GDPR Privacy Notice

Last updated 7 October 2025

Special provisions for users covered by the General Data Protection Regulation

CONTACT

If you have any questions or concerns regarding this Privacy Notice or our practices, please contact us by sending an email to policies@littlenudgemarketing.com.

GENERAL - WHO WE ARE AND WHAT WE DO

The purpose of this Privacy Notice is to explain how our website littlenudgemarketing.nl (the Website), and our company, Little Nudge Marketing B.V., a limited liability company incorporated in the Netherlands and having its registered address at John M. Keynesplein 4 in (1066 EP) Amsterdam and registered with the local trade register under company number 98187619 (“Little Nudge” or “we” or “us”) secures, shares and uses personal data that it collects and receives from you through its Website or otherwise. We use the terms “personal data”; “processing”; “controller” and “processor” as they are defined in the General Data Protection Regulation (“GDPR”). We may also use the terms personal data and personal information interchangeably.

Little Nudge is a company engaged in the delivery of digital marketing services for its customers (the Services). Its customers consist of other businesses, i.e. legal entities. Little Nudge does not provide services for consumers.

WHOSE DATA WE PROCESS

We process personal data about different categories of people, such as, in relation to our Services, the personal data of: people connected to our customers; people who sign up with us to receive informational newsletters; people who browse our Website and, in relation to our general business purposes, the personal data of people connected to our suppliers, people who are applying for a job with us and people connected to partners we may enter into business ventures with.

WE ARE YOUR CONTROLLER UNDER GDPR

With respect to the processing of personal data as part of our Services, Little Nudge shall be the Controller under GDPR. With respect to specifically the use of Google Analytics, which we use to track (on an anonymous basis) the behavior of visitors on our Website, we shall act as joint controllers together with Google. In all cases, Little Nudge shall be your point of contact for all questions and requests regarding the use of personal data.

WHICH DATA WE PROCESS AND WHY

We process personal data you directly share with us either through our Website or otherwise. Which data we process and why will depend on the nature of your relationship with us. For example, if we decide to offer visitors to our website the chance to receive a newsletter per email, your provided e-mail will only be used for the purpose of sending you the newsletter. If you are connected to our customer, your personal data will be used for the purpose of enabling us to communicate with our customer in the course of our Services. If you are connected to our customers, we may also use your email (insofar allowed under law) to send you direct marketing messages in relation to our own services like the ones you signed up for.

During the onboarding of a new customer, it will be clear for you which personal data we require. After all, you will be requested to directly provide us with the required personal data. Nevertheless, we like to set out here the personal data we require during customer onboarding. At the date of this privacy notice, we will request you to share the following data with us if you are connected to our customers: name, mailing address, company name, company website, and email address.

Aside from personal data which you directly share with us, we may also process information collected from your device, e.g. IP address, the type of device you use etc. Furthermore, we use Google Analytics to collect data connected to people’s behavior on our Website. We use this personal data for the purpose of optimizing our own marketing and our own ability to grow our customer base.

If we collected your personal data as part of our Services or general business purposes, the processing of your data may include disclosures to auditors (such as auditors at the local tax agency) and professional advisors.

LAWFUL BASES FOR PROCESSING

We will only process your personal data if we have a lawful basis for doing so. Depending on the nature of your relationship with us, the lawful basis for the processing of your personal data can include performance of contract; legitimate interests or fulfilment of legal obligations.

We rely on ‘performance of contract’ for the use of personal data of people connected to our customers in order to communicate with them, initiate a contract with our customers and to fulfil our contractual obligations towards our customers. Should we offer a newsletter on our website and you provide your e-mail to us in order to receive the newsletter, we shall consider this also as an agreement between us. The agreement then consists of your acceptance of our offer to receive the newsletter. For the use of your e-mail in sending you the newsletter, we shall also rely on the ‘performance of contract’ basis.
We rely on our ‘legitimate interests’ (i) for sending product information or direct marketing information to you. All marketing information will relate solely to our own services which are similar to the Services you signed up for; and (ii) for collecting information on the type of device used (iphone/android/desktop/mobile etc.) and for collecting information on your behavior on our Website with Google Analytics. We collect this information to get a better of how our customers are accessing our offers and using our Website so we can use this data for the purpose of optimizing the reach of our offers.
We rely on ‘fulfilment of legal obligations’ if we must share your personal information with third parties in the course of fulfilling our legal obligations, such as upon a request by an auditor, a court or accountant in relation to mandatory filings.

RIGHTS YOU HAVE REGARDING YOUR PERSONAL DATA

Since we process your personal data as a Controller, you have certain rights with respect to your personal data vis a vis us, including those set forth below.

For more information about the rights below, or to submit a request, please email policies@littlenudgemarketing.com. Please note that in some circumstances, we may not be able to fully comply with your request, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include personal data, if necessary to verify your identity and the nature of your request.

Access: you can request more information about the personal data we hold about you and request a copy of such personal data.
Rectification: if you believe that any personal data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
Erasure: you can request that we erase some or all of your personal data from our systems.
Portability: you can ask for a copy of your personal data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
Objection: you can contact us, as the Controller under GDPR, to let us know that you object to the further use or disclosure of your personal data.
Restriction of Processing: you can ask us to restrict further processing of your personal data.
Right to File Complaint: you have the right to lodge a complaint about our practices with respect to your personal data with the supervisory authority.

TRANSFERS OF PERSONAL DATA

If you provide your personal data (or your personal data is collected in line with this Privacy Notice) you acknowledge and authorize that any personal data about you may be shared with parties outside of the EU. For example, with large professional worldwide hosting companies or with third parties who need to receive your personal information as part of our Services and who are located outside of the EU. For instance, if a customer wishes to promote its products in the United States, we may cooperate with local U.S. marketing agencies who may then have to receive personal information of people connected to our customer. We will make sure that steps are taken to ensure any such transfers of your personal information to third parties are done in a secure manner.

SHARING OF PERSONAL DATA

Unless stated otherwise in this privacy notice, we do not share your personal data with third parties except (i) when this is necessary as part of our Services (think of a scenario where you would like us to cooperate with another marketing agency or platform to promote your products); and (ii) when we have to share your personal data with third parties as part of our compliance with applicable laws. For example, our accountant or a local auditor may require us to provide them with copies of our contracts with our customers. In such a case, such third parties will have access to the personal data recorded in said contracts. In all cases in which we share your personal data with third parties, we shall make sure that we take all steps necessary to protect your personal data, including by entering into data protection agreements with any recipients of your personal data.

SECURITY OF DATA

The security of your data is important to us. While no method of transmission over the internet, or method of electronic storage is 100% secure we strive to use commercially acceptable means to protect your personal data, however we cannot guarantee its absolute security.

RETENTION AND DELETION OF YOUR PERSONAL DATA

We delete your personal data as soon as the purpose for which we have collected and processed the data ceases to apply. Beyond this point in time, data is only stored if this is required by the laws, regulations or other legal requirements.

CHANGES TO THIS PRIVACY NOTICE

We reserve the right to revise, modify, or update this Privacy Notice at any time. We will notify you about material changes in the way we treat personal information by sending a notice to you or by placing a prominent notice on our site.