In accordance with the EU General Data Protection Regulation (GDPR) this Privacy Statement and Cookies Policy document provides information on the processing of personal data on the internet site located at along with any related websites, networks, such as LinkedIn, and other services provided by Stichting Circle Economy, hereafter Circle Economy, we or us.

This document may be changed over time. The most up-to-date version is published on our website. This policy was last changed on 15 December 2022. You can store or print this document by using the buttons at the top of this page.



This Privacy Statement is applicable to the processing by Circle Economy of all personal data of its customers, suppliers and business partners and other individuals. This Privacy Statement does not address the processing of personal data of employees in the context of their employment relationship with Circle Economy.


Name, username, contact details, email address, organisation, role, correspondence, communication channel you have chosen to use to connect with us, and other personal data you supply in messaging us.

Email address, name, correspondence with us, IP-address, pages visited on our websites, click- and surf behaviour, the length of sessions, delivery of newsletters, etc. are retrieved when making use of our digital services.

Address, email address, name, payment information, payment history, Chamber of Commerce and VAT details, and tax details are collected in the course of partnerships and business activities.

Name, contact details, correspondence, and other personal data necessary to get your feedback.


Data is either directly provided to us or indirectly from any related websites or networks. Your personal information is directly retrieved when visiting any of Circle Economy’s webpages, when registering in one of our digital tools or when contacting us through one of our message boards via email. Indirectly, data is given to us from networks such as LinkedIn, Twitter or Google.


Circle Economy employs the following computer programs and systems:

  • Google Workplace

This is how we collaborate. Employees have access to mail, documents and information.

  • Slack 

This is how we communicate online. Employees use Slack for instant messaging. 

  • Buffer 

This is the tool that we use to manage our social media accounts 

  • Asana 

This is how we manage projects and tasks and keep track of the projects 

  • Mail Chimp

This is our method for email marketing. Your information will be handled in this way if you submit a request to subscribe to our newsletter via the website.

  • Exact Online

Your data would be saved by this financial system if we had a contract and collaborated together.


  • To provide our services to you, which may include communicating with you about your use of our websites, allowing you to download our reports, responding to your inquiries, troubleshooting problems, connecting with you on social media and for other customer service purposes.
  • To better understand how you access and use our websites, both on an aggregated and individual user basis, on individual website pages and across them in order to improve our websites and respond to user desires and preferences, and for other research and analytical purposes;
  • To comply with the law, Circle Economy may process your personal data and may disclose your personal data to government institutions or supervisory authorities. This could, for example, be the case where tax or business conduct related obligations apply.
  • For marketing, and promotional purposes, including, for example, to send you news and newsletters, promotions, or to otherwise contact you about projects, opportunities or information we think may interest you provided you have opted into receiving such communications from us; to administer surveys and questionnaires
  • For the assessment and acceptance of a customer, supplier or business partner or other administrative purposes such as due diligence and screening against publicly available government and/or law enforcement agency sanctions lists
  • For administrative purposes such as sending reports, invoices and making payments, to deliver or receive and administer our or your products or services, and to further execute our agreement, including for the delivery of customer services
  • For business process execution and internal management in the performance and organisation of our business, such as general management, order management and internal management; for audits and investigations, to implement business controls, and to manage and use customer, supplier and business partner directories; for finance and accounting, archiving and insurance purposes, legal and business consulting and in the context of dispute resolution
  • For organisational analysis and development, to create management reports and to analyse Circle Economy's business
  • To check compliance with Circle Economy policies and regulations, such as the Code of Ethics and the IT Policy. During monitoring activities, your personal data may be accessed and viewed.‍


Circle Economy has taken adequate safeguards to ensure the confidentiality and security of your personal data. Circle Economy has implemented appropriate technical, physical and organisational measures to protect personal data against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorised disclosure or access as well as all other forms of unlawful processing (including, but not limited to, unnecessary collection) or further processing. Examples are IT security policies, staff training and secure servers.


Circle Economy will retain your data until it is no longer needed for historical, statistical or research purposes, or until it is no longer necessary to be preserved for possible future legal claims. Generally, Circle Economy applies the principles of the GDPR and will store your data for the shortest possible period of time. This means we will review your data as soon as there is reasonable belief it is no longer necessary for achieving the purposes for which the personal data was collected, and subsequently deleted.


Circle Economy and/or its affiliated partners are the controllers of the processing of all personal data that fall within the scope of this Privacy Statement. This Privacy Statement indicates what personal data are processed by Circle Economy and for what purpose, and to which persons or entities the data will or may be provided. Circle Economy may share your personal data with third parties (see Cookies Policy section).


Circle Economy processes data only if and to the extent that at least one of the following applies:

  • you have given consent to the processing of personal data for one or more specific purposes;
  • processing is necessary for the performance of a contract to which you are party to or in order to take steps at your request prior to entering into a contract;
  • processing is necessary for compliance with a legal obligation to which we are subject;
  • processing is necessary in order to protect your vital interests or the interests of another natural person;
  • processing is necessary for the performance of a task carried out in the public interest;
  • processing is necessary for the purposes of the legitimate interests pursued by us or by a third party


Circle Economy employees are authorised to access personal data only to the extent necessary to serve the applicable purpose and to perform their jobs. We will not sell your data to third parties and only when it is required for the execution of our agreement with you or to satisfy a legal need will we divulge this information. We will employ a processor agreement with businesses who handle your data as part of our assignment to maintain the same degree of security and confidentiality.

