Privacy statement

PRIVACY STATEMENT – HB RTS
1. Introduction
HB RTS (“we,” “us,” “our”) is committed to protecting the privacy of all visitors to our international website and users of our services. This Privacy Statement explains how we process your personal data. With regard to this processing of your personal data, HB RTS qualifies as the "controller" within the meaning of the General Data Protection Regulation (EU) 2016/679 ("GDPR"). The term "personal data" includes all information about an identified or identifiable natural person.
In this Privacy Statement, we inform you about the use of your personal data and your privacy rights, among other things. Please feel free to contact us if you have any additional questions. Our contact details are:
HB RTS Holding, LLC
41 Fermi Road
3542 CB Utrecht
Netherlands
+1 (0)30 - 78 20 979
2. Personal data we collect
We may process the following categories of personal data:
Customers
We may process the following (categories of) personal data of our (potential) customers and their contacts:
• Name and address details (last name, first names, initials, titles, gender, address, postal code, job title) as provided by the customer.
• Other contact details (phone number, email address, and similar information necessary for communication) as provided by the customer.
• Payment details, including bank account information as provided by the customer.
• Additional information, such as the customer's industry, company name, information about the contact person's work history (e.g., previous organizations where someone has worked), gender of the contact person(s), preferred language for correspondence, areas of interest, home address, date of birth, name of spouse/partner, hobbies, and other personal notes as gathered during interactions with the customer's contact person(s).
• Other data whose processing is required by or necessary to comply with applicable laws or regulations, as provided by the customer, obtained from a public source such as the Commercial Register, or received from supervisory or regulatory authorities or another third party.
Suppliers
HB RTS processes the following (categories of) personal data of individuals from whom we purchase products or services or who are employed by these suppliers:
• Name and address details (surname, first names, initials, titles, gender, address, postal code, place of residence) as provided by the supplier (or its contact persons).
• Other contact details (telephone number, email address, and similar details necessary for communication) as provided by the supplier (or its contact persons).
• Data for placing orders or purchasing services, calculating and registering fees and costs, making payments and collecting receivables, including the bank account number provided by the supplier (or its contact persons).
• Other data from suppliers that must be processed or is necessary to comply with applicable laws or regulations, as provided by the supplier (or its contact persons) or obtained from public sources such as the Trade Register.
Job applicants
HB RTS may process the following (categories of) personal data of applicants , as provided by you or your reference:
• Contact details (last name, first names, initials, titles, gender, address, postal code, city).
• Other contact details (phone number, email address, and similar information necessary for communication).
• Nationality and date of birth.
• Availability, resume, and employment history (copies of diplomas, certificates, reference letters), cover letter, and, if relevant to the vacancy: references as provided by the applicant or the referee.
• Information about the position applied for, notes from job interviews, and written communication with the applicant.
Third parties
We process (categories of) personal data from third parties, such as visitors to our website and references for job applicants:
• Name and address details (last name, first names, initials, titles, gender, address, postal code, city), to the extent known to us.
• Other contact details (phone number, email address, and similar information necessary for communication), to the extent known to us.
• Information automatically collected when you visit our website, including your IP address, company name identified through IP recognition, company details (industry, company size, and location), browser type and version, device data, website usage such as visit frequency and times, including repeat visits and interaction patterns, traffic source (e.g., campaign, referral, or organic), CRM integration (e.g., HubSpot for follow-up), cookies, and similar tracking technologies (see also our Cookie Policy).
• Data relating to electronic messages originating from or intended for third parties and data necessary to maintain contact with these third parties.
Data obtained from third parties
In principle, we obtain personal data directly from the individuals concerned or the company they work for. In addition, we may receive personal data from third parties, namely:
• Public business databases, such as the Chamber of Commerce.
• Lead generation partners.
• HB RTS partners or subsidiaries.
• Social media platforms when you interact with our content, currently LinkedIn and Facebook.
Newsletters
We process the following categories of personal data when you receive our newsletters :
• Your name.
• Your email address.
• Your company name.
Camera surveillance
At our locations, we use camera surveillance, whereby video recordings are made and the date and time of the recording are processed.
3. Legal bases for processing and purposes
We process your personal data based on one or more of the following legal processing bases:
a. If this is necessary for the performance of a contract to which you are a party, or to take pre-contractual steps at your request.
b. If this is necessary to comply with legal obligations.
c. If this is necessary to protect our legitimate interests or those of a third party.
d. Your consent.
When we process your personal data based on your consent, we will ask you for it separately. You can withdraw your consent at any time. Please note that withdrawing your consent does not affect the lawfulness of the processing of your personal data prior to the moment of withdrawal.
We use the above personal data for the purposes listed below. For each purpose, we have indicated which of the above legal bases (a to d) we use as a basis for doing so. If the processing is based on the principle of 'legitimate interest', we briefly explain this interest. If you have any specific questions about this, please feel free to contact us.
• Supplying and improving the requested products, logistics services, and RTI-related services, including preparing and providing quotations (a, b, and c: being able to offer and improve our products and services);
• For our administration, including calculating or registering reimbursements or benefits, income and expenses, and paying and collecting claims (including engaging collection agencies or bailiffs) (a, b, and c: the importance of correct administration);
• The ability to handle complaints and disputes about our products and services (a, b, and c: defending rights, maintaining and improving existing relationships through careful complaint handling, and improving the quality of our products and services);
• Managing customer relationships, marketing purposes, and communication with you, for example via the contact form on our website or via our newsletters, including marketing (a, b, c: the importance of bringing our products and services to the attention of our (potential) customers, d);
• Managing, securing, and improving our website, including analyzing website traffic and user behavior through analytical and marketing cookies (c: the importance of a secure and optimized website and an optimized offering of our products and services, d);
• Placing orders or purchasing services (a, b, and c: our interest in maintaining accurate records);
• Processing your application (a, b, c: our legitimate interest in assessing whether you are suitable for the position, and d: consent if you wish to remain in our portfolio);
• The protection of property and persons, as well as the prevention of fraud and abuse (c: the importance of ensuring the safety of visitors, employees, and company assets);
• Performing audits and other internal controls (a, b, and c: our interest in maintaining accurate records);
• Complying with our legal and statutory obligations (b, c: the importance of being able to comply with these obligations).
