Privacy Policy
roelwillems.com ("the website") is operated by Roel Willems Advisory B.V., Groene Loper 9, 2665 VK Bleiswijk, the Netherlands (KvK 42127774). Roel Willems Advisory B.V. is the controller for the personal data described in this policy. This policy explains which personal data is collected, why, and how it is protected, in accordance with the General Data Protection Regulation (GDPR).
Summary
This website is where I publish my essays and describe my advisory work. I collect as little personal data as possible: what is needed to send the newsletter, to reply when you contact me, and to schedule an introduction call if you book one. Anonymous statistics from Ghost's cookie-free analytics show which content is read. Website and newsletter data is stored on servers in the EU. Your data is never sold.
1. What data is collected
- Technical data: IP address, browser and device information, referrer and pages visited. The IP address is processed to deliver and protect the website; the statistics based on it are anonymized.
- Newsletter data (only if you subscribe): your email address, your name if you provide it, a member ID generated by Ghost, your subscription status and the date you subscribed.
- Newsletter engagement data (only if you subscribe): whether you open a newsletter and which links you click.
- Contact data (only if you contact me): your name, email address and the content of your message.
- Booking data (only if you book a call): your name, email address, the time you choose and any notes you add.
2. How your data is used
Your data is used only to:
- send the newsletter you subscribed to;
- see which essays and topics subscribers find useful, based on opens and clicks;
- reply to your messages;
- schedule and hold the introduction call you booked;
- deliver the website securely and protect it against abuse;
- improve the website and its content, using aggregated, anonymous statistics.
3. Legal basis for processing
- Consent: for the newsletter. You can withdraw your consent at any time through the unsubscribe link in every email.
- Steps at your request before a possible agreement: for booking and holding an introduction call.
- Legitimate interest: for replying to messages, for newsletter engagement statistics, for privacy-friendly website analytics, and for the security of the website.
4. Analytics and cookies
- The website uses Ghost's built-in analytics, which is first-party and cookie-free, and does not use persistent browser storage to recognize visitors across sessions, browsers or devices. More about Ghost analytics
- Unique visitors are counted per 24-hour window; a visit after that window counts as a new visitor.
- If you sign in as a subscriber, Ghost sets a session cookie to keep you signed in. This cookie is necessary for that function and is not used for tracking.
- Newsletters contain a small image and tracked links that record opens and clicks.
- The website does not use advertising, affiliate or third-party tracking cookies.
5. Where your data is processed
Your data is processed only by the service providers below, on behalf of Roel Willems Advisory B.V. and under a data processing agreement:
| Provider | Purpose | Location |
|---|---|---|
| Magic Pages e.U. (Austria) | Hosting of the website and newsletter | EU |
| Hetzner Online GmbH, engaged by Magic Pages | Servers and data storage | Germany |
| Cloudflare, Inc., engaged by Magic Pages | Content delivery, DNS and protection against attacks | EU, with a global network; Standard Contractual Clauses |
| Mailgun Technologies, Inc. (Sinch), engaged by Magic Pages | Newsletter delivery | EU region; administrative access from the US is possible, covered by Standard Contractual Clauses |
| Proton AG | Email and call bookings | Switzerland, which the European Commission recognizes as providing an adequate level of data protection |
Your data is not sold, and not shared with anyone else unless the law requires it.
6. Data retention
- Newsletter data is kept while you are subscribed and deleted within 30 days after you unsubscribe or ask for deletion. Backup copies are removed within three months after that.
- Contact and booking data is kept as long as needed to follow up on your message or call, and deleted within 12 months if no engagement follows, unless the law requires a longer period.
- Analytics data is kept in aggregated, anonymous form for trend analysis.
7. Your rights
Under the GDPR, you have the right to:
- access your personal data;
- correct or delete your data;
- withdraw your consent at any time;
- restrict or object to processing;
- receive your data in a portable format.
To exercise any of these rights, email privacy@roelwillems.com. I respond within one month.
You also have the right to lodge a complaint with the Dutch Data Protection Authority, the Autoriteit Persoonsgegevens.
8. Changes to this policy
If this policy changes, the updated version is published on this page with a new date.