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Privacy Policy

PrivacyPolicy

# Introduction Welcome to our platform. We are dedicated to providing you with the best possible service and experience. Our team works tirelessly to ensure that your needs are met with professionalism and care. ## Our Mission We strive to deliver innovative solutions that make a real difference in your daily life. Through continuous improvement and attention to detail, we aim to exceed your expectations at every turn. ## What We Offer Our comprehensive range of services is designed to support you in achieving your goals. Whether you're looking for expert guidance, reliable tools, or personalized support, we have everything you need to succeed. Thank you for choosing us as your trusted partner. We look forward to serving you and building a lasting relationship based on trust and mutual success.

This Privacy Policy explains how TriggerHive ('we', 'us', 'our') collects, uses and protects your personal data when you use our website or services. We are committed to protecting your privacy in accordance with the General Data Protection Regulation (GDPR) and other applicable privacy legislation. This policy was last updated on 28 January 2025.

Controller

TriggerHive is a sole proprietorship owned by Gijs van Hout, located at Julianastraat 92, 5427 AW Boekel, The Netherlands. Registered with the Chamber of Commerce under number 97815829. We act as data controller for personal data collected through our website and services.

# Role as Processor ## Processing Personal Data on Behalf of the Controller When we process personal data on your behalf as a processor, we do so strictly in accordance with your documented instructions and applicable data protection laws. ## Our Responsibilities as Processor - **Follow Instructions**: We only process personal data according to your written instructions - **Confidentiality**: We ensure that persons authorized to process personal data are bound by confidentiality - **Security Measures**: We implement appropriate technical and organizational measures to protect personal data - **Sub-processors**: We only engage sub-processors with your prior authorization - **Assistance**: We assist you in responding to data subject requests and meeting your compliance obligations - **Data Deletion**: We delete or return all personal data after the end of service provision, unless retention is required by law ## Data Processing Agreement Our relationship as processor is governed by a Data Processing Agreement (DPA) that includes: - The subject matter and duration of processing - The nature and purpose of processing - The types of personal data and categories of data subjects - Your rights and obligations as controller - Our obligations as processor ## Sub-processors When we engage sub-processors to carry out specific processing activities: - We inform you of any intended changes concerning the addition or replacement of sub-processors - You have the opportunity to object to such changes - We impose the same data protection obligations on sub-processors through a contract - We remain fully liable to you for the performance of sub-processor obligations ## Your Rights as Controller As controller, you retain the right to: - Issue instructions regarding data processing - Audit our compliance with data protection obligations - Terminate the processing relationship in case of non-compliance

When executing assignments for clients, TriggerHive may also act as a processor of personal data on behalf of the client. In that case, the client is the controller and TriggerHive processes data solely according to the client's instructions. For such processing activities, we enter into a separate Data Processing Agreement with the client, which sets out the specific arrangements regarding data processing, security and confidentiality.

Which Data We Collect

We may collect the following personal data: Name, Email address, Company name, Phone number, IP address and browser information, Information you provide in messages when you contact us, Billing details (address, VAT number), and Information necessary to deliver our services. We only collect this information when you voluntarily provide it to us, for example when you contact us through our website or use our services.

Legal Basis for Processing

We process your personal data on the basis of one or more of the following legal grounds: (a) Performance of a contract: to prepare quotations, deliver services and send invoices; (b) Legal obligation: to comply with tax retention obligations (7 years); (c) Legitimate interest: to secure our website, prevent fraud and improve our service delivery; (d) Consent: for sending newsletters or marketing communications (only with your explicit opt-in).

How We Use Your Data

We use your personal data for the following purposes: To prepare quotes and enter into agreements, To provide and improve our services, To respond to your questions and provide support, To send invoices and process payments, To send you information about our services (only with your explicit consent), To comply with legal obligations (such as tax retention requirements), To secure our website and prevent fraud. We will not use your data for purposes other than those for which it was collected, unless we have obtained your consent or are legally required to do so.

Retention Period

We only retain your personal data for as long as necessary to fulfill the purposes for which it was collected: Invoices and financial records: 7 years (statutory tax retention requirement). Customer communication and project documentation: duration of the agreement plus 2 years. Project files and source code: duration of the project plus the warranty period, unless otherwise agreed. Website inquiries that do not lead to a business relationship: maximum 2 years. Server log files: maximum 6 months.

Your Rights

Under the GDPR, you have the following rights regarding your personal data: Right of access to your data, Right to rectification of incorrect data, Right to erasure ('right to be forgotten'), Right to restriction of processing, Right to data portability, Right to object to processing, Right to withdraw consent at any time. To exercise these rights, you can contact us at gijs@triggerhive.com. We will respond to your request within 30 days. If you believe we are not processing your data correctly, you have the right to file a complaint with the Dutch Data Protection Authority (www.autoriteitpersoonsgegevens.nl).

Data Security

We implement appropriate technical and organizational measures to protect your personal data, including: Encryption of data during transport (TLS/SSL) and storage. Two-factor authentication (2FA) on all systems that access personal data. Regular backups with encryption. Strict access control based on 'need-to-know'. Encrypted storage media (disk encryption). Regular evaluation and updating of our security practices.

Subprocessors

We use the following external service providers (sub-processors) who may have access to personal data: Hosting provider: for hosting our website and applications. Email provider: for business communication. Accounting service: for invoicing and financial administration. Version control (GitHub/GitLab): for software development. Project management tools: for project communication with clients. All these parties are contractually obligated to protect personal data in accordance with the GDPR. We never sell your personal data to third parties.

International Transfer

Some of our subprocessors are located outside the European Economic Area (EEA), particularly in the United States. For these transfers, we ensure appropriate safeguards: Service providers certified under the EU-US Data Privacy Framework, or Standard Contractual Clauses (SCCs) approved by the European Commission. Upon request, we can inform you which safeguards apply to specific transfers.

AI tools

In software development, we may use AI-assisted tools (such as GitHub Copilot or similar services) to improve code quality and efficiency. We apply the following safeguards: We do not enter any personal data (names, email addresses, etc.) of end users or clients into these tools. Code snippets are anonymized before submission; no trade secrets, passwords, or API keys are shared. Where possible, we configure these tools to prevent submitted data from being used for model training.

# Project Information

When executing development assignments, we may have temporary access to the client's systems, databases or files. The following rules apply: We never use production data containing real personal data in test or development environments, unless strictly necessary and after written consent. Access to client systems is revoked immediately after project completion. Local copies of project files are deleted within 30 days after project completion, unless otherwise agreed or legally required. Specific agreements regarding data processing are recorded in the Data Processing Agreement.

Cookies

Our website uses functional cookies that are necessary for the operation of the website. Additionally, we use analytical cookies to collect anonymous statistics about website usage. We do not place tracking or marketing cookies. You can manage cookies through your browser settings; disabling functional cookies may affect the functioning of the website.

Third-Party Websites

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these external websites. We recommend reading the privacy policy of every website you visit.

Changes to the Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal or regulatory reasons. We will notify you of material changes by posting the new Privacy Policy on this page and updating the 'last updated' date.

Contact Information

If you have any questions about this Privacy Policy or our data practices, please contact us at: Email: gijs@triggerhive.com, Phone: +31 6 17218887, Address: Julianastraat 92, 5427 AW Boekel, The Netherlands.

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