We do not use personal data for automated decision-making within the meaning of Article 22 of the GDPR.
4. Sharing personal data
We do not disclose your personal data to third parties ("recipients" within the meaning of the applicable privacy legislation), unless this is necessary for the proper execution of the purposes set out in this Privacy Statement, if we are required to do so by law, or if you have given your consent. The third parties to whom the personal data is made available are obliged to treat your personal data confidentially. If these parties qualify as 'processors' within the meaning of the applicable privacy legislation, we will ensure that a processing agreement is concluded with these parties that meets the requirements of the GDPR. Third parties who provide services to us as independent controllers, such as accountants and notaries, are themselves responsible for the (further) processing of your personal data in accordance with applicable privacy legislation.
We may share data with:
• Subsidiaries of HB RTS.
• Logistics partners and service providers.
• IT and cloud service providers.
• Legal, financial, or compliance advisors.
• Our legal successors if we are acquired or merge with another company, for example in the event of bankruptcy, as well as third parties involved in such a proposed or actual transaction.
• Courts and government agencies when required by law.
• Other parties, such as regulators and other authorities, when required by law or when you have given your consent.
We do not sell your personal data.
5. International transfer of data
In order to deliver our products and services, we transfer your personal data to service providers outside the European Economic Area, namely the United Kingdom, Switzerland, and the United States. Transfers to the United Kingdom and Switzerland are based on the adequacy decisions of the European Commission, which you can find here. This means that your personal data is adequately protected there in accordance with the GDPR.
The transfer of your personal data to the United States is covered by the EU-US Data Privacy Framework (DPF), provided that the party to whom we transfer your personal data is certified under the EU-US DPF. You can find more information and the list of certified parties here. If this is not the case, we will enter into the European Commission'sStandard Contractual Clauses with this party. Before transferring your personal data, we will assess whether additional measures are necessary to ensure an adequate level of protection.
Please do not hesitate to contact us if you would like more information about the appropriate or suitable safeguards that apply to data transfers outside the European Economic Area, or if you would like to receive a copy of these.
6. Retention periods
We do not store your personal data in an identifiable form for longer than is necessary to achieve the purposes set out in this Privacy Statement. More specifically, we apply the following retention periods:
- Personal data that must be retained pursuant to Article 52 of the General Tax Act will be retained for seven years (from the end of the year in which the data in question lost its current value for (tax) business operations), in connection with our tax retention obligation under Article 52(4) of the General Tax Act.
- Marketing data: until the moment of unsubscribing (opt-out) or a request for deletion.
- Website logs: 12–24 months.
- The personal data you provide to us in connection with your application will be retained for up to four weeks after the application process has been completed. If you give your consent, we may retain your personal data for up to six months after the application process has been completed. This allows us to contact you about any future vacancies at HB RTS. When you join HB RTS, the application data you provide will become part of your personnel file.
- Camera footage is stored for 7 days.
The specific retention periods above may be extended if legal retention obligations apply or become applicable. We may also retain personal data for longer if this is necessary in light of our legitimate interests, for example for the handling of incidents and/or legal disputes.
7. Your privacy rights
You have the following rights with regard to the processing of your personal data by us:
- the right to request whether we process your personal data and, if so, to access your personal data and certain information about the processing of your personal data;
- the right to rectify your personal data if it is incorrect or incomplete;
- the right to have your personal data deleted (‘right to be forgotten’);
- the right to object to the processing of your personal data or to restrict the processing of your personal data;
- the right to withdraw consent for the processing of your personal data, if the processing is based on your consent;
- the right to receive or transfer your personal data to a third party designated by you in a structured, commonly used, and machine-readable format ("right to data portability").
We do not use automated decision-making within the meaning of Article 22 of the GDPR.
To exercise your rights, please contact us using the contact details above. We kindly request that you specify which processing activities or personal data your request relates to.
To prevent us from providing information to the wrong person, we may ask you for additional information to verify your identity. In principle, we will inform you within one month of receiving your request whether we can comply with it. In specific cases, e.g. if the request is complex, this period may be extended by two months. We will inform you of any such extension within one month of receiving your request. Under privacy legislation, we may refuse your request in certain circumstances. If this is the case, we will explain why. More information about your privacy rights can be found on the website of the Dutch Data Protection Authority.
If you have a complaint about how we process your personal data, we will be happy to work with you to resolve it. If this does not lead to the desired result, you have the right to lodge a complaint with the competent supervisory authority. In the Netherlands, this isthe Dutch Data Protection Authority. If you live or work in another European Union country, you can file a complaint with the supervisory authority in that country.
8. Security measures
We have taken appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing and against loss, destruction, damage, alteration, or disclosure. If you have any questions about the security of your personal data, or if you suspect or see signs of misuse, please contact us at: privacy@hbrts.com.
9. Changes to this Privacy Statement
This Privacy Statement was last amended on February 4, 2026. We reserve the right to amend this Privacy Statement. The most recent version of this Privacy Statement will always be published on our website. If substantial changes are made that could have a significant impact on one or more of the parties involved, we will endeavor to inform those parties directly.