Privacy Policy

Last updated: 24 June 2026

This Privacy Policy explains how Naturclearing.ddd ("we", "us", "our") collects, uses, stores, and protects your personal data when you visit our website or contact us. We process personal data in accordance with:

• the General Data Protection Regulation (EU) 2016/679 ("GDPR");
• the Dutch GDPR Implementation Act (Uitvoeringswet Algemene verordening gegevensbescherming — UAVG);
• the Dutch Telecommunications Act (Telecommunicatiewet), where relevant to electronic communications data;
• other applicable Dutch and European privacy legislation.

This policy fulfils our information obligations under GDPR Articles 13 and 14 and the UAVG.

1. Data Controller

The data controller (verwerkingsverantwoordelijke) responsible for your personal data is:

Naturclearing.ddd
Czaar Peterstraat 22
1018 SM Amsterdam
Netherlands
Email: help@naturclearing.world
Phone: +31 20 221 7770

For all privacy-related enquiries, data subject requests, or complaints, please use the contact details above. We have not appointed a Data Protection Officer (DPO) as our processing activities do not meet the mandatory appointment thresholds under GDPR Article 37; privacy matters are handled directly by our team.

2. Personal Data We Collect

We may collect the following categories of personal data:

• Identity and contact data: name and email address submitted via our contact form.
• Communication data: message content, enquiry subject, and records of correspondence by email or phone.
• Technical data: IP address, browser type and version, device type, operating system, language settings, time zone, and referring URL collected automatically when you visit our website.
• Usage data: pages viewed, time spent on pages, and interaction data — only when you consent to analytics cookies.
• Cookie and consent data: your cookie preferences, consent timestamps, and identifiers stored via cookies or local storage, as described in our Cookie Policy.

We do not intentionally collect special categories of personal data (such as health data) through the Website. Please do not include sensitive information in contact form messages unless necessary.

3. Purposes, Legal Bases, and Legitimate Interests

We process your personal data only where a legal basis under GDPR Article 6 applies:

• Responding to enquiries (contact form, email, phone) — Legitimate interest (Art. 6(1)(f) UAVG/GDPR) in handling and responding to your request, and Consent (Art. 6(1)(a)) when you tick the GDPR checkbox on our contact form. Our legitimate interest is communicating with visitors who contact us; we balance this against your privacy rights and minimise data collected.
• Website functionality and security — Legitimate interest (Art. 6(1)(f)) in operating, maintaining, and protecting the Website against abuse, fraud, and technical failures.
• Analytics — Consent (Art. 6(1)(a)), only after you accept analytics cookies via our cookie banner, in compliance with the Telecommunicatiewet.
• Marketing and advertising — Consent (Art. 6(1)(a)), only after you accept marketing cookies. You may withdraw consent at any time without detriment.
• Legal compliance and defence of legal claims — Legal obligation (Art. 6(1)(c)) or Legitimate interest (Art. 6(1)(f)) where required by Dutch or EU law.

Providing contact data via the contact form is voluntary. Without it, we cannot respond to your enquiry. We do not use your data for automated decision-making or profiling within the meaning of GDPR Article 22.

4. Data Retention

We retain personal data only for as long as necessary for the purposes described, in line with the GDPR storage limitation principle (Article 5(1)(e)) and UAVG:

• Contact form submissions and correspondence: up to 24 months after the last communication, unless a longer period is required for legal claims or statutory obligations under Dutch law.
• Technical and server logs: up to 12 months for security and troubleshooting purposes.
• Cookie consent records: up to 12 months, or until you withdraw consent and records are no longer needed.
• Analytics data: up to 26 months (Google Analytics default), only while your consent remains valid.

When retention periods expire, data is securely deleted or irreversibly anonymised. Backups containing personal data are overwritten according to our hosting provider's schedule, generally within 90 days of deletion.

5. Advertising and Analytics Data

We may use your contact message to respond to your enquiry and to improve our free educational content. Where you consent to analytics or marketing cookies, Google Ads and Google Analytics may process usage data as described in our Cookie Policy. We do not use contact form data for remarketing without a separate legal basis.

