Privacy Policy

1. Introduction

TECHLETES B.V. ("TECHLETES", "we", "us" or "our") respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, store, share and protect personal data in connection with our websites, business operations and services, and how you can exercise your rights under applicable data protection legislation.

TECHLETES provides consultancy, software development, data analytics, artificial intelligence (AI) solutions, automation, hosting and application management services.

We process personal data in accordance with applicable European and Dutch legislation, including:

• The General Data Protection Regulation (GDPR), Regulation (EU) 2016/679;
• The Dutch GDPR Implementation Act (Uitvoeringswet AVG);
• The Dutch Telecommunications Act (Telecommunicatiewet), where applicable to cookies and electronic communications;
• Other applicable privacy, employment, tax and information security legislation.

This Privacy Policy applies to processing activities for which TECHLETES is responsible, including our websites, business communications, customer and supplier relationships, recruitment and employment administration.

When we process personal data on behalf of a customer, different responsibilities apply, as explained in Section 5.

2. Who is responsible for your personal data?

For processing activities where TECHLETES determines the purposes and essential means, the data controller is:

TECHLETES B.V.

Polarisavenue 175
2132 JJ Hoofddorp
The Netherlands

Chamber of Commerce (KvK): 99772140
Website: https://www.techletes.ai
Privacy contact: privacy@techletes.ai

TECHLETES has appointed an internal Privacy Officer responsible for coordinating privacy compliance, handling privacy-related requests and overseeing the protection of personal data.

You may contact our Privacy Officer using the email address above.

3. What personal data do we process?

The personal data we process depends on your relationship with TECHLETES and the services or activities involved.

3.1 Website visitors

When you visit our websites, we may process:

• IP addresses and technical connection information;
• Browser type, operating system and device information;
• Pages visited and website interactions;
• Cookie preferences and consent settings;
• Website performance, security and diagnostic information;
• Information submitted through contact forms or other website features.

Not all information is collected from every visitor. Wherever possible, we use privacy-friendly analytics technologies and limit the collection of personal data to what is necessary.

Further information about cookies, website analytics and consent management is provided in Section 8.

3.2 Customers, prospects and business contacts

When you contact us, request a quotation, work with us or otherwise have a business relationship with TECHLETES, we may process:

• Name and business contact details;
• Employer, organisation, department and job title;
• Business email address and telephone number;
• Professional profiles, such as LinkedIn;
• Correspondence, meeting notes and agreed actions;
• Commercial interests, enquiries and proposals;
• Contracts, project information and related documentation;
• Billing and payment information where relevant;
• Other information necessary to maintain and manage the business relationship.

3.3 Employees, applicants and contractors

When you apply for a position, work for TECHLETES or provide services to us as a contractor, we may process personal data necessary for recruitment, employment or contractor administration.

Depending on the circumstances, this may include identification and contact details, CVs, qualifications, employment history, contracts, payroll and bank details, statutory identification information, working hours, leave records, access credentials and performance-related information.

Where necessary and legally permitted, we may process limited information relating to absence, occupational health or other legally regulated employment matters.

Medical information is handled with particular care. TECHLETES does not routinely collect or retain medical diagnoses or detailed medical records in its general HR systems. Medical assessments are handled by authorised occupational health professionals where required.

3.4 Users of applications and services

For applications and services for which TECHLETES is the data controller, we may process:

• Account and authentication information;
• Name, email address and organisational affiliation;
• User preferences and settings;
• Application usage and activity logs;
• Technical identifiers and security events;
• Information submitted through the application;
• Support requests and related correspondence.

Where TECHLETES acts solely as a processor on behalf of a customer, the customer's privacy information and the applicable data processing agreement govern the relevant processing.

3.5 Communications and meetings

When communicating with TECHLETES, we may process the contents of emails, messages, documents and meeting notes.

Where meetings or calls are recorded or transcribed, we will provide appropriate information to participants and establish a lawful basis for processing.

Depending on the circumstances, this may include audio recordings, transcripts and AI-generated meeting summaries.

Such information is used only for legitimate and specified purposes, such as documenting decisions, following up on agreed actions or delivering our services.

4. How do we obtain personal data?

We obtain personal data from several sources.

Directly from you

For example, when you contact us, submit a form, apply for a position, attend an event, enter into an agreement or use one of our services.

Through your organisation

Your employer, colleagues or other representatives may provide your contact details and relevant information in connection with a business relationship or project.

