Privacy Notice

Introduction

This privacy notice tells you how we collect and process your personal data when you use our site, from-scratch.net.

From Scratch Communications is the data controller (referred to as “we”, “us” or “our” in this privacy notice). So we’re responsible for any personal data you share with us.

We also run the German website Ethisches Marketing Jetzt, which has its own privacy notice. Access the privacy notice for Ethisches Marketing Jetzt here.

By giving us your data, you warrant to us that you are over 13 years of age.
It’s very important that the information we hold about you is accurate and up to date.
Please let us know if at any time your personal information changes by emailing us at privacy@from-scratch.net.

This privacy notice was last updated on 15 May 2024.

Contact Details

Full name of legal entity: From Scratch Communications
Email address: privacy@from-scratch.net
Postal address: De Oeverlanden 211, 1441 RE Purmerend, Netherlands
Phone: +31 (0)6458 20 123

What data do we collect about you, for what purpose, and on what grounds do we process it?

Personal data is any info that’s capable of identifying an individual. It does not include anonymised data.

We may process the following categories of personal data about you:

Communication Data

This is any communication that you send to us — whether it’s through:

• A contact form on our website;
• Email;
• Text message (SMS);
• Social media messaging;
• Other messaging services, such as Signal, Telegram and WhatsApp;
• Social media posting and commenting;
• Messenger owl, snail mail, bottle post,…

We save and process that data in order to communicate with you and for record keeping. For example, when you contact us via a form on this website, a copy of your message is saved in the backend of our WordPress website. We also receive your message by email and may decide to save it as a record of our communications.

While we hope this never happens, we’ll also use such data to establish, pursue or defend legal claims.

It’s in our legitimate interest to process it so we can reply to you, keep the necessary records and deal with legal situations as they occur.

When you fill in a form or place an order on this website, your data is stored on the servers of our WordPress host, Krystal. You’ll find the Krystal Hosting Privacy Policy here.

A copy of your message is also stored in our WordPress backend. WordPress is owned by Automattic, Inc. You can find the Automattic privacy policy here.

When you send us an email, your data is saved on the servers of our privacy-first email hosting provider, Fastmail. Find the Fastmail Privacy Policy here.

Customer Data

When you contact us to enquire about our services, we process info such as your:

• Name;
• Job title;
• Business info, such as your industry, website, etc.;
• Billing & delivery addresses;
• Email address;
• Phone number; and
• Enquiry details.

We need to process this data to perform a contract between you and us — and/or take steps to enter into such a contract (at your request), to supply the services you’ve bought, and to keep records of such transactions.

We may process your data in Gekko, Moneybird, Transkriptor, Notion and Butter.

• Gekko and Moneybird are bookkeeping, accounting and invoicing software tools made in the Netherlands. Read the Gekko Privacy Statement. Here’s the Moneybird Privacy Policy (in Dutch).
• Transkriptor is an American audio-to-text transcription software platform. The Transkriptor Privacy Policy is available here. According to the Transkriptor Support page, their data center is located in the European Union. It is a Tier IV, PCI DSS, and ISO 27001 compliant facility. Additionally, all data is encrypted and the company does not host or run their own routers, load balancers, DNS servers, or physical servers.
• Butter is a videoconferencing tool made in Denmark. To summarise their attitude to privacy: “We don’t own your data and we won’t sell it to others. Your data is your data. Period.” Read the full Butter Privacy Policy here.
• Notion is a project management and note-taking software platform headquartered in California, USA. Here’s an overview of the Notion Privacy Policy, Data Processing Addendum, GDPR information and more.

Payments you make via online payment links are encrypted and processed by our bank Bunq B.V.. Read the Bunq Privacy Policy.

Our team communicates via Discord, which is an American software tool with a European HQ in the Netherlands. While we avoid processing personal data in Discord, it’s impossible to rule out completely. Discord shares personal data outside the EEA. Here’s the Discord privacy policy.

