1. Responsible for Processing Your Data

NTS Holding BV is a private limited liability company incorporated under the laws of the Netherlands, with its registered office at Ambachtenstraat 9, 4731 RE Oudenbosch, the Netherlands, and registered with the Dutch Chamber of Commerce under registration number 24274933 (hereinafter referred to as “NTS Holding”).

NTS Computers Technology BV (a wholly owned subsidiary of NTS Holding BV) is a private limited liability company incorporated under the laws of the Netherlands, with its registered office at Ambachtenstraat 9, 4731 RE Oudenbosch, the Netherlands, and registered with the Dutch Chamber of Commerce under registration number 24238658 (hereinafter referred to as “NTS Computers”).

For the purposes described in this Privacy and Cookie Policy, NTS Holding and NTS Computers act as joint data controllers, jointly determining the purposes and means of collecting, storing, publishing, using, and otherwise processing personal data. Hereinafter, these two entities shall collectively be referred to as “NTS”.

Any reference to “we”, “us”, or “our” in this Privacy and Cookie Policy shall be deemed to refer to NTS.

2. Purpose of This Privacy and Cookie Policy

This Privacy and Cookie Policy explains how NTS collects, uses, and protects personal information obtained during your visit to any of the NTS websites, online applications, or mobile platforms. NTS is committed to safeguarding the privacy, confidentiality, and security of your personal data.

All personal data collected through our websites, applications, and mobile platforms are processed in accordance with applicable data protection laws and regulations, including EU Regulation 2016/679, commonly known as the General Data Protection Regulation (GDPR), as well as any future amendments and applicable national implementing legislation.

This Privacy and Cookie Policy is effective from 25 May 2018. Any future updates to our data protection practices or policies will be published on this website. We therefore encourage you to review this page regularly to stay informed of any changes

3. Purpose of Processing Personal Data

NTS handles your personal data with due care and implements appropriate measures to protect it. In accordance with applicable legal requirements, please be informed that NTS processes and uses your personal data for the following purposes:

1. To perform and fulfil contractual obligations;
2. To comply with legal and regulatory obligations; and
3. To pursue the legitimate interests of NTS.

In all other circumstances, NTS Computers and/or NTS Holding will obtain your consent before processing your personal data.

NTS Responsibilities

• Providing online shopping services;
• Storing your registration and personal data in a database to facilitate current and future purchases, as well as communications relating to such purchases;
• Conducting audits and security checks in relation to the website;
• Informing you of functional changes to the website and providing information regarding special offers or shopping services;
• Requesting feedback to improve the website and user experience;
• Where you have accepted cookies, anonymously measuring your user experience and optimising website performance;
• Resolving technical issues, tracing online orders, and preventing the loss of saved shopping basket information due to technical problems;
• Sending newsletters where you have subscribed and consented to the processing of your personal data;
• Managing customer accounts within the central database; and
• Responding to enquiries from customers and prospective customers.

NTS Computers Responsibilities

• Delivering purchased products or arranging collection dates where applicable;
• Where you have accepted our cookies or created an account, and have given your consent, NTS may provide you with personalised offers based on your browsing activities and purchasing history;
• Responding to enquiries from customers and prospective customers;
• Managing complaints and customer service matters;
• Issuing invoices;
• Facilitating product collection or enabling the logistics department to deliver purchased products; and
• Managing administrative records and complying with tax and accounting obligations.

Joint Responsibilities of NTS Computers and NTS Holding

1. Complying with applicable laws and regulations, adhering to court orders, judicial decisions, or regulatory requirements; and taking actions necessary in connection with legal proceedings or claims.

NTS will obtain your consent before using your personal data for marketing purposes, including sending promotional offers and electronic newsletters. You will only receive newsletters if you have subscribed to our mailing list. We will keep a record of your subscription as proof of your consent to receive such communications. If you no longer wish to receive marketing communications from us, you may unsubscribe at any time by clicking the unsubscribe link provided in our newsletters.

Advertising networks and media companies act as intermediaries between online retailers and advertisers. The marketing cookies they use allow them to display third-party advertisements on the NTS website.These third parties may combine information from your saved shopping basket on this website with data collected when you visit other websites. Such information is not collected, combined, or used by NTS. It is collected and processed by the respective media companies and/or advertising networks through which NTS provides advertising space on its website (similar to advertising space in newspapers). NTS is not responsible or liable for the data processing activities carried out by these third parties. We kindly refer you to the privacy and cookie policies of the relevant advertising networks and companies for more information. As cookies and privacy policies may be updated from time to time, we recommend that you review them regularly.

