Privacy policy

Last updated 2026-11-04

This notice explains how CircumPac processes personal data when you visit this website or contact us about our business. It covers the website and related business enquiries.

Who is responsible?

Data controller:
L.J.M. Alkemade
Trading name: CircumPac
Schoolstraat 17
2211EA Noordwijkerhout
Nederland
Dutch Chamber of Commerce (KvK): 99447371

For privacy questions or requests: info@circumpac.nl.

Data we use and why

Processing purposes and legal bases under the GDPR
Activity and dataPurpose and legal basis
Business enquiries: your name, work contact details, organisation and the information you send.To answer questions and discuss collaboration. Our legitimate interest (Article 6(1)(f)) is maintaining business communications. Where you personally request steps towards a contract with us, Article 6(1)(b) applies to those necessary steps.
Technical website requests and security records, where collected by the providers described below.To deliver the website, troubleshoot faults and protect it from abuse. Our legitimate interest (Article 6(1)(f)) is operating a reliable, secure website.
Necessary contract and accounting records, if an enquiry leads to business.To perform a contract with you personally (Article 6(1)(b)), administer business relationships with corporate contacts (Article 6(1)(f)), and meet applicable legal record-keeping duties (Article 6(1)(c)).

We obtain enquiry data from you, and technical data from your browser and the infrastructure used to deliver the site. Business contact information may also be provided by a colleague acting for your organisation.

You choose what to include in an enquiry. Without a return address or enough information about your request, we may be unable to respond. Details required to prepare or perform a contract must be provided for that purpose. Please do not send sensitive personal information that is unnecessary for your enquiry.

Website features and cookies

This website does not use analytics, advertising pixels, embedded third-party media, a newsletter sign-up or a contact form. Images, logos, styling and scripts are served from the website. Contact links open your own email application; clicking a link alone does not send us a message. Sending an email means your email provider will also process it under its own terms.

See our Cookie policy for information about necessary cookies and WordPress administration.

Service providers and other recipients

Website infrastructure:
Transip, WordPress

Business email:
Transip

These providers receive the data needed for their respective services. We use processing agreements where providers act as our processors. We may also disclose necessary data to professional advisers for accounting or legal matters, or to competent authorities where legally required. We do not sell your personal data or share enquiry data for third-party advertising.

International processing

Personal data covered by this notice is processed within the European Economic Area (EEA).

Contact us using the address above to request more information or a copy of applicable transfer safeguards.

How long we keep data

  • Enquiries: We retain routine business enquiries for up to 12 months after the enquiry is closed.
  • Contracts and administration: We retain contracts for the duration of the agreement and afterwards for as long as needed to meet legal obligations or handle legal claims. We retain core accounting records for seven years, or longer where required by law.
  • Technical logs: TransIP processes technical server logs, which may include IP addresses, browser information and request timestamps, to troubleshoot errors and protect the website. These logs are retained for 7 days.
  • Back-ups and other provider records: TransIP retains backups of our website files and database for up to 14 days. TransIP mailbox backups are retained for up to seven days.

Your rights

You can request access to your personal data, correction, erasure or restriction of processing. You can object to processing based on legitimate interests, on grounds relating to your situation. Where processing is based on consent or a contract and is automated, the right to data portability may apply. These rights are subject to the conditions and exceptions in the GDPR.

If we process data based on your consent, you may withdraw that consent at any time, without affecting the lawfulness of earlier processing. We do not use automated decision-making or profiling that produces legal or similarly significant effects.

Send requests to our privacy contact above. We normally respond within one month. For complex or numerous requests, this may be extended by up to two further months; we will explain any extension within the first month. We may need proportionate information to verify your identity. Please do not send a copy of your identity document unless we explain why it is needed.

You can complain to the Dutch supervisory authority, the Autoriteit Persoonsgegevens, or to the supervisory authority in your EU country of habitual residence, work or the alleged infringement.

Changes to this notice

We update this notice when our processing changes. The date above identifies the current version.