Privacy Policy


Latest update: October 2020

  1. Who are we and what do we do?

We are Beluga Auctions, a brand of Buybay B.V. (Beluga Auctions), also referred to as we or us).Beluga Auctions is a tech company that helps e-tailers, manufacturers and distributors to sell and buy returned products and overstock goods to/from other professional parties (B2B). Also if the goods have traces of use or other irregularities. Embracing sustainability, Beluga Auctions has developed an online platform (the Platform) on which these goods are auctioned (altogether, our Services). Please find more information about our Services on the website of our Platform: (our Website). Companies that make use of the Services of Beluga Auctions (either as buyer or seller) shall herafter also be referred to as “Clients”.


  1. What is this?

This is a Privacy Policy. In this document we explain what type of personal data we collect through our Website and Services. We also explain for what purposes we use the personal data, how we secure them and how we store them.


  1. Privacy and Privacy Legislation

We take privacy very seriously. We comply with the General Data Protection Regulation (GDPR)[1] and other relevant legislation regarding privacy. This legislation will hereinafter be referred to as the Privacy Legislation.


  1. Personal data

Personal data refers to all the information that could allow someone to be directly or indirectly identified. This definition is in accordance with the Privacy Legislation.


  1. Our Position as Controller

Within the context of our Services, we collect and process some Personal data of (persons working at or representing) our Clients.
In order to perform our Services, we must define the purposes and the means of such processing of Personal data, which means we act as Controller within the meaning of the Privacy Legislation. In this Privacy Policy we explain processing activities we undertake as Controller.


  1. What Personal data do we collect?

As Controller we may process the following (personal) data:


    1. (Personal) data:
    1. Purpose(s):
    1. Legal ground(s):
    1. Contact details
    2. First name and surname, e-mail address, telephone number and other relevant corporate information.
    1. We use these data to:
  • Get in touch and to maintain contact with our (potential) Clients;
  • Approach our Clients appropriately in our communications;
  • Install an account to access our Platform.
    1. We may process these personal data in order to (possibly) enter into, or to perform an existing contract.
    1. Auction information
    2. Information on biddings placed by Clients on the lots offered through the Platform.
    1. We use these data to:
  • Register the Clients’ praticipation in the auction;
  • Assess which Client has made the winning bid on the lot;
  • Handle the auction according to the procedure.
    1. We may process these Personal data, because we need these Personal data to perform our contract with our Clients.
    1. Payment and tax details
    2. Client name and address, contact details of our contact person at our Client, invoicing details, bank details (account number, IBAN and BIC-code) and a VAT identification number.
    1. We use these data to:
  • Send invoices to our Clients;
  • Process and administer payments;
  • Include in our (financial) administration to comply with Tax and Customs Administration regulations.
    1. We may process these Personal data, because we need these Personal data to perform our contract with our Clients.
    2. We are also legally obligated to process and/or share (some of) these data for/with the national tax authorities.
    1. Services history
    2. Information on the history of Services already rendered to the Client. This includes, among other things, information about earlier correspondence and (technical) reports on rendered Services.
    1. We use these data to:
  • Identify the Clients’ history of Services used;
  • Improve further Services we provide to our Clients.
    1. We may process these Personal data because we have a legitimate interest to process these data in order to provide our Services.
    1. Technical information
    2. Information on the device used to access our Services, IP-address and information on the used browser.
    1. We use these data to:
  • Communicate in the same language of the browser;
  • Adapt our Website to the used device.
    1. We may process these Personal data because we have a legitimate interest to provide a good functioning Website.
    1. Contact details of (potential) Clients using a contact form on the Website
    2. Name, e-mail address, company and any (personal) data included in the message.
    1. We use these data to:
  • Contact these (potential) Clients based on the message;
  • Help with the comment(s) and/or question(s) submitted via the contact form.
    1. We may process these Personal data because we have a legitimate interest to contact and assist (potential) Clients based on their comment or question.


Our social media pages:

(Personal) data:


Legal ground(s):

Information of visitors who leave a comment or otherwise post something on our social media pages, including the Personal data within these comments and/or posts.

We use these data to:

  • Contact the visitors in reply of their post and/or comment via our social media pages;
  • Process the feedback left on our social media pages.

We may process these Personal data, because we have a legitimate interest to process these data and because the visitors voluntarily made public such information.

