Privacy Policy

1. Who we are

First PMM is a trade name of SIJ Marketing, based in Oldenzaal, the Netherlands. SIJ Marketing is responsible (the “controller”) for the processing of personal data described in this policy.

• Email: sanne[at]firstpmm.com
• Website: firstpmm.com
• Chamber of Commerce (KvK) number: 67255493
• VAT identification number: NL001563070B62

Sanne IJspeerd is the contact person for all privacy-related questions and requests. You can reach Sanne at sanne[at]firstpmm.com.

2. What we process, why, and on what legal basis

2.1 Visiting the website

When you visit firstpmm.com, your browser automatically sends technical information to our hosting provider, Vercel, such as your IP address, the page you request, the date and time, and your browser and device type. This is needed to show you the website and to protect it against misuse and attacks. We do not use this information to identify you.

• Legal basis: our legitimate interest in providing a website that works and is secure (Article 6(1)(f) GDPR).

2.2 Contact form and email enquiries

When you send a message through the contact form, we receive your name, email address, company name (optional) and your message, including anything else you choose to write in it. The same applies to the information in an email you send us directly.

The contact form sends your message to our mailbox through our email delivery provider, Resend. The website itself does not store your message.

• Purpose: to read and answer your enquiry and to follow up on it.
• Legal basis: our legitimate interest in responding to enquiries and following up on them (Article 6(1)(f) GDPR). Where you ask for information because you yourself want to enter into an agreement with us, we process your data to take steps at your request before entering into that agreement (Article 6(1)(b) GDPR).
• Is it required?
  Sending us a message is voluntary. We need your name, email address and message to be able to reply; without them the form cannot be sent. Your company name is optional.

2.3 Working together

If you are a client, or you work for one of our clients, we process the personal data needed to carry out the assignment, such as your name, job title, business contact details and our correspondence.

• Legal basis: where you are personally our contracting party, the performance of our agreement with you (Article 6(1)(b) GDPR). Where you are a contact person at a client organisation, our legitimate interest in carrying out our agreement with that organisation and communicating with the people involved (Article 6(1)(f) GDPR).

2.4 Business and financial records

We keep business and financial records, such as quotes, agreements, invoices and relevant correspondence, as required by Dutch tax and accounting law.

• Legal basis: compliance with a legal obligation (Article 6(1)(c) GDPR).

2.5 Website analytics — only with your consent

If you agree in the cookie banner, we use Google Analytics 4 to understand how our website is used — for example which pages are visited, how visitors arrive at the site, and how many contact form messages are sent — so that we can improve the website. Google Analytics uses cookies and collects information such as the pages you visit, your interactions with the site, your browser and device type, and your approximate location. We do not send your name, email address or the content of your message to Google Analytics. If you do not give your consent, Google Analytics is not loaded at all.

• Legal basis: your consent (Article 6(1)(a) GDPR). You can withdraw your consent at any time via “Cookie settings” at the bottom of every page. Withdrawing your consent does not affect processing that took place before.

See our Cookie Policy for details.

3. Who processes your data on our behalf

First PMM does not sell your personal data. Your personal data is only shared with the service providers below, which process it on our behalf, or when we are legally required to share it.

These providers process personal data under data processing terms that form part of their service agreements with us.

4. Transfers outside the European Economic Area

Our service providers are based in the United States, and some personal data is processed or stored there:

• Vercel processes website data in the United States. Vercel is certified under the EU-U.S. Data Privacy Framework, and its data processing addendum includes the EU Standard Contractual Clauses.
• Resend stores email content and delivery logs in the United States. Its data processing addendum includes the EU Standard Contractual Clauses.
• Google may process data in the United States. Google LLC is certified under the EU-U.S. Data Privacy Framework; Google’s data processing terms include the EU Standard Contractual Clauses as a fallback. For Google Analytics, data from visitors in the EU is collected on servers in the EU.

The European Commission has decided that the EU-U.S. Data Privacy Framework provides an adequate level of protection for personal data transferred to certified US companies (adequacy decision of 10 July 2023). The Standard Contractual Clauses are contract terms approved by the European Commission. You can contact us for more information about these safeguards.

5. How long we keep your personal data

We keep personal data no longer than necessary for the purpose for which it was collected.

• Enquiries that do not lead to working together: up to 24 months after our last meaningful contact.
• Client correspondence and project information: for as long as needed to carry out the assignment and deal with any follow-up.
• Business and financial records: seven years, as required by Dutch tax and accounting law. This period starts once a record is no longer current — for example, after an agreement has ended.
• Copies at Resend:
  Resend automatically deletes email content and delivery logs after 30 days.
• Hosting logs at Vercel: runtime logs are kept for a maximum of one day.
• Analytics data: detailed data in Google Analytics is kept for 14 months. Aggregated statistics that do not identify individual visitors may be kept longer.

6. Your rights

You have the right to:

• access the personal data we hold about you;
• have incorrect personal data corrected;
• have your personal data deleted;
• restrict the processing of your personal data;
• object to processing based on our legitimate interests;
• receive your personal data in a structured, commonly used format, or have it transferred to another organisation (data portability);
• withdraw your consent at any time, where processing is based on consent. This does not affect processing that took place before.

To exercise any of these rights, email sanne[at]firstpmm.com. We will respond within one month. If a request is complex, or we receive many requests, this period may be extended by up to two further months; if so, we will let you know within the first month.

We may ask for additional information if we need it to confirm your identity. We will not ask for a copy of your identity document unless there is no other way to verify who you are.

You also have the right to file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). We would appreciate the chance to address your concerns first, so please feel free to contact us.

7. Automated decision-making

First PMM does not make decisions based on automated processing that may have significant consequences for individuals.

8. Children

Our website and services are not intended for children under the age of 16, and we do not knowingly collect their personal data.

9. How we protect your personal data

We take appropriate technical and organisational measures to protect personal data against loss, misuse and unauthorised access. These include:

• all traffic to and from our website is encrypted (HTTPS);
• contact form messages are handled on the server, and the access keys for our email provider are stored encrypted in our hosting environment, not in the website’s code;
• the website’s code and content management system are only accessible with login credentials;
• messages sent through the website are only accessible to Sanne IJspeerd.

No method of transmission or storage is completely secure. If you believe your personal data is not properly protected, or you suspect misuse, please contact us at sanne[at]firstpmm.com.

10. Cookies

We only use analytics cookies with your consent. You can read more, and change your choice at any time, in our Cookie Policy.

11. Links to other websites

Our website links to other websites, such as LinkedIn. We do not load content, buttons or tracking from those websites on our own pages. When you follow a link, the privacy policy of that website applies — for LinkedIn: linkedin.com/legal/privacy-policy.

12. Changes to this privacy policy

We may update this privacy policy, for example when our website or the services we use change. The latest version is always available on this page, with the date it was last updated at the top.