Privacy Policy
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Effective Date: December 24, 2025
Version: 1.0
Data Controller: SILARA B.V. (or applicable legal entity)
Chamber of Commerce (KVK) No: [Insert Number]
Location: [City], The Netherlands
SILARA ("we", "us", "our") processes personal data in strict compliance with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and the Dutch Implementation Act (Uitvoeringswet AVG).
This Policy describes how we process, store, and protect your data.
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1. Data We Collect & Sources
We collect data through direct interaction and automated technologies.
A. Data You Provide
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Identity Data: Name, username, date of birth.
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Contact Data: Email address, telephone number, billing/delivery address.
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Financial Data: Payment card details (processed directly by our PCI-DSS compliant payment providers; we do not store full card numbers).
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Correspondence: Records of communications with our support team.
B. Data Collected Automatically
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Technical Data: IP address, browser type/version, time zone setting, operating system.
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Usage Data: Clickstreams, page response times, download errors, and page interaction methods.
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Cookies: See Section 6 for details on Tracking Technologies.
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2. Legal Basis for Processing
We process your data only when we have a specific legal ground to do so, as defined in GDPR Article 6:
Purpose of ProcessingType of DataLegal Basis
User Registration & Service DeliveryIdentity, ContactContractual Necessity: We cannot provide the service without this.
Processing PaymentsFinancial, IdentityContractual Necessity
Fraud Prevention & SecurityTechnical, Identity, UsageLegitimate Interest: To protect our platform and users from misuse.
Marketing CommunicationsContact, IdentityConsent: (If you opted in) OR Legitimate Interest: (For existing customers, subject to opt-out).
Analytics & OptimizationTechnical, UsageConsent: (Via Cookie Banner)
Legal Compliance (Tax/Gov)Transaction DataLegal Obligation: (e.g., Dutch tax retention laws).
3. Data Sharing & Third Parties
We do not sell your data. We share data only with the following categories of Data Processors who act on our behalf under strict Data Processing Agreements (DPAs):
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Payment Gateways: (e.g., Stripe, Adyen, PayPal).
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Hosting Services: (e.g., AWS, Azure, DigitalOcean).
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Analytics Providers: (e.g., Google Analytics).
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Email/CRM Services: (e.g., Mailchimp, HubSpot).
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Legal/Regulatory Authorities: Only if required by a court order or binding Dutch law.
A full list of our current sub-processors is available upon request at privacy@silara.com.
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4. International Data Transfers
SILARA is based in the Netherlands (EEA). Some of our third-party service providers (e.g., Google, Stripe) may process data in the United States or other non-EEA countries.
To ensure your data remains protected, we rely on:
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Adequacy Decisions: Transfers to countries deemed "safe" by the European Commission.
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Standard Contractual Clauses (SCCs): Where no adequacy decision exists, we implement the EU Commission’s SCCs with our providers to legally protect your data transfer.
5. Automated Decision Making & Profiling
We may use automated tools to detect fraud or personalize your experience (e.g., recommending products).
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Fraud Detection: Decisions are made automatically to block suspicious transactions. You have the right to request human intervention to contest a decision.
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Profiling: We do not engage in legal or similarly significant profiling without your explicit consent.
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6. Cookies
We use cookies to distinguish you from other users.
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Essential Cookies: Loaded automatically; necessary for the site to function.
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Non-Essential Cookies (Analytics/Ads): Loaded only after you have given consent via our Cookie Banner.
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You may withdraw consent at any time via the "Cookie Settings" link in the footer.
7. Data Retention
We retain data only as long as necessary:
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Account Data: While your account is active + 2 years inactive.
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Transaction Data: 7 years (Mandatory under Dutch Tax Law - Belastingdienst).
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Marketing Data: Until you opt-out/unsubscribe.
8. Your Rights (GDPR)
You possess the following rights regarding your data:
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Right to Access: Request a copy of all data we hold on you.
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Right to Rectification: Correct inaccurate data.
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Right to Erasure ("Right to be Forgotten"): Request deletion of data (unless we are legally required to keep it).
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Right to Restrict Processing: Pause processing while a dispute is resolved.
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Right to Portability: Receive your data in a JSON/CSV format.
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Right to Object: Object to processing based on "Legitimate Interest" (including marketing).
To exercise these rights, email privacy@silara.com. We are legally required to respond within one month.
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9. Security
We implement appropriate technical and organizational measures (TOMs) including SSL encryption, 2FA for internal access, and regular vulnerability scanning. In the event of a high-risk data breach, we will notify the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) within 72 hours, and affected users without undue delay.
10. Contact & Complaints
If you believe we have infringed your rights, we encourage you to contact us first:
SILARA B.V.
[Address]
[Zip Code, City, NL]
Email: privacy@silara.com
You also have the right to lodge a formal complaint with the supervisory authority:
Autoriteit Persoonsgegevens
Postbus 93374, 2509 AJ Den Haag