Privacy Policy

Last Updated: June 25, 2026

At Kinzoku Consultancy & Trade, accessible from www.kinzokutrade.com, one of our main priorities is the privacy of our visitors and clients. This Privacy Policy document contains types of information that is collected and recorded by Kinzoku Consultancy & Trade and how we use it.

If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us.

1. Identity and Contact Details

The data controller responsible for processing your personal data through this website is:

• Company Name: Kinzoku Consultancy & Trade

• Website: www.kinzokutrade.com

• Email: info@kinzokutrade.com

• Chamber of Commerce (KvK) Number: 42042968

• VAT Number: NL005451507B80

2. Personal Data We Collect

We collect and process personal data only when you interact with our website, request quotes, or utilize our consulting services. This includes:

• Contact Information: Name, email address, phone number, and company name when you fill out a contact form or submit a Procurement Specification / RFQ.

• Service-Related Data: Trade information provided by you regarding industrial steel sourcing requests or Carbon Border Adjustment Mechanism (CBAM) advisory needs.

• Usage Data: IP address, browser type, operating system, referring URLs, and website interactions collected via cookies.

3. Legal Bases and Purposes for Processing

In accordance with Article 6 of the GDPR, we process your personal data under the following legal bases:

• Performance of a Contract: To process RFQs, provide steel sourcing quotes, and deliver our CBAM advisory services.

• Legitimate Interests: To analyze website performance, improve user experience, and secure our digital infrastructure.

• Legal Obligation: To comply with Dutch fiscal laws, customs regulations, EU safeguard quotas, or international trade compliance laws (such as CBAM reporting mandates).

• Consent: For sending marketing communications or newsletters, if you have explicitly opted in.

4. Data Sharing with Third Parties

We do not sell your personal data. We only share your data with trusted third parties when necessary to run our business or fulfill legal duties:

• Hosting Infrastructure: We host our website using Hostinger International Ltd. (and its affiliates). They provide the servers, cloud storage, and database management necessary to keep our website running securely. Hostinger processes website data (such as server logs and traffic data) as a Data Processor under a strict Data Processing Agreement (DPA).

• Service Providers: IT hosting providers, CRM tools, and analytics platforms (e.g., Google Analytics).

• Trade Partners: Logistics firms, customs agents, or steel manufacturers, solely to execute your specific sourcing orders and port-to-factory delivery.

• Authorities: Tax authorities (Belastingdienst), customs agencies, or EU regulatory bodies if legally required.

5. International Data Transfers

As an international trade and advisory firm working with overseas manufacturing mills, some data processing may occur outside the European Economic Area (EEA). If data is transferred outside the EEA, we ensure appropriate safeguards are in place (e.g., EU Standard Contractual Clauses) to guarantee a level of protection equivalent to the GDPR.

Our infrastructure host, Hostinger, utilizes data centers located within the European Union (e.g., France, Lithuania, or the Netherlands) to store data for EU-based clients. If any technical support routing or cloud redundancy briefly transfers technical data outside the EEA, it is strictly covered under Standard Contractual Clauses (SCCs) to ensure full GDPR compliance.

6. Data Retention Period

We store your personal data only for as long as necessary to achieve the purposes outlined in this policy.

• Contact & RFQ Requests: Deleted within 1 year if no business relationship is established.

• Client & Transaction Records: Retained for up to 7 years to meet Dutch tax law compliance standards (fiscale bewaarplicht).

7. Your Data Protection Rights (GDPR)

Under European law, you have the following rights regarding your personal data:

• Right of Access: You can request a copy of the personal data we hold about you.

• Right to Rectification: You can request that we correct inaccurate or incomplete data.

• Right to Erasure ("Right to be Forgotten"): You can request that we delete your data under certain conditions.

• Right to Restrict Processing: You can ask us to limit how we use your data.

• Right to Data Portability: You can request that we transfer your data to another organization.

• Right to Object: You can object to our processing of your data based on legitimate interests or direct marketing.

To exercise any of these rights, please contact us at info@kinzokutrade.com. We will respond to your request within one month.

8. Cookies and Tracking Technologies

Our website uses cookies to improve your browsing experience. You can manage your cookie preferences through your browser settings or via our on-site cookie banner. For a detailed breakdown of the cookies we use, please view our cookie preferences panel located via our website footer cookie link.

9. Security Measures

We implement appropriate technical and organizational security measures to protect your personal data against unauthorized access, loss, or alteration. This includes using secure HTTPS encryption for all traffic on our website.

10. Right to File a Complaint

If you believe that Kinzoku Consultancy & Trade is not processing your personal data lawfully, you have the right to file an official complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).