Legal
Privacy Policy
Personal data processing · Argelis Consultancy · v1.1 — June 2026
This Privacy Policy explains how Argelis Consultancy (“we”, “us”) processes personal data. It is governed by Dutch data protection law (AVG) as the default regime.
Where a client is based in the United Kingdom, additional notes appear at the end of relevant clauses in clearly marked boxes. Those additional notes apply alongside the main clause, not instead of it.
If you have any questions about this policy or how we handle your personal data, contact us at info@argelis.nl.
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1. Who We Are
1.1 Argelis Consultancy is a sole trader (eenmanszaak) registered in the Netherlands under KvK number 42076894, BTW/VAT number NL005477044B40. For data protection purposes, we are the controller (verwerkingsverantwoordelijke) of the personal data described in this policy.
1.2 We are established in the Netherlands; the Dutch AVG / Uitvoeringswet AVG applies, and the Autoriteit Persoonsgegevens (AP) is our lead supervisory authority.
1.3 Contact us about privacy matters at info@argelis.nl.
UK clients — additional terms
1.UK.1 Where we process personal data of individuals in the UK in connection with services to UK clients, the UK GDPR and Data Protection Act 2018 also apply; the Information Commissioner’s Office (ICO) is the relevant authority for that processing.
1.UK.2 We rely on the current EU–UK adequacy arrangements to transfer personal data between the Netherlands/EU and the UK, and will adopt Standard Contractual Clauses or the UK’s International Data Transfer Addendum if that status changes.
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2. What Personal Data We Collect
2.1 This website has no contact form, newsletter sign-up, analytics, or tracking cookies.
2.2 We collect personal data directly from you when you contact us (for example via info@argelis.nl) or during the scoping, contracting and delivery of a consultancy engagement. This typically includes your name, work email address, phone number, job title, employer, and the content of our correspondence with you.
2.3 Our hosting provider may process basic technical data (such as IP address) through standard, security-related server logging only. This is not used to build a profile of you or shared for marketing purposes.
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3. Why We Process Your Data
3.1 We process your personal data for the following purposes, each with the corresponding legal basis under Article 6 AVG:
(a) Responding to your enquiry and corresponding with you — legitimate interest, or performance of a contract once one is being negotiated.
(b) Preparing, entering into and performing a Service Agreement with your organisation — performance of a contract.
(c) Issuing invoices and maintaining financial administration — legal obligation, given Dutch fiscal record-keeping requirements.
(d) Maintaining the security and proper functioning of our website and email systems — legitimate interest.
3.2 We do not use your personal data for automated decision-making or profiling, and we do not sell or rent personal data to third parties.
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4. Who We Share Your Data With
4.1 We use a small number of carefully selected service providers (“processors”) to support our email correspondence, document handling, financial administration, and AI-assisted drafting and analysis tools. We do not publish the identity of these processors here, but details are available on request — contact info@argelis.nl.
4.2 We only work with processors that offer a written data processing agreement (verwerkersovereenkomst) or equivalent standard processing terms meeting Article 28 AVG requirements, and we review this before engaging them.
4.3 We do not share your personal data with any other third party, except where required by law (for example, a lawful request from the Belastingdienst or another authority).
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5. International Data Transfers
5.1 Some of the processors we use may store or process data outside the Netherlands, including elsewhere in the EU/EEA. Where that happens, we have satisfied ourselves that an adequate level of protection applies before engaging them.
5.2 Where non-anonymised personal data is exceptionally transferred outside the EEA, we rely on Standard Contractual Clauses or another valid AVG transfer mechanism — never on an ad hoc basis.
5.3 As an additional safeguard, where we use any data processor located outside the EU/EEA, we anonymise personal data before it is processed by that provider, so that no personal data leaves the EU/EEA in an identifiable form.
UK clients — additional terms
5.UK.1 Personal data may move between the UK and the Netherlands/EU as part of delivering our services. While the relevant adequacy arrangements between the UK and the EU remain in place, no additional safeguards are required for these transfers. We will put alternative safeguards (such as the UK’s International Data Transfer Agreement or Addendum) in place if that adequacy status changes.
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6. How Long We Keep Your Data
6.1 Correspondence and contact details are kept for as long as necessary to manage our relationship with you, plus a reasonable period afterwards in case of follow-up engagements — typically not exceeding two years after our last contact, unless a longer period is required by law or a live matter requires us to keep it longer.
6.2 Invoices and related financial records are kept for seven years, as required by Dutch tax law (fiscale bewaarplicht, Article 52 AWR).
6.3 When data is no longer needed for these purposes, we delete or anonymise it.
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7. Cookies
7.1 Argelis.nl does not use analytics, advertising, or tracking cookies. We do not run Google Analytics, social media pixels, or comparable tools.
7.2 Our hosting platform and content management system may set strictly necessary technical cookies needed for the website to function (for example, security-related cookies). These do not require consent under the ePrivacy rules because they are strictly necessary, and they do not track you across other websites.
7.3 If this changes in future — for example, if we add analytics — we will update this policy and request consent where required.
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8. How We Safeguard Your Data
8.1 We take a deliberately minimal, controlled approach: we limit which processors handle personal data at all, select only providers with industry-standard encryption and access controls, and restrict access to personal data to ourselves — no one else has standing access to it.
8.2 We use strong authentication on every account where personal data is stored, keep this website’s software up to date, and periodically review whether the processors and data we hold are still necessary — data that is no longer needed is deleted.
8.3 No system is completely secure. If we become aware of a personal data breach that poses a risk to your rights and freedoms, we will notify the Autoriteit Persoonsgegevens within 72 hours where required, and inform affected individuals where the law requires it.
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9. Your Rights
9.1 Under the AVG, you have the right to: (a) request access to the personal data we hold about you; (b) request rectification of inaccurate data; (c) request erasure of your data, where applicable; (d) request restriction of processing; (e) object to processing based on our legitimate interest; (f) request data portability, where applicable; and (g) withdraw consent at any time, where processing is based on consent.
9.2 To exercise any of these rights, contact us at info@argelis.nl. We will respond within one month, as required by the AVG.
UK clients — additional terms
9.UK.1 If you are based in the UK, you have equivalent rights under the UK GDPR, which you can exercise in the same way, by contacting info@argelis.nl.
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10. Complaints
10.1 If you are unhappy with how we have handled your personal data, please contact us first at info@argelis.nl so we can try to resolve it.
10.2 You also have the right to lodge a complaint with the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl), the Dutch supervisory authority for data protection.
UK clients — additional terms
10.UK.1 UK-based individuals may also lodge a complaint with the Information Commissioner’s Office (ico.org.uk).
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11. Changes to This Policy
11.1 We may update this Privacy Policy from time to time, for example to reflect changes in our processing activities or in the law. The version number and date at the top of this page indicate the latest revision. Material changes will be highlighted on this page.
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12. Contact Us
12.1 Argelis Consultancy, KvK 42076894, BTW NL005477044B40, the Netherlands.
12.2 For any privacy-related question, please email info@argelis.nl.
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