Privacy and Cookie Policy

Last updated: 14 October 2026. This notice explains how we handle personal information under the EU General Data Protection Regulation (GDPR) and the Dutch GDPR Implementation Act (UAVG).

1. Who we are

The controller of your personal information is Smart Horizon, Amsterdam, the Netherlands. Contact us about privacy at info@smart-horizon.eu.

2. Information we collect

• Enquiries and in-house requests: your name, organisation, work email, optional phone number, and the programme, location, dates and message you provide.
• Quotations and registrations: billing organisation, contact name and email, billing address, optional VAT or tax ID and purchase order reference, and participant names, email addresses, job titles, organisations and phone numbers you provide, together with notes and the selected course and session.
• Website and security data: IP address, browser details and requested pages recorded in server logs and used for rate limiting and security.
• Optional analytics and chat: only if you accept cookies, Google Analytics usage information and the content of any Tawk.to live-chat conversation.

Please do not send sensitive information (such as health details) unless it is needed, for example to arrange accessibility support.

3. How we use it and our lawful bases

• To respond to enquiries and prepare quotations: our legitimate interest in answering business requests, or steps you ask us to take before a contract.
• To process registrations, issue acknowledgements, invoices and booking communications, and administer training: performance of a contract, or steps before entering into one.
• To keep accounting and tax records: compliance with legal obligations.
• To protect the website and prevent misuse: our legitimate interests.
• Analytics and live chat cookies: your consent, which you can withdraw at any time.

Booking emails are transactional. We do not send marketing emails without consent, and we do not sell personal information or make decisions about you by purely automated means.

4. Who we share it with

We share personal information only as needed with our website hosting and email service providers, Google (Google Analytics, if you consent), Tawk.to (live chat, if you consent), training venues and trainers where needed to deliver a confirmed course, professional advisers, and authorities where required by law. Service providers act on our instructions.

5. International transfers

Some providers, including Google and Tawk.to, may process information outside the European Economic Area. Where they do, we rely on European Commission adequacy decisions or appropriate safeguards such as the Standard Contractual Clauses.

6. How long we keep it

We keep enquiry information for as long as needed to respond and follow up on your request. Quotation, registration, invoice and accounting records are kept for as long as required by Dutch company and tax law, generally seven years after the end of the relevant financial year. Server logs are kept only for as long as needed for security and troubleshooting.

7. Your rights

You have the right to request access to, correction or deletion of your personal information, to restrict or object to its use, to data portability, and to withdraw consent at any time. To exercise these rights, email info@smart-horizon.eu. You can also complain to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at autoriteitpersoonsgegevens.nl, although we would appreciate the chance to address your concern first.

8. Cookies and similar technologies

Strictly necessary storage is always used: your cookie choice is saved in your browser under sh-cookie-consent, and the administration area uses a secure session cookie. Optional cookies are set only after you select Accept: Google Analytics (_ga and _ga_*, up to two years) measures website use, and Tawk.to live chat sets cookies to maintain chat sessions. If you reject, the website remains fully usable, but live chat is not loaded. You can change your choice at any time using Cookie settings, also available in the website footer.

9. Changes to this notice

We will update this notice when our practices change and show the date of the latest version above.