Privacy Policy

This privacy policy explains how HM Digital Business Solutions ('we', 'us', 'our') collects, uses, and protects personal data when you visit our website (hm-digital.com) or engage with our services. We are committed to processing your personal data in a transparent, lawful, and secure manner in accordance with the General Data Protection Regulation (GDPR) and the Dutch GDPR Implementation Act (Uitvoeringswet AVG / UAVG).

1. Who We Are
Data controller: HM Digital Business Solutions

Email: robbert@hmdbs.com

Website: hm-digital.com

If you have any questions about how we handle your personal data, please contact us at the email address above.

2. What Personal Data We Collect

We collect personal data in the following situations:

Contact form
When you submit our contact form, we collect: your name, email address, company name, phone number (optional), and your message.

Meeting bookings
When you book a scoping call via our booking links (powered by Apollo.io), we collect: your name, email address, company name, and any information you provide during the booking process.

Website visitor tracking
We use the Apollo.io tracking script on our website to identify companies and contacts visiting our site. This script may collect your IP address, browser type, pages visited, and company information derived from your IP address. Outside the United States, this data is collected at the company level only.

Direct communication
If you contact us by email or phone, we retain the personal data you share with us in that communication.

3. Why We Process Your Data and Our Legal Basis
We process personal data for the following purposes:

To respond to enquiries and contact form submissions — legal basis: legitimate interest (Article 6(1)(f) GDPR)
To schedule and conduct scoping calls and sales meetings — legal basis: legitimate interest
To identify potential B2B prospects visiting our website — legal basis: legitimate interest in developing our business
To deliver our services (Lead Flow Engine, Apollo.io setup, Monday CRM implementation) to clients — legal basis: performance of a contract (Article 6(1)(b) GDPR)
To send relevant follow-up communications to prospects who have expressed interest — legal basis: legitimate interest
To comply with legal obligations — legal basis: legal obligation (Article 6(1)(c) GDPR)

We process B2B contact data on the basis of legitimate interest. Our services are directed at business professionals and companies. We balance our legitimate interest in outreach against your privacy rights and will always provide an easy way to opt out.

4. Third-Party Tools and Data Processors
We use the following third-party tools that may process personal data on our behalf:

Apollo.io (Apollo.io, Inc., USA) — prospecting, outreach, website visitor tracking, and meeting scheduling. Apollo.io is subject to EU-US Data Privacy Framework adequacy. Data processed: contact details, email interactions, website visit data. Privacy policy: apollo.io/privacy-policy

Monday CRM (monday.com Ltd., Israel) — CRM and contact management. Israel is recognised by the European Commission as providing adequate data protection. Data processed: contact details and interaction history. Privacy policy: monday.com/legal/privacy

Wix.com (Wix.com Ltd., Israel) — website hosting and contact form processing. Data processed: form submissions, website analytics. Privacy policy: wix.com/about/privacy

We ensure that all third-party processors provide sufficient guarantees regarding the security and lawful processing of personal data. We do not sell your personal data to third parties.

5. International Data Transfers
Some of the third-party tools we use are based outside the European Economic Area (EEA). In such cases, we ensure that data transfers are subject to appropriate safeguards:

Apollo.io (USA): transfers are covered by the EU-US Data Privacy Framework
monday.com (Israel): Israel is recognised by the European Commission as a country providing adequate protection

6. How Long We Retain Your Data
We retain personal data only for as long as necessary for the purposes described in this policy:

Contact form enquiries: up to 2 years from the date of last contact
Client data (during and after service delivery): up to 7 years for tax and accounting purposes, in line with Dutch legal requirements
Prospect and lead data: up to 2 years from the date of last meaningful interaction
Website visitor tracking data: subject to Apollo.io's retention policies — typically 90 days

After the applicable retention period, data is securely deleted or anonymised.

7. Your Rights Under GDPR
As a data subject, you have the following rights under the GDPR:

Right of access — you can request a copy of the personal data we hold about you
Right to rectification — you can ask us to correct inaccurate or incomplete data
Right to erasure — you can ask us to delete your personal data, subject to legal retention obligations
Right to restriction — you can ask us to restrict processing of your data in certain circumstances
Right to data portability — you can request your data in a structured, commonly used format
Right to object — you can object to processing based on legitimate interest, including direct marketing
Right to withdraw consent — where processing is based on consent, you may withdraw it at any time

To exercise any of these rights, please contact us at [your@hm-digital.com]. We will respond within 30 days. If you believe your rights have been violated, you have the right to lodge a complaint with the Dutch Data Protection Authority: Autoriteit Persoonsgegevens (AP) — autoriteitpersoonsgegevens.nl — Tel: +31 (0)70 888 85 00

8. Cookies and Tracking Technologies
Our website uses cookies and similar tracking technologies.

Specifically:

Functional cookies: necessary for the website to operate correctly (no consent required)
Analytics: we may use analytics tools to understand how visitors interact with our site
Tracking script: the Apollo.io tracking script identifies visiting companies and contacts for outreach purpose

In accordance with the Dutch Telecommunications Act (Telecommunicatiewet) and the EU ePrivacy Directive, we obtain your consent before placing non-essential cookies. You can manage your cookie preferences via the cookie banner on our website.

9. Security
We take appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or misuse. Our website is served over HTTPS. Access to personal data is restricted to those who need it to perform their work. We use reputable, security-certified third-party processors.

10. Changes to This Policy
We may update this privacy policy from time to time to reflect changes in our practices or in applicable law. The most recent version will always be published on this page with an updated date. We recommend checking this page periodically.

11. Contact
For any questions, requests, or complaints relating to this privacy policy or our data processing practices, please contact:

HM Digital Business Solutions:
Email: robbert@hmdbs.com
Website: hm-digital.com