Privacy Policy

01

1. Controller

Fresh Kiwi B.V., Dorpsweg 82, 1697 KD Schellinkhout, Nederland, is the controller for the personal data described in this policy. Chamber of Commerce 73320250. VAT NL859459032B01. Privacy questions can be sent to info@freshkiwi.nl or raised by phone at +31 6 42710575.

02

2. Personal data we process

• Contact details such as name, business email address, telephone number, job title and organisation.
• Information you provide through the contact form, email, phone calls, meetings, workshops or other communications.
• Quotation, contract, project, invoicing and payment information for customers and suppliers.
• Business information required to deliver an engagement, including process information, project documentation and contact details of involved employees.
• Technical information that may be generated when using the website, such as IP address, date and time, browser information and security or server logs.
• Your cookie or storage preference where this is stored locally in your browser.

03

3. Purposes

• Responding to enquiries and assessing potential engagements.
• Preparing proposals, performing contracts, delivering projects and managing customer relationships.
• Invoicing, payments and statutory administration.
• Securing the website and systems, preventing abuse and troubleshooting.
• Improving our services and appropriately following up business relationships.
• Meeting legal obligations and protecting our rights and those of others.

04

4. Legal bases

Depending on the situation, we process personal data because it is necessary to enter into or perform a contract, comply with a legal obligation, pursue a legitimate interest such as security or business relationship management, or because you have given consent where consent is legally required. Consent can be withdrawn for future processing at any time.

05

5. Contact form and CRM

When you use the contact form, the information you submit is forwarded to the CRM or workflow environment used by Fresh Kiwi so that we can follow up your request. Please do not submit sensitive personal data that is not necessary for your enquiry.

06

6. AI services and customer data

During customer engagements, Fresh Kiwi may process data on a customer’s behalf in AI, automation or integration solutions. Roles, safeguards, retention, subprocessors and any international transfers are documented where required in the contract, data processing agreement or project documentation. Fresh Kiwi does not use customer data for its own model training unless this has been expressly agreed in writing.

07

7. Recipients

We share personal data only where necessary for our operations, services or legal obligations. Recipients may include hosting and IT providers, email and CRM providers, accounting or professional advisers, and specialist delivery partners needed for an engagement. We use appropriate processor arrangements where required and restrict access to what is necessary.

08

8. Transfers outside the EEA

If a supplier processes personal data outside the European Economic Area, we assess whether there is a valid transfer mechanism, such as an adequacy decision or appropriate contractual safeguards including the European Commission Standard Contractual Clauses.

09

9. Retention

• Enquiries and commercial correspondence: generally no longer than 2 years after the last relevant contact, unless a longer period is needed for an ongoing relationship or legal interest.
• Project and contract documentation: for as long as needed for delivery, aftercare and the establishment or defence of legal claims.
• Financial and tax records: at least 7 years where the Dutch statutory tax retention period applies.
• Technical and security logs: no longer than necessary for security, troubleshooting and abuse prevention.
• Information subject to another legal retention period: for that statutory period.

10

10. Security

We take appropriate technical and organisational measures to protect personal data against loss, unauthorised access, alteration or disclosure. The measures applied depend on the nature, scale and sensitivity of the processing.

11

11. Your rights

• Access to your personal data.
• Correction of inaccurate data.
• Erasure where there is no valid reason to retain the data.
• Restriction of processing.
• Data portability where legally applicable.
• Objection to processing based on legitimate interests.
• Withdrawal of consent where processing is based on consent.

12

12. Requests and complaints

Send privacy requests to info@freshkiwi.nl. We may request additional information to verify your identity. You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

13

13. Changes

We may update this policy when our services, systems or legal obligations change. The current version is always published on this website with the date of the latest update.