CirculinQ Privacy and Cookie Statement

‘We protect your data, offer full transparency concerning your data and give you full control over the data that you provide.’

This is the Privacy and Cookie Statement of the website at (referred to below as ‘the Website’). This statement applies to all personal data of visitors to the Website (referred to below as ‘you’ and ‘your data’) that CirculinQ B.V. (referred to below as ‘we’, ‘us’ or ‘our’) processes via the Website.

In this statement, we explain how we will use the data that we gather via the Website and your rights relating to your personal data. This document contains the following information:

  1. Which personal data we gather and process, for which purposes
  2. Which personal data are gathered
  3. How we protect your data
  4. When we erase your data (saving periods)
  5. Your rights
  6. Changes
  7. Contact


1. Which personal data we gather and process, for which purposes.

‘Personal data’ refers to all the information with which the identity of a natural person can be verified, directly or indirectly. Such information could include a name, email address and the IP address of your computer.

We process your data for the purposes set out below. More information on the extent to which we gather information by placing cookies is provided in paragraph 2.

    In order to be able to respond to questions or comments sent in via contact forms, we may ask you for your email address and, if necessary, your name, address and the company for which you work.
    In order to be able to send CirculinQ newsletters to their recipients, we ask you for an email address and, if necessary, for your surname, initials, gender and additional information, such as a company name or job category, so that we can send you the right content.
    CirculinQ regularly launches campaigns in order to activate our (potential) clients and to remain connected to them. In addition to the information necessary for the subscription to our newsletter, we may also request additional data, such as addresses, telephone numbers or information on the use of products. On this basis, we can offer visitors to and users of our website more relevant content and send messages for price matching and other purposes.
    We may ask you for details of your email address and, if necessary, for your surname, initials, gender and additional information, such as a company name or job category, so that we can send you commercial emails. In general, we may process these data if you give us permission for this. You can withdraw this permission again at any time, deregister for further emails, update your preferences or contact CirculinQ.
    We use social media in order to draw the attention of our target group to our content, so that they remain engaged with CirculinQ in the environment in which our target groups are primarily active. We can save certain moments of engagement and behaviour, such as responses to our content or messages sent to the inboxes of our social media. Information on behaviour on social media can be related to data on behaviour on the Website. On the basis of such information, we can personalise your Website experience. Via data from the user profiles created, we can improve our targeting on social media, so that we can place more relevant advertisements. We may process these data if you give us permission for this. You can withdraw this permission again at any time. If you do not provide personal data, we do not receive any information on you and cannot personalise your experience on our website or improve the targeting of our advertisements on social media.
    At certain moments, CirculinQ can make use of online surveys in order to receive your feedback, so that we can improve our services and your user experience for you. In these surveys, we may ask for your name and email address and save your IP address. In principle, the data in these surveys are only reported in aggregate form. If we wish to contact you with regard to specific feedback or questions, we will naturally first ask permission for this during that survey.

1.2 Personal data

We process the following data of all our website visitors:

  • IP address
  • Cookies

In addition, you have the option of leaving personal data via our website yourself, for one of the purposes referred to above. We only process personal data that you leave with us yourself:

  • first name and surname
  • email address
  • address
  • telephone number
  • position and employer
  • country


2. Cookies

CirculinQ makes use of ‘cookies’ and similar technologies in order to gather additional data on the Website use and to improve our services.

What are cookies?
A cookie is a small, simple file that is saved on your device. It provides for the offer of the basic functionality of the website, for example, remembers your settings and preferences and is also used for statistical purposes. There are different types of cookies, each with different characteristics and functions. They can also be saved on the devices of users for short or longer periods. For example, session cookies are removed at the end of each browser session, but permanent cookies can remain on your device until a date pre-set by the owner. In addition to cookies, there are other digital technologies with which information is saved, or which are used to gain access to information saved on your terminal devices. We treat these technologies as if they were cookies and, where we refer to cookies in this privacy statement, this also refers to these technologies.

The difference between first-party and third-party cookies
We distinguish between first-party and third-party cookies. The word ‘party’ refers to the domain specified in the cookie: the website that places the cookie. CirculinQ manages first-party cookies itself or these are used on behalf of CirculinQ and these refer to the CirculinQ domain. Third-party cookies are placed by third parties and refer to their domain names. For example, if we use YouTube videos on our website, cookies are also placed from the YouTube domain.

