Personal Data Privacy Policy Updatedt: December 2018

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1 Personal Data Privacy Policy Updatedt: December 2018 Introduction For Smithfield Romania, the privacy of your personal data is very important and that is why we are committed to take all necessary measures to respect it. This Privacy Policy describes what personal data we collect from you, to which purpose and on what legal basis, who is it shared with, and your rights. This Privacy Policy may be updated at any time, without notice, by posting a new version herein. Please check this Policy every time you access the website, to identify and understand any changes occurring. Identity of Operator Name : Smithfield Romania SRL Trade Register No: J35/962/2000 Unique Registration Code: RO Registered office: Timisoara, 4 Polona Street, Building Complex GF + 2F What Personal Data We Collect and How We Use It Data provided by visitors By subscribing at our Newsletter or using the Contact area by filling your name, surname, and telephone number gives us access to these data in order to answer your message. Submitting your personal data represent your consent for Smithfield Romania to process your address to send future marketing communications. Personal data provided by your submission are therefore processed under your consent. You may withdraw your consent at any time, by ing to dpo@smithfield.ro or by accessing the Unsubscribe link you may find at the end of each marketing communication. Automatic Data Collection The IP address of your computer is automatically collected when visiting our website. The IP address is a number allocated to your computer when accessing the Internet. These addresses are recorded for IT security reasons in the information system logs managing the website. We DO NOT use your IP address to identify you or for other purposes than those of statistic information and website protection. Data of Customers/Suppliers and Their Representatives

2 Smithfield Romania collects and processes the personal data (Surname, Name, Position, and business phone no.) of representatives and contact persons, customers/suppliers, including those of collaborators, for the following purposes: (i) send the Company you work for, orders / offers / offer confirmations / invoices / notifications on the status of contracts concluded between Smithfield Romania and the Company you represent or any other documents and/or relevant information for potential or existing commercial relations between Smithfield Romania and the Company you work for. (ii) supply marketing materials, based on customers consent; (iii) compliance by Smithfield Romania of obligations imposed by law and regulatory bodies to which Smithfield Romania is subject, such as obligation to combat money laundering and counter-terrorism, and obligation to report to tax authorities; (iv) exercising or defending our legal rights or compliance with court orders. Legal Bases Used for Processing Personal Data The European law allows us to process personal data, as long as we have a legal basis to do this. Legal bases used by Smithfield Romania are the followings: Performance of a Contract. This legal ground is used when necessary to process personal data in order to fulfill contractual obligations or concluding an agreement; Legal obligation. This legal ground is used when we are obliged to process personal data to comply with a legal obligation, such as keeping of personal data for tax purposes or supply of information to a public authority; Legitimate interest. We will process your data to carry out the current operations of Smithfield Romania, and as long this not exceed your personal interests; Consent. In some cases, we will ask for special permission to process part of this personal data and will process it only based on your consent. You may withdraw your consent at any time, by contacting Smithfield Romania at dpo@smithfield.ro Examples of legitimate interests mentioned above are: Provide information and/or services to individuals who access our website or provide information about employment opportunities. Prevent fraud or criminal activities and protect our information systems. Personalize the online experience of people and improve performance, usability and effectiveness of Smithfield Romania s online presence. Conduct and analyze our marketing activities.

3 Cookies To ensure the smooth operation of the website, sometimes we place in your computer small data files known as cookies. What does cookie mean? The cookie is a small text file that a website saves in your computer or mobile device when visiting. Due to cookies, the website retains your actions and preferences for a determined period of time. Therefore, you don t have to retype your data every time you return to the website or browse from page to page. How are cookies used? We only use cookies for statistics and acceptance of personal data protection policy, cookies that can be deactivated directly from your browser. Statistic cookies help the owners of a website to understand the way visitors interact with websites by collecting and reporting information anonymously. Enabling cookies is not strictly necessary for the website operation but can improve your browsing experience. You may delete or block cookies but, in doing so, some website features might not work properly. Cookie information is not used to personally identify you. In addition, we keep your browsing preference data under control. Cookies are not used for other purposes than those described here. How can you control cookies? You may control and/or delete cookies as you wish; you may delete all cookies from your computer and you may set all browsers to block them. If doing so, you may be forced to manually set some preferences every time you visit the website. Also, some services or options might not work. Children under 16 Smithfield Romania understands the importance of protecting children s privacy, especially in an online environment. Our websites are not intentionally designed for or directed at children under the age of 16. It is our policy never to knowingly collect or maintain information about anyone under the age of 16, except as part of an engagement to provide professional services. Transfers to third parties We will not disclose your information to third parties for use in their own marketing purposes or their business, without your consent. However, we may disclose your data to other companies who provide us / perform services for us and act as operator / authorized person, such as companies dealing with our website maintenance or which sends communications on our behalf, as well as our customers and suppliers. These entities are

4 carefully selected to ensure they meet specific requirements in terms of protection of personal data. These entities have limited ability to use your data for any other purpose than to provide us with the services necessary for the website operation. Retention Period Smithfield Romania has implemented technical and organizational measures or the retention of your personal data. Thus, we shall retain your data in accordance with the data retention policy, applicable at the level of Smithfield Romania. However, we will cease to process any of your personal data, as long as it is not required for the purposes established, when you withdraw consent or when the legal basis on which personal data have been processes is no longer valid. Data Subject Rights When Smithfield Romania processes your personal data, you have the following rights: Information: You have the right to be informed of your personal data processing by Smithfield Romania. Access: You have the right to access those data. The person concerned has the right of receiving from the operator a confirmation whether his/her personal data are processed and if so, have access to his/her data. Rectify: If the personal data we maintain about you is inaccurate, you have the right to ask us to rectify the record of your data. Erasure: You have the right to request, without undue delay, erasing your personal data, in the following situations: your personal data are no longer necessary for meeting the purposes they ve been collected for; the agreement underlying the processing of your personal data has been withdrawn; there are no overriding legitimate reasons for data processing; your personal data have been processed unlawfully; your personal data must be deleted to fulfill a legal obligation. Restriction of processing: You have the right to limit the processing of your personal data, in the following situations: accuracy of personal data is contested by you, for a period which allows checking of accuracy; processing of personal data is illegal; Smithfield Romania no longer needs your personal data for processing purposes; you object to processing based on legitimate reasons. Portability: You have the right to receive the personal data provided to Smithfield Romania, in a structured format, which can be read automatically. If the technical means allow such an operation, Smithfield Romania may transfer such data to another Operator. You have this right when processing of personal data is based on your consent or when processing is done automatically. Objection: You have the right to object, on grounds related to your situation, to processing based on the legitimate interests of Smithfield Romania. Smithfield Romania will no longer

5 process your personal data, except when demonstrating compelling processing legitimate interests that take precedence over your interests, rights and freedoms or for establishment, exercise or defense of a right. You are entitled not be subject to a decision based solely on automated processing, including profiling, which produces legal effects on you; you may also lodge a complaint with the local Data Protection Authority (National Supervisory Authority For Personal Data Processing). How Can You Contact Us For questions regarding the terms of the Privacy Policy or for any questions regarding the above requests, please contact us at: Smithfield Romania 4 Polona Str., Timisoara dpo@smithfield.ro