This statement explains which personal data Swasch Agency processes, why we do so, who we share it with and what your rights are.
1.Who we are
Swasch Agency is a sole proprietorship (eenmanszaak) owned by Bas Lefeber and is responsible for the processing of personal data described in this statement (controller under the GDPR).
- Swasch Agency, sole proprietorship of Bas Lefeber
- Talmastraat 43, 2104 AB Heemstede, the Netherlands
- Chamber of Commerce (KvK) number: 66659809
- VAT ID: NL002392610B98
- Email: hello@swasch-agency.com
For any question about privacy or this statement, email hello@swasch-agency.com.
2.What data we process
Contact form. When you fill in the contact form, we receive your name, email address, company name, website, what you need help with, budget, monthly revenue, when you want to start and your message. Some of these fields are optional. We also store the language of the page and which page you sent the form from.
Email correspondence. When you email us or we email you, we process your name, email address, the content of the messages and anything you share in them yourself, such as your job title or phone number.
Clients. When you become a client, we process the contact and billing details of your contact persons and the data needed for the assignment and our records.
Business contact details for outreach. We sometimes contact companies for whom our work may be relevant. For this we use business contact details from public sources, such as the company website: name, job title, business email address and company name.
Website visits. On every visit to this site, our hosting provider Vercel processes technical data such as your IP address, browser, the time and the page requested (server logs). This is needed to run and secure the site.
Visitor identification via Apollo.io, only with consent. If you choose Accept in the cookie banner, we load the Apollo.io website tracker. It records which pages you view and tries to identify the company you work for based on your IP address. This shows us which companies are interested in our work. If you choose Essential only, the tracker is not loaded.
3.Why we use data and on what legal basis
- Answering your enquiry and preparing a proposal. Legal basis: steps taken at your request before entering into a contract (Art. 6(1)(b) GDPR) and our legitimate interest in answering business enquiries (Art. 6(1)(f) GDPR).
- Carrying out and invoicing an assignment. Legal basis: performance of the contract (Art. 6(1)(b)) and our legal obligation to keep business records (Art. 6(1)(c)).
- Business outreach. We send companies a limited number of personal messages about our work. Legal basis: our legitimate interest in bringing our services to the attention of companies for whom they are relevant (Art. 6(1)(f)). In every message you can tell us you do not want to hear from us again. We will then not contact you again.
- Running and securing the website (server logs). Legal basis: our legitimate interest in a secure, working site (Art. 6(1)(f)).
- Visitor identification via Apollo.io. Legal basis: your consent (Art. 6(1)(a)). You can withdraw it at any time via Cookie settings at the bottom of every page.
Where we rely on legitimate interest, we have weighed it against your privacy. We only use business data and keep contact limited.
4.Who we share data with
We do not sell your data. We only share it with service providers we need to run the site and our work, and only as far as necessary:
- Vercel: website hosting and server logs.
- Resend: sending the contact form emails, including the confirmation you receive.
- Hostinger: our mailbox, where email and form messages arrive.
- Apollo.io: visitor identification on the website, only with your consent.
We also provide data to authorities such as the Dutch Tax Administration when the law requires us to.
5.Transfers outside the European Economic Area
Vercel, Resend and Apollo.io are based in the United States, so your data may be processed outside the EEA. This only happens with appropriate safeguards, such as certification under the EU-US Data Privacy Framework or the European Commission's standard contractual clauses.
To find out which safeguard applies to a service, email hello@swasch-agency.com.
6.How long we keep data
- Enquiries and correspondence that do not lead to an assignment: at most 2 years after the last contact.
- Client records, such as quotes, invoices and related correspondence: 7 years, because of the Dutch statutory retention obligation for tax purposes.
- Contact details for outreach: at most 2 years after the last contact, or shorter if you object earlier. After an objection we only keep your email address on an internal suppression list, so we do not contact you again.
- Visitor identification data (Apollo.io): at most 2 years.
- Server logs: briefly, in line with Vercel's retention periods.
- Your cookie choice: 12 months.
7.Your rights
You have the right to:
- access your data;
- have incorrect data corrected;
- have your data erased;
- have processing restricted;
- object to processing based on legitimate interest, including outreach. We always honour an objection to outreach;
- receive your data in a common file format or have it transferred;
- withdraw your consent. This does not affect processing that already took place based on your consent.
Send your request to hello@swasch-agency.com. We respond within one month. To make sure a request comes from you, we may ask you to confirm your identity.
8.Complaints
You have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at autoriteitpersoonsgegevens.nl. We would also like to hear from you directly, so we can sort it out together.
9.Automated decision-making
We do not make decisions based solely on automated processing that produce legal effects for you or similarly significantly affect you.
10.Security
We protect your data with appropriate technical and organisational measures, such as encrypted connections (HTTPS) and access to data only for those who need it.
12.Changes
We update this statement when the way we work changes. The date at the top shows when that last happened.