From publicly available professional sources

We may obtain relevant business contact information from company websites, public business registers, professional networking platforms such as LinkedIn and other publicly accessible professional sources.

Through referrals and business relationships

Existing customers, partners and other professional contacts may introduce or refer individuals to TECHLETES.

Through service providers

Where appropriate and lawful, we may receive data from recruitment platforms, business information providers or other authorised third parties.

Automatically

Certain technical information is generated when you visit our websites or use applications and services.

When personal data is obtained indirectly, we provide the information required by Article 14 GDPR within the applicable statutory timeframe, unless a lawful exception applies.

We take reasonable steps to ensure that personal data obtained from third parties is relevant, accurate and obtained and used lawfully.

5. Our role as data controller or data processor

The GDPR distinguishes between data controllers and data processors. TECHLETES may act in either capacity depending on the processing activity.

5.1 TECHLETES as data controller

TECHLETES generally acts as an independent data controller when it determines why and how personal data is processed.

Examples include:

• Operating our corporate websites;
• Managing customer, supplier and partner relationships;
• Maintaining our CRM and commercial administration;
• Conducting recruitment and employment administration;
• Managing our financial and legal obligations;
• Securing our own systems and infrastructure;
• Performing internal business operations.

For these activities, TECHLETES determines the applicable purposes, legal bases and retention arrangements.

5.2 TECHLETES as data processor

When providing services to customers, TECHLETES may process personal data on their behalf.

This can occur when we:

• Develop, implement or maintain software applications;
• Host or manage customer applications and databases;
• Perform data analysis, migration or integration;
• Develop or operate AI-powered applications;
• Process documents, communications or other information through automated workflows;
• Provide technical support, maintenance or security services.

In these circumstances, the customer generally acts as the data controller and determines the purposes and legal basis for processing.

TECHLETES processes such personal data in accordance with the customer's documented instructions, the applicable agreement, any data processing agreement and applicable law.

Our data processing agreements address matters including confidentiality, security, subprocessors, international transfers, assistance with data subject requests, personal data breaches and the return or deletion of data.

Depending on the customer agreement, additional restrictions may apply, including requirements that personal data be processed exclusively within the European Economic Area (EEA).

Where TECHLETES acts as a processor, questions or requests about the purposes of the customer's processing should generally be directed to the relevant customer. We will assist the customer with such requests where required.

This Privacy Policy does not replace customer-specific privacy notices or data processing agreements.

6. Why do we process personal data?

We process personal data only where we have an applicable legal basis under Article 6 GDPR.

The principal purposes and legal bases are described below.

6.1 Enquiries, quotations and agreements

We process personal data to respond to enquiries, prepare quotations and take steps towards entering into agreements.

Legal basis: Legitimate interests or taking steps at the request of the data subject before entering into a contract, where Article 6(1)(b) GDPR applies.

6.2 Services and customer relationships

We process personal data to deliver our services, carry out projects and maintain customer relationships.

Legal basis: Performance of a contract, where applicable, or legitimate interests in maintaining business relationships.

6.3 Suppliers, partners and contractors

We process personal data to establish, perform and manage commercial relationships and agreements.

Legal basis: Performance of a contract, legitimate interests or compliance with legal obligations, depending on the circumstances.

6.4 CRM and commercial relationships

We process professional contact information to maintain business relationships, identify commercial opportunities and organise our business activities.

Legal basis: Legitimate interests.

6.5 Marketing and newsletters

We may process personal data to send newsletters, promotional messages and other business communications.

Legal basis: Consent where legally required, or another valid legal basis combined with an applicable legal exception for marketing communications.

6.6 Recruitment and selection

We process personal data to assess applications, select candidates and prepare employment or contractor agreements.

Legal basis: Pre-contractual steps, legitimate interests and, where appropriate, consent.

6.7 Employment and financial administration

We process personal data for payroll administration, tax obligations, personnel management and other statutory administrative requirements.

Legal basis: Performance of a contract, compliance with legal obligations or, where appropriate, legitimate interests.

6.8 Website analytics and information security

We process technical information and, where relevant, limited personal data to operate, secure, analyse and improve our websites and applications.

Legal basis: Legitimate interests, provided that the processing is necessary, proportionate and complies with applicable privacy and cookie legislation. Where consent is required for specific technologies, processing is based on consent.

