Privacy Policy
How we collect, use, and protect your personal data.
Last updated: 10 April 2026 | Version 2.0
1. Data Controller
The data controller responsible for the processing of your personal data is:
AzilutCloudJansstraat 10, 2011 RR Haarlem
Noord-Holland, Netherlands
KVK: 12345678
BTW: NL123456789B01
Email: [email protected]
Phone: +31 6 69 72 84 93
2. Personal Data We Collect
We collect the following personal data when you use our website or services:
a) Contact form data
- First name and last name
- Email address
- Phone number (optional)
- Message content and area of interest
- IP address (for security and rate-limiting)
b) Cookies and tracking data
We use cookies and similar tracking technologies. Please refer to our Cookie Policy for full details.
c) Technical data
Anonymised data such as browser type, pages visited, and approximate geographic location may be collected through analytics tools after your consent.
3. Legal Basis for Processing (GDPR Art. 6)
| Purpose | Legal Basis |
|---|---|
| Responding to enquiries / contact forms | Art. 6(1)(b) — performance of a contract / pre-contractual steps |
| Providing coaching services | Art. 6(1)(b) — performance of a contract |
| Analytics cookies | Art. 6(1)(a) — consent |
| Marketing / advertising cookies (Google Ads, Microsoft Advertising) | Art. 6(1)(a) — consent |
| Security and fraud prevention | Art. 6(1)(f) — legitimate interest |
| Legal obligations (tax records, KVK) | Art. 6(1)(c) — legal obligation |
4. How We Use Your Data
- To respond to your enquiry and provide our career coaching services
- To send service-related communications (appointment confirmations, follow-ups)
- To improve the website experience through analytics (only with consent)
- To display relevant advertising via Google Ads and Microsoft Advertising (only with consent)
- To comply with legal obligations (e.g., invoice records)
- To protect the security of our website (fraud detection, rate limiting)
We do not use your data for automated decision-making or profiling as defined in GDPR Art. 22.
5. Third-Party Processors and Data Sharing
We share data with the following third parties only where necessary and under appropriate data processing agreements:
| Processor | Purpose | Country |
|---|---|---|
| Google LLC (Google Ads / Analytics) | Advertising & analytics (consent required) | USA (SCCs) |
| Microsoft Corporation (Microsoft Advertising / UET) | Advertising (consent required) | USA (SCCs) |
| Web hosting provider | Website hosting | EU/NL |
| Email service provider | Transactional emails | EU |
We do not sell your personal data to third parties.
Where data is transferred outside the EEA (e.g., to Google or Microsoft in the USA), this is done under Standard Contractual Clauses (SCCs) approved by the European Commission.
6. Data Retention
- Contact form submissions: 2 years from the date of enquiry, then deleted.
- Client coaching records: 7 years (Dutch tax record requirements — Belastingdienst).
- Cookie consent logs: 1 year (stored locally in your browser).
- Analytics data: As configured in Google Analytics / Microsoft Clarity (maximum 14 months, then anonymised).
7. Your Rights Under GDPR
As a data subject you have the following rights:
- Right of access (Art. 15): Obtain a copy of your personal data we hold.
- Right to rectification (Art. 16): Request correction of inaccurate data.
- Right to erasure (Art. 17): Request deletion of your data ("right to be forgotten").
- Right to restriction (Art. 18): Request that we limit how we process your data.
- Right to data portability (Art. 20): Receive your data in a machine-readable format.
- Right to object (Art. 21): Object to processing based on legitimate interests.
- Right to withdraw consent (Art. 7(3)): Withdraw consent for cookies at any time via our Cookie Preferences panel.
To exercise any of these rights, contact us at: [email protected] or write to our address above. We will respond within 30 days.
8. Cookies
We use cookies in accordance with the Dutch Telecommunicatiewet (Art. 11.7a) and GDPR. We obtain your explicit opt-in consent before placing any non-essential cookies. For full details, see our Cookie Policy.
You can change your cookie preferences at any time by clicking Cookie Settings in the footer of any page.
9. Children's Privacy
Our services are directed at adult professionals (18+). We do not knowingly collect personal data from children under 16. If you believe we have inadvertently collected data from a minor, please contact us immediately at [email protected].
10. Complaints
If you believe we have not handled your personal data correctly, you have the right to lodge a complaint with the Dutch supervisory authority:
Autoriteit Persoonsgegevens (AP)Bezuidenhoutseweg 30, 2594 AV Den Haag
Phone: 088 - 180 52 50
Website: autoriteitpersoonsgegevens.nl
11. Changes to This Policy
We may update this Privacy Policy from time to time. The "last updated" date at the top indicates when changes were last made. Material changes will be communicated via a prominent notice on our website. We encourage you to review this page periodically.
12. Contact
For any privacy-related questions or to exercise your rights, please contact us:
Email: [email protected]
Phone: +31 6 69 72 84 93
Address: Jansstraat 10, 2011 RR Haarlem, Netherlands