User Data

That’s info about how you use our website, our calendar booking tool, our Cloud storage, and any other online services we may give you access to.

We process that data to:

• run our website and make sure we show you good stuff;
• make our website secure;
• maintain back-ups of our website and databases;
• make sure you can access and edit any files we’ve shared with you;
• keep confidential files safe from unauthorised access; and
• enable publication and administration of our website, other online services and business.

It’s in our legitimate interest to process it so we can properly administer our website and our business.

When we share documents or other files with you, we usually do so via a guest account on Dropbox or via Notion. Occasionally we may share a public Dropbox link with you if the content is not confidential. Here’s a link to the Dropbox Privacy Policy.

Technical Data

That’s data about your use of our website and online services such as:

• Your language settings;
• Page views and navigation paths;
• Details about the number of times you use our website

We process that data to:

• analyse your use of our website and other online services;
• administer and protect our business and website
• show you our website in the right language; and
• understand the effectiveness of our marketing.

We use the privacy-friendly analytics platform Plausible to understand how our website is used. The source of this data is from the built-in WordPress statistics tracking system and one essential cookie set by Polylang, our language plugin:

• Default name: ‘pll_language’
• Value: the language code of the last browsed page

Our website is built with WordPress, which is owned by Automattic, Inc. Check out the Automattic privacy policy, the Polylang privacy policy and the Plausible privacy policy.

It’s in our legitimate interest to process this data so we can properly administer our website and our business, grow From Scratch and develop our marketing strategy.

Marketing Data

This includes your preferences in receiving marketing from us, as well as your communication preferences.

Privacy and Our Email Newsletter

We use MailerLite to manage our email marketing subscriber list and to send emails to our subscribers. MailerLite is a third-party provider based in the EU, which may process your data using industry standard technologies to help us monitor and improve our newsletter.

Like most newsletter providers, MailerLite allows us to track the success of our email marketing by providing statistics about open and click through rates. We usually don’t track this kind of user behaviour.

MailerLite’s privacy policy is available here.

You can unsubscribe from our marketing emails by clicking on the unsubscribe link provided at the end of each newsletter.

Privacy and Our Calendar Booking Forms

When you book a Coaching session, Impact Day or other appointment, you submit information to our third-party supplier Morgan, who are based in Switzerland.

The data processing performed by Morgen on our behalf relates to the service of end-to-end appointment scheduling. Find out more about the data processing details and procedure in the Morgen AG Privacy Policy.

Privacy and Surveys

When you respond to From Scratch surveys, we collect your responses via Crowdsignal. Crowdsignal is a survey tool made by Automattic, the company behind WordPress. Here’s a link to the Automattic Privacy Policy.

Previously, we used Typeform for some of our forms and all our surveys. We switched to Crowdsignal so your data isn’t spread across too many different third-party suppliers. However, we still have a Typeform account so we can run surveys on behalf of clients who need certain features that Crowdsignal doesn’t offer.

Typeform is based in Spain. They save and process your answers on their platform. Their plain-English privacy policy is available here.

 

Why Do We Collect Marketing Data?

We process this data to:

• let you take part in our promotions such as competitions, prize draws and free giveaways;
• show you good stuff on our website and in our emails;
• make sure that if and when we advertise, it resonates with you and doesn’t put you off; and
• measure or understand the effectiveness of our marketing.

It’s in our legitimate interest to process this marketing data so we can study how customers use our products and services, develop our offer, grow our business and decide our marketing strategy.

We may use customer data, user data, technical data and marketing data to show you relevant website content and to understand the effectiveness of the content we serve you. It’s in our legitimate interest to process it in this way so we can grow our business.

We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely, to grow our business).

In some cases, we may be legally required to collect your personal data, or it may be necessary under the terms of our contract. In such situations, if you don’t give us that data when we ask for it, we may not be able to perform the contract (for example, to deliver goods or services to you). We may therefore have to cancel a product or service you have ordered. If we do, we’ll let you know at the time.

We’ll only use your personal data for the purpose we collected it for, or for a reasonably compatible purpose if necessary. For more information about this, please email privacy@from-scratch.net. In case we need to use your details for an unrelated new purpose, we’ll let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

Sensitive Data

We don’t collect any sensitive data about you. Neither do we collect any information about criminal convictions and offences.

(Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.)

How We Collect Your Personal Data

We collect data about you when you give it directly to us (for example by filling in forms on our site or by sending us emails). We may also automatically collect certain data from you as you use our website, by using cookies and similar technologies.

We may get data from third parties such as:

• Analytics providers such as WordPress, based outside the EU;
• Search information providers such as Google based outside the EU;
• Providers of technical, payment and delivery services such as Mollie;
• Data brokers or aggregators.

We may also get data from publicly available sources such as the British Companies House or the Dutch Kamer van Koophandel based inside the EU.

Marketing Communications

When we send you marketing communications, it’s either because you’ve given us your consent, or because it’s in our legitimate interest so we can grow our business.

We don’t share your personal data with any third party for their own marketing purposes — unless we have your express consent.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or by emailing us at privacy@from-scratch.net.

If you opt out of getting marketing communications, we’ll still process any personal data you gave us as a result of other transactions (such as purchases, email conversations, etc.). We’ll also still send you emails to confirm any meetings you’ve booked with us, send you proposals you’ve asked for, exchange ideas about the copy we’re writing for you, invoice you as part of our contract, etc.

Sharing Your Personal Data

We may have to share your personal data with the following parties:

• IT and system administration service providers;
• Service providers such as Virtual Assistants (VAs), freelance copywriters, designers and consultants who help us with administrative, creative and marketing tasks such as project deliverables, sending out email newsletters, transcribing recorded calls, invoicing, etc.;
• Professional advisers including lawyers, bankers, accountants and insurers;
• Government bodies that require us to report processing activities;
• Third parties to whom we sell, transfer or merge parts of our business or our assets.
• If you’ve hired us for a project that includes members of the From Scratch team, then we’ll need to share your personal data with them so they can carry out the work set out in our contract. Some of the team may work for us as freelancers. Their contract includes a data processing agreement that ensures the same level of data protection as if they worked for us in-house.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it lawfully. We only allow such third parties to process your personal data for specified purposes and in line with our instructions.

Transferring Your Data Outside the EEA

Countries outside of the European Economic Area (EEA) don’t always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Some of our third-party service providers are based outside the EEA or use service providers outside the EEA. So, we need to transfer your data outside the EEA to use their services and allow them to process it.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data. This means that at least one of the following safeguards must be in place:

• We’ll only transfer your personal data to countries that the European Commission have approved as giving an adequate level of protection for personal data; or
• We use specific contracts, codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
• We avoid US-based providers. If there’s no European provider offering the features we desire, we make sure that the US provider has equivalent safeguards in place — by using GDPR model clauses and/or a suitable Data Processing Agreement.

If none of those safeguards is available, we will ask your explicit consent to the specific transfer. You’ll have the right to say no and to change your mind any time.

Data Security

We’ve put security measures in place to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation.

In addition, we allow only those employees and partners access to your personal data who have a business need to know it. They’ll only process your personal data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

Keeping Your Data

We’ll only keep your personal data for as long as we need it for the purposes we collected it — including legal, accounting, or reporting needs.

When deciding how long we should keep it, we look at:

• Its amount, nature and sensitivity;
• Potential risk of harm from unauthorised use or disclosure;
• The processing purposes (if these can be achieved by other means); and
• Legal requirements.

For tax purposes, the law requires us to keep basic information about our customers (including contact, identity, financial and transaction data) for at least seven years after they stop being customers.

In some circumstances, we may anonymise your personal data for research or statistical purposes — in which case we may use that information indefinitely without further notice to you.

