Privacy

This is a translation for convenience; the Dutch version is legally binding.

FrankDegen, PO Box 21213, 3001AE Rotterdam, is responsible for the processing of personal data as described in this privacy statement.

Contact details

PO Box 21213
3001AE Rotterdam
https://www.frankdegen.com

Frank Degen is the Data Protection Officer of FrankDegen and can be reached at info@frankdegen.com

Personal data we process

FrankDegen processes your personal data because you use our services and/or because you provide this data to us yourself.

Below is an overview of the personal data we process:

• First and last name
• Address details
• Telephone number
• Email address
• Other personal data you actively provide, for example via the contact form, in correspondence and by telephone
• IP address and technical data about your visit, such as browser and device type (via Cloudflare, see below)
• Internet browser and device type (only via Google Analytics, if you consent)

Special and/or sensitive personal data we process

Our website and/or service does not intend to collect data about website visitors younger than 16, unless they have permission from a parent or guardian. However, we cannot verify whether a visitor is older than 16. We therefore encourage parents to be involved in their children's online activities, to prevent data about children being collected without parental consent. If you believe we have collected personal information about a minor without such consent, please contact us at info@frankdegen.com and we will delete this information.

For what purpose and on what legal basis we process personal data

FrankDegen processes your personal data for the following purposes:

• Answering your question or sign-up via the contact form
• Handling your payment
• Being able to call or email you if this is necessary to provide our services
• Delivering goods and services to you
• FrankDegen also processes personal data when we are legally required to do so, such as data we need for our tax return.

Automated decision-making

FrankDegen does not make decisions based on automated processing on matters that may have (significant) consequences for people. These are decisions taken by computer programs or systems without human involvement (for example an employee of FrankDegen).

How long we keep personal data

FrankDegen does not keep your personal data longer than strictly necessary to achieve the purposes for which it was collected. We use the following retention periods for the following (categories of) personal data:

• Personal data: as long as legally required or as long as needed for customer contact.
• Personal details: as long as legally required or as long as needed for customer contact.
• Address: as long as legally required or as long as needed for customer contact.

Sharing personal data with third parties

FrankDegen does not sell your data to third parties and will only provide it if this is necessary to perform our agreement with you or to comply with a legal obligation. With companies that process your data on our behalf, we conclude a processing agreement to ensure the same level of security and confidentiality of your data. FrankDegen remains responsible for these processing operations. This website is hosted by Versio (the Netherlands); Google Analytics is only used if you consent.

Cloudflare

All traffic to this website passes through Cloudflare, Inc. Cloudflare delivers the website faster (by temporarily storing images and other files) and protects it against attacks and spam. To do so, Cloudflare processes your IP address and technical data about your visit (legal basis: legitimate interest in a fast and secure website). Cloudflare is a US company; a data processing agreement applies, and transfers outside the EU are covered by the EU-US Data Privacy Framework and the European Commission's standard contractual clauses.

Contact form

When you fill in the contact form, FrankDegen receives your name, email address, optionally your phone number, the subject and your message by email. A copy of the message is kept on the web server so nothing is lost if an email does not arrive. This data is only used to handle your question or sign-up and is not kept longer than necessary for that.

To prevent spam, the form uses Cloudflare Turnstile. Turnstile uses technical data from your browser and device to check that the form is filled in by a human; usually you won't notice anything. Turnstile does not place tracking cookies and the data is only used for this check.

Quitclaim (consent for use of photographs)

If you sign a quitclaim as the person photographed, FrankDegen stores:

• your name, date of birth and place of residence;
• your email address and/or phone number;
• for minors (under 18): the name and relationship of the parent or guardian who signs on your behalf;
• the signed text, your signature and typed name;
• as proof of signing: date and time, IP address, the device/browser used, the language and text version, and a verification code;
• whether you confirmed your email address via the link in the confirmation email.

This data is needed to show that you have given permission to use the images (legal basis: the agreement you enter into with the quitclaim, and the legitimate interest in being able to demonstrate this). It is kept for as long as the images are used, and for up to two years after that. The signed quitclaim is stored as a PDF on the server of our hosting provider in the Netherlands and is only accessible to Frank Degen. You receive a copy by email, or you can download it immediately after signing.

Newsletter

If you sign up for the newsletter, your email address and optionally your first and last name are stored with Laposta (the Netherlands), the service used to send the newsletter. You first receive an email to confirm your subscription. You can unsubscribe at any time via the link at the bottom of every newsletter; your data is then deleted.

Cookies, Cloudflare Web Analytics and Google Analytics

To see how often the website is visited, FrankDegen uses Cloudflare Web Analytics. It counts visits without cookies, without storing your IP address and without tracking you across websites; it only records which pages are viewed, which website you came from and which type of browser and device you use. No consent is required for this.

This website does not place tracking cookies without your consent. To measure how the website is used, FrankDegen uses Google Analytics, but only if you give consent via the cookie notice. Google Analytics then places cookies (starting with _ga) to count visits anonymously, for example which pages are viewed and on which type of device. Google Signals and sharing data for advertising are switched off. Your choice is stored in your browser for 12 months (not as a cookie).

You can change your choice at any time via "Cookie settings" at the bottom of every page. If you withdraw consent, the Google Analytics cookies are deleted. You can also set your browser not to store cookies and delete previously stored information.

Viewing, changing or deleting your data

You have the right to view, correct or delete your personal data. You also have the right to withdraw any consent to data processing or to object to the processing of your personal data by FrankDegen, and you have the right to data portability. This means you can ask us to send the personal data we hold about you in a computer file to you or to another organisation you name.

You can send a request for access, correction, deletion or transfer of your personal data, or a request to withdraw your consent or object to the processing of your personal data, to info@frankdegen.com.

To make sure the request was made by you, we ask you to include a copy of your ID with the request. In this copy, black out your passport photo, MRZ (machine readable zone, the strip with numbers at the bottom of the passport), passport number and citizen service number (BSN), to protect your privacy. We will respond to your request as quickly as possible, and within four weeks.

FrankDegen also points out that you can file a complaint with the national supervisory authority, the Dutch Data Protection Authority (Autoriteit Persoonsgegevens), via: https://autoriteitpersoonsgegevens.nl/nl/contact-met-de-autoriteit-persoonsgegevens/tip-ons

How we protect personal data

FrankDegen takes the protection of your data seriously and takes appropriate measures to prevent misuse, loss, unauthorised access, unwanted disclosure and unauthorised modification. If you feel your data is not properly secured or there are indications of misuse, please contact us at info@frankdegen.com.

FrankDegen has taken the following measures to protect your personal data:

• Security software, such as a virus scanner and firewall.
• TLS (formerly SSL): we send your data over a secure internet connection. You can recognise this by 'https' and the padlock in the address bar.
• DKIM, SPF and DMARC are three internet standards we use to prevent you from receiving emails in our name that contain viruses, are spam or are intended to obtain personal (login) data.
• DNSSEC is an extra layer of security (on top of DNS) for translating a domain name to its associated IP address (server name); it is provided with a digital signature, which can be checked automatically. This prevents you from being redirected to a fake IP address.