4. What Data Do We Collect?

As part of the account creation process, we only collect personal data that is necessary to provide our services to you. This includes:

• Name and address of the account holder
• Contact persons or representative agencies (if applicable)
• Email addresses and telephone numbers

For bidding, website management, and content management purposes:

• Technical and pseudonymised data
• Your feedback on the use of our platform, as well as any other information you provide through the platform to help us improve the functionality of our website and services
• For reporting purposes, anonymised data that cannot be traced back to individual persons

For purchase transactions:

• Purchased items
• Bank details
• Payment methods and date of payment
• Date of birth (if required by law)

5.Legal Basis for Processing Data

The legal basis for our data processing activities is twofold:

• The performance of the agreement entered into with you through your account registration, as well as any purchase agreements concluded with you; and
• Our legitimate interest as a professional wholesale business in communicating with customers and managing our platform to ensure proper functioning of our web shop and enable you to use our services.

Only in the case of sending marketing emails and newsletters does a different legal basis apply. We will only send newsletters if you have given your consent by subscribing via our website. You may unsubscribe at any time, as stated in Section 3 of this Privacy and Cookie Policy.

6. Further Details

NTS does not collect or store special categories of personal data, such as data revealing political opinions, religious beliefs, or health-related information, as defined under Article 9 of the GDPR (AVG).

Sensitive data, such as creditworthiness information, may only be required in the case of credit applications. This information is used to verify whether bidders are able to purchase the requested products and to help prevent payment and delivery issues.

Only in relation to its employees does NTS process health-related data and other information necessary for the execution of employment contracts, as well as additional benefits and services such as pension schemes and insurance.

7. Protection of Personal Data

NTS ensures the effective protection of personal data by using encrypted communications and secure connections, in line with the latest technological standards where necessary. NTS has also implemented measures to safeguard both physical and virtual access to data within its premises and computer systems.

In addition, we apply appropriate administrative, technical, and organisational measures to ensure a level of security that is proportionate to the specific risks identified.

8. Storage of Personal Data

Your personal data will only be stored for as long as necessary and will be deleted once it is no longer required, taking into account any applicable legal retention obligations. NTS maintains appropriate processes for the safekeeping and management of such records.

NTS works with third parties to provide services and will only share personal data with the following categories of recipients:

Associated companies: entities within NTS Holding and its subsidiaries, provided they offer an equivalent level of data protection and that such data transfers are permitted.

Service providers: we engage third-party companies and individuals to perform services on behalf of NTS, such as delivery and payment processing (including credit card payments and “buy now, pay later” services). Where such providers are engaged, NTS enters into agreements ensuring that they do not obtain independent rights to process the data. These service providers may only access personal data necessary for the performance of their tasks and are not permitted to use it for any other purposes.

In all other cases, you will be informed if your personal data needs to be shared with third parties, and you will be given the opportunity to provide separate consent where required.

For employees, NTS may engage external service providers in connection with employment agreements, such as:

• Pension providers
• Insurance companies
• Other service providers, such as leased vehicle providers (where applicable)

Before any disclosure of personal data, NTS ensures that the necessary contractual safeguards are in place to protect your data.

Where personal data is transferred to third parties outside the European Economic Area (EEA), NTS ensures that such transfers comply with applicable data protection laws and this Privacy Policy.

As a general principle, and where possible, personal data is processed within the European Union and is not transferred outside the EU. Transfers to non-EU countries will only take place where the recipient can ensure an adequate level of data protection, either under applicable legislation in that country or through contractual arrangements in accordance with EU-approved standard contractual clauses or equivalent safeguards.

9. Rights Concerning Your Personal Data

You have the following legal rights, provided that you submit your request in writing and include a copy of your identity card for identity verification purposes:

Right to information and access to personal data
At any time, you may request information about our data processing activities and the personal data we hold about you.

Right to rectification of inaccurate or incomplete data
You are entitled to request the correction or completion of any inaccurate or incomplete personal data without undue delay.

Right to data portability
In certain cases, you have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit such data to another data controller. This right applies where processing is based on consent or on the performance of a contract, and where processing is carried out by automated means.

Right to restriction of processing
You may request that we restrict the processing of your personal data if:

• You contest the accuracy of the data, for a period allowing us to verify its accuracy;
• The data is no longer needed for processing purposes, but you require it for the establishment, exercise, or defence of legal claims;
• The processing is unlawful and you request restriction of use instead of deletion.

