Privacy Policy

Last updated: | Flushexpel | Korte Poolsterstraat 2, 3067 LV Rotterdam, Netherlands

Flushexpel ("we", "us", "our") is committed to protecting the personal data of all individuals who interact with our website and services. This Privacy Policy explains what data we collect, why we collect it, how we use it, and what rights you have regarding your data under the General Data Protection Regulation (GDPR) and applicable Dutch law.

1. Who We Are

The data controller responsible for your personal data is Flushexpel, registered with the Dutch Chamber of Commerce (KVK) under number 85247391, VAT number NL863247159B01, and operating from Korte Poolsterstraat 2, 3067 LV Rotterdam, Netherlands. You can contact us by telephone at +31 10 420 5066, by email at service@flushexpel.world, or by post at the address above.

2. What Personal Data We Collect

We collect personal data in the following circumstances:

• Contact form submissions: When you complete the contact form on our website, we collect your full name, email address, and the content of your message.
• Program enquiries: When you enquire about or enrol in a movement program, we may collect your name, email address, telephone number, and relevant information about your working environment and physical needs.
• Technical data: When you visit our website, we automatically collect technical information including your IP address, browser type, device type, pages visited, and approximate geographic location. This data is collected via server logs and, if you consent, via cookies.
• Communications: If you contact us by email or telephone, we retain a record of that communication.

3. Legal Basis for Processing

We process your personal data on the following legal bases as defined in Article 6 of the GDPR:

• Legitimate interests (Article 6(1)(f)): We process technical data and enquiry data to operate and improve our website and services.
• Consent (Article 6(1)(a)): Where you have checked the consent box on our contact form or accepted cookies, we process data on the basis of your freely given consent.
• Contract performance (Article 6(1)(b)): When you enrol in a program, processing is necessary for the performance of the agreement between you and us.
• Legal obligation (Article 6(1)(c)): We retain certain data where required by Dutch tax law and commercial record-keeping obligations.

4. How We Use Your Data

We use personal data for the following purposes:

• Responding to enquiries and messages sent via the contact form
• Delivering movement programs and associated specialist support
• Sending service-related communications directly related to your program
• Improving the content, functionality, and user experience of our website
• Complying with legal and regulatory obligations
• Analysing anonymised usage data to understand which content is most valuable to visitors

We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects.

5. Data Sharing and Third Parties

We do not sell, rent, or trade your personal data to third parties. We may share your data with carefully selected third-party service providers who assist us in operating our website and delivering our services, including:

• Web hosting and server infrastructure providers operating within the European Economic Area (EEA)
• Email delivery services used to respond to contact form submissions
• Analytics providers, subject to your cookie consent

All third parties with whom we share data are required to handle it in accordance with GDPR and under appropriate data processing agreements.

We may disclose your data where required by law, court order, or at the request of competent Dutch or European Union authorities.

6. International Data Transfers

Where data is processed outside the EEA, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission, to maintain an equivalent level of data protection.

7. Data Retention

We retain personal data only for as long as necessary for the purpose for which it was collected:

• Contact form data: retained for 24 months from the date of submission, unless a longer period is necessary to resolve an ongoing matter
• Program participant data: retained for the duration of the active program relationship and for seven years thereafter for legal and accounting purposes
• Technical log data: typically retained for 12 months
• Cookie data: as specified in our Cookie Policy

8. Your Rights Under GDPR

As a data subject under the GDPR, you have the following rights:

• Right of access (Article 15): You may request a copy of the personal data we hold about you.
• Right to rectification (Article 16): You may request that inaccurate or incomplete data be corrected.
• Right to erasure (Article 17): You may request that we delete your data where there is no legitimate reason for us to continue processing it.
• Right to restriction of processing (Article 18): You may request that we limit how we use your data in certain circumstances.
• Right to data portability (Article 20): You may request your data in a structured, machine-readable format where processing is based on consent or contract.
• Right to object (Article 21): You may object to processing based on legitimate interests or for direct marketing purposes.
• Right to withdraw consent (Article 7(3)): Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at the address or telephone number listed at the top of this policy. We will respond within 30 days. If you are dissatisfied with our response, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at autoriteitpersoonsgegevens.nl.

9. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or alteration. Our website is served over HTTPS to protect data in transit. Access to stored personal data is restricted to authorised personnel only.

While we take data security seriously, no system is entirely immune to risk. If you have reason to believe there has been a data breach affecting your information, please contact us immediately.

10. Cookies

Our website uses cookies to enhance functionality and understand how visitors use our content. For full details on the types of cookies we use, their purposes, and how to manage your preferences, please refer to our Cookie Policy.

11. Children's Privacy

Our website and services are intended for adults aged 18 and over. We do not knowingly collect personal data from individuals under the age of 18. If you believe we have inadvertently collected data from a minor, please contact us so we can delete it promptly.

12. Links to Other Websites

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those websites and encourage you to review their respective privacy policies before submitting any personal data.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data processing practices or applicable law. The most recent version will always be available on this page with the date of the latest revision shown at the top. We encourage you to review this policy periodically.

14. Contact Us

For any questions or requests relating to this Privacy Policy or your personal data, please contact us:

• Post: Flushexpel, Korte Poolsterstraat 2, 3067 LV Rotterdam, Netherlands
• Telephone: +31 10 420 5066
• Email: service@flushexpel.world
• KVK: 85247391 | BTW: NL863247159B01