Gizlilik

Privacy Policy

Last updated: 05-10-2025

1. Introduction and Scope

This Privacy Policy describes how Freedom Combination (hereinafter "The Foundation," "we," "us," or "our"), a non-profit organization established in the Netherlands, processes personal data when you use our services.

The Foundation acts as the Data Controller for the personal data processed under this policy. We are committed to protecting the privacy of our users in compliance with the General Data Protection Regulation (GDPR/AVG) and applicable Dutch law.

This Policy applies to the following websites, which share a common backend system for registration, login, and donations:

• https://www.freedomcombination.com
• https://www.trendrights.com
• https://www.kunsthalte.com

By registering an account, logging in, making a donation, or submitting content across any of these domains, you agree to the processing of your data as described in this Policy.

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2. Contact Information

Data Controller: Freedom Combination Registered Address: Taandersplein 1, 3027 CN Rotterdam Contact Email: info@freedomcombination.com

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3. Data We Process and Lawful Basis

Personal data refers to any information relating to an identified or identifiable natural person, including names, addresses, account details, and audio/video recordings. The processing of this data is justified by specific Lawful Bases under GDPR Article 6.

We collect and process personal data for the following purposes:

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3.1. Account Management and Service Provision

• Registration, Login, User Profiles (Authors/Normal Users/Admins)

  • Data Categories: Name, Email Address, Login Credentials, IP Address, Account Status
  • Lawful Basis: Performance of a Contract (GDPR Art. 6(1)(b))
  • Purpose: To create, authenticate, and manage your user account across the three websites.
  • Retention Period: Duration of the account, plus 6 months after termination (for operational clean-up).

• User-Generated Content (UGC) Upload

  • Data Categories: Artwork, Blogs, Content Metadata, Timestamps
  • Lawful Basis: Performance of a Contract (GDPR Art. 6(1)(b))
  • Purpose: To publish and display content pursuant to the Terms & Conditions.
  • Retention Period: As long as the content is published on the websites.

• Processing of Sensitive Data within UGC

  • Data Categories: Special categories of personal data (e.g., health data, political opinions) if voluntarily submitted by users.
  • Lawful Basis: Explicit Consent (GDPR Art. 6(1)(a))
  • Purpose: To process and publish sensitive data that the user voluntarily provides.
  • Retention Period: As long as the content is published.

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3.2. Donations and Financial Compliance

• Donation Processing & Record Keeping

  • Data Categories: Donor Identity, Transaction Details, Donation Amount
  • Lawful Basis: Legal Obligation (GDPR Art. 6(1)(c))
  • Purpose: To comply with mandatory bookkeeping and financial reporting requirements of the Netherlands Tax Administration (Belastingdienst).
  • Retention Period: Minimum 7 years from the end of the year in which the transaction took place, as required by Dutch fiscal law.

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3.3. Website Analytics (Vercel) and Technical Functionality

• Vercel Analytics

  • Data Categories: Anonymized Usage Data, Device Information, Page Views (strictly limited data)
  • Lawful Basis: Legitimate Interest (GDPR Art. 6(1)(f))
  • Purpose: To monitor site performance, measure usage for internal purposes, and ensure security.
  • Retention Period: Maximum 25 months for statistical data; associated analytics cookies limited to 13 months.

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4. Vercel Analytics and Cookie Policy

The Foundation uses Vercel Analytics for internal statistical purposes only and has implemented a strictly technical configuration to ensure this data is non-personally identifiable and consent-exempt under the ePrivacy Directive, as enforced by the Dutch Data Protection Authority (AP).

This means:

1. No Explicit Consent Banner Required: We rely on the legal ground of Legitimate Interest for this limited data processing.
2. Strict Anonymization: Your IP address is anonymized (masked) before processing, and the tracking is strictly limited.