Privacy Policy

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1. Who we are

ciferi is operated by DVSC (KVK: 92458378), based in the Netherlands. DVSC is the data controller for any personal data collected through ciferi.com. References to "we," "us," or "ciferi" in this policy refer to DVSC.

2. What data we collect

We collect only the data you voluntarily provide:

• Email address — when you subscribe to our newsletter, download a free resource, or purchase a product.

We do not collect names, phone numbers, IP addresses for profiling, or any special category data. Our free tools run entirely in your browser — no calculation inputs are sent to our servers.

3. How we use your data

We use your email address for the following purposes:

• Delivering the lead magnet or resource you requested.
• Sending our weekly newsletter with practical audit insights.
• Transactional emails related to purchases (order confirmations, download links).

We do not sell, rent, or share your personal data with third parties for their marketing purposes.

4. Lawful basis

We process your email address on the basis of consent (Article 6(1)(a) GDPR). You provide this consent when you enter your email address and click a submit button on any of our forms. For purchase-related emails, we also rely on contractual necessity (Article 6(1)(b) GDPR).

5. Data processors

We use the following third-party services to operate ciferi.com:

• MailerLite (Lithuania, EU) — email marketing and delivery.
• Cloudflare (US, with EU processing) — website hosting, CDN, and security.
• Gumroad (US) — payment processing for paid products.

Each processor handles data under a data processing agreement and processes your data only as instructed by us.

6. Data retention

We retain your email address for as long as you remain subscribed to our communications. When you unsubscribe, your email address is removed from our active mailing lists. Gumroad retains transaction records as required by applicable tax and accounting laws.

7. Cookies and tracking

ciferi.com does not use cookies for tracking or advertising. We use Cloudflare Web Analytics, which collects anonymous, aggregated page-view data without cookies or personal identifiers. No consent banner is required.

8. Your rights

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

• Access — request a copy of the data we hold about you.
• Rectification — correct inaccurate data.
• Erasure — request deletion of your data.
• Portability — receive your data in a structured, machine-readable format.
• Withdraw consent — unsubscribe at any time via the link in every email, or by contacting us directly.
• Lodge a complaint — you may file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) if you believe your rights have been violated.

9. International transfers

Some of our processors (Cloudflare, Gumroad) are based in the United States. These transfers are covered by Standard Contractual Clauses (SCCs) or equivalent safeguards as required by the GDPR.

10. Changes to this policy

We may update this privacy policy from time to time. Material changes will be noted with an updated date below. Continued use of ciferi.com after changes constitutes acceptance of the revised policy.

11. Contact

For any privacy-related questions or to exercise your rights, email [email protected].

Last updated: March 2026