Privacy Statement

Steeltrace is a SaaS platform that automates the entire MTC process from mill to end product providing a central quality data-hub, to which all parties can contribute.

The protection of personal data is very important to SteelTrace.

SteelTrace respects your privacy and ensures that your personal information is always treated confidentially and in accordance with currently applicable laws and regulations. 

What are personal data?

Personal data are data that relate to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more elements characteristic of his or her physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

The General Data Protection Regulation (GDPR) does not apply to deceased persons, because according to the law these are no longer natural persons. When the data of a deceased person says something about another person (more specifically the next of kin), it may be personal data. Then they do not concern the deceased, but the other, living person. 

The GDPR makes a distinction between ‘ordinary’ personal data and special categories of personal data. Special categories of personal data are data that are particularly sensitive by their nature. Specifically, it concerns: data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a person, data on health and data relating to a person’s sexual behavior or sexual orientation. The processing of these special categories of personal data is prohibited, unless a specific exception applies or the data subject has given his or her explicit consent to the processing.

In addition to the special categories of personal data, personal data of a criminal nature are also so sensitive that there is a special regulation for this. 

A national identification number is a unique number established by law. In the Netherlands, the best-known national identification number is the social security number (BSN). This may only be used for purposes prescribed by law.

To whom does this Privacy Statement apply?

This Privacy Statement applies to all persons for whom SteelTrace processes personal data:

• visitors to our website;
• (potential) clients of SteelTrace;
• recipients of our newsletters and other
• third parties who communicate with SteelTrace;
• visitors to the SteelTrace office building;

Which personal data does SteelTrace process?

• contact details that you have provided to us (such as name, e-mail address, telephone number) and the data you provide to us for the benefit of your business;
• data relating to your visit to our website or while reading digital newsletters (e.g. IP address);
• data that we have derived from other sources such as information on business social media platforms and the trade register of the Chamber of Commerce. Our website contains hyperlinks to websites of other parties and a social media button from e.g. LinkedIn (if you click on this button, your personal data will be processed by LinkedIn). SteelTrace is not responsible for any information or content on such websites, nor for the services offered by LinkedIn. View the privacy statements that have been posted on the other websites and LinkedIn;
• camera images when visiting the building.

For what purposes does SteelTrace process your personal data?

• the processing is required for the performance of a contract to which you are party, or it is required to take specific measures, on your request, before the contract is entered into;
• maintaining contact and communicating with you;
• marketing activities such as sending newsletters;
• conducting customer satisfaction surveys and improving the quality of our services (such as improving our website).

On the basis of which legal grounds does SteelTrace process your personal data?

• performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract; 
• legal obligation: this is when SteelTrace is required to process your personal information in order to comply with a legal obligation;
• legitimate interests: SteelTrace will process information about you where it is in our legitimate interest in running a business to do so in order to further that business, so long as it doesn’t outweigh your interests;
• your consent: in some cases, SteelTrace will ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so. You may withdraw your consent at any time by contacting us.

How does SteelTrace protect your personal data?

SteelTrace takes appropriate technical and organizational measures to protect your personal data against loss, misuse, alteration or against any form of unlawful processing. Despite SteelTrace’s best efforts, however, security cannot be absolutely guaranteed against all threats.  If you would like more information about the security of your personal data, we ask you to contact us.

How does SteelTrace share your personal data with third parties? 

SteelTrace does not share personal data with third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards (such as: Third Party inspection bodies).

SteelTrace does not share personal data with third parties for commercial purposes and does not transfer personal data to countries outside the European Economic Area (EEA).

For the processing of your personal data, it may sometimes be necessary to engage other service providers (processors). SteelTrace requires the processor to undertake to process the data exclusively on behalf of SteelTrace, with due observance of SteelTrace’s instructions and to take appropriate security measures to keep the personal data strictly confidential, in accordance with the applicable laws and regulations. SteelTrace will conclude a processing agreement with these processors that meets the requirements of the GDPR.

How long does StreelTrace keep your personal data? 

There is no specific retention period for personal data on the basis of the GDPR, but it is not the intention to keep this data longer than necessary. SteelTrace does not store your personal data longer than is necessary to achieve the purposes stated in this Privacy Statement. When we no longer need your information, we will take all reasonable steps to remove it from our systems.

What are your rights?

SteelTrace will respect your rights under applicable law and you can make various requests to us regarding your personal data. According to applicable law:

• you have the right to be informed about the processing of your personal data and ask us for an overview of your personal data that we process (the right to access);
• if your personal data is incorrect or incomplete, you have the right to ask us to rectify it;
• you can object to SteelTrace using your personal data for its own legitimate interests if you have a justifiable reason (the right to restriction of processing);
• you have the right to ask us to transfer your personal data directly to you or to another company (the right to data portability);
• you have the right to object and complain;
• you have the right to erasure or ‘right to be forgotten’: delete your personal data;
• you have the right to object to automated decisions.

Changes and updates to this Privacy Statement:

From time to time, SteelTrace may update or change this Privacy Statement. Therefore, please regularly consult this Privacy Statement.

Cookies:

Cookies will be placed on your computer or internet-enabled device whenever you visit our website. This allows the site to remember your computer or device and serves a number of purposes.

On our website a notification banner will appear allowing you to provide and manage your consent to use cookies (cookie banner). Below is a summary of the categories of cookies that (may) be used on our website, and how your consent may impact your experience of certain features as you navigate our website:

Analytical cookies: Performance cookies are cookies used to gather data to enhance the performance of a website.

Strictly necessary cookies: Strictly necessary cookies are essential in order to enable users to move around the website and use its features, such as accessing secure areas of the website. These cookies must be enabled or the site will not function. Use of these cookies does not require your prior consent and cannot be blocked either.

Functionality cookies: Functionality cookies are used to remember customer selections that change the way the site behaves or looks. If you do not consent to use these cookies that will impact your experience on the website, and you may need to repeat certain selections each time you visit.

Tracking cookies: Tracking cookies are used to deliver content relevant to your interests. They are also used to limit the number of times you see certain marketing materials, as well as help measure the effectiveness of those marketing materials. If you do not provide consent for tracking cookies, your computer or other internet-enabled device will not be tracked for marketing-related activities.

In principle we will only use performance, functionality and tracking cookies based on your consent which you can provide and manage via the cookie banner.

For more information about this you can visit the website “ Rijksoverheid.nl“.

Complaints and/or questions:

We would like to point out the right to file a complaint with the Dutch Data Protection Authority (de Autoriteit Persoonsgegevens). However, we would appreciate it if you first send your complaint to SteelTrace via the contact form. Also, if you have any questions about how we process your personal data or if you wish to exercise any of your rights, you can contact us via the contact form.

This Privacy Statement was updated on march 11th 2022