Who we are (data controller)
Kuberdon is a trading name of JB CAPITAL BV, a company registered in Belgium.
- BCE / VAT
- BE 1005.101.429
- Registered address
- Strijdersstraat 64, 3000 Leuven, Belgium
- Contact for privacy matters
- [email protected]
- Data Protection Officer
- Not appointed; not legally required for the scale and nature of our processing.
What personal data we collect
We only collect data you choose to give us, plus minimal technical data needed to run the site.
- The enquiry formYour name, work e-mail, organisation, role, and any message you write.
- The digest mailing listYour e-mail address, the moment you consented, the IP address you consented from, and the version of the wording you agreed to. Nothing else — the digest form asks for no name. We keep the consent record because the GDPR requires us to be able to demonstrate that you asked for this.
- E-mail correspondenceThe content of e-mails you send us and our replies.
- Technical and server logsIP address, browser type, and request data, kept briefly for security and to keep the site running.
- Analytics (only with your consent)Privacy-friendly, aggregated usage statistics — see the Cookie Policy for details.
We do not intentionally collect special categories of data (health, beliefs, etc.). Please do not include such data in free-text fields.
Why we use it and our legal basis
| Purpose | Legal basis (GDPR Art. 6) |
|---|---|
| Answering your enquiry and scoping a possible audit | 6(1)(b) steps prior to a contract, and/or 6(1)(f) legitimate interest in responding to business enquiries |
| Sending you the information or proposal you asked for | 6(1)(b) / 6(1)(f) |
| Keeping the site secure and operational | 6(1)(f) legitimate interest |
| Sending you the weekly digest | 6(1)(a) consent — given by ticking the box and then confirming by e-mail, and withdrawable from every issue |
| Keeping a record that you consented to the digest | 6(1)(c) legal obligation — GDPR Art. 7(1) requires us to be able to demonstrate consent |
| Privacy-friendly analytics | 6(1)(a) consent |
How long we keep it
Form and enquiry data is kept for up to 18 months from your last contact with us, after which it is deleted, unless a longer period is required for a contract or by law (for example invoicing and accounting records). Digest subscriptions are kept until you unsubscribe. Unsubscribing stops all mail immediately; your address then stays in our sending tool marked as unsubscribed, so that we can honour the request and not re-add you, and we remove it entirely on request. The consent record for a subscription is an archived e-mail and is kept for as long as the subscription plus 12 months, because it is the evidence that you asked to be on the list. You can ask for deletion sooner at any time.
Where your data lives (EU data residency)
By default your data is stored and processed on servers in the EU/EEA. We do not transfer personal data outside the EU/EEA unless adequate safeguards are in place, and we will say so here if that ever changes.
Who we share it with (processors and sub-processors)
We use a small number of carefully chosen service providers, each bound by a data-processing agreement (DPA):
- Website hosting
- DigitalOcean App Platform — Amsterdam (AMS) region.
- E-mail and form delivery
- Resend — EU residency tier.
- Digest mailing list
- Resend Audiences — EU residency tier. The list itself lives there; we hold no separate database.
- Analytics (only with your consent)
- PostHog — EU-hosted (eu.posthog.com).
We never sell your personal data and we do not use it for third-party advertising.
The digest mailing list
The digest is opt-in twice over: you tick a box, and then you confirm by clicking a link in an e-mail we send you. Until you click it your address sits in our sending tool marked as unsubscribed and receives nothing, which is what stops anyone signing up an address that is not theirs. Every issue carries an unsubscribe link that works in one click and needs no reply from us. We do not profile you, we do not track whether you opened anything for any purpose beyond delivery, and we never pass your address to anyone. Subscribing does not put you on any other list, and enquiring about our work does not subscribe you.
Your rights
Under the GDPR you have the right to access your data; correct it; have it erased; restrict or object to processing; data portability; and withdraw consent at any time (without affecting prior lawful processing). To exercise any of these, e-mail [email protected].
You also have the right to lodge a complaint with the Belgian supervisory authority: the Data Protection Authority (Gegevensbeschermingsautoriteit / Autorité de protection des données), Rue de la Presse 35, 1000 Brussels — [email protected].
Changes to this policy
We may update this policy as Kuberdon grows. The current version and its date will always be shown here.