Last updated: January 1, 2026

This Privacy Policy explains how Army of the Tread B.V. (“Army of the Tread,” “we,” “us,” or “our”) collects, uses, stores, and protects personal data when you visit or interact with https://www.armyofthetread.nl (the “Website”).

We are committed to protecting your privacy and processing personal data in compliance with:

  • The EU General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679)

  • Applicable Dutch data protection laws

By using the Website, you acknowledge and understand the practices described in this Privacy Policy.


1. Data Controller

The data controller responsible for processing your personal data is:

Army of the Tread B.V.
A private limited liability company (besloten vennootschap) incorporated in the Netherlands.

Further corporate details will be made available in accordance with Dutch and EU legal requirements.


2. Personal Data We Collect

We may collect and process the following categories of personal data:

2.1 Data You Provide Voluntarily

  • Name

  • Email address

  • Company name and role (if applicable)

  • Information submitted through contact or inquiry forms

  • Communications sent to us by email or via the Website

2.2 Data Collected Automatically

When you visit the Website, we may automatically collect:

  • IP address

  • Browser type and version

  • Device type and operating system

  • Pages visited and interaction data

  • Date and time of access

  • Referring URLs

This data is typically collected through cookies or similar technologies.


3. Purposes of Processing

We process personal data only where permitted by law and for the following purposes:

  • Operating, maintaining, and securing the Website

  • Responding to inquiries and communications

  • Providing information about our projects, services, and sustainability initiatives

  • Improving Website performance and user experience

  • Meeting legal, regulatory, and compliance obligations

  • Protecting our legal rights and preventing fraud or misuse

We do not sell personal data and do not use personal data for automated decision-making or profiling.


4. Legal Bases for Processing

Under GDPR, we rely on one or more of the following legal bases:

  • Consent (Article 6(1)(a)) – where you have explicitly provided it

  • Contractual necessity (Article 6(1)(b)) – where processing is required to respond to or manage a request

  • Legal obligation (Article 6(1)(c)) – where required by law

  • Legitimate interests (Article 6(1)(f)) – such as operating and securing our Website, provided your rights do not override those interests


5. Cookies and Similar Technologies

We use cookies and similar technologies to ensure the proper functioning of the Website and to understand how visitors interact with it.

Where required by law, cookies will be used only after obtaining your consent.

For detailed information, please refer to our Cookie Policy, which forms part of this Privacy Policy framework.


6. Data Sharing and Disclosure

We may share personal data only with:

  • Trusted service providers acting as data processors (e.g., hosting, IT, analytics), under appropriate data processing agreements

  • Professional advisors (legal, financial, compliance) where necessary

  • Public authorities or regulators where required by law

We do not transfer personal data to third parties for marketing purposes.


7. International Data Transfers

Where personal data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, such as:

  • European Commission adequacy decisions

  • Standard Contractual Clauses (SCCs)

  • Other lawful transfer mechanisms under GDPR


8. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including:

  • Responding to inquiries

  • Complying with legal or regulatory obligations

  • Resolving disputes and enforcing agreements

Retention periods are determined based on the nature of the data and applicable legal requirements.


9. Data Security

We implement appropriate technical and organizational measures to protect personal data against:

  • Unauthorized access

  • Loss or destruction

  • Alteration or disclosure

While we take reasonable steps to safeguard data, no system can be guaranteed to be completely secure.


10. Your Rights Under GDPR

As a data subject, you have the following rights:

  • Right of access

  • Right to rectification

  • Right to erasure (“right to be forgotten”)

  • Right to restriction of processing

  • Right to data portability

  • Right to object to processing

  • Right to withdraw consent at any time (where processing is based on consent)

To exercise your rights, please contact us using the details below.

You also have the right to lodge a complaint with a supervisory authority, including the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).


11. Children’s Data

The Website is not directed at individuals under the age of 16. We do not knowingly collect personal data from children.


12. Third-Party Websites

The Website may contain links to third-party websites. We are not responsible for the privacy practices or content of those websites.

We encourage you to review the privacy policies of any third-party sites you visit.


13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted on the Website with an updated “Last updated” date.

Your continued use of the Website constitutes acknowledgment of the updated policy.


14. Contact

For questions about this Privacy Policy or our data practices, please contact:

Army of the Tread B.V.
Via the contact form on https://www.armyofthetread.nl