Privacy notice
How we handle personal data.
This notice covers the website at noetra.eu and the mail you send us. The last section covers data in client engagements.
Who is responsible
- Controller
- Luis Zadra, trading as Noetra, a Belgian eenmanszaak
- Postal address
- Hubert Frère-Orbanlaan 247, 9000 Gent, Belgium
- luis@noetra.eu
- Website
- Joshua Clercx maintains this website and its code on Luis's instructions, as a processor
What happens when you open a page
Cloudflare serves this site. Its network receives your IP address, the page you ask for, your browser's user agent and the time, and keeps them in its request logs.
Lawful basis: legitimate interest under Article 6(1)(f) in running and securing a website.
Audience measurement
Every page loads Cloudflare Web Analytics, a small script from
static.cloudflareinsights.com that reports to
cloudflareinsights.com. It counts page views and shows roughly where in the
world they come from. It sets no cookie and stores nothing on your device.
Lawful basis: legitimate interest under Article 6(1)(f) in knowing whether anyone reads the site.
We hold no copy of this data ourselves. We see counts, not individual visits.
What happens when you email us
Mail sent to an address at noetra.eu is delivered to our mailboxes in Google Workspace. Google holds it on our instructions, as a processor.
The contact form
The form on the home page collects your name, email address, company and message. A program on Cloudflare's network checks the submission and hands it to Brevo, a French email provider, which delivers it to luis@noetra.eu. The program keeps no copy.
The check uses Cloudflare Turnstile, a bot challenge that loads from
challenges.cloudflare.com when you first use the form. Turnstile receives
your IP address.
Lawful basis for mail and the form: legitimate interest under Article 6(1)(f) in answering an enquiry you started and in keeping automated submissions out. Once the exchange is about a possible engagement, Article 6(1)(b), steps taken at your request before a contract, applies as well.
Cookies
This site sets no cookies and stores nothing on your device, so it shows no consent banner.
Turnstile runs without pre-clearance, the setting that would make it set a cookie. Anything it keeps on your device is strictly necessary for sending the form, which Article 5(3) of the ePrivacy Directive exempts from consent.
Who else sees your data
| Who | What they do | Where | Relationship |
|---|---|---|---|
| Cloudflare | Serves the site, measures page views, checks contact form submissions | Global network, US company | Processor under Cloudflare's data processing addendum |
| Brevo | Delivers contact form submissions to our mailbox | France | Processor |
| Runs our mailboxes in Google Workspace | Global, US company | Processor under the Cloud Data Processing Addendum |
Transfers outside the EEA
Cloudflare and Google are US companies and process data worldwide. Both are certified under the EU-US Data Privacy Framework, and transfers to them rely on the European Commission's adequacy decision for that framework. Both agreements also carry Standard Contractual Clauses, which apply if that decision falls away. Copies are available on request.
How long anything is kept
- Your emails
- For as long as the conversation is live, then for as long as we may need to show what was agreed. We review the mailbox once a year and delete what is no longer needed. Deleted mail can be recovered for 55 days, and Google erases it from its systems within 180 days after that.
- Contact form submissions
- The form itself keeps nothing. Brevo keeps a record of the send under its own retention policy. Once delivered, the message is an email and the line above applies.
- Server logs and audience measurement
- Held by Cloudflare under its own retention policy.
Your rights
You can ask for a copy of what we hold about you, and ask us to correct it, delete it, restrict its use or hand it to someone else. Because we rely on legitimate interest, you can also object at any time, and we then stop unless we have compelling grounds that override your objection.
Email luis@noetra.eu or write to the postal address above. We answer within one month, free of charge.
Giving us your details is not a statutory or contractual requirement. Without an email address we cannot reply.
We make no automated decisions about you, including profiling, that have legal or similarly significant effects.
If you want to complain
You can complain to the Belgian Data Protection Authority:
- Authority
- Gegevensbeschermingsautoriteit / Autorité de protection des données
- Address
- Drukpersstraat 35, 1000 Brussel, Belgium
- Telephone
- +32 (0)2 274 48 00
- contact@apd-gba.be
- Website
- gegevensbeschermingsautoriteit.be
Client engagement data
When Noetra analyses a client's data, the client is the controller and Noetra the processor under Article 28. Noetra acts only on the client's documented instructions, under a signed data processing agreement that names the data, the purpose, the duration, the security measures and the deletion terms.
Most of that data describes companies rather than people: contracts, invoices, subscriptions and usage. The personal data in it is mainly contact names, user records and the names of people who sign contracts.
Joshua Clercx is the only person on the sub-processor annex. The rest of the annex is infrastructure. Clients get notice and a right to object before that list changes.
Changes to this notice
Each change gets a new version number and date at the top of this page.