6.9 Legal obligations and disputes

We process personal data where necessary to comply with legal obligations, manage disputes, conduct audits or protect our legal interests.

Legal basis: Compliance with legal obligations or legitimate interests.

6.10 Internal business processes and AI

We may process personal data using approved digital tools and AI applications to support internal business processes.

Legal basis: Legitimate interests, performance of a contract or compliance with legal obligations, depending on the activity.

Where we rely on legitimate interests, we assess the necessity of the processing and balance our interests against the rights and freedoms of the individuals concerned.

Our legitimate interests include maintaining professional relationships, operating and improving our business, protecting our infrastructure, providing effective services, preventing misuse and protecting our legal interests.

Where processing is based on consent, you may withdraw that consent at any time.

Where special categories of personal data are processed, an additional condition under Article 9 GDPR must apply, together with any relevant Dutch legal requirements.

7. Business development, CRM and marketing

TECHLETES maintains a Customer Relationship Management (CRM) system to manage professional relationships, business opportunities, proposals, communications and commercial activities.

We may use professional contact information to identify relevant organisations, communicate with business contacts and maintain relationships with existing or prospective customers.

Such processing may be based on our legitimate interests where those interests are not overridden by the rights and freedoms of the individuals concerned.

However, a legitimate interest under the GDPR does not automatically authorise unsolicited marketing communications.

We comply with applicable Dutch rules governing electronic marketing and telemarketing, including requirements concerning prior consent, permitted exceptions, sender identification and the right to unsubscribe or object.

When electronic marketing is permitted, recipients can object or unsubscribe free of charge through an available opt-out mechanism or by contacting privacy@techletes.ai.

If you object to the processing of your personal data for direct marketing, we will stop using your personal data for that purpose.

We may retain limited information necessary to ensure that your marketing preferences and objections continue to be respected.

TECHLETES does not sell personal data to third parties for their independent marketing purposes.

8. Cookies and website analytics

Our websites use cookies and similar technologies to provide essential functionality, maintain security and understand how visitors use our websites.

We aim to minimise the processing of personal data and use privacy-friendly, self-hosted technologies wherever possible.

8.1 Necessary cookies and local storage

Necessary cookies and similar storage technologies support essential website functionality, including security, technical operation and remembering privacy preferences.

These technologies do not require consent where they meet the applicable legal conditions.

8.2 Website analytics with Umami

We use Umami, a privacy-focused web analytics platform that we host and manage ourselves, to analyse website visits.

Umami provides insights into:

• Visitor numbers and page views;
• Pages visited and navigation patterns;
• Traffic sources and referring websites;
• General technical characteristics, such as browser and device types;
• Approximate geographical information;
• Interactions and events on our websites.

In its standard configuration, Umami does not use cookies or persistent visitor identifiers. The platform is designed to analyse website usage without tracking individual visitors over extended periods.

Depending on the technical configuration, limited information such as technical connection data may be processed temporarily to generate statistics.

Analytics data is processed within our own hosting environment. We do not use external web analytics services such as Google Analytics and do not disclose analytics data to external providers for their own analytics purposes.

We use this information exclusively to analyse and improve the usability, performance and functionality of our websites.

To the extent personal data is processed, we rely on our legitimate interests in improving our websites for limited, privacy-friendly analytics, provided that the applicable legal requirements are satisfied.

Where specific analytics technologies require prior consent under applicable law, they are activated only after that consent has been obtained.

8.3 Consent management with Klaro

We use Klaro, a self-hosted consent management platform, to manage cookie preferences and consent choices.

Through Klaro, you can determine which optional cookies and technologies may be used on our websites.

Klaro may store your consent preferences locally in your browser, for example through a cookie or your browser's local storage functionality. This allows us to remember your preferences so that you do not need to provide them again on every visit.

Non-essential cookies and tracking technologies requiring consent are activated only after you have provided the relevant consent.

You can change your preferences and withdraw previously given consent at any time through the privacy or cookie settings on our website.

Withdrawing consent does not affect the lawfulness of processing performed before withdrawal.

8.4 Transparency and periodic review

The cookies and similar technologies used depend on the functionality of the relevant website and your consent preferences.

Where applicable, we provide additional information through our cookie settings about the purposes and operation of optional technologies.

TECHLETES periodically reviews its websites, analytics technologies and consent configurations to assess compliance with applicable privacy and cookie legislation.

