Privacy Policy

Miro Kloosterman operates as the Data Controller pursuant to Article 4(7) GDPR for all personal data collected through this website and associated services. For any inquiries, requests to exercise your statutory rights, or clarification of our practices, you can reach us directly at:

We only collect minimal personal data necessary to facilitate high-quality interactions, coordinate retreats and consultations, and maintain secure digital operations:

• Discovery Call & Contact Forms: When booking a call or reaching out, you provide your name, email address, phone number/messaging handle, and responses to scheduling questions. We use this information strictly to correspond with you and prepare for your consultation.
• Newsletter Subscription: If you opt-in to receive our letters and updates, we collect your email address. You can unsubscribe at any time via the link included in every newsletter.
• Technical & Log Data: When visiting our website, technical details such as your IP address, browser type, operating system, access timestamps, and page request headers are recorded in standard server log files to maintain network security and system stability.
• Cookie Identifiers & Device Information: Subject to your consent, we process cookie identifiers and online identifiers to understand how our website is used and optimize its layout and flow.

We use cookies and similar technologies to ensure our website operates securely and efficiently. Under GDPR, you have the right to accept or decline optional cookies:

• Necessary Cookies: Required for fundamental site functionality, secure communication, and cookie consent preferences.
• Analytics Cookies: Active only if you grant consent via our Cookie Banner or Settings. Analytics services process pseudonymized technical information that does not directly identify you, but may still constitute personal data under the GDPR.
• Functional & Media Cookies: Used to display embedded media content (e.g. video players) and retain viewing preferences.

You can adjust or withdraw your consent at any time by clicking Manage Cookies in the website footer.

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

• Consent (Art. 6(1)(a) GDPR): For sending newsletters, non-essential cookies, and optional analytical tracking.
• Performance of a Contract / Pre-Contractual Steps (Art. 6(1)(b) GDPR): To schedule, coordinate, and deliver discovery calls, coaching sessions, or retreat bookings initiated by you.
• Legitimate Interests (Art. 6(1)(f) GDPR): To ensure IT infrastructure security, prevent fraudulent abuse, and optimize website accessibility.
• Explicit Consent for Sensitive Data (Art. 9(2)(a) GDPR): Where health-related details are voluntarily provided in free-text form submissions.

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected or to comply with statutory retention requirements:

• Contact & Consultation Inquiries: Retained for up to 12 months following your last interaction, unless a coaching or retreat contract ensues.
• Newsletter Subscriptions: Retained until you withdraw consent or unsubscribe via the provided link.
• Analytical Data: Pseudonymized analytics logs are retained for 14 months before automated deletion.
• Server Security Logs: Automatically erased after 30 to 90 days.

Under the GDPR, you have the following rights regarding your personal data:

• Right of Access (Art. 15 GDPR): You may request confirmation of whether we process your data and obtain a copy of held records.
• Right to Rectification (Art. 16 GDPR): You may request immediate correction of inaccurate or incomplete details.
• Right to Erasure (“Right to be Forgotten”) (Art. 17 GDPR): You may request the deletion of your personal data where statutory conditions apply.
• Right to Restriction of Processing (Art. 18 GDPR): You may request restricted handling of your data under specific legal conditions.
• Right to Data Portability (Art. 20 GDPR): You may request your data in a structured, commonly used, and machine-readable format.
• Right to Object & Withdraw Consent (Art. 21 & 7(3) GDPR): You can revoke consent or object to processing based on legitimate interests at any time.

We will respond to your request without undue delay and, in most cases, within one month as required by the GDPR. Where legally permitted, this period may be extended by up to two additional months if your request is particularly complex. To exercise your rights, please contact us by email.

You also have the right to lodge a formal complaint with the competent supervisory authority:
Autoriteit Persoonsgegevens (Dutch Data Protection Authority)
Website: https://autoriteitpersoonsgegevens.nl

To deliver our web platform and administrative services, we utilize specialized third-party service providers acting as subprocessors under Article 28 GDPR. Where required, we enter into Data Processing Agreements (DPAs) with our processors to ensure compliance and high data protection standards:

• Web3Forms: Processes submitted form data to securely transmit your message to us. Their processing is governed by their privacy policy and data protection terms.
• Kit (formerly ConvertKit): Manages email newsletter subscriptions and distribution under strict security protocols.
• Google Analytics (Google Ireland Limited): Used with IP anonymization enabled to analyze aggregated website usage while minimizing the processing of identifiable information.
• Microsoft Clarity (Microsoft Ireland Operations Limited): Provides pseudonymized heatmap analytics and aggregated navigation insights to refine user experience.
• YouTube (Google Ireland Limited): Embedded video content operates in privacy-enhanced mode where available to minimize automatic tracking prior to user playback.

Some of our service providers (such as Google, Microsoft, Kit, and Web3Forms) may process personal data outside the European Economic Area (EEA), including in the United States. Where international transfers occur, we ensure appropriate safeguards are implemented in compliance with Chapter V GDPR, relying on adequacy decisions under the EU-U.S. Data Privacy Framework, European Commission Standard Contractual Clauses (SCCs), or other legally recognized transfer mechanisms.

We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects under Articles 13–15 GDPR.

This website and our services are not intended for children under the age of 16, and we do not knowingly collect personal data from children. If you believe a minor has provided us with personal data, please contact us immediately so we can remove it.

We may update this Privacy Policy periodically to reflect changes in our operational practices or legal requirements. Any revisions will be posted directly on this page along with an updated effective date.