Privacy Policy

Elite Parts B.V., trading as “dutchub” (“dutchub”, “we”, “us”, “our”), respects your privacy and is committed to protecting your personal data. This policy explains what personal data we collect when you visit our website, contact us, partner with us, or use our dashboard, why we collect it, how long we keep it, who we share it with, and what rights you have. It applies to the dutchub website (and subdomains) and to the services dutchub provides through it.

dutchub is a Netherlands-based online brand distributor and brand-management service. We buy products from brands and sell and grow them across European online marketplaces, provide a performance dashboard to the brands we work with, and supply B2B buyers. Because our services are primarily business-to-business, most of the personal data we handle relates to business contacts rather than consumers.

1. Who is responsible for your data?

The controller responsible for processing your personal data is:

• Company: Elite Parts B.V. (trading as dutchub)
• Address: Keulschevaart 19, 3621 MX Breukelen, the Netherlands
• Email: hello@dutchub.com (general) · b2b@dutchub.com (B2B)
• Chamber of Commerce (KvK): 87844109
• VAT (BTW): NL864423834B01

Data Protection Officer (DPO)

We have not appointed a Data Protection Officer, as we do not consider this to be legally required for our organisation. For any privacy question, please use the contact details above.

2. Who this policy applies to

Depending on how you interact with dutchub, you may be one of the following:

• Website visitors — people who browse our website or submit a form.
• Brand and partner contacts — representatives of brands who enquire, partner, or are onboarded for distribution and brand management.
• Dashboard users — people who access the dutchub dashboard on behalf of a brand.
• B2B buyers — resellers, retailers and institutions who buy from us.
• Marketplace end-customers — where dutchub is the seller of a marketplace order, we receive limited data to fulfil that order.

3. What personal data we process

We only process the personal data needed for the purposes described below.

3.1 Website visitors

• Technical data: IP address, browser and device type, pages visited, and referral source (for security and, where applicable, analytics).

3.2 Brand and partner contacts (enquiries and onboarding)

• Name, business email, phone number, company/brand and role.
• The content of your message and the products or brand discussed.
• Contract, onboarding and commercial correspondence.

3.3 Dashboard users

• Account data: name, business email, and login credentials (passwords stored encrypted).
• Usage data relating to the account.

The dashboard also displays a brand’s business performance data (sales, revenue, orders, inventory, SKU data). This is largely the partner’s business data rather than your personal data; where it contains personal data, our role is described in section 5.

3.4 B2B buyers

• Business contact details, company data, and order and delivery information.

3.5 Marketplace order data (where dutchub is the seller)

• Name, delivery/invoice address and order details, received from the marketplace to fulfil that order, including returns and warranty.

4. Purposes and legal bases

Under the GDPR, every processing activity needs a valid legal basis. The main ones we rely on are:

• Partnering, onboarding and providing our services: performance of a contract, or pre-contractual steps at your request (Art. 6(1)(b)).
• Responding to enquiries and B2B requests: pre-contractual steps and/or our legitimate interest in responding to a business request (Art. 6(1)(b)/(f)).
• Invoicing, accounting and tax: compliance with a legal obligation (Art. 6(1)(c)).
• Fulfilling marketplace orders, returns and warranty: performance of a contract (Art. 6(1)(b)).
• Security and fraud prevention: our legitimate interest in protecting our website, systems and customers (Art. 6(1)(f)).
• Website analytics and improvement: your consent (for non-essential cookies) or our legitimate interest (for anonymous, aggregated statistics) see section 11.

5. Our role: controller and processor

For most data described above (website visitors, our own contacts, B2B buyers, dashboard account data, and marketplace orders we fulfil), dutchub acts as an independent controller: we decide why and how the data is used.

Where we process a brand’s data on that brand’s behalf, for example, business data made available through the dashboard when offered as a standalone service, dutchub may act as a processor for that brand. In that case, a data processing agreement (DPA) under Art. 28 GDPR governs the processing, and the brand remains the controller.