9. Artificial intelligence and automated processing

Artificial intelligence and automation are core components of TECHLETES' services and internal operations.

We may use AI-assisted tools for activities such as software development, document analysis, information retrieval, data processing, drafting, meeting summarisation and workflow automation.

Where these activities involve personal data, we apply the relevant GDPR requirements and our internal information security and supplier assessment procedures.

9.1 Use of customer data

When TECHLETES processes personal data on behalf of a customer, the permitted purposes and processing activities are governed by the applicable agreements and documented instructions.

Customer data is not authorised for use in training general-purpose AI models for TECHLETES' independent purposes without the necessary contractual authorisation and lawful basis.

Where external AI model providers or other third-party services are used, their involvement is assessed according to the nature of the information, applicable data processing arrangements, security requirements and customer-specific restrictions.

9.2 Internal AI-assisted processing

TECHLETES may use approved AI tools to support internal activities for which it acts as a controller.

Personal data is submitted to these services only where there is an appropriate purpose and legal basis, and subject to applicable contractual and organisational safeguards.

The identity of any external AI provider, applicable processing locations, retention arrangements and permitted uses of submitted information depend on the specific service and configuration.

9.3 Automated decision-making

TECHLETES does not use solely automated decision-making in its own standard recruitment, CRM or business administration activities to make decisions producing legal or similarly significant effects on individuals.

AI-assisted outputs may support human work and decision-making.

Customer applications may contain different AI or automated decision-making functionality. Where this involves processing controlled by a customer, the customer is responsible for providing the relevant information about such processing.

If TECHLETES introduces automated decision-making covered by Article 22 GDPR in activities for which it is the controller, we will provide the legally required information and safeguards.

10. Who do we share personal data with?

We share personal data only where appropriate and necessary for a legitimate and specified purpose, where required by law or where another valid legal basis applies.

Depending on the processing activity, recipients may include the following categories.

Cloud and productivity providers

Services used for email, collaboration, document management, development and internal operations, including Microsoft 365, Notion and GitHub.

Hosting and infrastructure providers

Providers supporting website hosting, applications, databases, backups, network infrastructure and technical security.

Website analytics and consent management

We use the self-hosted Umami platform for website analytics and the self-hosted Klaro platform for managing cookie preferences and consent.

These systems are managed within our own hosting environment. We do not use external providers for these functions that process the collected data for their own purposes.

AI and automation providers

Approved AI model providers and automation services, where their use is permitted and relevant to the processing activity.

Financial and administrative service providers

Including accountants, payroll administrators, payment providers and financial administration services such as Moneybird and Nmbrs.

IT support and security providers

Including our managed IT service provider and other authorised specialists who may require access for support, maintenance or security purposes.

Business and communication providers

Including CRM systems, recruitment platforms, professional networking services, email communication providers and marketing services.

Professional advisers and public authorities

Including legal advisers, auditors, insurers, regulators, tax authorities and other bodies where disclosure is necessary or legally required.

Where a third party acts as a processor on our behalf, we arrange appropriate contractual and organisational safeguards as required by Article 28 GDPR.

Some recipients act as independent controllers for their own legally defined purposes. In those cases, their processing is governed by their own obligations and applicable privacy information.

We do not share all categories of personal data with every recipient.

Access is limited according to the relevant purpose and the responsibilities of the recipient.

Where appropriate, customer-specific subprocessors are identified separately in the applicable processing documentation or subprocessor information made available to customers.

11. International transfers

TECHLETES is established in the Netherlands and generally prefers processing personal data within the European Economic Area (EEA).

However, certain suppliers, cloud services, support operations and digital tools may involve access to or processing of personal data outside the EEA.

Where personal data is transferred to a country outside the EEA, we assess the applicable requirements of Chapter V GDPR.

Where required, transfers take place on the basis of an appropriate transfer mechanism, such as:

• An adequacy decision by the European Commission;
• The EU-US Data Privacy Framework, where the relevant recipient and processing are covered by an applicable adequacy decision;
• Standard Contractual Clauses approved by the European Commission, together with supplementary safeguards where necessary;
• Another applicable mechanism permitted under the GDPR.

We assess international transfer risks in accordance with applicable legal requirements.

Where specific customer agreements require EEA-only processing, the relevant processing must comply with those contractual restrictions, including applicable requirements concerning hosting, access, support and subprocessors.

