Privacy Policy

Last updated: 15th January 2026

1. Introduction

ClearMemorium B.V. ("we", "our", or "us") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, store, and protect your personal data when you use our real estate consultancy services or visit our website at clearmemorium.info.

As a company registered in the Netherlands (Registration Number: NL91837463), we comply with the General Data Protection Regulation (GDPR) and Dutch data protection laws.

2. Data Controller Information

ClearMemorium B.V. is the data controller for the personal information we collect and process. You can contact us regarding data protection matters at:

• Address: Lindelaan 221, 4890 EL Breda, Netherlands
• Email: [email protected]
• Phone: +31 764936578

3. Data We Collect

We collect and process various types of personal data depending on how you interact with our services. The data we collect includes:

3.1 Information You Provide Directly

• Contact Information: Name, email address, phone number, postal address
• Professional Information: Company name, job title, business requirements
• Property Information: Details about properties you own or are interested in
• Communication Records: Emails, phone calls, meeting notes, and other correspondence
• Service Preferences: Your consultancy requirements and service preferences

3.2 Information Collected Automatically

• Website Usage Data: Pages visited, time spent, browser type, device information
• Technical Information: IP address, browser settings, operating system
• Cookies and Tracking: As detailed in our Cookie Policy

4. How We Use Your Information

We use your personal data for legitimate business purposes and in accordance with the legal bases provided under GDPR. We use of your data includes:

4.1 Service Delivery

• Providing real estate consultancy services
• Conducting property valuations and market analysis
• Preparing reports and recommendations
• Managing client relationships and communications

4.2 Business Operations

• Processing enquiries and service requests
• Managing contracts and billing
• Maintaining business records
• Complying with legal and regulatory requirements

4.3 Website and Marketing

• Improving our website functionality and user experience
• Sending relevant information about our services
• Market research and business development

5. Cookies and Tracking Technologies

We may use cookies and tracking technologies for analytics, advertising, and remarketing purposes, including Google Ads. These technologies help us measure campaign effectiveness, deliver relevant advertisements, and improve our services. You can manage your cookie preferences at any time through our cookie consent banner.

For detailed information about our use of cookies, please see our Cookie Policy.

6. Legal Basis for Processing

Under GDPR, we process your personal data based on the following legal grounds:

• Contract Performance: To provide our consultancy services
• Legitimate Interests: For business operations and service improvement
• Legal Compliance: To meet regulatory and legal obligations
• Consent: For marketing communications and optional services

7. Data Sharing and Third Parties

We do not sell your personal data to third parties. We may share your information in the following circumstances:

• Service Providers: Trusted partners who assist with our operations
• Legal Requirements: When required by law or legal proceedings
• Business Partners: With your explicit consent for specific projects
• Professional Advisors: Legal, financial, and technical consultants

8. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected or as required by law. Our data retention periods include:

• Client Records: 7 years after the end of our business relationship
• Financial Records: As required by Dutch tax and accounting laws
• Marketing Data: Until you withdraw consent or object to processing
• Website Data: As specified in our Cookie Policy

9. Your Rights

Under GDPR and Dutch data protection law, you have the following rights regarding your personal data:

• Right of Access: Request information about how we process your data
• Right to Rectification: Correct inaccurate or incomplete information
• Right to Erasure: Request deletion of your personal data
• Right to Restrict Processing: Limit how we use your data
• Right to Data Portability: Receive your data in a structured format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent for consent-based processing

10. Data Security

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

• Encryption of sensitive data in transit and at rest
• Regular security assessments and updates
• Access controls and staff training
• Secure data storage and backup procedures

11. International Data Transfers

We primarily process data within the European Economic Area (EEA). If we transfer data outside the EEA, we ensure appropriate safeguards are in place, including:

• Adequacy decisions by the European Commission
• Standard Contractual Clauses
• Binding Corporate Rules
• Certification schemes and codes of conduct

12. Contact Information

If you have questions about this Privacy Policy or wish to exercise your data protection rights, please contact us:

• Privacy Email: [email protected]
• General Email: [email protected]
• Phone: +31 764936578
• Address: ClearMemorium B.V., Lindelaan 221, 4890 EL Breda, Netherlands

13. Complaints

If you believe we have not handled your personal data in accordance with this Privacy Policy or applicable law, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or your local supervisory authority.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any material changes by posting the updated policy on our website and updating the "Last updated" date at the top of this page.