Privacy Policy

1. Data Controller Information

2. Data We Collect

2.1 Information You Provide

• WhatsApp contact information (phone number)
• Quiz responses and personality preferences
• Communication preferences
• Any information you voluntarily share via WhatsApp

2.2 Automatically Collected Data

• Website usage analytics (Google Analytics, Microsoft Clarity)
• Browser type, device information, IP address
• Pages visited, time spent, interaction patterns
• Cookies and similar tracking technologies

3. Legal Basis for Processing (GDPR Art. 6)

• Consent (Art. 6.1.a): WhatsApp communications, marketing, analytics cookies
• Legitimate Interest (Art. 6.1.f): Website functionality, security, fraud prevention
• Contract Performance (Art. 6.1.b): Order processing when available

4. How We Use Your Data

• Manage the exclusive waitlist and notify about product availability
• Provide personalized quiz results and product recommendations
• Send marketing communications (with your consent)
• Improve website functionality and user experience
• Comply with legal obligations and prevent fraud
• Analyze website performance and user behavior

5. Data Sharing and Third Parties

5.1 Service Providers

• Google Analytics: Website analytics (anonymized IP)
• Microsoft Clarity: User behavior analysis
• WhatsApp (Meta): Communication platform
• Hosting Provider: Website hosting and maintenance

5.2 Data Transfers Outside EU

Some services (Google, Microsoft, Meta) may transfer data outside the EU. We ensure adequate protection through:

• Standard Contractual Clauses (SCCs)
• Adequacy decisions where applicable
• Additional safeguards as required by GDPR

6. Your Rights Under GDPR

• Right of Access (Art. 15): Request copies of your personal data
• Right to Rectification (Art. 16): Request correction of inaccurate data
• Right to Erasure (Art. 17): Request deletion of your data
• Right to Restrict Processing (Art. 18): Limit how we use your data
• Right to Data Portability (Art. 20): Receive your data in machine-readable format
• Right to Object (Art. 21): Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent at any time

How to Exercise Your Rights: Contact us at [email protected] or via WhatsApp. We will respond within 30 days.

7. Data Retention

• WhatsApp Data: Until you request deletion or withdraw consent
• Analytics Data: 26 months (Google Analytics default)
• Website Logs: 12 months maximum
• Marketing Data: Until consent is withdrawn

8. Cookies and Tracking

We use cookies for:

• Necessary Cookies: Website functionality (no consent required)
• Analytics Cookies: Performance measurement (consent required)
• Marketing Cookies: Personalization and advertising (consent required)

You can manage cookie preferences through our cookie banner or browser settings.

9. Data Security

We implement appropriate technical and organizational measures:

• HTTPS encryption for all data transmission
• Regular security updates and monitoring
• Access controls and staff training
• Incident response procedures
• Regular security assessments

10. Children's Privacy

Our services are not intended for children under 16. We do not knowingly collect personal data from children under 16. If we become aware of such collection, we will delete the data immediately.

11. Data Protection Officer

For privacy-related inquiries, contact our Data Protection Officer:

12. Supervisory Authority

You have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens):

13. Changes to Privacy Policy

We may update this privacy policy to reflect changes in our practices or legal requirements. We will notify you of significant changes via:

• Website notification banner
• WhatsApp message (if subscribed)
• Email notification (if provided)