Our social media pages are also controlled by the social medium itself. Please check their own privacy policies, to see how each social medium handles Personal data:

Instagram: Privacy Policy

LinkedIn: Privacy Policy


  1. How long do we keep the Personal data?

Beluga Auctions will delete the Personal data if they are no longer necessary for the purposes as mentioned above. In any case, we use the following retention periods:

  • Personal data regarding potential Clients | These data are stored as long as necessary to determine whether we enter into an agreement with a potential Client and for a maximum period of 24 months after our last contact.
  • Personal data regarding Clients | These data are stored as long as we have a contract with our Client or the Client has an active profile on our Platform, and for a maximum period of 24 months after. If the profile has been inactive for almost 2 years, we will send you a notification that we must soon delete the profile if the profile remains inactive. If we do not receive a reply, we will remove the profile and Personal data contained in it after 2 years of inactivity, unless we are legally obliged to retain the data for a longer period.
  • Personal data in our records for the tax authorities | These data are stored for seven (7) years, unless we are legally obliged to retain the data for a longer period.
  • Other information | We store other Personal data only for as long as necessary for the purposes. This means that other Personal data will be deleted as soon as it is no longer necessary for the purposes for which we processed it.


  1. Do we share your Personal data with others?

We use the Services of processors for the processing of (Personal) data. Within this context these processors receive Personal data from us which they process on our behalf. We use processors to host our e-mail and to store (Personal) data.

The processors must strictly follow our instructions regarding the processing of such Personal data. Therefore, they will not use the Personal data for their own purposes. We will ensure that all processors comply with the requirements of the Privacy Legislation.

Apart from the above, we may also share your Personal data with the a relevant Client where you buy or sell your product from/to. We do this in order to enable you to smoothly transact the purchase and/or sale of a product with the concerning buyer and/or seller.


  1. Data Export outside the European Union

We may transmit Personal data to parties outside the EU, if one of our processors is established outside the EU. We make sure the transmission of Personal data outside the EU always happens in conformity with the Privacy Legislation (chapter 5 of the GDPR), meaning the Personal data will only be transferred to a company or country that provides an adequate level of protection.


  1. How do we protect your Personal data?

We work hard to protect your Personal data from unauthorized or unlawful access, alteration, disclosure, use or destruction. We inter alia take the following technical and organizational measures to protect your Personal data:

  • Secure network connections with Secure Socket Layer (SSL) technology or a technology that is similar to SSL;
  • The access to the data within our company is limited to the persons that need the data (need-to-know-basis);
  • Back-ups of the data;
  • Employee confidentiality statements;
  • NDAs and appropriate Data Processing Agreements with third parties who (sub)process the data on our behalf;
  • The (access to) data is secured with two-factor authentication;
  • The (access to) data is secured with the passwords that need to be changed every month;
  • All new employees are trained about data privacy during onboarding;
  • Periodic training about data privacy to all employees;


  1. Cookies

We may use cookies on our Website. A cookie is a simple small text file that can be stored in your computer when visiting the Website. This text file identifies your browser and/or computer. When visiting our Website again, the cookie ensures that our Website recognizes your browser or computer.

We use the following types of cookies:

Functional cookies | Functional cookies are essential to the operation of our Website. They allow you to navigate through our Website and use the functions incorporated in it.

Analytical or statistical cookies | Analytical cookies are used to review the quality and effectiveness of the Website. For instance, we can see how many users visit the Website and what pages are visited. We use this information to improve our Website and Services.

Tracking cookies | Tracking cookies follow the click behavior and surfing behavior of our visitors. Through cookies of external providers, including Google, Facebook, Twitter, LinkedIn can be used to post ads based on previous visits of a user to our Website.

If you do not wish to have cookies sent to your computer, you can change this through the cookie settings of your browser. Bear in mind that some functions or Services of our Website may not function, or not so well, without cookies.


  1. Third Party Websites

You can find (hyper)links on our Website which link to the websites of partners, suppliers, advertisers, sponsors, licensors or other third parties. We do not have control of the content or links which appear on these websites and we are not responsible for the practices of websites linked to or from our Website. Furthermore, these websites, including their content and links, may constantly change. These websites may have their own privacy policies, user terms and customer policies. Browsing and interaction on any other website, including websites which are linked to or from our Website, are subject to the terms and conditions and policy of such website.


  1. Amendments

We are constantly looking for ways to improve our Platform and Services. Therefore, we may update this Privacy Policy from time to time. If we change the Privacy Policy significantly, we will post a notification on our Website together with the updated Privacy Policy.

  1. Your rights

As laid down in the Privacy Legislation, you have the right to:

  • Ask us for access to and/or a copy of the Personal data we process of you, including the location where your data are processed, who receives your Personal data, how long we keep your Personal data and for what purposes we process the data. At your request, we can also transmit such copy to another data controller;
  • Ask us to adjust, review or remove your Personal data from our systems;
  • Ask us to restrict the processing of your Personal data;
  • Object to the processing of your Personal data;
  • File a complaint with the Dutch Data Protection Authority, if you believe that we process your Personal data unlawfully.

If you have any questions, comments or concerns regarding the way we handle your Personal data, please contact us through the contact information below:


Beluga Auctions                      T:             020-242-0500       

Bijsterhuizen 2514D     E:   

6604 LN Wijchen          W:   


Trade register number:           62831747

VAT number:                           NL854975342B01