1. Controller & Contact Details
Controller: IntraConnection Lab BV
Registered address: Stationsplein 32, 3511 ED Utrecht, The Netherlands
Privacy contact / DPO contact: legal@intraconnection.group
2. Scope of this Policy
This Policy applies to our website (the “Website”) and to our newsletter and waiting-list sign-ups available on the Website. It addresses processing of personal data of individuals in the European Union (EU) and the United Kingdom (UK). This is a combined policy covering GDPR and (where relevant) UK GDPR requirements.
3. Categories of Personal Data We Process
We collect and process the following categories of personal data when you interact with the Website:
- Newsletter sign-up: name, email address, country.
- Waiting-list sign-up (mobile app): name, email address.
- Contact forms / enquiries: name, email address, and the content of your message.
- Website logs and telemetry (standard): IP address, date/time, URLs visited, referrer, user agent, device/OS/browser information; basic error/event logs.
- Email interaction data (standard): whether you open our emails and click links (open/click tracking).
- Cookies and similar technologies: strictly necessary cookies; non-essential cookies (analytics and marketing) only with your consent (see Section 8).
- Special categories of data: We do not intentionally collect special categories of personal data.
- Children’s data: The Website and our services are not intended for children (see Section 13).
4. Sources of Personal Data
- Directly from you: when you submit forms (newsletter, waiting list, contact).
- Automatically: via your browser/device as you access the Website (see Section 8 on cookies and similar technologies).
5. Purposes and Legal Bases
We process personal data for the purposes and on the legal bases set out below:
Legal basis: Consent (Art. 6(1)(a) GDPR / UK GDPR)
Legal basis: Consent (Art. 6(1)(a))
Legal basis: Legitimate interests (Art. 6(1)(f)): efficiently handling inbound enquiries about our services
Legal basis: Legitimate interests (Art. 6(1)(f)): ensuring the security and integrity of the Website
Legal basis: Consent (Art. 6(1)(a))
Legitimate interest assessment (LIA): We rely on narrowly tailored interests such as (i) operating, securing, and debugging the Website, and (ii) responding to inbound requests. We consider the nature of data (primarily technical identifiers), implement proportionate safeguards, and provide an easy right to object (Section 11).
Marketing rules: For newsletters and other electronic direct marketing, we obtain explicit opt-in consent. You can withdraw consent at any time (Section 11).
6. No Contractual Necessity
We do not rely on contract as a legal basis for the Website activities described here.
7. Disclosures to Processors and Other Recipients
We use service providers acting as processors to help deliver the Website and communications. At the time of this Policy, we use EEA-based providers only and do not transfer personal data outside the EEA/UK.
Processor categories (examples; specific vendor names to be completed as applicable):
- Email service provider (ESP) for newsletter/waiting-list communications and consent records.
- Hosting / CDN for serving the Website and storing server logs.
- Analytics provider (if enabled) for aggregated site metrics.
- Error logging / observability (if enabled) for stability and debugging.
For each processor, we will have a written data processing agreement in place. We do not sell your personal data. There is no intra-group sharing. We do not provide third-party links requiring separate privacy warnings in this Policy.
9. International Data Transfers
We do not transfer personal data outside the EEA/UK. If this changes, we will implement an appropriate transfer mechanism (e.g., EU SCCs and UK Addendum) and update this Policy.
10. Data Retention
We retain personal data only for as long as necessary for the purposes set out below, after which data are deleted or irreversibly anonymized. Suppression lists are maintained as required to respect withdrawals.
11. Your Rights
Subject to conditions and exemptions under GDPR/UK GDPR, you have the right to:
- Access your personal data;
- Rectify inaccurate or incomplete data;
- Erase your data (“right to be forgotten”);
- Restrict processing;
- Data portability (for data you provided to us on the basis of consent);
- Object to processing based on legitimate interests; and
- Withdraw consent at any time (without affecting lawfulness of processing before withdrawal).
How to exercise your rights: Email legal@intraconnection.group. We may request reasonable information to verify your identity and your request. We respond within one month of receipt; we may extend by up to two additional months for complex or numerous requests (we will notify you if we need more time). You also have the right to lodge a complaint with a supervisory authority (see Section 12).
Marketing opt-out: Every marketing email includes an unsubscribe link. You may also contact us at the above address.
13. Children’s Privacy
The Website and our services are not intended for children. We do not knowingly collect personal data from:
- Children under 16 in the Netherlands/EU Member States applying 16 as the consent age; and
- Children under 13 in the UK.
If you believe a child has provided us personal data, please contact legal@intraconnection.group and we will take appropriate steps to delete such data.
14. Data Security
We implement appropriate technical and organizational measures proportionate to risks, and we assess vendors accordingly.
16. Changes to this Policy
We may update this Policy from time to time. The “Last updated” date at the top indicates the effective date of the current version. If we make material changes, we will take appropriate steps to inform you (for example, by a notice on the Website). Please review this Policy periodically.
17. How to Contact Us
Questions or requests about this Policy or your personal data may be sent to:
Email: legal@intraconnection.group
Postal: IntraConnection Lab BV, Stationsplein 32, 3511 ED Utrecht, The Netherlands