1. Introduction
Funnel Adviseur respects the privacy of everyone who contacts us. We process personal data carefully and in accordance with the General Data Protection Regulation (GDPR), the Dutch GDPR Implementation Act and the Dutch Telecommunications Act.
This privacy policy explains which data we collect, why we collect it, how long we retain it and which rights you have. Questions and requests can be sent to mail@funneladviseur.nl.
2. Who does this policy apply to?
This policy applies to:
- Visitors to funneladviseur.nl.
- People who contact us by email, telephone, WhatsApp, LinkedIn or a website form.
- Business contacts at current and prospective clients, suppliers and collaboration partners.
Processing on behalf of clients
When we process personal data on behalf of a client, such as customer data in a CRM implementation, we act as a processor. A separate data-processing agreement is concluded with that client. This policy covers the processing for which Funnel Adviseur is the controller.
3. Which personal data do we process?
3.1 Contact and client communication
When you contact us or request a proposal, we process:
- First and last name
- Company name and role
- Email address
- Telephone number, where provided
- Your message, attachments and subsequent correspondence
- Time and channel of contact
3.2 Scheduling a meeting
When you schedule an introductory or advisory call through the online planner, we additionally process:
- The selected time slot
- Notes or topics you choose to share in advance
- A unique Google Calendar event identifier and, where used, a Google Meet video link
- Confirmations, reminders and suppression signals in our email and marketing automation
3.3 Website use, cookies and analytics
We use Google Analytics 4 (GA4) to measure website use. Google Consent Mode v2 is configured so that analytics and marketing cookies are not stored without your explicit consent. If you consent, GA4 may process the following information:
- Anonymised IP address
- Device and browser type, operating system and language
- Pages visited, visit duration and click paths
- Traffic source, such as a search engine, referrer or campaign
- Conversion events, such as submitted forms or scheduled meetings
3.4 AI Praktijkbrief subscription
If you subscribe to the AI Praktijkbrief, Funnel Adviseur stores your email address, first name, selected topics, the page where you subscribed, the consent wording and technical hashes of the IP address and user agent locally as evidence of pending consent. Resend sends the double opt-in confirmation email. Only after you click its confirmation link do we store your first name, email address, selected topics, source, newsletter status and confirmation time in Twenty CRM for newsletter management. This AI Praktijkbrief subscription is not stored in ActiveCampaign.
3.5 Administrative access
For the restricted /admin environment, we process a username, a salted bcrypt password hash, a session token and the login time. This information is only available to authorised Funnel Adviseur administrators.
4. Why do we process this data?
We process personal data only for the following purposes:
- Answering questions and preparing proposals.
- Performing agreements and related administration.
- Scheduling, confirming and attending meetings.
- Financial administration, invoicing and debtor management.
- Sending relevant service emails, such as confirmations, reminders and active-project updates.
- Sending the AI Praktijkbrief after double opt-in consent.
- Improving the website and our services using aggregated statistics.
- Measuring campaign and website interaction through marketing cookies, only after consent.
- Meeting legal obligations, including tax-record retention.
- Establishing, exercising or defending legal claims.
5. Legal bases
Processing is based on one of the following grounds under Article 6 GDPR:
- Contract: Performance of a contract or pre-contractual steps at the data subject’s request under Article 6(1)(b) GDPR.
- Legal obligation: Compliance with a legal obligation, including tax-record retention, under Article 6(1)(c) GDPR.
- Legitimate interest: Funnel Adviseur’s legitimate interest in a functioning and secure website and in business-relationship management under Article 6(1)(f) GDPR. We balance this interest against your privacy.
- Consent: Consent, including for analytics and marketing cookies and use in client references, under Article 6(1)(a) GDPR. Consent can be withdrawn at any time.
6. Retention periods
After a retention period expires, the data is deleted or irreversibly anonymised.
- Enquiries without an engagement: Up to 24 months after the last contact, unless you request earlier deletion.
- Proposals and contracts: For the duration of the engagement plus seven years for tax-record purposes.
- Invoices and financial records: Seven years under Article 52 of the Dutch State Taxes Act.
