privacy statement

Privacy & Cookie Notice

January 2025

  • Who are we? 

Hamilton Bright is a company registered in The Netherlands with a registered address of with a registered office at Wagenmakersstraat 1, 8601 VA Sneek, The Netherlands. We are the data controller for the purposes of this Privacy Notice. This Privacy Notice relates to this website https://www.hamiltonbright.com/, part of the Advantage Smollan Group.

  • What is this Privacy Notice for?

This Privacy Notice gives you information about how we will use personal data and other private information collected by or provided by you to Hamilton Bright. When we refer to ‘personal data’ in this Privacy Notice it means any information that relates to you from which you can be identified. This Privacy Notice governs the processing of your personal data, including in connection with your use of our Site, so please read it carefully.

  • What Personal Data may we collect?

We may collect the following personal data about you:

  • The personal details you provide (such as full name and title, postal address (including billing and shipping addresses), email address, date of birth) when creating an account with Hamilton Bright.
  • Payment details you provide for the purpose of processing any payments for work completed by Hamilton Bright on your instruction.
  • Personal details including your name, contact details, resume, and any other information you choose to provide, when corresponding with us by phone, email, online job application or that you provide to us when you visit https://www.hamiltonbright.com/.  
  • Any other personal or private information about you that you choose to submit to this Site or any other websites we operate. 
  • Information about your preferences (e.g. cookie data, clickstream data, browsing history, responses to direct marketing, and opt-outs from direct marketing) and any information provided to us by third parties.
  • For some of your personal information you will have a contractual requirement to provide us with your personal information. If you do not provide us with the requested personal information, we may not be able to properly perform our contract with you and may not be able to provide you with our services.

  • Cookies and Similar Technology

A cookie is a small text file that is stored on your computer, tablet or smartphone when you first visit this website. Hamilton Bright uses technical, functional and analytical cookies on this Website. The cookies we use are for the technical operation of the website, to help us to understand how visitors interact with website, and to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers. You can opt out of cookies by setting your internet browser so that it no longer stores cookies. In addition, you can also delete all information that was previously stored via the settings of your browser.

  • How we use your Personal Data

We may use your personal data in the following ways:

  • To operate our business and provide you with services you have requested.
  • To verify your identity.
  • To acknowledge, confirm and deal with your enquiry, job application, brief or order.
  • Where we are asked to deal with any other enquiries or complaints you may make.
  • To notify you about any changes to this Site, or services provided through this Site.
  • To provide you, with information about our services. Any marketing email that you receive from us will allow you to unsubscribe to further email promotions.
  • To contact you in connection with user/customer/member surveys and use any information you choose to submit in response.
  • The management of job applications.
  • To administer our Site and ensure that our Site is presented in the most effective manner for you and your computer/device.
  • For internal business/technical operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our Site secure.
  • On an aggregate basis, to understand how individuals collectively use the features of our Site.
  • To give effect to your legal rights and your rights under this Privacy Notice.
  • To protect against fraud, identity theft, and other unlawful activity.
  • To establish or exercise any legal rights or claims.
  • To satisfy our obligations under applicable law, this Privacy Notice, and any other policies or terms that are applicable to our relationship with you.
  • For other purposes to which you have consented, and we may combine personal data that you provided to us with other information we collect about you for the purposes set out in this Privacy Notice.
  • Via the SmartSpotter app, user location data is stored to detect fraud. The terms and conditions for the use of the app, and how this location data is handled, is specified in the SmartSpotter privacy statement.

  • Disclosure of your personal data

We may share your personal data with third parties in the following situations:

Organisation Name Purpose Location
Companies affiliated with Hamilton Bright, including its parent company Smollan  In connection with the administration and running of the business EU & UK, South Africa
Microsoft CRM Dynamics Business to business management USA
Data Orbis B.V.  Field marketing management and reporting EU
TeamTailor B.V. Recruitment EU
To other third parties in line with applicable legal requirements  To comply with legal obligations that we are subject to Various

Other disclosures:

