Privacy Policy – TORWASH / SLUDGE2VALUELIFE

Privacy Policy

Last updated: March 2026

TORWASH BV ("we", "us", or "our") is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, store, and protect personal data when you visit the TORWASH website (torwash.com) or the SLUDGE2VALUELIFE project website (s2vl.torwash.com), together referred to as the "Website", subscribe to updates, submit a contact form, or otherwise interact with us online.

This policy is written in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and applicable Dutch data protection legislation, including the Uitvoeringswet AVG (UAVG).

1. Who We Are (Data Controller)

The data controller responsible for your personal data is:

TORWASH BV
The Netherlands
General enquiries: info@torwash.com
SLUDGE2VALUELIFE project enquiries: s2vl@torwash.com

If you have any questions about how we handle your personal data, or if you wish to exercise any of your rights under the GDPR, please contact us using the details above.

2. What Personal Data We Collect

We only collect personal data that is necessary for the purposes described in this policy. Depending on how you interact with the Website — whether torwash.com or the SLUDGE2VALUELIFE project pages — we may collect the following categories of data:

2.1 Data you provide directly

  • Contact form submissions: name, email address, organisation, phone number (if provided), and the content of your message;
  • Newsletter or update subscriptions: name and email address;
  • Event registrations or collaboration enquiries: name, email address, organisation, and job title.

2.2 Data collected automatically

When you visit the Website, we may automatically collect certain technical data, including:

  • IP address (anonymised where possible);
  • Browser type and version;
  • Operating system;
  • Pages visited and time spent on the Website;
  • Referring URL (the page you came from);
  • Date and time of your visit;
  • Cookie identifiers (see Section 7 below).

This data is collected via cookies and analytics tools and is used in aggregate or anonymised form wherever possible. The same analytics setup applies across both torwash.com and s2vl.torwash.com.

3. How and Why We Use Your Personal Data

We process your personal data only where we have a lawful basis to do so under Article 6 of the GDPR. The table below explains the purposes and corresponding legal bases:

Purpose Data used Legal basis
Responding to your contact form enquiries (TORWASH or SLUDGE2VALUELIFE) Name, email, message content Legitimate interests (Art. 6(1)(f))
Sending project or company news and updates (newsletter) Name, email address Consent (Art. 6(1)(a))
Managing collaboration or media requests Name, email, organisation, job title Legitimate interests (Art. 6(1)(f))
Website analytics and performance monitoring IP address, browsing behaviour, device data Consent (Art. 6(1)(a)) / Legitimate interests
Ensuring website security and preventing fraud IP address, access logs Legitimate interests (Art. 6(1)(f))
Compliance with legal obligations As required Legal obligation (Art. 6(1)(c))

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

4. EU Funding and Reporting Obligations

As a beneficiary of the LIFE Programme (Grant Agreement No. 101212627) for the SLUDGE2VALUELIFE project, TORWASH BV may be required to share certain project-related information — including names and contact details of participating organisations and key contacts — with the European Commission, the European Climate, Infrastructure and Environment Executive Agency (CINEA), and authorised monitors or auditors. This processing is carried out on the basis of a legal obligation (Art. 6(1)(c) GDPR) and compliance with the Grant Agreement. This obligation relates specifically to data collected in connection with the SLUDGE2VALUELIFE project and does not extend to general TORWASH website enquiries unrelated to the project.

Where personal data of individual persons (not organisations) is shared in this context, we ensure appropriate safeguards are in place and that the disclosure is limited to what is strictly necessary.

5. Sharing Your Personal Data

We do not sell, rent, or trade your personal data to third parties. We may share your data with trusted third parties only in the following circumstances:

  • Project partners: Where necessary to manage project collaboration and communication, data related to the SLUDGE2VALUELIFE project may be shared with official project partners. All partners are bound by equivalent data protection obligations;
  • Service providers: We may use third-party service providers to host the Website, manage email communications, or analyse website traffic (e.g. hosting providers, email platforms, analytics tools). These providers act as data processors on our behalf and are bound by data processing agreements in accordance with GDPR Article 28;
  • Legal authorities: We may disclose personal data to law enforcement or regulatory authorities if required to do so by applicable law, court order, or governmental regulation;
  • EU institutions: As described in Section 4 above, where required under the terms of the LIFE Programme Grant Agreement for the SLUDGE2VALUELIFE project.

6. International Data Transfers

We are based in the Netherlands and primarily process your personal data within the European Economic Area (EEA). If we use service providers located outside the EEA, we ensure that appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) approved by the European Commission, to ensure your data is protected to the same standard as within the EU.