You may request further information about relevant international transfer safeguards, including how to obtain a copy of applicable contractual safeguards, by contacting privacy@techletes.ai.

12. How long do we retain personal data?

We retain personal data only for as long as necessary for the purposes for which it was collected, subject to applicable legal obligations and legitimate retention requirements.

Different categories of personal data have different retention periods.

12.1 Website and contact information

Information submitted through contact forms or direct enquiries is retained for the time reasonably necessary to respond, maintain relevant correspondence and follow up on the enquiry.

Where an enquiry results in a customer relationship, relevant information may become part of our customer or contractual records.

Technical and analytics information is retained in accordance with the purposes and retention settings of the relevant systems.

For our self-hosted Umami website analytics platform, the applicable retention periods are determined by the settings configured within our own environment.

12.2 CRM and business contacts

Business contact data is retained while it is relevant to an active or reasonably prospective professional relationship.

Records are periodically reviewed for relevance and accuracy. Data that is no longer necessary for legitimate business purposes is deleted or anonymised, unless another legal basis justifies retention.

Where a person objects to direct marketing, limited suppression information may be retained to ensure the objection continues to be respected.

12.3 Recruitment

If an application does not result in employment, applicant information is normally deleted no later than four weeks after the recruitment procedure has ended.

With the applicant's specific consent, relevant information may be retained for future recruitment opportunities for up to one year after the recruitment procedure.

Applicants may withdraw this consent at any time.

12.4 Employment and personnel records

Employment and payroll records are retained according to applicable statutory requirements.

Relevant financial and payroll records are generally subject to a seven-year fiscal retention requirement.

Where legally required, copies of identity documents and relevant wage tax records may be retained for five years after termination of employment.

Other personnel records are retained according to their specific purpose, applicable employment legislation and the relevant retention schedule.

12.5 Financial and contractual information

Financial administration, invoices and other records subject to Dutch fiscal retention obligations are generally retained for seven years.

Other contractual correspondence and documentation may be retained for an appropriate period where necessary to meet contractual obligations, establish or defend legal claims or comply with applicable law.

12.6 Security and operational logs

Security and operational logs are retained for periods proportionate to their purposes, taking into account the need to investigate incidents, maintain system integrity, prevent misuse and comply with applicable requirements.

Retention arrangements are defined and reviewed according to the relevant system, risk and contractual context.

Where an investigation, dispute or statutory requirement justifies further retention, the relevant records may be preserved for an appropriate additional period.

12.7 Customer data processed on behalf of customers

Where TECHLETES acts as a processor, retention and deletion are governed by the applicable customer instructions, agreement and data processing agreement.

Upon termination of the relevant services, personal data is returned or deleted in accordance with those arrangements, subject to applicable legal requirements.

Where backup systems or technical recovery arrangements prevent immediate deletion of every copy, the remaining data is protected and deleted or overwritten in accordance with the applicable retention and deletion process.

13. How do we protect personal data?

TECHLETES maintains an information security management system (ISMS) aligned with ISO/IEC 27001 and the scope of its certified information security activities.

We apply technical and organisational safeguards appropriate to the nature of the information, the processing activities and the associated risks.

Depending on the system and context, these safeguards include:

• Role-based access controls and least-privilege access;
• Multi-factor authentication and secure authentication mechanisms;
• Encryption of information in transit and, where applicable, at rest;
• Security logging, monitoring and incident detection;
• Controlled management of systems, software and infrastructure;
• Secure development and change management practices;
• Backup and recovery arrangements;
• Supplier and subprocessor assessments;
• Confidentiality obligations and employee security awareness;
• Information classification, retention and secure deletion procedures;
• Periodic risk assessments, reviews and audits.

Security measures are periodically assessed and improved in response to changes in technology, identified risks, incidents and applicable requirements.

No technical or organisational system can guarantee absolute security. Our objective is to maintain safeguards appropriate to the risks of the processing.

Further information is available in our public Information Security Policy.

14. Personal data breaches

TECHLETES maintains procedures for identifying, assessing, recording and responding to information security incidents and personal data breaches.

Where TECHLETES acts as a controller, we assess whether a personal data breach must be notified to the Dutch Data Protection Authority and, where required, to affected individuals.

Notifications are made in accordance with the applicable GDPR requirements, including the 72-hour reporting deadline where relevant.

