Privacy policy.

Frently B.V. ("Frently", "we", "our", "us") is committed to protecting the privacy and personal data of all individuals who use our website www.frently.nl and related services. This Privacy Policy explains what personal data we collect, why we collect it, how we use it, with whom we may share it, and what rights you have under applicable law.Frently provides legal assistance to tenants in the Netherlands, including rent checks, service cost recovery, and representation before the Huurcommissie(Rental Committee). In the course of providing these services, we necessarily process personal data.This Privacy Policy applies to all visitors to our website, prospective clients, and existing clients. We process personal data in accordance with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) and any applicable Dutch implementing legislation.

2. Data Controller

The data controller responsible for your personal data is:

Frently B.V.

Website: www.frently.nl\

Email: info@frently.nl

If you have any questions, concerns, or requests regarding your personal data, please contact us at the email address above.

3. What Personal Data We Collect

3.1 Data You Provide Directly

• Contact information: your name, email address, phone number, and postal address.

• Rental contract and tenancy documents: your rental agreement, lease start date, rent amount, service cost breakdowns, and related correspondence with your landlord.

• Financial data: information about payments made to your landlord, bank account details where relevant for processing refunds or legal proceedings.

• Case-related correspondence: emails, messages, or documents you share with us in connection with your case.

• Identity documents: where required for legal representation purposes, copies of identification documents.

3.2 Data Collected Automatically

• Usage data: IP address, browser type, operating system, pages visited, referring URL, and timestamps.

• Cookies and tracking technologies: see Section 9 (Cookies) for details.

4. Legal Basis for Processing

We process your personal data on the following legal bases under Article 6 GDPR:

• Performance of a contract (Art. 6(1)(b)): processing necessary to provide you with our services, including reviewing your rental contract, preparing case files, and representing you before the Huurcommissie.

• Legitimate interests (Art. 6(1)(f)): processing for website analytics, security, fraud prevention, and internal business administration, where such interests are not overridden by your rights.

• Legal obligation (Art. 6(1)(c)): processing required to comply with applicable laws and regulations, including record-keeping and anti-money laundering obligations.

• Consent (Art. 6(1)(a)): where you have explicitly consented to specific processing, such as receiving marketing communications or the use of non-essential cookies.

Where we process special categories of data (e.g. financial hardship information relevant to a legal case), we rely on Art. 9(2)(f) GDPR (establishment, exercise, or defence of legal claims).

5. How We Use Your Personal Data

We use your personal data for the following purposes:

• To assess your rental situation and determine whether you have a valid claim.

• To provide legal services, including drafting correspondence, preparing submissions, and representing you.

• To communicate with you about your case status, required documents, and outcomes.

• To process payments on a no-cure-no-pay basis where applicable.

• To comply with legal and regulatory obligations.

• To improve our website and services through analytics.

• To send you service-related communications (e.g. case updates, document requests).

• With your consent, to send you newsletters or promotional communications.

6. Sharing Your Personal Data

We do not sell your personal data. We may share your data with:

6.1 Third-Party Service Providers

We engage trusted processors who act on our behalf, including:

• IT and hosting providers (servers located within the European Economic Area).

• Email and communication services.

• Legal software and case management tools.

• Payment processors.

All processors are bound by data processing agreements ensuring GDPR compliance.

6.2 Regulatory Bodies and Courts

Where required for your legal case, we share relevant documentation with the Huurcommissie, courts, or other competent authorities in the Netherlands.

6.3 Legal Obligations

We may disclose your data where required by law, court order, or to protect our legal rights.

6.4 International Transfers

We do not routinely transfer your personal data outside the European Economic Area. Where any transfer occurs, we ensure appropriate safeguards are in place in accordance with Chapter V of the GDPR (e.g. Standard Contractual Clauses).

7. Data Retention

We retain your personal data only for as long as necessary for the purposes described in this Policy, or as required by law. Specifically:

• Client case files: retained for 7 years following the conclusion of your case, in accordance with Dutch legal and tax record-keeping requirements.

• Website usage data: retained for a maximum of 26 months.

• Marketing consent records: retained until you withdraw consent plus an additional 1 year for compliance demonstration.

After the relevant retention period expires, personal data is securely deleted or anonymised.

8. Your Rights Under the GDPR

As a data subject, you have the following rights under the GDPR:

• Right of access (Art. 15): you may request a copy of the personal data we hold about you.

• Right to rectification (Art. 16): you may request correction of inaccurate or incomplete data.

• Right to erasure (Art. 17): you may request deletion of your personal data, subject to legal retention obligations.

• Right to restriction of processing (Art. 18): you may request that we limit how we use your data in certain circumstances.

• Right to data portability (Art. 20): you may request your data in a structured, machine-readable format.

• Right to object (Art. 21): you may object to processing based on legitimate interests, including direct marketing.

• Right to withdraw consent: where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at info@frently.nl. We will respond within one month. If you believe we have not handled your data correctly, you have the right to lodge a complaint with the Dutch Data Protection Authority:

Autoriteit Persoonsgegevens Website: www.autoriteitpersoonsgegevens.nl Telephone: +31 (0)70 888 8500

9. Cookies

Our website uses cookies and similar technologies. Cookies are small text files stored on your device that help us operate and improve our website.

9.1 Types of Cookies We Use

• Strictly necessary cookies: essential for the website to function. These cannot be disabled.

• Analytical/performance cookies: help us understand how visitors use our website (e.g. Google Analytics). These are only placed with your consent.

• Functional cookies: remember your preferences to enhance your experience.

You can manage or withdraw your cookie consent at any time via your browser settings or our cookie preference centre. Note that disabling certain cookies may affect website functionality.

10. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or alteration. These measures include:

• Encrypted transmission (TLS/HTTPS) for all data transfers.

• Access controls ensuring only authorised personnel can access case data.

• Secure storage of documents with access logging.

• Regular security reviews and staff training on data protection.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the Autoriteit Persoonsgegevens in accordance with our obligations under Art. 33–34 GDPR.

11. Children's Privacy

Our services are intended for adults aged 18 and over. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will promptly delete it.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will publish the updated version on our website with a revised "Last updated" date. For material changes, we will notify you by email if we hold your contact details.

We encourage you to review this Policy periodically.