7. Cookies and Tracking Technologies

The Website uses cookies — small text files stored on your device — and similar tracking technologies to improve your experience and help us understand how torwash.com and s2vl.torwash.com are used.

7.1 Types of cookies we use

  • Strictly necessary cookies: Required for the Website to function correctly. These cannot be disabled without affecting core functionality. No consent is required for these cookies.
  • Analytics cookies: Used to collect information about how visitors use the Website (e.g. which pages are visited most, how long users stay). This data is aggregated and anonymised. We use these cookies only with your consent.
  • Preference cookies: Allow the Website to remember choices you make (such as language preferences). Used only with your consent.
  • Marketing/tracking cookies: At this time, we do not use marketing or advertising cookies on the Website.

7.2 Managing cookies

When you first visit the Website, you will be presented with a cookie consent banner. You may accept or decline non-essential cookies at that time. You can also change your cookie preferences at any time through your browser settings. Please note that disabling certain cookies may affect the functionality of the Website.

For more information about managing cookies, visit www.allaboutcookies.org.

8. How Long We Keep Your Data

We retain personal data only for as long as necessary for the purposes for which it was collected, or as required by law. Our general retention periods are as follows:

  • Contact form enquiries: Up to 2 years after the last communication, unless further retention is required for legal or project purposes;
  • Newsletter subscriptions: Until you withdraw your consent or unsubscribe. After unsubscribing, your data will be deleted within 30 days;
  • Website analytics data: Aggregated data may be retained for up to 26 months; individual-level data is anonymised or deleted within 14 months;
  • SLUDGE2VALUELIFE project correspondence: For the duration of the project and for a period of at least 5 years after project closure, in accordance with LIFE Programme requirements;
  • Legal and financial records: Retained for 7 years in accordance with Dutch fiscal and legal obligations.

9. Your Rights Under the GDPR

As a data subject under the GDPR, you have the following rights with respect to your personal data:

  • Right of access (Art. 15): You have the right to request a copy of the personal data we hold about you;
  • Right to rectification (Art. 16): You have the right to request that inaccurate or incomplete data is corrected;
  • Right to erasure (Art. 17): You have the right to request that we delete your personal data, subject to certain exceptions (e.g. where retention is required by law);
  • Right to restriction of processing (Art. 18): You have the right to request that we limit how we use your data in certain circumstances;
  • Right to data portability (Art. 20): Where processing is based on consent or contract, you have the right to receive your data in a structured, commonly used, machine-readable format;
  • Right to object (Art. 21): You have the right to object to processing based on legitimate interests at any time. We will stop processing unless we can demonstrate compelling legitimate grounds;
  • Right to withdraw consent (Art. 7(3)): Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal;
  • Right not to be subject to automated decision-making (Art. 22): You have the right not to be subject to decisions based solely on automated processing, including profiling, where those decisions have legal or similarly significant effects.

To exercise any of these rights, please contact us at info@torwash.com (general enquiries) or info@s2vl.torwash.com (SLUDGE2VALUELIFE project enquiries). We will respond to your request within 30 days. In complex cases, we may extend this period by a further 60 days, in which case we will inform you.

You also have the right to lodge a complaint with the Dutch supervisory authority:

Autoriteit Persoonsgegevens (AP)
Website: www.autoriteitpersoonsgegevens.nl
Telephone: +31 (0)70 888 85 00

10. Data Security

We take the security of your personal data seriously. We implement appropriate technical and organisational measures to protect your data against unauthorised access, loss, alteration, or disclosure. These measures include:

  • SSL/TLS encryption for data transmitted via the Website;
  • Access controls limiting who within TORWASH BV and among project partners can access personal data;
  • Regular review of our security practices;
  • Data processing agreements with all third-party service providers who process data on our behalf.

Despite these measures, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security, but we will notify you and the relevant authorities in the event of a data breach as required by GDPR Articles 33 and 34.

11. Children's Privacy

The Website is not directed at children under the age of 16. We do not knowingly collect personal data from children. If you believe that we have inadvertently collected data from a child, please contact us immediately and we will take steps to delete the information.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the scope of the SLUDGE2VALUELIFE project. Any changes will be posted on this page with an updated "last updated" date. We encourage you to review this policy periodically. Where changes are significant, we will notify you by email (if we hold your email address) or via a notice on the Website.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way we handle your personal data, please contact us:

TORWASH BV
The Netherlands
General enquiries: info@torwash.com
SLUDGE2VALUELIFE project enquiries: s2vl@torwash.com