Privacy policy

Privacy policy 

Last updated: 07/02/2025 

  1. Introduction 

Full Circle Group Holding B.V. (“We”) are committed to protecting and respecting your privacy. 

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. Provisions of this privacy policy may not apply to you depending on your location or citizenship. 

For the purpose of the EU General Data Protection Regulation 2016/679 (GDPR), the controller of your data is Full Circle Group Holding B.V. a company registered in The Netherlands under company number 82678499 whose registered office is at Heliumweg 38, 3812 RE Amersfoort, The Netherlands. 

All personal data will be held and processed in accordance with applicable data protection and privacy law, including the GDPR, the GDPR, Electronic Communications (Amendments etc)(EU Exit) Regulations 2019, the CCPA (as defined below) and the Data Protection Act 2018. 

This policy (together with our Terms of use (as set out on our website https://www.fullcirclewindservices.com/terms-of-use/) and any engagement letter or terms of service entered into with you as a client) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us 

  1. Objectives 

This policy aims to: 

  • ensure that all the personal data in our custody is adequately; 
  • protected against threats to maintain its privacy and security; 
  • ensure that our employees are fully aware of the contractual, statutory, or 
  • regulatory implications of any privacy breaches; 
  • limit the use of personal data to those intended and permitted by law; 
  • make all the stakeholders aware about the lawful processes for collection, usage, transfer, retention, disposal of personal data; and 
  • ensure that any third parties who process personal data on our behalf observe applicable laws;3. Data we collect 

We may collect and process the following personal data about you: 

  • Personal data you provide us. You may give us personal data about you by filling in forms on our website or by corresponding with us by phone or email. This includes personal data you provide when you register to use our site, onboard as a client to our services, provide any personal data on our site, make an enquiry, provide feedback and when you report a problem with our site. 

The personal data you give us may include your name; address; e-mail address; phone number; billing information; personal identification (such as passports, driving licenses and other information required for us to carry out client background checks); date of birth; country of residence; photographs; organisation details (if relevant); or other personally identifiable personal data in documents that you send us. 

  • Personal data we may collect about you.  
  • Each time you visit our site we may collect the following personal data (provided you have opted-in through our cookie banner; https://www.fullcirclewindservices.com/cookie-policy/): 
  • information about your visit, including the full URL clickstream to, through and from our site (including date and time); pages you viewed or searched for; 
  • page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page; 
  • internet protocol (IP) address, your location data, login data, browser type and version, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.Personal data we receive from other sources.  
  • We also work with third parties (including, for example, clients, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) who may share your data with us provided you have consented to it or a legal basis exists for sharing. 
  1. How we use your data

We collect and process personal data to provide, improve, and secure our services in compliance with applicable data protection laws, including the General Data Protection Regulation (GDPR). We may use the data we collect for the following purposes: 

  • service provision & account management – to create and manage user accounts, authenticate access, and provide requested services. 
  • customer support – to respond to inquiries, provide technical support, and resolve issues. 
  • personalization – to tailor our services, content, and communications to user preferences. 
  • security & fraud prevention – to detect, prevent, and respond to fraudulent activities, unauthorized access, or security incidents. 
  • legal & compliance obligations – to comply with legal requirements, enforce our terms of service, and protect our legal rights. 
  • marketing & communications – to send updates, promotional materials, or service-related messages, where permitted by law and with the option to opt out. 
  • analytics & performance improvement – to analyze usage trends, improve our services, and conduct research and development. 

We only process personal data when we have a lawful basis to do so, such as user consent, contract fulfillment, legal obligations, or legitimate interests that do not override individual rights.4. The Legal Basis for Processing your personal data (for the EEA and the UK ) 

In accordance with GDPR, the main grounds that we rely upon in order to process your personal data are as follows: 

  • Consent. where you have provided explicit consent for the processing of your personal data for specific purposes.. 
  • Contractual necessity. where data processing is necessary for the performance of the contract or provision of our services. 
  • Legal obligation. Where we are required by law to process personal data. 
  • Legitimate interest. Where processing is necessary for our legitimate interest, provided that such intertest does not override your rights and freedoms. 
  • Whenever possible, we will always seek to obtain your consent prior to processing any personal data. 
  1. Your Rights (for EEA and the UK and)

You have certain rights in relation to the personal data that we hold about you. Details of these rights and how to exercise them are set out below. Please note we will require evidence of your identity before we are able to respond to your request. 