6. How long we keep your data

We keep personal data no longer than necessary for the purposes for which it was collected:

• Order, invoice and accounting data: 7 years, in line with the Dutch tax retention obligation (Art. 52 AWR).
• Partner / CRM and contract data: for the duration of the relationship, plus 7 years after it ends.
• Dashboard account data: while the account is active, plus 12 months after closure.
• Newsletter data (email): until you unsubscribe or withdraw consent.
• Enquiry and contact data: up to 2 years after your request is handled.
• Cookies / analytics data: see section 11 and the retention period of the relevant tool.

After the retention period we delete or anonymise your data, unless we are legally required to keep it longer.

7. Who we share your data with

We never sell your data. We share it only with parties that help us deliver our services (“processors”), or where we are legally required to. With every processor acting on our behalf, we conclude a processing agreement under Art. 28 GDPR.

8.1 Website hosting and software

Our website and dashboard run on our hosting and platform providers, which process data on our behalf with appropriate security measures (including SSL/TLS encryption and secure credential storage).

8.2 Marketplaces

We sell products through European online marketplaces. Where you order via a marketplace, we receive the data needed to fulfil that order. For that order data, dutchub acts as an independent controller for the purpose of handling the order, returns and warranty. Your use of the marketplace itself (your account there, browsing, their marketing) is governed by that platform’s own privacy policy, for which dutchub is not responsible.

8.3 Shipping and logistics

To deliver orders, we share name and address data with carriers such as PostNL, DHL or DPD, used solely for delivery.

8.4 Accounting and administration

Our financial administration is handled by an external accounting partner, subject to the statutory retention periods and confidentiality.

8.5 Other tools

We do not use any additional tools for functionality or security, such as analytics, anti-spam, chat or translation tools.

We also share data where legally required, for example at the request of a supervisory authority or in the context of a criminal investigation.

9. Transfers outside the EU/EEA

Some processors may process data outside the European Economic Area (EEA), including in the United States. Where this happens, we ensure appropriate safeguards are in place, such as:

• The EU–US Data Privacy Framework certification (where applicable to the party); or
• Standard Contractual Clauses (SCCs) approved by the European Commission.

10. How we protect your data

We take appropriate technical and organisational measures to protect your personal data against loss, misuse or unauthorised access, including:

• Encrypted connections (SSL/TLS) for data sent via our website and dashboard;
• Secure storage of passwords;
• Access to personal data limited to staff who need it for their work;
• Processing agreements with parties that process data on our behalf.

If you suspect your data is not properly secured, or you notice signs of misuse, please contact us at hello@dutchub.com.

11. Cookies and similar technologies

Our website uses cookies and similar technologies. A cookie is a small text file stored on your device. Where we place only strictly necessary/functional cookies, no consent is required (Art. 11.7a(3) Dutch Telecommunications Act). As soon as we use analytics, marketing or email-marketing tools that place non-essential cookies, we will implement a cookie banner with granular consent before those tools go live, and update this section.

You can also refuse or delete cookies via your browser settings; note this may affect how the website works.

12. Your rights

Under the GDPR you have the following rights regarding your personal data:

• Access — request which data we process about you.
• Rectification — have inaccurate or incomplete data corrected.
• Erasure (“right to be forgotten”) — request deletion, where we no longer need the data or are not legally required to keep it.
• Restriction — request that we temporarily limit processing.
• Data portability — receive your data in a structured, common format to transfer to another party.
• Objection — object to processing based on legitimate interest, or to direct marketing.
• Withdraw consent — for processing based on consent (such as the newsletter), at any time.

To exercise a right, email hello@dutchub.com. We respond within one month, as required by the GDPR. We may ask you to identify yourself first, to avoid disclosing data to the wrong person.

13. Complaints

If you are unhappy with how we handle your personal data, please contact us first at hello@dutchub.com. We are happy to resolve it with you. You also always have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) via autoriteitpersoonsgegevens.nl.

14. Minors

Our services are aimed at businesses and are not directed at children. We do not knowingly collect personal data from children under 16. If you believe we have collected such data without the required consent, please contact us and we will delete it.

15. Changes to this policy

We may update this policy from time to time, for example when we start using new services or tools, or when law or regulation requires it. The most current version is always on this page, with the date of the last change at the top. We recommend reviewing it periodically.

16. Contact

Questions about this policy or about how dutchub handles your personal data?