This privacy declaration has been established in response to the General Data Protection Regulations (GDPR) and concerns the processing of personal data of (contact) persons with our business relations.

This privacy declaration has been prepared by:  

             Verenfabriek de Spiraal B.V. / Tribelt B.V.

            Metaalstraat 9

            7483 PD Haaksbergen

            the Netherlands

            +31 74 291 45 08 / +31 74 250 18 77


With our business relations we mean all the parties involved in our business operations, with the exception of employees. Among employees we mean, next to the employees with a permanent or temporary employment, also temporary workers, self-employed professionals and other types of temporary contracts. A separate privacy declaration has been prepared for the employees, for which they can contact the HRM department. The privacy of applicants is also covered in the privacy declaration of employees.

In the context of processing the personal data of business relations, we make (when necessary or desired) a distinction between customers, suppliers and contractors, other relations and visitors of our website. This also includes prospective (potential) business relations.


Collection and usage of personal data  

We would like to inform you that we will collect and use the personal data provided to use since:

  1. – You have given your permission for this;
  2. – This is necessary in order to get to and to execute a possible agreement;
  3. – This is necessary in order to promote our legislative interests.

We use your data in order to contact you for purposes in the interest of our company. Think hereby for instance of discussing a potential cooperation, providing and obtaining information and maintaining our network.

In case you are a (potential) customer of us, we use your data in order to send you a quotation, to be able to determine to which specifications or desires a certain case or service should comply to, to be able to deliver products or in order to carry out activities for you, to be able to provide invoices and in order to communicate smoothly and efficiently about the implementation of the agreement.  

In case you are a (potential) supplier or other contractor, your personal data is also necessary in order to make and execute an agreement. With purchase, it is required to inform you to which specifications or desires a certain case or service in our opinion should comply to, to send a quotation or to enable to place an order with you, to pay your invoices, and to realize a smooth and efficient communication on other aspects of the agreement.

Of all business relations, with the exception of visitors of our website(s), it is the case that we process the following data; surname, including possible inserts, name, employer, function, gender, email address, telephone data and/or other information from your business card.

You are not obliged to provide us with your personal data. It is possible, in case you do not provide us, or provide us with insufficient personal data, that we cannot realize the previously mentioned purposes.

If you visit our location in Haaksbergen, we would like to inform you about the use of security cameras. The footages will only be consulted in case of (possible) burglary, (possible) theft or a security incident. The footages will not be used to track and or follow the movements of our visitors. 

In case you are a visitor of our website, we use your data in order to optimize our website by means of Google Analytics. Google Analytics makes use of a cookie, which is a small file that will be stored on your computer. This program thereby provides important statistics about the number of visitors, the pages visited, the power sources and other essential information that can be used to continuously improve our website. There is no use of ‘behavioural targeting’, by which you obtain special content based upon your click behavior. Data from contact forms will never be processed in Google Analytics. In case you make use of a contact form, we will use the data obtained as prescribed above in the paragraph “In case you are a (potential) customer of us….”


Transfer to third parties

In relation to the execution of a possible agreement with you, it is possible that we have to provide your personal data to parties whom supply components, materials and products to us, or, whom carry out activities in the name of us.

We make use of an external server space for the storage of our backups (parts of) our contact files and (parts of) our sales and purchasing administration, of which your personal data are also a part.  Moreover, we make use of Microsoft Office and the associated storage facilities for e-mails and other files. In addition to Microsoft Office software, we use various company specific software packages. The suppliers, in case they have got our permission, have access to our systems in order to provide us with the support required. Our ICT service providers has next to that also access to our systems.

In order to provide you with relevant information on occasion we make us of a newsletter mailing service (Mailchimp). Your personal data is thereby transferred to the provider of this service. We will only use this service in order to send the same information to a large group of intended recipients. We first of all do this to prevent that our own mail server overloads. Second of all, we hereby prevent that our mail server is being seen as a server used to send SPAM with.

In addition, as mentioned and explained earlier, we use website statistics collected by Google Analytics.

With all third parties Data Processing Agreements (DPA’s) have been made in order to secure your privacy.


Retention period of personal data

Our experience has shown that our clients appreciate that we belong to each other’s network, and that we approach each other in this way. That is why we consider it as essential that we keep the personal data which we retain, for a longer period available.

Due to the aforementioned reason, and to the manageability of the system regarding the deletion of personal data, we maintain a retention period of seven years for the personal data of relations. This is, besides a few exceptions, the maximum period for which legally have to maintain (parts of) our administration.

In case we consider it necessary to maintain the contact data for a longer period than the aforementioned period, we will only do this when there are valid reasons for this. An example could be that you as a customer impose on us that we should maintain the files belonging to an agreement for a longer period.

Data registered due to your visit to our website, will be stored by Google (Analytics). In order to evaluate and compare the effect of certain marketing activities we have determined that this data needs to be stored for a longer period. To be clear, we only register the IP-address of the location (not your device) from where you are visiting our website and the routing (which pages in which order) of your visit.

The footages of our camera-security systems are automatically deleted after 14 days. Only in case of an incident, it could be necessary to retain these longer. This will then solely contain the footages in relation to the incident. 


Data security

We pay a lot of attention to the security of data which we process from our business relations. In addition to your privacy, it is in our commercial interest that our data won’t become public. Where your data is in our systems, we have thorough access control with authority structure and password policy, we very strictly regulate external access and we use adequate security software which is up-to-date.

For the external back-up of our data, it is the case that there are saved encrypted and that the data is uploaded encrypted (via https).

With regard to the third parties that process the personal data for us, it is the case that we have agreed upon processing agreements. Thereby, taken into consideration the security level at which the third party works.


Your rights

You have the right to ask us to view your personal data. If there is reason to do so, you can also request us to complement your personal data or to change inaccuracies. You also have the right to request us to delete your personal data or to restrict the usage of your personal data. Next to that, you can also object to the collection and usage of your personal data and file a complaint with the Authority Personal Data. Finally, you can request us to obtain your personal data or to transfer this data to another. In order to exercise your rights, you can contact us via the aforementioned telephone numbers and e-mail addresses. You can of course also contact us with questions or for further information about the collection and usage of your personal data.

Haaksbergen, May 31 2018