1. About this policy
Pro Commodities B.V. ("Pro Commodities", "we", "us") values your privacy and handles your personal data with care. This policy explains what data we collect, why we collect it, how we use it, and what rights you have under the EU General Data Protection Regulation (GDPR) and Dutch privacy law.
This policy applies to all visitors of procommodities.nl and to anyone who contacts us through this website, by email, or by phone.
2. Who is responsible for your data
The data controller is:
Pro Commodities B.V.
Amsterdam, the Netherlands
Email: info@procommodities.nl
KvK: 63890860
3. What data we collect
We only collect data that is necessary for the purposes described below. Specifically:
Data you provide to us
- Contact form data: name, company, country, email address, phone number, product of interest, estimated volume, destination, and any message you send us.
- Email correspondence: any information you share with us by email.
Data we collect automatically
- Technical data: IP address, browser type and version, operating system, referring URL, pages visited, and timestamps. This is logged by our hosting provider for security and performance reasons.
- Cookies: we use only strictly necessary cookies for the website to function. We do not use tracking, advertising, or analytics cookies without your consent.
4. Why we use your data
We process your personal data for the following purposes:
- To respond to your enquiry: when you fill in the contact form or email us, we use your data to reply, prepare a quotation, and follow up on the trading opportunity.
- To execute and manage contracts: if we enter into a trading agreement, we use the necessary data to fulfil our contractual obligations.
- To comply with legal obligations: for example, accounting, tax, anti-money-laundering, and trade compliance requirements.
- To secure and improve our website: we use technical data to detect malicious activity and to improve site performance.
5. Legal basis
We process your data on the following legal bases under Article 6 GDPR:
- Performance of a contract (Art. 6(1)(b)) — for processing related to a quotation or trading agreement.
- Legitimate interest (Art. 6(1)(f)) — for handling enquiries, securing our website, and managing our business operations.
- Legal obligation (Art. 6(1)(c)) — for tax, accounting, and trade compliance requirements.
- Consent (Art. 6(1)(a)) — where applicable, for example for non-essential cookies (we currently do not use any).
6. Who we share your data with
We do not sell your personal data. We share data only with parties that help us run our business and only to the extent necessary:
- Service providers: our hosting provider, email provider, and accounting software provider. All processors are bound by data processing agreements compliant with the GDPR.
- Trade and shipping partners: when fulfilling a trading agreement, your business contact details may be shared with shipping companies, customs agents, and producers as strictly necessary.
- Authorities: when required by law, for example tax authorities or trade compliance regulators.
We do not transfer your personal data outside the European Economic Area (EEA) unless adequate safeguards are in place, such as Standard Contractual Clauses or an adequacy decision by the European Commission.
7. How long we keep your data
We retain your personal data only for as long as necessary:
- Contact enquiries that do not result in a trading relationship: up to 2 years after the last contact.
- Trading relationships: for the duration of the contractual relationship and up to 7 years afterwards, in line with Dutch tax law.
- Server logs: typically up to 30 days, longer if needed for security investigations.
8. Your rights
Under the GDPR, you have the right to:
- Access the personal data we hold about you
- Rectify inaccurate or incomplete data
- Erase your data ("right to be forgotten") in certain situations
- Restrict the processing of your data
- Data portability — receive your data in a structured, machine-readable format
- Object to processing based on legitimate interest
- Withdraw consent at any time, where consent was the legal basis
- Lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) if you believe we are not handling your data correctly
To exercise any of these rights, please email info@procommodities.nl. We will respond within 30 days.
9. How we protect your data
We take appropriate technical and organisational measures to protect your data, including:
- HTTPS encryption on the website
- Restricted access to data on a need-to-know basis
- Regular security updates of our systems
- Data processing agreements with all our service providers
10. Cookies
This website uses only strictly necessary cookies that are required for the site to function. We do not currently use analytics, advertising, or tracking cookies. If this changes in the future, we will request your explicit consent through a cookie banner before placing any non-essential cookies.
11. Changes to this policy
We may update this policy from time to time to reflect changes in our practices or in applicable law. The "last updated" date at the top of this page indicates when the policy was last revised. Material changes will be communicated via the website or directly to relevant clients.
12. Contact
For any questions about this policy or about how we handle your personal data, please contact us at info@procommodities.nl.
This privacy policy is provided as a general template and should be reviewed by your legal advisor before publication, particularly the sections on KvK number, retention periods, and data transfers, to ensure full alignment with your specific business operations.