We will also assess whether our legitimate interests override your interests in the event of a complaint relating to data processing.

Right to erasure (right to be forgotten)
You may request the deletion (in whole or in part) of your personal data in the following circumstances:

• The data is no longer necessary for the purposes for which it was collected or otherwise processed;
• The data is no longer required for the performance of our agreement or is no longer legally required;
• The processing is based on consent and you have withdrawn your consent;
• The data has been processed unlawfully;
• You object to the processing and there are no overriding legitimate grounds;
• The data must be deleted to comply with a legal obligation.

In exceptional cases, we may refuse deletion if processing is required to comply with legal obligations or for the establishment, exercise, or defence of legal claims, or where there is a legitimate interest.

Right to Object to the Processing of Your Personal Data
You may object to the processing of your personal data where it is based on our legitimate interests. In such cases, we will no longer process your data unless we can demonstrate compelling legitimate grounds or legal obligations requiring us to do so. Where your personal data is used for direct marketing purposes, you may object at any time or withdraw your consent. You also have the right not to be subject to profiling for direct marketing purposes.

Right to lodge a complaint
If you have any concerns regarding our data processing, you may contact us in writing via our Data Protection Officer (DPO). For contact details, please refer to Section 1. You also have the right to lodge a complaint with your local data protection authority. Where NTS acts as the data controller, the relevant supervisory authority is the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

10. Cookies

NTS uses cookies on its auction website to improve functionality and enhance your browsing experience. Cookies allow NTS, for example, to recognise you on your next visit to the web shop. They also enable NTS to collect statistical data, such as the number of page visits and the popularity of individual pages and topics.Cookies are small text files stored by your browser on your computer, tablet, or smartphone. NTS may use these cookies to gather information about how its services are used and, where possible, to adapt and improve these services to better meet your needs.

It is important to note that emails and marketing campaigns are not generated through cookies. Neither your email address nor your telephone number is stored in cookies, and cookies are not used to create identifiable personal profiles. You have the option to accept or disable cookies for any website by adjusting your browser settings. Please note that certain website functions may not be available if you disable cookies. If you are unsure how to change your browser settings or delete cookies, please refer to your browser’s instructions.

Types of Cookies Used on the NTS’s Website:

Session cookies
Session cookies are used to manage and secure your current visit to our website. These cookies are automatically deleted when you close your browser. A complete overview of the cookies used on this website, including their functions and expiry periods, can be found at the bottom of this page.

Persistent cookies
By using persistent cookies, websites can remember your information and settings for future visits. This allows for easier and faster access, for example, by keeping you logged in. These cookies also help with selecting items and storing them in your shopping basket, so you can return later to review them and decide whether to complete your purchase. A complete overview of the cookies used on this website, including their functions and expiry periods, can be found at the bottom of this page.

11. Browser Settings

If you do not wish for websites to store cookies on your device, you may adjust your web browser settings so that a warning is displayed before cookies are stored. You may also configure your browser to block all cookies or only cookies from third-party providers. In addition, you can delete cookies that have already been stored through your browser settings. Please note that these settings must be configured separately for each browser and device you use. Please be aware that NTS cannot guarantee the proper functioning of the website if cookies are disabled. As a result, certain features may no longer be available, or you may lose access to parts of the website.The steps to adjust these settings vary depending on the browser. If needed, please refer to your browser’s help function or follow the instructions provided for your specific browser.

• https://support.google.com/chrome/answer/95647?hl=en
• https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer#w_cookie-settings
• https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
• http://support.apple.com/kb/PH5042
• http://help.opera.com/Windows/12.10/en/cookies.html

You can block cookies from specific providers via the following website : http://www.youronlinechoices.eu/.

12. Hyperlinks

The NTS website may contain hyperlinks to other websites, including those of business partners that are not part of NTS. NTS accepts no responsibility for the privacy practices or content of these external websites.

13. Contact Information

NTS reserves the right to amend this Cookie Statement from time to time. We therefore recommend that you review this statement regularly to stay informed of any updates.

If you have any questions, comments, additions, or complaints regarding this Privacy and Cookie Statement, please contact us at:

NTS Computer Technology BV
Seinhuiswachter 10
3034 KH Rotterdam
Netherlands

Tel: +31 10 404 62 62
Email: info@nts.nl

Please contact us during working hours by telephone or fax, or use the contact form available on our website: https://ntscomputers.com.my/.