PRIVACY

Last updated: September 2026

CONTROLLER

Gefferie Group B.V., IJsbaanpad 2, Amsterdam, the Netherlands.

Chamber of Commerce (KvK) 80008739.

Contact: Use the contact form

WHAT WE COLLECT

We collect the information you provide through our contact form and technical data necessary to operate this site securely.

Analytics: We do not currently use analytics cookies on this site.

Third-party content: Links to Substack (dwaynegefferie.substack.com) are governed by Substack’s privacy policy.

WHY WE COLLECT IT

• To respond to strategy enquiries and take pre-contractual steps
• To maintain site security and prevent abuse
• For aggregate analytics purposes (if analytics are enabled in future)

WHAT WE DO NOT DO

• We do not sell personal data
• We do not make automated decisions with legal effect
• We do not process cardholder data on this site
• We do not operate consumer checkout or payment processing

SHARING

We share personal data only in the following circumstances:

• With our hosting provider (Vercel) under data processing agreement
• With our contact form service provider (if applicable) under data processing agreement
• With professional advisers under confidentiality obligations
• With authorities where required by law

RETENTION

Enquiry data: We retain contact form submissions for 24 months after last contact, unless a contractual relationship requires longer retention.

Server logs: Technical logs are retained for 90 days.

YOUR RIGHTS

Under GDPR and UK GDPR, you have the right to:

• Access your personal data
• Correction of inaccurate data
• Erasure of your data
• Restriction of processing
• Data portability
• Object to processing

To exercise these rights, contact us via our contact form.

You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or the UK Information Commissioner’s Office.