Privacy Policy
Last Updated: January 29, 2025
This Privacy Policy explains the nature, scope, and purpose of the processing of personal data (hereinafter referred to as “Data”) on our website and related services. We process personal data in accordance with the General Data Protection Regulation (GDPR) and other applicable laws.
1. Controller Information
Sarwary Holding B.V.
Stollenbergweg 76
6572 AD, Berg en Dal
The Netherlands
E-mail: [email protected]
Chamber of Commerce number: 74464760
VAT identification number: NL859912073B01
For data protection inquiries, please contact us at: [email protected]
2. Processed Data and Legal Basis
We process personal data only where legally permitted, based on:
- Art. 6(1)(b) GDPR (contract performance)
- Art. 6(1)(c) GDPR (legal obligations)
- Art. 6(1)(f) GDPR (legitimate interest)
- Art. 6(1)(a) GDPR (consent where required)
Types of Processed Data
- Contact Data (e.g., name, email address)
- Technical Data (e.g., IP address, browser type, device data, log files for security purposes)
- Communication Data (e.g., emails, form submissions)
We do not process special categories of personal data (e.g., health data, biometric data) as defined under Art. 9 GDPR.
3. Purpose of Processing
We process data for the following purposes:
- To provide and operate our website
- To respond to inquiries
- To secure our website (e.g., protection against spam, bot attacks)
- To send newsletters (only with explicit consent)
4. Data Retention
We store personal data only as long as necessary:
- Inquiries via contact form: 12 months
- Security logs (Wordfence): 7 days
- Newsletter subscriptions: Until consent is withdrawn
5. Data Transfers and Third-Party Services
We use external service providers to support our operations. These providers process data only as necessary and comply with GDPR.
Hosting & Security
- Hetzner (Germany): Our website is hosted on Hetzner servers within the EU. (Art. 6(1)(f) GDPR – legitimate interest)
- Cloudflare (USA): Used as a CDN to ensure website performance and protection against attacks. Standard Contractual Clauses (SCCs) ensure compliance. (Art. 6(1)(f) GDPR – legitimate interest)
- Wordfence (USA): Security tool for detecting attacks and blocking malicious activity. (Art. 6(1)(f) GDPR – legitimate interest)
- hCaptcha (USA): Protects against spam and bot attacks. SCCs ensure GDPR compliance. (Art. 6(1)(f) GDPR – legitimate interest)
Marketing & Communication
- MailerLite (EU): Used for sending newsletters. Subscribers must explicitly opt-in (Art. 6(1)(a) GDPR – consent).
- TidyCal (USA): Appointment booking tool. Data is processed based on user consent (Art. 6(1)(b) GDPR – contract performance).
Spam Protection
- Akismet (USA): Detects spam in contact form submissions. SCCs ensure GDPR compliance. (Art. 6(1)(f) GDPR – legitimate interest)
We do not use Google Analytics, Google Tag Manager, Facebook Pixel, or any tracking cookies.
6. Rights of Data Subjects
Under GDPR, you have the following rights:
- Right to Access (Art. 15 GDPR) – Obtain confirmation if your data is being processed.
- Right to Rectification (Art. 16 GDPR) – Correct inaccurate or incomplete data.
- Right to Erasure (Art. 17 GDPR) – Request deletion of your data (unless legal obligations prevent this).
- Right to Restriction of Processing (Art. 18 GDPR) – Limit how we process your data.
- Right to Data Portability (Art. 20 GDPR) – Receive a copy of your data in a structured format.
- Right to Object (Art. 21 GDPR) – Object to data processing based on legitimate interests.
- Right to Withdraw Consent (Art. 7(3) GDPR) – Withdraw previously given consent at any time.
To exercise any of these rights, contact us at: [email protected]
You also have the right to file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or your local EU data protection authority.
7. Cookies & Tracking
We only use essential cookies for security and functionality. No marketing or tracking cookies are used.
You can configure cookie settings in your browser. Note that disabling essential cookies may limit website functionality.
8. Changes to This Privacy Policy
We may update this Privacy Policy as needed. The latest version is always available at adjmal.com/privacy-policy. If significant changes occur, we will notify users by email (if applicable).
If you have any questions regarding this Privacy Policy, please contact us at: [email protected]
