. In the context of this Policy, the User’s personal information includes the following:
   1. Personal information that the User provides about themselves when using the Site, including the following personal data:
      1. e-mail address
      2. full name
      3. telephone number
      4. place of employment
   2. Usage data that is automatically transmitted to the Company by the Site, in the course of its use, by means of software installed on the User’s device, including information from cookies about the User’s device:
      1. the IP address of the User’s computer;
      2. the Site pages visited, the time spent visiting the Site, and the time spent on these pages;
      3. unique device identifiers and other diagnostic data. The Company uses cookies and similar tracking technologies to track the User’s activity on the Site and to store the User’s information. Cookies are files that contain a small amount of data that may include an anonymous unique identifier. Cookies are sent to the User’s browser from the website and stored on the User’s device. Other tracking technologies that are used include web beacons, tracer tags and scripts to collect and track information as well as to improve the Site. The User may decline all cookies. By declining cookies, the User may not be able to access certain parts (functions) of the Site.
   3. The Company’s use of cookies includes, but is not limited to, the following:
      1. session cookies – to manage the Site;
      2. preference cookies – to remember the User’s preferences and various settings;
      3. security cookies – to ensure security.
   4. Other personal information that may be processed based on the User’s consent to the processing of personal information.

3. Purposes of collecting and processing Users’ personal information

1. The Site collects and stores only that personal information that is necessary to provide the User with access to the Service or that is processed based on the consent to the processing of personal information that the User provided in the feedback form, except in cases where legislation provides for the mandatory storage of personal information for a period specified by law.
2. The Company processes the User’s personal information, including the collection, receipt, recording, systematisation, accumulation, storage, clarification (updates, changes), extraction, use, transfer (disclosure, access), blocking, deletion or destruction, both automatically and without the use of automation as well as by means of mixed processing for the following purposes:
   1. receiving feedback from the User, including by sending notifications or requests, and processing User requests and queries;
   2. confirming the accuracy and completeness of the personal information provided by the User;
   3. monitoring Site usage;
   4. conducting statistical and other research on the basis of anonymised data from the Site;
   5. for other purposes that may be stipulated by the User’s consent to the processing of personal data or by an agreement between the User and the Company.

4. Terms for the processing of personal information and the transfer thereof to third parties

1. The processing of the User’s personal information is carried out in accordance with the Company’s Personal Information Processing Policy and the requirements of laws on personal information.
2. All of the User’s personal information is kept confidential and secure.
3. The Company may transfer the User’s personal information to third parties in the following cases:
   1. with the User’s consent to such transfer;
   2. if the transfer is necessary for the User’s use of the Site;
   3. in order protect the Company’s rights and legitimate interests;
   4. in other cases stipulated by law.
4. The processing of personal information may be assigned to a third party pursuant to a corresponding agreement with a third party that establishes the obligations of that party to maintain the confidentiality and security of personal information.
5. The Site may contain links to other sites that are not operated by the Company. If the User click on a link, they will contact a website belonging to a third party. The Company strongly recommends that the User reads the privacy policy on each site they visit. The Company does not control or assume any responsibility for the content, privacy policy or actions of third-party sites or services.

5. Measures to protect personal information

1. When processing personal information, the Company takes the necessary legal, administrative and technical measures to protect personal information from unlawful or accidental access, destruction, modification, blocking, copying, disclosure or distribution, as well as from other unlawful actions in relation to the User’s personal information in accordance with the Company’s Personal Information Processing Policy and the requirements of laws on personal information.

6. The Company’s obligations and your obligations

1. The User must:
   1. provide the Company with accurate personal information necessary to use the feedback service.
2. The Company must:
   1. use the personal information received exclusively for the purposes specified in the User’s consent to the processing of the User’s personal information;
   2. maintain the confidentiality of the User’s personal information.

7. Additional terms

1. The Policy is available on the Site at www.x5.com. The Company is entitled to amend the Policy without notification. It is the User’s responsibility to review the Policy periodically for any amendments.
2. The latest version of the Policy shall enter into force upon being posted on the Site unless provided otherwise by the latest version of the Policy.
3. If the User has any questions about the Policy, they can contact the Company at the Company’s address.

Posted at: https://www.x5.com/privacy-policy/

Date of publication: 7 May 2024

Date of entry into force: 7 May 2024