Privacy Policy

Introduction

Discernment ("we", "us", "our") is committed to protecting your privacy. This policy explains how we collect, use, and protect your personal data when you use our website and services.

Discernment is a registered business in the Netherlands (KVK: 82057133). We process personal data in accordance with the General Data Protection Regulation (GDPR) and Dutch data protection law.

Data Controller

What data we collect

Website visitors

When you visit our website, we may collect:

• Technical information (IP address, browser type, device type)
• Pages visited and time spent on the site
• Referral source

We use this information to understand how our website is used and to improve the user experience. We do not use tracking cookies for advertising purposes.

Contact form submissions

When you contact us, we collect:

• Name
• Email address
• Organisation (if provided)
• Message content

We use this information solely to respond to your enquiry and, if applicable, to provide our services.

Service delivery

When you engage our services (Discernment Snapshot or On-ramp), we collect:

• Information provided in intake questionnaires
• Notes from assessment sessions
• Information necessary for invoicing

Client information gathered during service delivery is used only to provide the agreed services and is not shared with third parties without explicit consent.

Legal basis for processing

We process your personal data based on:

• Contract performance: When necessary to deliver services you have requested
• Legitimate interests: For website analytics and improving our services
• Consent: When you have given explicit consent (e.g., newsletter subscription)
• Legal obligation: When required by law (e.g., tax records)

Data retention

• Contact enquiries: Retained for 2 years after last contact, then deleted
• Service delivery data: Retained for the duration of the engagement plus 7 years for legal/tax purposes
• Website analytics: Aggregated data retained indefinitely; individual session data retained for 26 months

Data sharing

We do not sell your personal data. We may share data with:

• Service providers: Hosting providers, email services, payment processors — all bound by data processing agreements
• Legal authorities: When required by law

International transfers

Your data is primarily processed within the European Economic Area (EEA). Where we use service providers outside the EEA, we ensure appropriate safeguards are in place (such as Standard Contractual Clauses or adequacy decisions).

Your rights

Under GDPR, you have the right to:

• Access: Request a copy of your personal data
• Rectification: Request correction of inaccurate data
• Erasure: Request deletion of your data ("right to be forgotten")
• Restriction: Request limitation of processing
• Portability: Receive your data in a machine-readable format
• Objection: Object to processing based on legitimate interests
• Withdraw consent: Where processing is based on consent

To exercise these rights, contact us at privacy@discernment.ai. We will respond within 30 days.

Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. This includes encryption, access controls, and regular security assessments.

Cookies

Our website uses essential cookies required for the site to function. We use minimal analytics to understand site usage. You can control cookie preferences through your browser settings.

Complaints

If you believe we have not handled your personal data properly, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens):

Changes to this policy

We may update this privacy policy from time to time. Significant changes will be communicated through our website. The "last updated" date at the top of this page indicates when the policy was last revised.

Contact

For questions about this privacy policy or how we handle your data, contact us at privacy@discernment.ai.