Last updated: 09/06/2025
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, 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 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.
Objectives
This policy aims to:
- Ensure that all personal data in our custody is adequately protected against threats to 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.
- Inform all stakeholders about the lawful processes for collection, usage, transfer, retention, and disposal of personal data.
- Ensure that any third parties who process personal data on our behalf observe applicable laws.
Data We Collect
We may collect and process the following personal data about you:
1. Personal data you provide us:
You may give us personal data by filling in forms on our website or by corresponding with us via phone or email. This includes when you register, become a client, submit a form, give feedback, or report issues.
Data may include:
- Name, address, email, phone number
- Billing information
- Personal identification (e.g. passport, driver’s license)
- Date of birth, country of residence, photographs
- Organisation details
- Other identifiable personal data in documents you send us
2. Personal data we collect automatically:
Each time you visit our website (provided you opt in via our cookie policy), we may collect:
- Full URL clickstream
- Pages visited, page response times, download errors
- IP address, location, login data, browser type and version
- Device and technical data
3. Personal data from third parties:
We may receive personal data from third parties (e.g. clients, partners, service providers, credit agencies), provided you have consented to the sharing or where a lawful basis exists.
How We Use Your Data
We process personal data to provide, improve and secure our services. Uses include:
- Service provision & account management
- Customer support
- Personalization of services
- Security & fraud prevention
- Compliance with legal obligations
- Marketing & communications (only where permitted and with opt-out available)
- Analytics & service improvement
We only process personal data where a lawful basis applies, such as user consent, contract necessity, legal obligation, or legitimate interest.
Legal Basis for Processing (EEA & UK)
In accordance with GDPR, we process your personal data on the following grounds:
- Consent – when you provide clear, explicit permission
- Contractual necessity – for the performance of a contract
- Legal obligation – when required by law
- Legitimate interest – provided your rights are not overridden
Your Rights (EEA & UK)
You have the right to:
- Access – Request a copy of your data.
- Correction/Completion – Correct inaccurate or incomplete data.
- Erasure – Request deletion when data is no longer necessary.
- Object/Restrict processing – In certain circumstances.
- Data portability – Receive your data in a portable format.
To exercise these rights, contact us using the details in the Contact section below.
Right to Withdraw Consent
If we rely on your consent, you may withdraw it at any time by contacting us. We will then stop processing your data unless we have another lawful basis to do so.
Your Rights (California – CCPA)
If you are a California resident subject to the CCPA, you have the right to:
- Know how your data is used
- Access and receive your data
- Object to the sale or sharing of your data
- Request deletion of your data
We do not monetize your data. If you choose to exercise your rights, we will not discriminate against you. You may also designate an authorized agent to act on your behalf.
Where We Store Your Data
We store your data in the European Economic Area (EEA). If we transfer it outside the EEA, we will:
- Obtain your consent or rely on a lawful basis
- Use jurisdictions with an adequacy decision or appropriate safeguards (e.g., Standard Contractual Clauses)
Data Retention
We retain your data only as long as necessary for the purposes it was collected, including legal and accounting obligations. Retention depends on the type, purpose, sensitivity, and potential risk of the data.
Complaints
If you’re unhappy with how we handle your data, you can contact us or file a complaint with the relevant authority:
The Netherlands
Autoriteit Persoonsgegevens
Bezuidenhoutseweg 30, 2594 AV DEN HAAG
Tel: 088 – 1805 250
Website
UK
Information Commissioner’s Office
Tel: 0303 123 1113
Website
For complaints outside the Netherlands or UK, see the list of EEA authorities.
Changes to This Policy
Any changes will be posted on this page and, where appropriate, notified via email. Please check back regularly for updates.
Contact
For questions regarding your personal data, please contact: