Privacy Statement

1.Who Are We? (Identity & Contact Details)

SamenGro Consulting is the data controller responsible for processing your personal data. Below are our full contact details as required under Article 13 of the AVG/GDPR:

Company Name	SamenGro Consulting
KVK Number	99628333
VAT Number (BTW-id)	NL005399611B89
Email	info@samengro.com
Website	www.samengro.com
Country of Establishment	The Netherlands

2. What Personal Data Do We Collect?

We collect and process the following categories of personal data, depending on how you interact with our website and services:

Data you provide directly
• Name and job title
• Business email address and phone number
• Company name and industry
• Information shared in contact forms, quote requests, or meeting bookings
• Any other details you voluntarily provide in written communications
Data collected automatically
• IP address and browser type
• Pages visited and time spent on our website
• Referral source (how you found our website)
• Cookie identifiers (see our separate Cookie Policy)

We do not collect special categories of personal data (such as health data, political views, or biometric data).

3. Why Do We Process Your Data? (Purpose & Legal Basis)

We process your personal data only for specific, legitimate purposes and always with a valid legal basis under Article 6 of the AVG/GDPR:

Purpose	Legal Basis	Examples
Responding to enquiries and quote requests	Legitimate interest / Pre-contractual steps (Art. 6.1b)	Contact form submissions, email responses
Delivering our consulting services	Contract performance (Art. 6.1b)	Project work, reports, integrations
Sending service-related communications	Legitimate interest (Art. 6.1f)	Project updates, invoices
Website analytics and improvement	Consent (Art. 6.1a)	Cookie-based analytics
Legal and financial record-keeping	Legal obligation (Art. 6.1c)	Invoices, tax records (AVG / Belastingdienst)

4. How Long Do We Keep Your Data? (Retention Periods)

We retain personal data no longer than necessary for the purposes for which it was collected, in compliance with Dutch law:

Client and project data: 7 years after the end of the contract (required by Dutch tax law — Belastingdienst)
Contact and enquiry data (non-clients): 12 months from the date of last contact
Website analytics data: As defined in our Cookie Policy (typically 13 months)
Financial records and invoices: 7 years (Wet bewaarplicht administratie)

After the retention period expires, your data will be securely deleted or anonymised.

5. Who Do We Share Your Data With?

We do not sell, rent, or trade your personal data. We may share data with trusted third-party processors only where strictly necessary:

Hosting and website infrastructure providers
Email and communication platforms
Accounting and invoicing software
Calendar and meeting scheduling tools (e.g., for booking consultations)

All third-party processors are contractually bound via a Data Processing Agreement (Verwerkersovereenkomst) to process data only on our instructions and in accordance with the AVG.

We do not transfer personal data outside the European Economic Area (EEA) unless adequate safeguards are in place (e.g., Standard Contractual Clauses).

6. Your Rights Under the AVG/GDPR

As a data subject, you have the following rights under Chapter III of the AVG. You can exercise these rights free of charge by contacting us at info@samengro.com:

Your Right	What This Means
Right of Access (Art. 15)	You may request a copy of all personal data we hold about you.
Right to Rectification (Art. 16)	You may request correction of inaccurate or incomplete data.
Right to Erasure (Art. 17)	You may request deletion of your data, subject to legal retention requirements.
Right to Restriction (Art. 18)	You may request we limit processing of your data in certain circumstances.
Right to Portability (Art. 20)	You may request your data in a machine-readable format.
Right to Object (Art. 21)	You may object to processing based on legitimate interests.
Right to Withdraw Consent	Where processing is based on consent, you may withdraw at any time without affecting prior processing.

We will respond to your request within 30 days. If we need to extend this period, we will notify you in advance.

7. Right to Lodge a Complaint with the AP

If you believe we are not handling your personal data correctly, you have the right to lodge a complaint with the Dutch Data Protection Authority:

Authority	Autoriteit Persoonsgegevens (AP)
Website	www.autoriteitpersoonsgegevens.nl
Phone	+31 (0)70 888 85 00
Address	Hoge Nieuwstraat 8, 2514 EL Den Haag

We would, however, appreciate the opportunity to address your concern directly before you contact the AP. Please reach out to us first at info@samengro.com.

8. How Do We Protect Your Data?

We take appropriate technical and organisational security measures to protect your personal data against unauthorised access, loss, or misuse. These include:

Encrypted connections (HTTPS/SSL) on our website
Access controls limiting who can view personal data
Regular review of data processing activities
Use of reputable, AVG-compliant service providers

9. Cookies

Our website uses cookies. For detailed information on which cookies we use, their purpose, and how to manage or withdraw your consent, please refer to our Cookie Policy, available at www.samengro.com/cookie-policy/.

10. Changes to This Privacy Statement

We may update this Privacy Statement periodically to reflect changes in our practices or legal requirements. The ‘Last Updated’ date at the top of this document will reflect any revisions. We recommend reviewing this page regularly.