Privacy Policy

Last updated: [30-10, 2025]

1) Who we are

This website and related services (“Services”) are operated by Essential Group B.V. (“Essential Group,” “we,” “us,” or “our”), doing business as THM Digital Impact. We act as the central marketing and advertising arm for multiple standalone brands and operate via partner access only—brands maintain ownership of their assets.

Legal entity: Essential Group B.V.
Registered address: Kaya Breda 1-5, Hato, Bonaire
Email: info@thmdigitalimpact.com

Scope. This Privacy Policy explains how we collect, use, share, and protect personal information when you visit our site, contact us, or interact with our Services. If you engage with a brand we support, that brand’s own privacy policy also applies.

2) What information we collect

2.1 Information you provide

Contact details (name, email, phone) when you submit forms or contact us.
Business information (B2B clients) such as company name, role, billing contacts.
Support content (messages, attachments) you send to us.

2.2 Information collected automatically

Usage & device data. IP address, device/browser type, language, referring/exit pages, pages viewed, approximate geolocation (city/country), timestamps, and similar log data.
Cookies & similar technologies. We use essential, analytics, and advertising technologies. See our Cookie Policy and Cookie Settings link for details and choices.

2.3 Information from advertising & analytics partners

Meta technologies (Meta Pixel & Conversions API). Event data to measure campaign performance, improve ad relevance, and reduce ad waste. This may include pages visited, actions taken (e.g., add to cart or purchase on client sites we support), device information, and hashed identifiers (e.g., email/phone hashed before transmission).
Other processors. Reputable analytics, anti-fraud, hosting, and email service providers.

We do not intentionally collect special-category/sensitive data (e.g., health, biometric).

3) Why we use your information (purposes & legal bases)

3.1 Purposes

Provide and improve the Services (operate our site, troubleshoot, secure).
Analytics & performance (understand traffic and improve content).
Advertising & measurement (consent-based where required; optimize relevance, reduce ad waste).
Communications (respond to inquiries, provide updates).
Compliance & enforcement (detect/prevent fraud, enforce terms, meet legal obligations).

3.2 Legal bases (EEA/UK where applicable)

Legitimate interests: site operation, security, analytics, B2B relationship management (balanced against your rights).
Consent: non-essential cookies/advertising tech.
Contract: to perform under a contract with a client or vendor.
Legal obligations: tax, accounting, regulatory requests.

4) How we share information

We do not sell personal information for money. We may share information with:

Service providers / processors (hosting, security, analytics, email, support).
Advertising & measurement partners (e.g., Meta) for permitted, disclosed purposes. Meta may act as an independent controller for some processing; consult Meta’s privacy resources and ad preferences.
Professional advisors (legal, tax, accounting).
Authorities or third parties when required by law or to protect rights, safety, or users.
Business transfers (e.g., merger, acquisition, or asset sale).

Processors are bound by contracts to safeguard data and act only on our instructions.

5) International transfers

We operate and use providers in multiple countries. Where required, we implement appropriate safeguards (e.g., Standard Contractual Clauses) and assess partners for adequate protection.

6) Retention

We retain personal information only as long as necessary for the purposes described or as required by law. Typical timeframes:

Web logs & security events: ~12 months (adjusted if needed for investigations).
Analytics data: ~14–26 months (or provider default) unless aggregated/anonymized sooner.
Contact records & support tickets: 24–36 months after last interaction.
B2B client files/invoices: 7–10 years for accounting/tax.

We may anonymize data (irreversibly) and keep it for research or statistics.

7) Your choices & rights

7.1 Cookie and tracking choices

Use the Cookie Settings link (footer/banner) to manage non-essential cookies and ad tech (analytics, advertising). You can also adjust browser settings or platform preferences (e.g., Meta Ad Preferences).

7.2 EEA/UK residents (GDPR/UK GDPR)

You may have rights to request: access, correction, deletion, restriction, objection (including to direct marketing), portability, and withdrawal of consent (does not affect prior lawful processing).
To exercise, email info@thmdigitalimpact.com with “Privacy Request” and your country of residence. You may lodge a complaint with your local supervisory authority.

7.3 U.S. residents (e.g., CA/VA/CO/CT and similar)

Depending on your state, you may have rights to know/access, delete, correct, opt out of sale/share and targeted advertising, and appeal a decision.
We do not sell personal information for money. We may “share” personal information for cross-context behavioral advertising (as defined in California law). Use Cookie Settings to opt out of advertising technologies (serves as a “Do Not Sell/Share” control), or email info@thmdigitalimpact.com. Authorized agents may submit requests with proof of authorization.

7.4 Verifying & responding

We may need to verify your identity (e.g., email confirmation or additional details). We respond within the legal timeframe for your region.

8) Security

We use technical and organizational measures to protect personal information, including HTTPS/TLS encryption in transit, access controls, least-privilege permissions, 2FA for internal systems where feasible, and periodic access reviews. No method is 100% secure; you use the Services at your own risk.

9) Children

Our Services are not directed to children under 16 (or the age defined by local law). We do not knowingly collect data from children. If you believe a child provided data to us, contact info@thmdigitalimpact.com to request deletion.

10) Third-party sites & services

Our site may link to third-party websites, plug-ins, or services. Their privacy practices are governed by their own policies; we are not responsible for their content or handling of personal information.

11) Meta technologies disclosure (Pixel & Conversions API)

We use Meta Pixel and Conversions API to measure campaign performance, improve ad relevance, and reduce ad waste. These tools may process:

Pages visited, events/actions (e.g., add to cart, purchase);
Device, browser, and network identifiers;
Hashed contact identifiers (e.g., email/phone hashed client-side before transmission).

Manage preferences via our Cookie Settings and your Meta ad preferences. We respect applicable consent requirements.

12) Do Not Track & Global Privacy Control

There is no common industry standard for DNT signals. Where legally required and technically feasible, we honor Global Privacy Control (GPC) or similar signals as an opt-out of sale/share/targeted advertising.

13) Contact us

Privacy email: info@thmdigitalimpact.com
Postal address: Essential Group B.V., [Registered address]
If applicable – DPO/Privacy Lead: [Name, email]
If applicable – EEA/UK Representative: [Entity/contact]

14) Changes to this Policy

We may update this Privacy Policy from time to time. The “Last updated” date reflects the latest version. Material changes will be posted on this page and, where appropriate, notified by email or banner.

15) Region-specific disclosures (summaries)

California (CPRA).

Categories collected: identifiers (online IDs), internet activity (usage logs), geolocation (approximate), inferences (to improve relevance), and professional info (B2B contacts).
Sources: you, your devices/browsers, service providers, and advertising/analytics partners.
Purposes: see Section 3.
Disclosures for business purposes: processors (hosting, analytics, ad measurement, security, support); see Section 4.
Retention: see Section 6.
Sensitive personal information: not used/disclosed for inferring characteristics.

Virginia/Colorado/Connecticut and similar states.
We process personal data for targeted advertising and measurement where permitted by law and with consent where required. Opt out via Cookie Settings or by emailing info@thmdigitalimpact.com. You may appeal a denied request by replying to our decision email with “Appeal.”

16) Cookie summary (see full Cookie Policy)

Strictly necessary: site operation, security, consent storage.
Analytics: usage insights and performance.
Advertising: measure ads and improve relevance (e.g., Meta).