Privacy Policy
Last updated: 4 May 2025
1. Who are we?
Ontwikkelaars is a trade name of Coded BV and Coded Holding BV, established in the Netherlands. We are the data controller within the meaning of the General Data Protection Regulation (GDPR) for the personal data collected through our website.
Questions about this privacy policy can be directed to: privacy@ontwikkelaars.nl.
2. What personal data do we process?
We only process data that you actively provide to us, depending on how you contact us:
- Contact form — name, email address, phone number (optional), company name (optional), project type, indicative budget and your message
- Newsletter — email address
- Appointment system — name, email address, company name (optional), message, and the date, time and timezone of the appointment
- Website visits — no personal data; our analytics service places no cookies and collects no personally identifiable information
3. Purposes and legal bases
We process your personal data for the following purposes and on the following legal bases (Art. 6 GDPR):
- Responding to contact requests and quote enquiries — legal basis: legitimate interest (Art. 6(1)(f))
- Sending the newsletter — legal basis: consent (Art. 6(1)(a)); you can unsubscribe at any time via the unsubscribe link in every email
- Scheduling and conducting an introductory meeting — legal basis: performance of a (pre-)contractual measure (Art. 6(1)(b))
- Compliance with legal obligations, such as tax record-keeping requirements — legal basis: legal obligation (Art. 6(1)(c))
4. Retention periods
We do not retain your data longer than necessary:
Contact requests — maximum 12 months after handling.
Newsletter addresses — until you unsubscribe.
Appointment data — maximum 12 months after the appointment date.
Accounting data — 7 years in accordance with Dutch tax retention obligations.
5. Recipients and transfers outside the EEA
We do not share your data with third parties for commercial purposes. We use the following categories of processors with whom data processing agreements have been concluded:
- EU-based cloud provider for database storage and management — servers in the European Economic Area, no transfer outside the EEA
- Email delivery service for confirmation and newsletter emails — based outside the EEA; transfer takes place on the basis of standard contractual clauses (Art. 46(2)(c) GDPR)
- Appointment scheduling system for booking introductory meetings — based outside the EEA; transfer on the basis of standard contractual clauses
- Privacy-friendly web analytics service — processes no personal data and places no cookies; no data processing agreement required
6. Your rights under the GDPR
Under the GDPR you have the following rights. You can exercise them by emailing privacy@ontwikkelaars.nl. We respond within 30 days.
- Right of access (Art. 15) — request details of the personal data we process about you
- Right to rectification (Art. 16) — have inaccurate or incomplete data corrected
- Right to erasure (Art. 17) — request deletion of your data ('right to be forgotten')
- Right to restriction of processing (Art. 18) — temporary restriction of processing in certain circumstances
- Right to data portability (Art. 20) — receive your data in a common, machine-readable format
- Right to object (Art. 21) — object to processing based on legitimate interest
- Right to withdraw consent (Art. 7(3)) — for processing based on consent, at any time and without consequences
7. Lodging a complaint with the supervisory authority
If you are dissatisfied with how we handle your personal data, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens):
Autoriteit Persoonsgegevens www.autoriteitpersoonsgegevens.nl Phone: +31 88 1805 250
We would appreciate the opportunity to resolve any concerns with you directly before you contact the authority.
8. Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss or disclosure. Our website uses encrypted connections (TLS/HTTPS). Access to personal data is restricted to staff members who need it for their work.
9. Changes to this policy
We may update this privacy policy if our practices or applicable law changes. The date at the top of this page indicates the most recent version. For significant changes we will notify you by email or with a notice on our website.
10. Contact
Do you have questions about this privacy policy or would you like to exercise one of your rights?
Email: privacy@ontwikkelaars.nl Company: Coded BV · Coded Holding BV Trade name: Ontwikkelaars Country: the Netherlands
Coded BV · trading as Ontwikkelaars · the Netherlands · privacy@ontwikkelaars.nl