Privacy statement

This statement covers the website lexaero.nl, correspondence with Lexaero, and the business contact details Lexaero holds. It gives the information required by the GDPR and, where it applies, by the Swiss Federal Act on Data Protection (FADP). The controller is Ali Fouad, trading as Lexaero, established in The Hague, the Netherlands. Questions and requests go to contact@lexaero.nl.

1. This website

The website sets no cookies and uses no analytics, tracking pixels or embedded content from other sites. Fonts, images and the film are served from the site's own domain. The route you set, the situations you tick and a message you have started are kept in your browser's session storage, not in a cookie, so that they follow you from page to page. They are removed when the message is sent, your browser discards them when the tab is closed, and they reach nobody unless you send the form.

When you open a page, the hosting provider records technical data in its server logs: your IP address, the date and time, the page requested, your browser type and, where your browser sends it, the page you came from. Lexaero uses this only to deliver the site and keep it secure, on the basis of its legitimate interest in doing so (Article 6(1)(f) GDPR). Log entries are deleted after 30 days at most.

2. The contact form and email

The contact form asks for your name, your email address and your message, and optionally your company. The form is sent over an encrypted connection to the website's server, which forwards it by email to Lexaero's mailbox. The website stores no copy. The hosting provider's mail server keeps a delivery record (time, sender and recipient address) in its logs. If delivery fails, the message is returned to a Lexaero mailbox. A hidden field, a timing check and a cap on the number of messages per hour filter out automated submissions, and no third-party anti-spam service is involved.

Whether you use the form or write by email, Lexaero uses your details and what you write to answer you and, where you ask for one, to prepare a proposal. You are not obliged to provide anything, but without contact details Lexaero cannot reply.

The legal basis is the steps taken at your request before entering into a contract (Article 6(1)(b) GDPR), or otherwise Lexaero's legitimate interest in answering business correspondence (Article 6(1)(f) GDPR).

Please do not send confidential information, or sensitive personal data about yourself or others, in a first message. Correspondence that does not lead to an engagement is deleted 12 months after the last contact.

3. When Lexaero writes to you first

Lexaero sometimes contacts a company it believes it can help. It sends a first message by email only where the law that applies to the recipient allows one without prior consent, for example to an address the company has published for receiving business proposals. Otherwise it writes by post or through a professional network's own messaging. For that purpose it holds the name, role and business contact details of the person concerned, taken from the company's own website, public registers and professional networking profiles. Every message says who Lexaero is, where the details came from and how to object.

The legal basis is Lexaero's legitimate interest in offering its services to businesses for which they are relevant (Article 6(1)(f) GDPR). You can object at any time, without giving a reason, by replying to the message. Lexaero then stops, and keeps only your address on a do-not-contact list for as long as it carries out outreach.

If there is no reply, the details are deleted 12 months after the last message.

4. Clients

For clients, Lexaero keeps the contract, correspondence, deliverables and invoices for the duration of the engagement and for seven years after it ends. It does so to perform the contract with the client, which for the individuals involved rests on Lexaero's legitimate interest in carrying out its engagements (Article 6(1)(f) GDPR) and, where the client is an individual, on Article 6(1)(b) GDPR. It also does so to meet the seven-year retention duty of Dutch tax law (Article 6(1)(c) GDPR) and to be able to answer questions or claims about its work (Article 6(1)(f) GDPR). Where the Wwft applies, Lexaero also keeps the identification records the Act requires for five years after the engagement ends.

Personal data that a client entrusts to Lexaero in the course of an engagement is handled under the terms of that engagement, including a data-processing agreement where Lexaero acts as processor.

5. Who receives the data

Lexaero does not sell personal data or share it for anyone else's marketing. It uses service providers that process data on its behalf, each under a data-processing agreement. They include:

  • Microsoft, for email and documents (Microsoft 365)
  • TransIP B.V., Leiden, the Netherlands, which hosts this website

Data may also be disclosed where the law requires it, for example to the Dutch tax authorities.

6. Where the data is held

Lexaero is established in the Netherlands and keeps its data with providers that store it in the European Economic Area. Where a provider can access or process data from another country, the transfer rests on an adequacy decision where one applies, at present the EU-US Data Privacy Framework for Microsoft's services, and otherwise on the European Commission's standard contractual clauses. A copy of the clauses is available on request.

7. Your rights

You can ask Lexaero for access to the personal data it holds about you, and for its correction, deletion, restriction or transfer. You can object to processing that rests on legitimate interest. An objection to being contacted about Lexaero's services is always honoured. Write to contact@lexaero.nl. You will receive an answer within one month.

Lexaero makes no decisions about you by automated means and does not build profiles.

If you are not satisfied, you can complain to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or to the supervisory authority where you live. People in Switzerland can turn to the Federal Data Protection and Information Commissioner (FDPIC).

8. Changes

When this page changes, the version number and date at the top change with it. Earlier versions are available on request.