GDPR / AVG

What this page covers

This page explains how Revenue Guru Insights complies with the General Data Protection Regulation (Regulation (EU) 2016/679) and the Dutch implementing law (Uitvoeringswet AVG). For a full breakdown of what data we process and why, see our Privacy Policy.

Your rights

You have the following rights under the GDPR / AVG:

How to exercise your rights

Email joris@revenueguru.nl with the subject "Privacy request". Tell us which right you want to exercise. To prevent unauthorized requests, we may ask you to verify your identity (for example, by replying from the email address we have on file).

We respond within 30 days. For complex or stacked requests, we may extend this by up to two further months and tell you why. There is no fee for reasonable requests.

Data we process

Through this marketing site:

• Email correspondence you send us via the contact links
• Standard server logs (IP address, browser type, page requested) collected by our hosting provider for security
• Aggregate visit statistics via Vercel Web Analytics — cookieless, IP hashed before processing, no individual identification, only aggregate counts (pageviews, country, device type, referrer)

That's it. No tracking pixels, no advertising IDs, no individual analytics profiling, no third-party data brokers.

Through the RGI application at app.revenueguru.nl: hotel commercial operations data (reservations, occupancy, rates) processed under a separate Data Processing Agreement signed with each hotel customer. We do not store guest personal data from hotel PMS systems — only nationality codes, never names, emails, addresses, or payment data.

Legal basis for processing

• Contact emails: processed on the basis of your own initiative (Art. 6(1)(b) — pre-contractual measures) and our legitimate interest in responding to inquiries.
• Server logs: legitimate interest in operating the site securely (Art. 6(1)(f)).
• RGI app data: contractual necessity under the customer agreement (Art. 6(1)(b)).

International transfers

Some of our infrastructure providers (Vercel, Resend) are headquartered outside the European Economic Area. When personal data is transferred outside the EEA, we rely on the European Commission's Standard Contractual Clauses or equivalent transfer mechanisms required by GDPR Article 46.

Data retention

We don't keep data longer than necessary. Email correspondence is kept while it's relevant to an active conversation or business relationship. Server logs are rotated by our hosting provider (typically days to weeks). Customer app data is governed by the Data Processing Agreement and deleted at contract end (or earlier on request).

Right to lodge a complaint

If you believe we've handled your data wrongly, you can complain to the Dutch supervisory authority:

Autoriteit Persoonsgegevens
autoriteitpersoonsgegevens.nl

We'd appreciate the chance to address your concern first — please email joris@revenueguru.nl before filing a complaint, but the right to complain directly remains yours.

Data Protection Officer

We are not required by GDPR to appoint a formal Data Protection Officer. For all data protection matters, the responsible person is Joris Bruyning, reachable at joris@revenueguru.nl.

Updates

We update this page when our practices change. The "last updated" date at the top reflects the current version.