Where TECHLETES acts as a processor, we notify the relevant controller without undue delay after becoming aware of a personal data breach, in accordance with the GDPR and applicable contractual arrangements.

We cooperate with customers and other relevant parties in investigating and mitigating incidents, as required.

15. Your privacy rights

Under the GDPR, you have certain rights regarding your personal data.

These rights are subject to the conditions and limitations established by applicable law.

Right of access

You can request confirmation of whether we process your personal data and obtain access to that information.

Right to rectification

You can request correction or completion of inaccurate or incomplete personal data.

Right to erasure

You can request deletion of personal data where the applicable legal conditions are satisfied.

Right to restriction

You can request that we restrict processing in circumstances provided for by the GDPR.

Right to data portability

Where applicable, you can request to receive personal data in a structured, commonly used and machine-readable format, or have it transferred to another controller where technically feasible.

Right to object

You can object to processing based on legitimate interests, including profiling based on those interests, on grounds relating to your particular situation.

Where your personal data is processed for direct marketing purposes, you may object at any time, and we will cease processing that data for direct marketing.

Right to withdraw consent

Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing before withdrawal.

Rights concerning automated decision-making

Where applicable, you have rights regarding decisions based solely on automated processing that produce legal or similarly significant effects.

15.1 Exercising your rights

You can exercise your rights by contacting:

privacy@techletes.ai

We generally respond within one month of receiving a request.

Where permitted by the GDPR, this period may be extended by up to two additional months due to the complexity or number of requests. If an extension is necessary, we will inform you within the initial one-month period.

We may request additional information where reasonably necessary to verify your identity and prevent unauthorised disclosure of personal data.

We do not normally charge a fee for exercising privacy rights, unless an applicable GDPR exception permits this.

Where TECHLETES processes personal data solely on behalf of a customer, we may refer your request to the relevant customer or assist that customer in handling it.

16. Is providing personal data mandatory?

In many situations, providing personal data is voluntary.

However, certain information may be necessary to respond to an enquiry, prepare a proposal, conclude or perform an agreement, create an account or comply with legal obligations.

Where personal data is required for contractual or statutory purposes, failure to provide it may prevent us from entering into or fulfilling the relevant agreement or performing the requested activity.

Consent to optional website analytics or marketing activities is not a condition for using the essential features of our corporate website.

17. Children and sensitive personal data

Our corporate website and general business services are primarily intended for professional and organisational users and are not specifically directed at children.

We do not intentionally collect personal data from children for independent marketing purposes.

Certain customer applications may process personal data relating to children or other vulnerable individuals where this falls within the customer's authorised processing activities and applicable contractual and legal requirements.

We also recognise that some services or employment-related processes may involve special categories of personal data or other sensitive information.

Such information is processed only where legally permitted, necessary for the relevant purpose and subject to appropriate safeguards.

Where special categories or criminal-offence-related personal data are involved in customer projects, additional contractual, legal and security requirements may apply.

18. Third-party websites and services

Our websites and communications may contain links to external websites, platforms or applications.

These services may be operated by independent organisations with their own privacy policies and data processing practices.

TECHLETES is not responsible for the independent processing activities of third parties that are outside our control.

We encourage you to review the privacy information of external services before providing them with personal data.

19. Complaints and supervisory authority

If you have a concern about how TECHLETES processes personal data, we encourage you to contact our Privacy Officer so that we can investigate and respond.

You also have the right to lodge a complaint with a competent supervisory authority.

In the Netherlands, the relevant authority is:

Autoriteit Persoonsgegevens (Dutch Data Protection Authority)

Website: https://autoriteitpersoonsgegevens.nl

You may also have the right to seek a judicial remedy under applicable data protection law.

20. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes in our activities, systems, services, legal requirements or data protection practices.

The latest version will be made available through our website and will indicate when it was last updated.

Where required by law, we will provide additional notice or obtain consent before introducing materially different processing activities.

Changes to this Privacy Policy do not retrospectively establish a legal basis for processing previously conducted without one.

21. Contact

For any questions, complaints or requests concerning privacy, personal data or this Privacy Policy, please contact:

TECHLETES B.V. — Privacy Officer

Polarisavenue 175
2132 JJ Hoofddorp
The Netherlands

Email: privacy@techletes.ai
Website: https://www.techletes.ai

We aim to handle privacy-related enquiries carefully, transparently and in accordance with applicable legal requirements.