Circospin B.V. respects your privacy and makes every effort to protect your personal data. We find it important that our services are transparent, personal and reliable. Therefore, we are constantly looking for ways to improve our services and tailor them as much as possible to your personal wishes and needs. In doing so, we process your personal data carefully and securely. Moreover, we only process your personal data in accordance with the General Data Protection Regulation (hereinafter: AVG) and/or other special privacy legislation.

This privacy statement explains to you which personal data Circospin B.V. of you, why we do so, how we protect your personal data, what rights you have as a data subject and how you can exercise them. We also indicate how and where you can file a complaint.

Who is responsible for processing your personal data?
Circospin B.V. is the controller and is located at Pijlkruid 77 (2408 LJ) in Alphen aan den Rijn and is registered in the register of the Chamber of Commerce under number 82488142. Circospin B.V. can be reached by e-mail at info@circospin.nl or by phone at 0172-889100.

What personal data does Circospin B.V. process from you?
Circospin B.V. processes your personal data if you have provided it to us and if you use the services of Circospin B.V. By personal data we mean any information about an identified or identifiable natural person. We may process at least the following personal data:
– Name information
– Payment details
– E-mail addresses
– Phone numbers

Why does Circospin B.V. process these personal data?
We process your personal data for the following purposes:
– Handling your payment
– Sending our newsletter and/or advertising flyer
– To be able to call or email you if necessary to perform our services
– Informing you of changes to our services and products

How does Circospin B.V. secure your personal data?
All personal data provided by you will be treated with the utmost care and absolute confidentiality. We ensure that appropriate technical and organizational measures are taken to adequately protect your personal data against misuse, loss, unauthorized access, unwanted disclosure and unauthorized changes.

Furthermore, the personal data you provide will only be used for the aforementioned purposes and shared with those persons within our organization, who necessarily need to know your personal data in order to serve you properly.

If you feel that your personal data is nevertheless not properly secured or there are indications of abuse, please contact Circospin B.V. by sending us an e-mail or calling us.

Does Circospin B.V. your personal data with third parties?
Circospin B.V. shares your personal data with third parties only if the sharing is necessary for the proper performance of the agreement Circospin B.V. has concluded with you, to comply with any legal obligation or when you have given your explicit consent. With these third parties, who process your data on our behalf, Circospin B.V. concludes a processing agreement to ensure that they also have an appropriate level of security and confidentiality of your data as we use ourselves.

Where does Circospin B.V. store your personal data?
Storage of your personal data will only take place in the European Economic Area (EEA), and in particular in the Netherlands. If storage outside the EEA will nevertheless take place, Circospin B.V. will seek your explicit prior consent. Circospin B.V. will also ensure that additional safeguards are in place with respect to the storage of your personal data outside the EEA.

Does Circospin B.V. engage in automated decision making or profiling?
Circospin B.V. does not engage in automated decision making or profiling.

For how long does Circospin B.V. retain your personal data?
Circospin B.V. will not retain your personal data longer than necessary for the purpose for which we have obtained your personal data as well as a reasonable period thereafter for any administrative and financial settlement of your order. Circospin B.V. may also retain your personal data for a longer period if you provide express and specific consent to do so. Finally, Circospin B.V. may also keep your personal data for longer if Circospin B.V. is required by law to do so.

Once the agreed or legal deadlines have expired, Circospin B.V. will delete your personal data.

Circospin B.V. maintains the following retention periods for the categories of personal data listed below: Circospin B.V. does not retain your personal data longer than is strictly necessary to realize the purposes for which your data are collected.

Are personal data processed and stored when visiting the website of Circospin B.V.?
When the web page of Circospin B.V., https://www.circospin.nl is visited by you, the following data are automatically stored and processed in a protocol for the purpose of providing the service:
– Browser cookies

The processing of this data is necessary for technical reasons in order to make our services available. The data can also be used to compile internal system and usage statistics. However, this does not involve data that can be traced back to specific individuals. Insofar as statistics are compiled to design that web page according to the wishes of users, pseudonyms are used for this purpose.

In order to efficiently and pleasantly do business with Circospin B.V. or through our websites, cookies are used. Cookies are pieces of information that your internet browser stores on your computer. Circospin B.V. uses these cookies to recognize you on your next visit. This way you do not have to enter the same required data every time. Through this use it is possible to improve our services, improve the functionality of our website and to adapt to the needs of our visitors. The use of cookies does not mean that we know everything about you; It concerns summary information. Circospin B.V. uses these cookies to optimize your convenience. It is not our intention to infringe on your privacy while using the website. It is possible to set your browser settings so that no information is stored on your computer or that you are informed in advance about the use of these cookies.

We also use Google Analytics to track website services and receive reports on visitor numbers. The information obtained by Google is anonymized and does not include your IP address. Google may provide the obtained information to third parties if Google has the information processed by third parties or if Google is legally required to do so. If you want to prevent the collection of this anonymous data, we recommend installing the Google Analytics Opt-out Browser Add-on. You can opt out of Google’s advertising cookie [https://www .google.com/settings/ads/onweb#display_optout], or block Google Anlytics cookies by installing the opt-out plugin. Opting out is also possible on the Network Advertising Initiative’s opt-out page.

The information, which Google obtains, is stored in the United States. Google complies with the rules of the Privacy Shield, which allows them to offer an adequate level of protection as referred to in the AVG.

What rights do you have under the AVG?
You have the following rights as a data subject under the AVG:
– Right to access your personal data;
– Right to delete your personal data. If there is a legal retention obligation, your personal data will be deleted immediately after the expiration of this retention obligation;
– Right to correction or restricted use of data collected and processed;
– Right to data portability (the right to transfer personal data);
– Right to be forgotten;
– Right to object to data processing.

Circospin B.V. will process your request regarding the exercise of your right(s) within the statutory period of 4 weeks. For complex requests, the period may be extended once by 4 weeks. In handling your request(s), Circospin B.V. will make use of the legal possibilities to grant or reject your request(s). If your request is rejected, we will give proper reasons.

If Circospin B.V. acts as a processor and another party is the controller of your personal data, Circospin B.V. will forward your request(s) to the controller as soon as possible. You will in that case receive a response to your request(s) from the controller.

How can you file a complaint?
It is possible that despite our careful handling of your personal data you are still dissatisfied with something. In this case, please contact the following address for information on how to file a complaint: Marco Pastoor, m.pastoor@circospin.nl, 0651696130.

In addition, you can fill out the contact form on the website.

Should you be dissatisfied with the handling of your complaint, you can contact the Personal Data Authority. This can be done via the complaint form on the website of www.autoriteitpersoonsgegevens.nl, but you can also send a letter to:
Personal Data Authority
PO Box 933374
2509 AJ The Hague
0900-2001201

Please always mention in your letter which personal data and which organization it concerns, whether you have had previous contact with that organization and how they responded to your complaint. Also indicate what you want to achieve with the complaint.

Change privacy statement
Circospin B.V. reserves at all times the right to adapt this privacy statement to the latest developments in the field of the AVG and other privacy legislation. On the website you will find the most current version of the privacy statement. In case of discussion, the latest privacy statement, which is published on the website, will be used.

Circospin B.V.
December 2021