  • We may disclose your personal data to our employees and agents to the extent necessary to provide you with the services you have requested.
  • To our third party service providers who provide services such as sample fulfilment, data analysis, payment processing, information technology and related infrastructure provision, email delivery, postal delivery, auditing and other services.
  • We may make your personal data available to selected third parties who act on our behalf to support our operations (for example, card processing or payment services) and credit reference agencies to protect against possible fraud, subject to appropriate contractual protections in accordance with applicable law.
  • If we sell or transfer all, or any portion, of our business or our company assets to any third party, personal data held by us from you may be one of the transferred assets.
  • To protect us or contractors against loss or damage (including without limitation, exchanging information with the police, courts or law enforcement organisations).
  • To the extent necessary to establish, exercise or defend legal rights or claims, or for the purposes of investigating actual or suspected unlawful activity.
  • Security

We take the security of our customer and clients’ data very seriously and we use appropriate measures to protect all personal information collected in a secure, controlled environment consistent with data protection legislation. 

  • International transfers

Hamilton Bright uses some third parties who are based outside of the EU, so your personal data may be transferred internationally. Where your data is shared to a country outside of the EU, we will ensure that necessary arrangements are in place to provide appropriate safeguards for your information. These arrangements may involve the use of an Adequacy Decision, Standard Contractual Clauses, or other permitted mechanisms.

  • Lawful basis for processing

The EU General Data Protection Regulation (GDPR) requires that we must have a lawful basis when processing (using) your information. We may rely upon one of the following lawful bases for the processing that we carry out:

Lawful Basis

Relevant Processing Activity
The processing activity is carried out with your consent.
  • Placing cookies and other similar technologies on your device (subject to certain exceptions)
  • Sending marketing communications to you.
The processing activity is necessary for the performance of a contract
  • We will process your personal data necessary to perform a contract or to take steps at your request, before entering a contract, including job applications.
The processing activity is in our legitimate interests
  • To further our marketing activities and to help spread awareness of Hamilton Bright and our services.
  • Job application management
  • To ensure that we are providing you with quality services and to allow us to improve our services where possible.
  • To enable business management and forecasting.
  • To process general enquiries.
  • Monitoring your location through company apps.
The processing activity is necessary for compliance with a legal obligation
  • We may need to process your personal data to comply with relevant laws, regulatory requirements and to respond to lawful requests, court orders and legal process.
  • Data Retention

We will only retain your personal data for as long as we require the personal data in connection with the purposes set out in this Privacy Notice, except where we are required, or permitted, under applicable law, to retain your personal data for additional periods of time.

  • Business to Business Marketing

As a part of our marketing practice, including individual employees of such company, by telephone or email to inform them of our services that could result in a mutual commercial interest. We obtain the contact details for such companies and its employees from public information including company websites, business and social media, sector news and industry conferences. We also may have obtained such contact details directly from you or your company if you or your company have previously contacted us using a corporate phone number or corporate email address. Any personal data collected and processed for our business-to-business marketing practice as detailed herein is done so pursuant to our legitimate interest to market our services to you.

  • Your Data Protection Rights

Subject to applicable law, you may have the following rights in relation to your personal data:

  • the right to request access to or copies of the Personal Data that we process 
  • the right to rectification of any inaccuracies in your Personal Data
  • the right to erasure of your Personal Data
  • the right to restrict processing 
  • the right to object to processing 
  • the right to data portability
  • rights in relation to automated decision making and profiling; please note that Hamilton Bright does not undertake any automated decision making or profiling.

If you wish to exercise any of these rights please select this LINK and complete the online form. We may also need to ask you for further information to verify your identity before we can respond to any request.

  • Change to our Privacy Notice

If we change this Privacy Notice, we will let you know about the changes by publishing the updated version on our website, https://www.hamiltonbright.com/. We are committed to protecting and respecting your privacy and will continue to do so in any future changes we make to this Privacy Notice.

  • Contact

Questions, comments or requests regarding this Privacy Notice or any of our processing should be made to our Data Protection Team by completing the form available via this LINK or post at: Data Privacy, Hamilton Bright, Wagenmakersstraat 1, 8601 VA Sneek, The Netherlands.

  • The right to lodge a complaint with a supervisory authority

You have the right to complain to the Supervisory Authority