The following third parties have access to your personal data, where relevant, for the provisioning of their products or services to Circle Economy:

  • Banks
  • Insurance companies
  • IT suppliers
  • Accountants

When third parties are given access to your personal data, Circle Economy will take the required contractual, technical and organisational measures to ensure that your personal data are only processed to the extent that such processing is necessary. The third parties will only process your personal data in accordance with applicable law.

If your personal data are transferred to a recipient in a country that does not provide an adequate level of protection for personal data, Circle Economy will take measures to ensure that your personal data are adequately protected, such as entering into EU Standard Contractual Clauses with these third parties.

In other cases, your personal data will not be supplied to third parties, except where required by law.

When a third party processes your personal data solely following Circle Economy instructions, it acts as a data processor. We enter into an agreement with such a data processor for the processing of personal data. In this agreement we include obligations to ensure that your personal data are processed by the data processor solely to provide services to us.


We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements. In certain circumstances we may be required by law to retain your personal data, or may need to retain your personal data in order to continue providing a service.

Pursuant to GDPR, users have the following rights regarding their personal data.

Circle Economy acknowledges that you have the right to access your personal data. Upon request Circle Economy will provide you with information about whether we hold any of your personal data. You may access, correct, or request deletion of your personal data by contacting us at  We will respond to your request within a reasonable timeframe in accordance with applicable law. Users are able to retain and reuse their personal data for their own purpose.

Circle Economy acknowledges that you have the right to correct your personal data. You can change your and update any personal information held by Circle economy by contacting us via Your previous mentionings or contributions will be associated with the updated information. Circle Economy acknowledges that you have the right to remove, or request the removal of, content or information that was posted publicly on Circle Economy’s webpages or associated platforms. If you would like us to delete your records in our system, you are able to do so by contacting us at with a request to delete your personal data and entering “Delete my personal information” in the subject line. We will use commercially reasonable efforts to honour your request. We do not have control over third parties (e.g., Other Users) who may have copied or reposted this information. If you have included personal data in online forum postings or in information or communications shared with Other Users, you may not be able to update, correct or delete this information from the Platform.

Circle Economy acknowledges that you have the right to restrict processing of personal data. You may, of course, decline to share personal data with the Platform, in which case the Platform will not be able to provide to you some of the features and functionality found on Circle Economy. For example, absent personal data, you cannot post an Idea or Comment.



We also collect information through the use of cookies. Cookies are small files of information which save and retrieve information about your visit to this website – for example, how you entered our site, how you navigated through the site, and what information was of interest to you.

Circle Economy does not retain a cookie longer than necessary. We use session cookies and permanent cookies:

  • A session cookie can track usage such as the webpages you visit and what options you use. When you close the internet browser, the session is ended and the cookie is deleted.
  • A permanent cookie enables the Website to recognize you at a subsequent visit.


Circle Economy stores cookies that are essential in providing the functionalities of the Website. For instance, cookies that support logging in to password-protected pages on the Circle Economy website.

If you do not wish to receive any cookies at all, you may set your browser to refuse cookies altogether. Please note that in that case you may no longer be able to use all the functionalities of the Website.

Non-strictly necessary cookies

Only if you have given prior consent, Circle Economy places cookies that are not strictly necessary for providing the functionalities of the Website. Through such non-strictly necessary cookies we collect information about your use of the Website and remember your preferences. Examples of collected information are which pages are visited and the length of a user session. Through these cookies we aim to improve your user experience of our Website. If you do not consent to cookies being placed, these cookies will be blocked.

Please see below a summary of the non-strictly necessary cookies that Circle Economy uses.



You can set your browser not to accept cookies, and find information on how to remove cookies from your browser in this link. However, in a few cases, some of our website features may not function as a result.


Only if you have given prior consent, Circle Economy will use Third Party cookies. If you do not consent to the placement of such cookies, these cookies will be blocked. 

Google Analytics is a web analysis service that is offered by Google Inc. (Google). Google Analytics uses cookies to analyse the usage of the Website by Users. Google uses aggregated statistical data to give Circle Economy an insight in the way Users use the Website. Google may only provide these data to third parties if Google is required to do so by law, or to the extent of third parties processing these data on behalf of Google. You can find more information on Google Analytics here.

Hotjar is a behaviour analytics and user feedback service that helps Circle Economy understand the behaviour of the Website users and get their feedback through tools such as heatmaps, session recordings, and surveys. You can find more information about Hotjar’s data and privacy policy here.

The Facebook pixel is a product of Facebook, Inc (Facebook) that allows Facebook to use cookies to provide targeted advertising to Circle Economy users and aggregated statistical data to give insight to Circle Economy in the way Users use the Website following adverts. You can find more information about Facebook’s data and privacy policy here.

The Twitter tag is a product of Twitter, Inc (Twitter). Twitter uses cookies to provide targeted advertising to Circle Economy users and aggregated statistical data to give insight to Circle Economy in the way Users use the Website following adverts. You can find more information about Twitter’s data and privacy policy here.

The LinkedIn Insight Tag is a product of LinkedIn Corporation (LinkedIn). LinkedIn uses cookies to provide targeted advertising to Circle Economy users and aggregated statistical data to give insight to Circle Economy in the way Users use the Website following adverts. You can find more information about LinkedIn’s data and privacy policy here.


If you have any questions about Our Company’s privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Email us at: