Linea Clara attaches great importance to the protection of your personal data. This statement sets out which data we process, for what purpose, on what legal basis, and what rights you have. We process personal data in accordance with the General Data Protection Regulation (GDPR) and other applicable privacy legislation.

1. Data controller

The controller for the processing of your personal data is:

Name: Linea Clara, sole proprietorship operated by Maurice de Valois Turk

Address: César Francklaan 38, 2102 ED Heemstede, the Netherlands

Email: maurice@lineaclara.nl

Telephone: +31 6 5151 4050

Chamber of Commerce: 72202173

2. Personal data we process

Linea Clara processes personal data that you provide to us yourself, as well as data that is necessary for the performance of our services. The categories are:

Contact details: name, position, organisation, email address, telephone number and correspondence address.

Content of your message: information you include in an email, telephone conversation or in the contact form on our website.

Engagement data: data necessary for the performance of an engagement, including file information, financial documents and correspondence.

Invoicing data: name, address, VAT number, bank account number and other data required for invoicing and financial administration.

Identification data: where we are required, under legal obligations including the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft), to verify your identity and the identity of ultimate beneficial owners.

We do not, in principle, process special categories of personal data, unless this is necessary for the performance of an engagement and you provide such data to us yourself.

3. Purposes and legal bases

We process your personal data for the following purposes:

Performance of the engagement: preparing proposals, performing engagements, drafting reports and analyses, and related correspondence. Legal basis: performance of the contract (article 6(1)(b) GDPR).

Responding to your enquiry or request: when you contact us by email, telephone or via the contact form on our website. Legal basis: pre-contractual measures or legitimate interest in responding to your message (article 6(1)(b) and (f) GDPR).

Compliance with legal obligations: including tax retention obligations, identification requirements and any reporting obligations. Legal basis: legal obligation (article 6(1)(c) GDPR).

Relationship management: maintaining client administration and issuing invoices. Legal basis: performance of the contract and legitimate interest (article 6(1)(b) and (f) GDPR).

Handling complaints and disputes: to defend against or bring legal claims. Legal basis: legitimate interest (article 6(1)(f) GDPR).

4. Cookies, analytics and tracking

The Linea Clara website does not use any analytics, advertising or tracking cookies. No data is collected via services such as Google Analytics, Meta Pixel or comparable technologies. No profiles of website visitors are built.

For the proper functioning of the website, our hosting provider (Webflow) may keep technical log files, including IP addresses, for security, error detection and availability purposes. This data is not used by Linea Clara for analysis or profiling.

5. Contact form

If you send us a message via the contact form on our website, we receive the data you enter in the form, as well as the content of your message. This data is used solely to handle your enquiry or request and is not used for any other purpose.

6. Recipients of your data

Linea Clara does not provide your personal data to third parties, unless this is necessary for the performance of the engagement, to comply with a legal obligation, or in connection with proceedings for which the engagement was given.

For our business operations, we use a limited number of processors that process personal data on our instructions. These include:

Hosting provider: for hosting the website.

Email service provider: for business email communication.

IT and storage services: for the secure storage of files and correspondence.

Bookkeeper and accountant: for financial administration and statutory reporting.

Where required, data processing agreements have been concluded with these parties, setting out arrangements for the protection of your personal data.

7. Transfer outside the European Economic Area

Linea Clara aims to process personal data within the European Economic Area (EEA). Where a processor processes data outside the EEA, this is done only on the basis of appropriate safeguards, including the European Commission's standard contractual clauses or an adequacy decision.

8. Retention periods

Linea Clara does not retain your personal data for longer than is necessary for the purposes for which it was collected, or as required under law and regulation. The following retention periods apply in particular:

Files and correspondence: seven years after the end of the engagement, unless a longer retention period is reasonably necessary in connection with liability or pending proceedings.

Financial administration: seven years, on the basis of statutory tax retention obligations.

Identification data (Wwft): five years after termination of the business relationship.

Messages via the contact form or by email that do not lead to an engagement: no later than two years after the last correspondence.

9. Security

Linea Clara takes appropriate technical and organisational measures to protect your personal data against loss, misuse, unauthorised access and unauthorised disclosure. These measures include access controls, encrypted storage and structured password management.

10. Your rights

Under the GDPR, you have the following rights with respect to your personal data:

Right of access: you may request which personal data we process about you.

Right to rectification: you may request correction of inaccurate or incomplete data.

Right to erasure: you may request erasure of your data, to the extent that there is no legal obligation to retain it.

Right to restriction: you may request restriction of the processing of your data.

Right to data portability: you may request your data in a structured, commonly used and machine-readable format.

Right to object: you may object to the processing of your personal data on the basis of legitimate interest.

Right to withdraw consent: where processing is based on your consent, you may withdraw it at any time.

You may exercise your rights by contacting maurice@lineaclara.nl. We will respond to your request within the statutory period of one month. To verify your identity, we may ask for additional information.

11. Complaints

If you have a complaint about the processing of your personal data, we ask that you first contact us at maurice@lineaclara.nl, so that we can discuss your complaint and address it where possible. You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at www.autoriteitpersoonsgegevens.nl.

12. Changes

Linea Clara reserves the right to amend this privacy statement. The most current version is always available at www.lineaclara.nl. We recommend that you consult this statement periodically.

Linea Clara

Maurice de Valois Turk

César Francklaan 38, 2102 ED Heemstede, the Netherlands

www.lineaclara.nl

Version April 2026

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