Privacy Policy

1. Introduction

Emerald Elephant Solutions BV ("we", "our", or "us") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, and protect your personal information when you use our website and services.

This policy applies to all personal data we process as a data controller under the General Data Protection Regulation (GDPR) and Dutch data protection laws.

2. Information We Collect

2.1 Information You Provide Directly

• Contact Information: Name, email address, phone number, company name, job title
• Communication Data: Information in emails, messages, and other communications with us
• Project Information: Details about your business needs, requirements, and project specifications
• Contract Data: Information necessary for contract execution and invoicing

2.2 Information We Collect Automatically

• Website Usage Data: IP address, browser type, pages visited, time spent on pages
• Technical Data: Device information, operating system, internet connection details
• Cookies: Small files stored on your device (see our Cookie Policy for details)

3. How We Use Your Information

3.1 Legal Bases for Processing

We process your personal data based on:

• Contract performance: To provide our consulting services
• Legitimate interests: To improve our services and communicate about our business
• Legal obligations: To comply with accounting, tax, and other legal requirements
• Consent: For marketing communications (where required)

3.2 Purposes of Processing

• Providing executive interim management, business consulting, and project management services
• Developing and delivering custom software solutions
• Communicating about our services and responding to inquiries
• Managing client relationships and contracts
• Invoicing and accounting
• Improving our website and services
• Complying with legal and regulatory requirements

4. Data Sharing and Disclosure

We do not sell your personal data. We may share your information with:

4.1 Service Providers

• IT service providers and hosting companies
• Accounting and legal advisors
• Subcontractors involved in project delivery (with your consent)

4.2 Legal Requirements

We may disclose your information when required by law, court order, or regulatory authority.

4.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.

5. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including:

• Encryption of data in transit and at rest
• Regular security assessments and updates
• Access controls and authentication measures
• Staff training on data protection
• Secure backup and recovery procedures

6. Data Retention

We retain your personal data only as long as necessary for the purposes outlined in this policy:

• Client data: For the duration of our business relationship plus 7 years for legal and accounting purposes
• Marketing data: Until you withdraw consent or we determine it's no longer necessary
• Website data: Typically 2 years for analytics purposes

7. Your Rights Under GDPR

You have the following rights regarding your personal data:

• Right of access: Request a copy of your personal data
• Right to rectification: Correct inaccurate or incomplete data
• Right to erasure: Request deletion of your data (right to be forgotten)
• Right to restrict processing: Limit how we use your data
• Right to data portability: Receive your data in a portable format
• Right to object: Object to processing based on legitimate interests
• Rights regarding automated decision-making: Not to be subject to automated decisions

To exercise these rights, please contact us using the information provided below.

8. International Data Transfers

Your personal data is primarily processed within the European Union. If we transfer data outside the EU, we ensure appropriate safeguards are in place, such as:

• Adequacy decisions by the European Commission
• Standard Contractual Clauses
• Binding Corporate Rules

9. Cookies and Website Technologies

Our website uses cookies and similar technologies. For detailed information about our use of cookies, please refer to our separate Cookie Policy.

10. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to read their privacy policies.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on our website and updating the "Last Updated" date below.

12. Children's Privacy

Our services are not directed to children under 16 years of age. We do not knowingly collect personal information from children under 16.

13. Supervisory Authority

If you believe we have not adequately addressed your privacy concerns, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens):

• Website: www.autoriteitpersoonsgegevens.nl
• Phone: 088 – 1805 250
• Address: Postbus 93374, 2509 AJ Den Haag