Your Legal Rights

The data protection laws give you certain rights in relation to your personal data.

You have the right to request:

• Access;
• Correction;
• Erasure;
• Restriction; and
• Transfer of your data.

You also have the right to:

• Object to processing;
• Port your data; and
• Withdraw consent (where the lawful ground of processing is consent).

You can learn more about your rights here:

in Dutch via Autoriteit Persoonsgegevens

in British English via the Information Commissioner’s Office

in German via the Bundesbeauftragte für den Datenschutz und die Informationsfreiheit

(As an aside – isn’t it amusing that the German data protection office has the longest name? So stereotypical!)

To exercise your rights, please email us at privacy@from-scratch.net.

We won’t ask you to pay a fee to access your personal data (or to exercise any of the other rights).

However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. In those circumstances, we may refuse to comply with your request.

We may need to request specific information from you to help us confirm it’s you and make sure you have the right to access the personal data (or to exercise any of your other rights). This is a security measure so we don’t share that personal data with anyone who has no right to get it. We may also contact you to ask you for more information about your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In that case, we’ll let you know.

If you aren’t happy with any aspect of how we collect and use your data, you have the right to complain.

The Autoriteit Persoonsgegevens is the Dutch supervisory authority for data protection issues.

We’d love to be the first to know if you do have a complaint so that we can try to resolve it for you.

Third-Party Links

This website includes links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We don’t control those third-party websites and are not responsible for their privacy statements.

When you leave our website, we encourage you to read the privacy notice of every website you visit — in particular when you visit our social media profiles.

Privacy and Our Social Media Profiles

On our website, you’ll find links to our social media profiles. We have chosen not to embed any social media content or “Like” buttons in order to minimise tracking. Still, it’s worth checking out those privacy policies so you know what happens when you follow the links and visit our profiles.

Embedded Videos

We reserve the right to embed YouTube videos in so-called “extended data protection mode” on this website.

This means that we only show you locally saved preview images of such videos when you visit a page with an embedded video. Content from YouTube is not automatically loaded and your data is not automatically transmitted to YouTube. YouTube also does not set any cookies if you do not start playback.

The YouTube content will only play if you give your express consent for each video. As a result, YouTube receives the information that you have visited our site, any technically required usage data and the option to implement tracking technologies. We have no influence on further data processing by YouTube.

YouTube Privacy Policy

LinkedIn Privacy Policy

Cookie Policy

What’s a cookie?

A “cookie” is a piece of information that is stored on your device or computer hard drive. It records how you move your way around a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.

Cookies are used by nearly all websites and do not harm your system. Still, we keep their use to an absolute minimum.

If you want to check or change what types of cookies you accept, you can usually do this within your browser settings. You can block cookies at any time by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you block all cookies (including essential cookies) you may not be able to access all or parts of our site.

How Do We Use Cookies?

We use cookies to track your use of our website. This allows us to understand how you use the site so we can develop and improve it as well as products and/or services in response to what you might need or want.

Cookies are either:

Session cookies: those are only stored on your device/computer during your web session and are automatically deleted when you close your browser. They usually store an anonymous session ID, allowing you to browse a website without having to log in to each page. They don’t collect any personal data from your computer.

Or:

Persistent cookies: a persistent cookie is stored as a file on your device/computer, and it remains there when you close your browser. The cookie can be read by the website that created it when you visit that website again.  We use such cookies to make sure you don’t see popups too often.

Cookies can also be categorised as follows:

Strictly necessary cookies: those are essential to let you use the website effectively — such as when buying a product and / or service. Therefore, they can’t be turned off. Without those cookies, the services available to you on our website wouldn’t work. They don’t gather information about you that could be used for marketing or remembering where you’ve been on the internet.

Performance cookies: those let us monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.

Functionality cookies: those allow our website to remember choices you make and provide enhanced features. For instance, we can serve our website in your preferred language or suppress a popup you only saw quite recently. The information those cookies collect is usually anonymised.