  • Right of Access. You have the right at any time to ask us for a copy of the personal data that we hold about you and to check that we are lawfully processing it. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your personal data, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so. 
  • Right of Correction or Completion. If personal data we hold about you is not accurate or is out of date and requires amendment or correction you have a right to have the data rectified or completed. 
  • Right of Erasure. In certain circumstances, you have the right to request that personal data we hold about you is erased e.g. if the personal data is no longer necessary for the purposes for which it was collected or processed or our processing of the personal data is based on your consent and there are no other legal grounds on which we may process the personal data. 
  • Right to Object to or Restrict Processing. In certain circumstances, you have the right to object to our processing of your personal data. For example, if we are processing your personal data on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You may also have the right to restrict our use of your personal data, such as in circumstances where you have challenged the accuracy of the personal data and during the period where we are verifying its accuracy. 
  • Right of Data Portability. In certain instances, you have a right to receive any personal data that we hold about you in a structured, commonly used and machine-readable format. 

In such circumstances, you can ask us to transmit that personal data to you or directly to a third party organisation. 

While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third party organisation’s systems. We are also unable to comply with requests that relate to personal data of others without their consent. 

You can exercise any of these rights at any time by contacting us using the details in the ‘Contact’ section below. 

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliate such as Stripe or our Facebook, Twitter, Instagram, LinkedIn or other social media pages. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. 

  • Right to Withdraw Consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. You can do this by contacting us using the details in the ‘Contact’ section below. Once we have received notification that you have withdrawn your consent, we will no longer process your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. 

Your rights (for California) 

The provisions contained in this section apply to you if you are a consumer residing in the State of California and otherwise subject to the California Consumer Privacy Act 2018 as amended ( “CCPA”) and for such consumers this section supersedes any conflicting provision in this privacy policy. At Full Circle, we take your privacy very seriously, and we never monetize your personal data; we use it in order to provide our clients with services and improve the functioning of our website. 

When it comes to your rights as a consumer, we want to make sure you have everything you need to make informed decisions. You have the right to: 

Know how your personal data is used; 

Access, request and receive the personal data we have collected in a portable manner; 

Object to having your data sold or shared; and 

request that we delete your personal data. 

  

Consistent with California law, if you choose to exercise your rights, we won’t charge you different prices or provide different quality of services unless those differences are related to your personal data. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requestor’s valid government issued identification, and the authorized agent’s valid government issued identification. 

  1. Where we Store your personal data

The personal data that we collect from you will be stored in the European Economic Area (“EEA”) and in compliance with GDPR. However, occasionally, we may need totransfer and store you personal data outside the EEA. In such cases, we will obtain your consent or ensure we have proper legal basis for such transfer. We will never transfer your personal data to any jurisdiction that does not have an adequacy decision by the relevant regulatory authority or without implementing a proper Data Processing Agreement (DPA) that ensures an equivalent level of data protection and user rights. Any such transfers will be conducted in full compliance with applicable data protection laws, utilizing appropriate safeguards such as Standard Contractual Clauses (SCCs) or other legally recognized mechanisms to maintain the integrity and security of your data. 

  1. How Long we Hold your personal data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. The criteria that we use to determine retention periods will be determined by the nature of the data and the purposes for which it is kept, the sensitivity of the data and the potential risk of harm from unauthorised use or disclosure. 

  1. Complaints

If you are unhappy about our use of your personal data, you can contact us using the details in the Contact section below. You are also entitled to lodge a complaint with: 

The Netherlands 

Autoriteit Persoonsgegevens
Bezuidenhoutseweg 30
2594 AV DEN HAAG 

Telephone: 088 – 1805 250 

Website: https://autoriteitpersoonsgegevens.nl/nl/contact-met-de-autoriteit-persoonsgegevens/informatie-en-meldpunt-privacy 

the UK 

Information Commissioner’s Office 

Telephone: 0303 123 11113
Website: https://ico.org.uk/make-a-complaint/ 

If you live or work outside of the Netherlands or the UK or you have a complaint concerning our activities outside of the Netherlands or the UK, you may prefer to lodge a complaint with a different supervisory authority. A list of relevant authorities in the EEA can be accessed here. 

Changes to our Privacy Policy 

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy. 

Contact 

If you have any questions about how we collect, store or use your personal data, please contact us at contact@fullcirclewindservices.com 

 

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