Privacy Policy
1. Who are we?
KamerJager is a service of Energy67 (sole proprietorship), based in Aerdenhout, Netherlands. Chamber of Commerce: 78287588. VAT: NL003313477E. For questions about this privacy policy, contact [email protected].
2. What personal data do we process?
We process personal data of users who are at least 16 years old:
- Account data: username, email address, password (hashed), phone number.
- Auto-Book data: first name, last name, email, phone number, cover letter, filter preferences.
- Verification data: phone number and verification codes (via SMS, processed by Twilio).
- Usage data: search filters, notification preferences, interaction data.
- Technical data: IP address, browser type, device information (via functional cookies).
3. Why do we process your data?
| Purpose | Legal basis (GDPR) |
|---|---|
| Create and manage account | Performance of contract (Art. 6-1b) |
| SMS verification via Twilio | Performance of contract (Art. 6-1b) |
| Auto-Book: automatically respond to rooms on your behalf | Consent (Art. 6-1a) |
| Send room notifications via Telegram/email | Performance of contract (Art. 6-1b) |
| Payment processing (Mollie) | Performance of contract (Art. 6-1b) |
| Fraud and abuse prevention | Legitimate interest (Art. 6-1f) |
4. Processors and third parties
We share your personal data with:
- Twilio (US) — SMS verification. EU-US Data Privacy Framework applies.
- Mollie (NL) — Payment processing. Based in the Netherlands, processes within the EEA.
- Telegram — Notification service. Processes your Telegram user ID if you use the bot.
- Cloudflare (US) — CDN and security. EU-US Data Privacy Framework applies.
- Hosting provider — Server and database hosting in the EU/EEA.
Transfers outside the EEA are based on the EU-US Data Privacy Framework or Standard Contractual Clauses (SCCs).
5. Retention periods
- Account data: until you delete your account, plus a maximum of 30 days.
- Auto-Book data: until you delete it or close your account.
- Verification codes: maximum 10 minutes after sending.
- Technical log files: maximum 90 days.
- Billing data: 7 years (legal obligation).
6. Cookies
KamerJager only uses functional cookies necessary for the service to work. We do not use tracking, advertising, or analytics cookies.
7. Your rights
Under the GDPR you have the following rights:
- Right of access — request which data we process.
- Right to rectification — correct inaccurate data.
- Right to erasure — request deletion of your data.
- Right to restriction — request limited processing.
- Right to data portability — receive your data in a structured format.
- Right to object — object to processing based on legitimate interest.
- Right to withdraw consent — withdraw consent at any time.
Submit your request via [email protected]. We respond within 30 days. You also have the right to file a complaint with the Dutch Data Protection Authority.
8. Security
We take appropriate technical and organisational measures to protect your personal data, including encrypted connections (HTTPS/TLS), hashed passwords, access control, and regular security updates.
9. Changes
We may update this privacy policy from time to time. The most recent version is always available on this page.
Energy67 — Aerdenhout — KVK: 78287588 — BTW: NL003313477E