Which specific cookies does CirculinQ use?We use the following cookies on the Website and will explain the purpose of this. You can also find the precise cookies, the profiling requirement, settings and storage times  here .

Cookie type First/third-party Explanation
Functional cookies First-party cookies CirculinQ uses functional cookies to enable the website to function properly and keep it secure.
Analytical cookies First and third-party cookies Analytical cookies enable us to identify anonymised behaviour and count the number of visitors to a website, in order to see how visitors behave on a website and to record which content is read. In this way, we can determine how often pages are visited and what the most popular pages are. This helps us to improve the website and the services offered.
Personalised cookies First and third-party cookies Selected external parties can place tracking cookies in order to track personal behaviour on CirculinQ websites, with the aim of creating and sharing more personalised and segmented content. We request your prior consent for placing these cookies.


Bear in mind that CirculinQ may be obliged by local legislation to request your consent for the use of some cookie technologies. If that is the case, we will request your permission to place cookies as soon as you visit the Website. If you do not give permission to place cookies, we will not place them. However, in that case we cannot personalise the content on our Website. If you have given permission for the use of cookies, you have the right to withdraw that permission at any time.

If functional or analytical cookies are refused, CirculinQ will have no information available on the performance of the Website and the quality of its contents. In that case, CirculinQ cannot improve the user experience of the Website.


Changing browser settings

Most browsers can be set to refuse cookies or to inform you when you receive a cookie. If you do not want the Website to be able to place cookies on your devices, change the browser settings. How you can change the browser settings varies from one browser to another. You can change your browser settings to reject all cookies or third-party cookies only. You can remove cookies that have already been placed. If you reject cookies, some functions of the Website may be lost or you may not be able to access certain pages (fully) anymore. Click one of the icons below to go directly to your browser instructions or, if necessary, use the help function of your browser:

  1. Chrome
  2. Firefox
  3. Internet Explorer
  4. Safari


3. How we protect your data

We have taken appropriate technical and organisational measures to protect your personal data against unintentional or illegitimate erasure or unintentional loss, alteration, improper disclosure or access and against all other forms of illegitimate processing. In addition, we require our data processors to take appropriate technical and organisational measures too.

3.1 Data sharing

In general, we will not share your personal data with group entities outside the European Economic Area (EEA). We may share your data with out group entities within the European Union. Cookies can be placed by third parties. Check the list of cookies to see which parties gather such data.

We may share your data with third parties that supply us with database, server, maintenance, security, marketing or other similar services (referred to below as ‘data processors’). If we grant access to your data, we require these third parties to handle your data in confidence and oblige these parties to process these data only on our behalf. Some third parties are established in countries outside the EEA. We have contracted controller-to-processor EU Model Clauses with data processors outside the EEA in order to ensure that your Employee Data are adequately protected. If you wish to view the relevant data transfer contracts, you can contact us by using the contact information at the bottom of this privacy statement.

We may also disclose your data if we believe that this is required by law or in order to comply with a legal request.


4. When we erase your data (saving period)

Your data will not be kept for longer than is necessary for the purpose for which these personal data were collected, unless provided otherwise in law. For example, if you erase your account or no longer wish to receive notifications, we will erase the data unless we need these for a purpose other than that set out in this policy, or if we are required by law to keep these data. See the cookie list in (1)H for the specific periods for saving cookies.


5. Your rights

Pursuant to the General Data Protection Regulation (GDPR), visitors have various rights relating to their personal data, in order to protect their privacy:

  • The right of access
  • The right to rectification/completion
  • The right to erasure
  • The right to restrict processing
  • The right to data portability
  • The right to object to processing

Requests to exercise one or more of the above rights can be submitted to KWS in writing, via In order to ensure that you made the request concerned, we ask you to send a copy of your identity document with the request. To protect your privacy, we ask you to black out your passport photograph and Citizen Service Number (BSN) in that copy.

Depending on the nature of your request, when we receive it we will first make an assessment of interests and will determine whether we can and may comply with the request. We will then send an appropriate response.

You have the right to send a complaint to a supervisory authority.


6. Changes

We reserve the right to unilaterally change this privacy statement. Changes will be published on our website. Check our website regularly, so that you stay up to date on any changes. This privacy statement was updated on 05.10.2020.


7. Contact

Please don’t hesitate to contact us if you have any questions or complaints!

CirculinQ B.V.
Lange Dreef 9
NL-4131 NJ Vianen