Privacy policy

1. Who we are

FlagCue ("we", "us", "our") is the data controller for personal data collected via this website.

• Legal entity: Caroline Signature
• Registered office: Leuvenstraat 4, 1066HC, Amsterdam, the Netherlands
• Chamber of Commerce (KvK) number: 42022720
• Contact: info@flagcue.nl

2. What personal data we collect

When you submit our waitlist or pilot signup form, we collect the following categories of personal data:

• Identification: full name, email address, and optionally phone number
• Business information: company name, type of location, and number of units (optional)
• Free-text input: the problem description or pilot request notes you provide
• Technical and marketing data: UTM parameters from your link, referrer URL, and language preference

We do not collect special categories of personal data (such as health or religion). Please do not include such information in free-text fields.

3. Why we process your data

We use the personal data you provide for the following purposes:

• To respond to your waitlist or pilot inquiry
• To onboard you for a paid pilot, if applicable
• To send you product updates, launch information, and onboarding emails
• To analyse anonymised patterns in submissions in order to improve our product
• To comply with our legal obligations

4. Legal basis for processing

We process your personal data on the following legal bases under GDPR Article 6:

• Pre-contractual steps (Art. 6(1)(b)) — when you request a pilot or respond to onboarding
• Legitimate interest (Art. 6(1)(f)) — responding to waitlist inquiries and anonymised product improvement
• Consent (Art. 6(1)(a)) — for marketing and product update emails; you can withdraw consent at any time
• Legal obligation (Art. 6(1)(c)) — where required by tax, accounting, or other Dutch law

5. How long we keep your data

We retain personal data only as long as necessary for the purposes for which it was collected:

• Waitlist signups: until we publicly launch, plus 12 months thereafter, or until you request deletion
• Pilot signups: duration of the pilot, plus 24 months for follow-up
• Financial and billing records (for paid pilots): 7 years (Dutch tax law)
• Technical and marketing data: 24 months from collection

6. Who we share your data with

We do not sell your personal data and do not share it with advertising networks. We share data with the following categories of processors, who are bound by data processing agreements (DPAs):

• Hosting and database: Railway (United States) — application hosting and MongoDB storage
• Transactional email: our email service provider, for confirmation and onboarding messages

We may share personal data with public authorities where we are legally required to do so.

7. International transfers

Some of our processors are located outside the European Economic Area (EEA), notably in the United States. When personal data is transferred outside the EEA, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission as the appropriate safeguard for such transfers.

You can request a copy of the SCCs by contacting us at info@flagcue.nl.

8. Your rights

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

• Right of access — receive a copy of the personal data we hold about you
• Right to rectification — correct inaccurate or incomplete data
• Right to erasure ("right to be forgotten") — request deletion of your data
• Right to restrict processing — limit how we use your data
• Right to object — object to processing based on legitimate interest
• Right to data portability — receive your data in a machine-readable format
• Right to withdraw consent — stop marketing emails at any time

To exercise any of these rights, email info@flagcue.nl. We will respond within one month, as required by the GDPR.

You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, autoriteitpersoonsgegevens.nl) if you believe we are not handling your personal data in accordance with the law.

9. Cookies, analytics, and tracking pixels

We use a combination of essential, analytics, and marketing tracking technologies on this website. When you first visit, we show a cookie banner so you can choose what you allow. Until you accept, only essential storage is active.

• Essential (always on, no consent required): technical cookies and local storage needed to remember your language preference, to operate the waitlist and pilot forms, and to store your cookie choice itself.
• Analytics (consent required): tools that aggregate page views, time on page, form completions, and visitor flows so we can improve the site. Depending on the provider, these may set cookies or transmit identifiers (for example Google Analytics, Plausible, PostHog, or similar).
• Marketing pixels (consent required): tracking pixels and tags that measure the effectiveness of our outreach campaigns and let us reach similar audiences. Examples include the Meta (Facebook/Instagram) Pixel, LinkedIn Insight Tag, Google Ads conversion tag, and similar.

Where consent is required, no cookies, pixels, or identifiers from the analytics or marketing categories are loaded before you actively accept. You can change your choice at any time by clearing your browser storage for this site, or by contacting us at info@flagcue.nl, and the banner will appear again on your next visit.

Some analytics and marketing providers are based outside the EEA. When that is the case, we rely on the international-transfer safeguards described in section 7.

10. Security

We protect your personal data with industry-standard measures, including TLS encryption in transit, encrypted storage at rest, restricted database access, and regular security updates.

No system is fully secure. If we become aware of a personal data breach that is likely to affect your rights and freedoms, we will notify you and the Dutch Data Protection Authority within 72 hours, as required by the GDPR.

11. Changes to this policy

We may update this policy as our service evolves. The "Last updated" date at the top of this page reflects the most recent revision. Material changes will be communicated by email to subscribers where appropriate.

12. Contact

For any privacy-related questions, requests, or complaints, contact us at info@flagcue.nl.