What this site collects, and what it doesn't.

Who is responsible

Novo Horizonte Consultancy, an eenmanszaak established in Rotterdam, the Netherlands, is the controller for the processing described here.

• KvK 69690561
• btw-id NL527645928B01
• Email joao@novohorizonteconsultancy.com

The establishment address is available on request. It is not published here because it is a private residence.

What this website does not do

• No cookies are set, so there is no cookie banner and nothing to consent to.
• No analytics, no tag manager, no heatmaps, no advertising or tracking pixels.
• No third-party fonts, scripts or embedded content. Everything the page needs is served from this domain.
• No contact form, and no newsletter sign-up.

The self-check on the home page runs entirely in your browser. Your answers are never transmitted, stored or logged. Closing the tab discards them.

What is processed

Server logs

Serving a web page requires a server, and a server records the requests it answers. Those records include your IP address, the page requested, the time, and your browser's user-agent string. This is technically necessary to deliver the site and to protect it against attack.

Email you send me

If you write to me, I hold your message and your address for as long as needed to answer you and to keep a record of the correspondence. If it leads to an engagement, it becomes part of that file and is kept for the statutory retention period that applies to business records.

Who else is involved

Two processors, and no others.

Website hosting and DNS

This site is hosted on Cloudflare Pages, and the domain's DNS is managed by Cloudflare. Cloudflare Inc. is established in the United States and operates a global network, which means server logs may be processed outside the European Economic Area. Cloudflare offers a data processing addendum incorporating the European Commission's standard contractual clauses, which is the transfer mechanism relied on here.

I have weighed this. The site collects nothing from visitors, so the only personal data involved is the IP address in a server log. Against that, keeping the domain, DNS and hosting with one provider reduces the number of processors and the opportunities for misconfiguration.

Email

Email for this domain is handled by mailbox.org, operated by Heinlein Hosting GmbH, Schwedter Str. 8/9b, 10119 Berlin, Germany (Amtsgericht Berlin-Charlottenburg, HRB 220010 B). Messages are processed and stored on their servers in Germany. A data processing agreement is in place.

Client data during engagements

This statement covers this website. Processing of client data during an engagement — including any personal data in registers, assessments or documentation I review — is governed by the agreement for that engagement and, where I act as a processor, by the data processing agreement that forms part of it.

Your rights

Under the GDPR you may request access to the personal data I hold about you, ask for it to be corrected or erased, object to processing based on legitimate interest, and ask for processing to be restricted. Write to joao@novohorizonteconsultancy.com and I will respond within one month.

If you are not satisfied with how I handle your request, you may complain to the Dutch supervisory authority, the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl). You are also free to complain to the supervisory authority in your own country of residence.

Changes

If what this site does changes — a booking tool, a contact form, anything that collects something — this statement is updated before that change goes live, not after. The date below tells you when it was last reviewed.