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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.

SteelTrace uses hCaptcha to provide security on our various on-site forms (e.g. the Contact Form and the Newsletter Sign Up Form). hCaptcha collects some information from your device (e.g. browser version, IP address) to protect against spam and bots whilst remaining GDPR-compliant. Please see the hCaptcha Privacy Policy for more details.

If you opt-in to analytical/performance cookies, we may use Hotjar to help analyse the experience of users on our website, and improve the overall user experience on the site. To do this, Hotjar monitors keyboard and mouse movement and sends this to the Hotjar servers, which SteelTrace later reviews to monitor any issues visitors may be having. NOTE: any data entered into forms is excluded. Please see the Hotjar Privacy Policy for more details.

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.


Cookies will be placed on your computer or internet-enabled device when you visit our website. We use two key types of cookie: required/functional and analytical/performance cookies. We do not use marketing cookies.

Analytical/performance cookies are only loaded if you consent to their use (see Cookie Consent below).

Required/Functional Cookies

These cookies allow us to record your privacy choices, log when you have dismissed our automated newsletter popup, and help ensure security on our various on-site forms

These are required to allow the site to function, and may be loaded on the site automatically.

Cookie Name Description
tracking_consent Used to record the decision made by the user to allow all cookies, or only allow functional cookies.
newsletter_hidden Set after the user has dismissed the automated ‘sign up for our newsletter’ pop up, to prevent it automatically reappearing.

In addition, we use hCaptcha to provide security on our various on-site forms (e.g. the Contact Form and the Newsletter Sign Up Form). Whilst hCaptcha may not directly store cookies on your browser, it does collect some information to protect against spam and bots whilst remaining GDPR-compliant. Please see the hCaptcha Privacy Policy for more details.

Analytical/Performance Cookies

These cookies allow us to analyse the usage of our site, so that we can review and improve on the user experience of the site. They also allow us to engage with potential customers who submit forms on this site in a proactive and relevant fashion.

NOTE: Unless you consent to allow all cookies, none of the cookies below are set, and the associated code is not loaded.


We host our own instance of Mautic to help us engage with our customers. We use it to monitor how our marketing campaigns work for potential customers, by tracking which form(s) you submit (e.g. to get our blockchain guide), and seeing which follow-up emails that we send you result in you clicking to visit our site again. This helps us fine-tune our communications with potential customers.

We do not share any of the collected information with third parties.

We use the following cookies in our Mautic installation:

Cookie Name Description
mautic_device_id Used by Mautic to track the Contact for either the tracking pixel or if the same key is not found in the browser’s local storage for the monitored site.
mtc_id Stores the Mautic ID of the tracked Contact. It was used for tracking prior to Mautic 2.13 but is no longer used and kept for BC reads.
mautic_referer_id Stores a reference to the last tracked page for the Contact and used by Mautic to determine when a Contact exits a page they visited.
mtc_sid Deprecated cookie that is the same as mautic_device_id. It is no longer actively used by Mautic but kept for BC reads.

For more details, please read the Mautic Contact Tracking page.


We host our own instance of Matomo analytics as a privacy-focussed alternative to Google Analytics. We use it to track which pages you visit, so that we can better understand which pages on our site are the most popular, and to optimise the content of our site to ensure you can get access to the information you need, quickly and easily. We also use it to analyse where in the world our visits are coming from, and where our visitors found our site.

We do not share any of the collected information with third parties.

We use the following cookies in our Matomo installation:

Cookie Name Description
_pk_id* Stores a few details about the user such as the unique visitor ID.
_pk_ref* Used to store the attribution information, the referrer initially used to visit the website.
_pk_cvar* Short lived cookie (expires after 30 minutes) used to temporarily store data for the visit.
_pk_ses* Short lived cookie (expires after 30 minutes) used to temporarily store data for the visit.

* The cookies start with this text, and will have a unique ending, e.g. _pk_ref.1.1234

For more details, please read the Matomo Cookie Details FAQ.

Marketing Cookies

We do not use marketing cookies.

Cookie Consent

Analytical/performance cookies are only loaded if you agree via our ‘Cookie Consent’ dialogue, which displays when you first visit the site.

You may change your decision at any time via the ‘Change Cookie Consent’ link in the page footer. Revoking consent will delete the analytical/performance cookies listed above.

For more information about this you can visit the website

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.

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.

This Privacy Statement was updated on November 28th 2022