1. Data Controller
The data controller responsible for your personal data is:
| Company | ETURN B.V. |
| KvK number | 53545702 |
| VAT number | NL.8509.21.399.B01 |
| Address | Fluorietweg 21A, 1812 RR Alkmaar, Netherlands |
| info@eturn.eu | |
| Phone | +31 (0)72 303 68 00 |
2. Data We Collect
Depending on how you interact with us, we may process the following categories of personal data:
- Contact details: name, company name, email address, telephone number.
- Project enquiry data: site address, installation type, energy requirements.
- Communication records: emails, call notes and correspondence relating to a project or quotation.
- Contractual data: signatory details, invoicing addresses, bank account information (IBAN).
- Website usage data: IP address, browser type, pages visited, session duration (via analytics cookies, subject to your consent).
3. Purposes & Legal Basis
| Purpose | Legal basis (GDPR Art. 6) |
|---|---|
| Responding to contact form enquiries | Art. 6(1)(b) – pre-contractual steps |
| Preparing and executing EPC contracts | Art. 6(1)(b) – contract performance |
| Invoicing and accounting | Art. 6(1)(c) – legal obligation |
| Safety and certification compliance | Art. 6(1)(c) – legal obligation |
| Sending service updates to existing clients | Art. 6(1)(f) – legitimate interest |
| Website analytics (with consent) | Art. 6(1)(a) – consent |
4. Retention Periods
We retain personal data only for as long as necessary for the purpose for which it was collected, or as required by law:
- Enquiry data (no contract concluded): 12 months from last contact.
- Contractual and invoicing records: 7 years (Dutch tax law, Belastingdienst requirement).
- Project documentation and warranties: duration of the warranty period plus 2 years.
- Website analytics: maximum 13 months (rolling).
5. Sharing of Data
We do not sell, rent or trade your personal data. We share data only where necessary:
- Sub-contractors and installation partners engaged to deliver a specific project (data processing agreements are in place).
- Our accountant and financial administration software (processing agreement in place).
- Government authorities where required by law (e.g. Belastingdienst, local municipalities for permit applications).
- Our hosting and email service providers, all operating within the EEA and covered by data processing agreements.
6. International Transfers
We operate primarily within the European Economic Area (EEA). When we use cloud services hosted outside the EEA, we ensure appropriate safeguards are in place, such as the European Commission's Standard Contractual Clauses (SCCs) or an adequacy decision.
7. Your Rights (GDPR)
Under the General Data Protection Regulation (EU 2016/679), you have the following rights:
- Right of access (Art. 15) – obtain a copy of the personal data we hold about you.
- Right to rectification (Art. 16) – correct inaccurate or incomplete data.
- Right to erasure (Art. 17) – request deletion of your data, subject to legal retention obligations.
- Right to restriction (Art. 18) – limit how we process your data in certain circumstances.
- Right to data portability (Art. 20) – receive your data in a structured, machine-readable format.
- Right to object (Art. 21) – object to processing based on legitimate interest.
- Right to withdraw consent – where processing is based on consent, you may withdraw it at any time without affecting prior processing.
To exercise any of these rights, contact us at info@eturn.eu. We will respond within 30 days. You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at autoriteitpersoonsgegevens.nl.
8. Cookies
Our website uses the following categories of cookies:
- Strictly necessary cookies – required for the website to function. No consent needed.
- Analytics cookies – we use anonymised analytics to understand how visitors use our site. These are only placed with your explicit consent.
You can manage or withdraw cookie consent at any time through the cookie banner or by adjusting your browser settings.
9. Security
We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. These include TLS encryption for data in transit, access controls, and regular security reviews. In the event of a data breach that poses a risk to your rights and freedoms, we will notify the Autoriteit Persoonsgegevens within 72 hours, and you directly if required.
10. Changes to this Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The "Last updated" date at the top of this page will always reflect the most recent revision. Significant changes will be communicated to existing clients by email.
11. Contact
For any privacy-related questions or to exercise your rights, please contact:
- Email: info@eturn.eu
- Post: ETURN B.V., Fluorietweg 21A, 1812 RR Alkmaar, Netherlands
- Phone: +31 (0)72 303 68 00