- Meeting and email correspondence: Up to 36 months after the last interaction.
- AI Praktijkbrief subscriptions: For as long as you remain subscribed; you can unsubscribe at any time using the link in the AI Praktijkbrief. Unconfirmed registrations and tokens are periodically deleted or anonymised.
- Analytics: Up to 14 months at user level.
- Administrative access logs: Up to 12 months.
7. With whom do we share data?
We only share personal data with selected providers that process data for us or on our instructions. We enter into data-processing agreements where required. The main categories are:
- Hosting and infrastructure: Hetzner Online GmbH in Germany for hosting our website and data, and Cloudflare, Inc. for CDN and DDoS protection.
- Calendar and video calls: Google Ireland Ltd. for Google Calendar and Google Meet.
- Analytics: Google Ireland Ltd. for Google Analytics 4 and Consent Mode v2.
- Email: Resend, Inc. for transactional email and Google Ireland Ltd. for business email.
- Newsletter management: Twenty CRM for confirmed AI Praktijkbrief contacts and their selected topic preferences.
- Marketing automation: ActiveCampaign, Inc. for email flows, contact management and site tracking after marketing-cookie consent.
- AI services: Anthropic PBC for the Claude API and Google Ireland Ltd. for Gemini and Imagen in our knowledge-base workflow. These providers process the input we supply under the applicable settings and agreements.
- Accounting: Bookkeeping software and, where applicable, an external accountant subject to confidentiality and processing arrangements.
No sale of personal data
We do not disclose personal data to third parties for their own commercial purposes and never sell personal data. A current list of subprocessors is available on request.
8. Transfers outside the EEA
Some subprocessors are established outside the European Economic Area, including in the United States. Transfers only take place with safeguards under Chapter V GDPR, including:
- An adequacy decision by the European Commission, including the EU-US Data Privacy Framework for participating US organisations.
- Standard Contractual Clauses adopted by the European Commission.
- Additional technical and organisational measures, such as encryption and pseudonymisation, where appropriate.
9. Security
Funnel Adviseur applies appropriate technical and organisational measures, including:
- Encryption in transit using TLS 1.2 or higher.
- Password storage as bcrypt hashes and AES-256-GCM encryption at rest for access tokens of connected services.
- Environment separation and access according to the principle of least privilege.
- Regular security updates, logging of administrative actions and monitoring of suspicious activity.
- Production backups, including geographically separated storage.
Reporting an issue
If you suspect a security incident or vulnerability, report it confidentially to mail@funneladviseur.nl. We aim to respond within 48 hours.
10. Your rights
Under the GDPR you may have the following rights in relation to your personal data:
- The right of access.
- The right to rectify inaccurate data.
- The right to erasure in the circumstances set out in the GDPR.
- The right to restrict processing.
- The right to data portability in a structured, commonly used and machine-readable format.
- The right to object to processing based on legitimate interests or for direct marketing.
- The right to withdraw consent at any time.
Submitting a request or complaint
Send requests to mail@funneladviseur.nl. To prevent misuse, we may ask for additional identification. We respond within four weeks.
If you disagree with our handling of a request, you may lodge a complaint with the Dutch Data Protection Authority, the Autoriteit Persoonsgegevens.
12. Automated decision-making
Funnel Adviseur does not make decisions that produce legal effects or similarly significantly affect a person solely through automated processing, including profiling. Decisions about accepting engagements, pricing and substantive publication are made by Pascal Bouman, potentially supported by automated suggestions. AI-generated content is manually reviewed before publication.
13. Children
Our services are directed at business clients. We do not knowingly process personal data of children under 16. If you believe that we have processed a child’s data, contact us so that we can delete it as soon as possible.
14. Changes to this policy
Funnel Adviseur may update this policy due to changes in law, subprocessors or services. Material changes are communicated through our channels. The current version and last-updated date are always published on this page.
15. Contact
For questions, comments or requests concerning this privacy policy, contact:
- Email: mail@funneladviseur.nl
- Telephone: +31 6 16 66 85 80
- Post: Funnel Adviseur, Pascal Bouman, KVK 91131235 — postal address available on request