Privacy Policy

This Privacy Policy explains how Sivers Kittelson ("I", "me", "my") collects, uses, stores, and protects personal data submitted through this website (siverskittelson.com) and its contact form. This policy complies fully with the General Data Protection Regulation (GDPR – EU 2016/679) and applicable Dutch data protection legislation. 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:

Sivers Kittelson
Luchthavenweg 81, 5657 EA Eindhoven, Netherlands
Email: hello@siverskittelson.com
Phone: +31 40 123 4567

2. Categories of Personal Data Collected

Data you submit 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 — provided only if you choose to include it)
• The subject or topic of your enquiry
• The content of your message
• Consent record: the date, time, and your IP address at the moment you activated the GDPR consent checkbox

Technical data collected automatically

Standard web hosting infrastructure generates server log data including IP addresses, browser type, operating system version, referring URL, pages accessed, and timestamps. This technical data is retained for security and diagnostic purposes only and is not combined with personal identity data for any commercial or profiling use.

3. Legal Bases for Processing

Personal data is processed exclusively 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 on the contact form, you provide explicit consent for your submission data to be processed for the purpose of responding to your enquiry. This consent may be withdrawn at any time without consequence to prior lawful processing.
• Contract performance (Art. 6(1)(b)): Where you engage a paid service, personal data is processed as necessary to deliver and administer that service arrangement.
• Legitimate interests (Art. 6(1)(f)): Basic website security measures and server log maintenance are conducted on the basis of legitimate interests that do not override your fundamental privacy rights and freedoms.

4. How Personal Data Is Used

Your personal data is used only for the following stated purposes:

• To respond to your enquiry and provide the information or service requested
• To schedule and deliver personal Focused Dialogue sessions or Ongoing Practice arrangements
• To fulfil purchases of digital products such as the Practice Field Guide
• To maintain active correspondence related to a service engagement
• To meet accounting, tax, and legal record-keeping obligations under Dutch law

Personal data is not used for automated profiling, unsolicited marketing communications, or any commercial purpose beyond the direct delivery of the service you have requested. I do not sell, rent, license, or otherwise transfer your personal data to any third party for commercial benefit.

5. Retention Periods

Data is retained only for the minimum period genuinely necessary:

• Contact form data with no resulting service engagement: deleted within 12 months of last communication.
• Client service records: retained for 7 years from the end of the service in accordance with Dutch fiscal law (Belastingwet), after which they are permanently deleted.
• Consent records: retained alongside associated personal data for the same duration to demonstrate legal compliance.
• Server log data: automatically overwritten after 90 days maximum.

6. Cookies and Third-Party Technologies

This website does not deploy analytics platforms, advertising networks, social media tracking pixels, or behavioural profiling tools. No commercial or tracking cookies are set by this site.

The following third-party technologies are embedded for functional purposes only:

• Google Maps (Google LLC): A location map is embedded on the main page. Viewing or interacting with this map may cause Google to set cookies and process your IP address under Google's own privacy policy.
• Google Fonts (Google LLC): Typography is loaded from Google's CDN. Google may log your IP address as part of the font delivery process.
• Font Awesome (Fonticons, Inc. via Cloudflare CDN): Icon assets are delivered via Cloudflare's CDN, which may log access requests.

I have no access to or control over data collected independently by these third-party services. Please consult their respective privacy policies for complete information.

7. Data Sharing

Your personal data is not shared with third parties except in these strictly limited circumstances:

• Data processors: I may use contracted third-party tools for email management, scheduling, or digital product delivery. All such processors are bound by written data processing agreements and may only act on my documented instructions.
• Legal obligations: Data may be disclosed to competent public authorities when required by applicable Dutch or EU law, binding court order, or formal regulatory mandate.
• Business succession: In the event of a business transfer or restructuring, personal data may pass to a successor entity under equivalent privacy protections.

8. International Data Transfers

Where any service or tool I use involves transferring personal data outside the European Economic Area (EEA), I ensure that appropriate safeguards are in place as required by GDPR Chapter V, including Standard Contractual Clauses (SCCs) approved by the European Commission or another recognised lawful transfer mechanism.

9. Your GDPR Rights

You have the following rights in relation to your personal data under the GDPR:

• Right of access (Art. 15): Request a copy of the personal data I hold about you.
• Right to rectification (Art. 16): Request correction of any inaccurate or incomplete data.
• Right to erasure (Art. 17): Request deletion of your data, subject to any legal retention obligations.
• Right to restriction (Art. 18): Request that processing of your data be limited in specific circumstances.
• Right to portability (Art. 20): Receive your data in a structured, machine-readable format for transfer to another controller.
• Right to object (Art. 21): Object to processing based on legitimate interests.
• Right to withdraw consent (Art. 7(3)): Withdraw consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact me at hello@siverskittelson.com. I will respond within 30 calendar days. In complex cases, this may be extended by a further two months with advance notification.

10. Supervisory Authority

If you believe your personal data has been processed in violation of the GDPR, you may lodge a complaint with the Dutch data protection supervisory authority:

Autoriteit Persoonsgegevens (AP)
Bezuidenhoutseweg 30, 2594 AV Den Haag
Website: autoriteitpersoonsgegevens.nl

11. Security

I implement appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, disclosure, alteration, or destruction. Measures include encrypted data transmission (HTTPS/TLS), restricted access controls, and periodic review of data handling practices. No online transmission can be unconditionally guaranteed against all risks, but I take these responsibilities seriously and maintain continuous vigilance.

12. Children

This website is not directed at individuals under 16 years of age. I do not knowingly collect personal data from children under 16. If you believe a child has submitted data through this website, please contact me immediately at hello@siverskittelson.com and I will delete such data without delay.

13. Policy Revisions

This Privacy Policy may be updated periodically to reflect changes in the law or in my data processing practices. The current version is always published at this URL, with the "last updated" date reflecting any revision. Material changes will be accompanied by a visible notice on the website.

14. Contact

Sivers Kittelson
Luchthavenweg 81, 5657 EA Eindhoven, Netherlands
Email: hello@siverskittelson.com
Phone: +31 40 123 4567
Office hours: Mon–Fri 9:00–18:00, Sat 10:00–13:00