Privacy Policy

This Privacy Policy explains how Horack Sandoe ("I", "me", "my") collects, uses, stores, and protects personal data submitted through this website (horacksandoe.com) and its contact form. This policy complies fully with the General Data Protection Regulation (GDPR – EU 2016/679) and applicable Dutch data protection law. By submitting personal information through this website, you confirm that you have read and understood this policy.

1. Data Controller

The data controller responsible for all personal data processed via this website is:

Horack Sandoe
Noordsingel 2, 3035 EC Rotterdam, Netherlands
Email: hello@horacksandoe.com
Phone: +31 10 456 7890

2. Personal Data Collected

Data you provide voluntarily

When you complete and submit the contact form, the following personal data is collected:

• First name and last name
• Email address
• Phone number (optional — only if you choose to include it)
• The subject or topic of your enquiry
• The content of your message
• Consent record: timestamp and IP address at the moment you activated the GDPR consent checkbox

Technical data collected automatically

Standard web hosting infrastructure may generate server log data including IP addresses, browser type and version, operating system, referring URL, pages visited, and access timestamps. This data is used solely for security and diagnostic purposes and is not combined with personal identity data for commercial use.

3. Legal Bases for Processing

All personal data is processed on one or more of the following legal bases under Article 6 of the GDPR:

• Consent (Art. 6(1)(a)): By activating the consent checkbox, you give explicit consent for your submission data to be processed to respond to your enquiry. This may be withdrawn at any time.
• Contract performance (Art. 6(1)(b)): Where you engage a paid service, data is processed as necessary to deliver that arrangement.
• Legitimate interests (Art. 6(1)(f)): Basic website security and server log maintenance are conducted on legitimate interests that do not override your privacy rights.

4. How Your Data Is Used

Your data is used exclusively to respond to your enquiry; deliver requested services; schedule and conduct Focused Enquiry sessions or Sustained Work arrangements; deliver purchased digital products such as the Sandoe Primer; maintain service correspondence; and comply with Dutch accounting and legal obligations. Your data is not used for profiling, unsolicited marketing, or commercial purposes beyond direct service delivery. I do not sell, rent, or transfer your personal data to third parties for commercial benefit.

5. Retention Periods

• Contact form data with no resulting service: deleted within 12 months of last communication.
• Client service records: retained 7 years from service conclusion per Dutch fiscal law, then permanently deleted.
• Consent records: retained alongside associated data for the same duration.
• Server log data: overwritten after 90 days maximum.

6. Cookies and Third-Party Technologies

This website does not deploy analytics platforms, advertising networks, or tracking pixels. No commercial cookies are set by this site. The following third-party technologies are present for functional purposes only:

• Google Maps (Google LLC): Embedded on the main page. Interaction may cause Google to set cookies and process your IP per Google's privacy policy.
• Google Fonts (Google LLC): Loaded from Google's CDN; Google may log your IP during delivery.
• Font Awesome (Fonticons, Inc. via Cloudflare CDN): Icons delivered via Cloudflare, which may log access requests.

I have no access to or control over data independently collected by these providers.

7. Data Sharing

Personal data is not shared with third parties except: data processors bound by processing agreements (email tools, scheduling, digital delivery); legal authorities when required by law or court order; or a successor entity in a business transfer under equivalent protections.

8. International Data Transfers

Where any service transfers data outside the EEA, appropriate safeguards are in place per GDPR Chapter V, including European Commission-approved Standard Contractual Clauses or an equivalent mechanism.

9. Your GDPR Rights

You hold rights to: access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), portability (Art. 20), objection (Art. 21), and withdrawal of consent (Art. 7(3)). Contact me at hello@horacksandoe.com. I will respond within 30 calendar days, extendable by two further months in complex cases with advance notice.

10. Supervisory Authority

You may file a complaint with the Dutch supervisory authority: Autoriteit Persoonsgegevens (AP), Bezuidenhoutseweg 30, 2594 AV Den Haag. Website: autoriteitpersoonsgegevens.nl

11. Security

I apply appropriate technical and organisational measures to protect personal data — including HTTPS/TLS encryption, access controls, and periodic review — while acknowledging that no internet-based system can be unconditionally guaranteed against all risks.

12. Children

This website is not directed at individuals under 16. I do not knowingly collect data from children under 16. If you believe a child has submitted data, contact me immediately at hello@horacksandoe.com and I will delete it without delay.

13. Policy Updates

This policy may be revised periodically. The current version is always at this URL with the "last updated" date reflecting any revision. Material changes will be announced on the website.

14. Contact

Horack Sandoe
Noordsingel 2, 3035 EC Rotterdam, Netherlands
Email: hello@horacksandoe.com
Phone: +31 10 456 7890
Hours: Mon–Fri 9:00–18:00, Sat 10:00–14:00