6. Recipients, Processors, and Data Sharing

We do not sell or rent your personal data. We may share data with the following categories of recipients:

• Hosting and infrastructure providers — servers located within the EEA or protected by appropriate safeguards.
• Analytics providers (e.g. Google LLC) — only with your consent; subject to data processing agreements under GDPR Article 28.
• Marketing and advertising partners (e.g. Google Ads, Meta) — only with your consent.
• Professional advisers — lawyers or accountants, bound by confidentiality, where legally required.
• Public authorities — courts, regulators, or law enforcement when required by Dutch or EU law.

All processors act only on our documented instructions and are contractually bound by GDPR Article 28 data processing agreements. A list of key processors is available on request at help@naturclearing.world.

7. International Transfers

Your data is primarily processed within the European Economic Area (EEA). Where data is transferred to countries outside the EEA — including the United States (e.g. Google LLC, Meta Platforms) — we ensure appropriate safeguards as required by GDPR Chapter V and the UAVG, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission;
• transfers to countries benefiting from an European Commission adequacy decision;
• supplementary measures where required following Schrems II case law.

You may request a copy of applicable safeguards by contacting us at the email address above.

8. Your Rights Under the GDPR and UAVG

Under the GDPR and UAVG, you have the following rights as a data subject:

• Right of access (Art. 15) — obtain confirmation of processing and a copy of your personal data.
• Right to rectification (Art. 16) — correct inaccurate or incomplete data.
• Right to erasure ("right to be forgotten", Art. 17) — request deletion where legally applicable.
• Right to restriction of processing (Art. 18) — limit how we use your data in certain circumstances.
• Right to data portability (Art. 20) — receive data you provided in a structured, commonly used, machine-readable format, where processing is based on consent or contract and carried out by automated means.
• Right to object (Art. 21) — object to processing based on legitimate interests, including direct marketing at any time.
• Right to withdraw consent (Art. 7(3)) — withdraw consent at any time, without affecting the lawfulness of processing before withdrawal. Withdraw cookie consent via our cookie banner settings or by clearing site data.
• Right not to be subject to automated decision-making (Art. 22) — we do not use automated decision-making or profiling that produces legal or similarly significant effects.

To exercise any of these rights, contact us at help@naturclearing.world. We will respond within one month of receipt, as required by the AVG. This period may be extended by two further months for complex requests; we will inform you of any extension and the reasons within the first month. We may request proof of identity to protect your data. Exercising your rights is free of charge unless requests are manifestly unfounded or excessive.

9. Right to Lodge a Complaint

If you believe we have not handled your personal data in accordance with the GDPR or UAVG, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens):

Autoriteit Persoonsgegevens
Postbus 93374, 2509 AJ Den Haag, Netherlands
Phone: +31 70 388 85 00
Website: autoriteitpersoonsgegevens.nl

We encourage you to contact us first so we can try to resolve your concern directly.

10. Data Security and Breach Notification

We implement appropriate technical and organisational measures under GDPR Article 32 to protect personal data against unauthorised access, loss, destruction, or alteration. Measures include HTTPS/TLS encryption, access controls, secure hosting, and periodic review of our security practices.

In the event of a personal data breach likely to result in a risk to your rights and freedoms, we will notify the Autoriteit Persoonsgegevens within 72 hours where required under GDPR Article 33, and inform affected individuals without undue delay where required under Article 34.

11. Children's Privacy

Our website is not directed at children under 16 years of age, the minimum age of digital consent in the Netherlands under GDPR Article 8 as implemented by the UAVG. We do not knowingly collect personal data from children under 16. If you believe we have collected such data, please contact us immediately and we will delete it promptly.

12. Changes to This Policy

We may update this Privacy Policy to reflect changes in law, technology, or our practices. Material changes will be posted on this page with an updated "Last updated" date. Where required by law, we will seek renewed consent or provide additional notice. We encourage you to review this policy periodically.

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