DATA CONTROLLER
RAJI Concierge · CoC: 86585185 · info@rajiconcierge.com · +31 6 51456085

​

1. PERSONAL DATA WE PROCESS
We may process the following categories of personal data:

• Contact details: name, email address, phone number

• Service data: travel preferences, special requests, dietary requirements, loyalty programme numbers, and other information necessary to deliver our services

• Financial data: invoice details, payment references (no card data, this is processed and stored by our payment providers)

• Communications: email correspondence, chat messages, call notes

• Technical data: IP address, browser type, device information, and cookie data (see our Cookie Policy)

We only process personal data that is necessary for the purposes described below.

​

2. LEGAL BASES & PURPOSES (ART. 6 GDPR)

We process personal data on the following legal grounds:

• Performance of a contract
  Processing bookings, coordinating with suppliers, and delivering requested concierge services

• Legal obligation
  Compliance with applicable laws, including tax obligations (7-year retention) and anti-money laundering regulations where applicable

• Legitimate interest
  Fraud prevention, system security, internal administration, and client relationship management, provided that such interests do not override your fundamental rights

• Consent
  Sending newsletters, marketing communications, and providing personalised recommendations. Consent may be withdrawn at any time

​

3. RETENTION PERIODS

We do not retain personal data longer than necessary. The following standard retention periods apply:

• Client files: 7 years after the last service (statutory tax retention requirement)

• Marketing data: until withdrawal of consent + up to 1 month to process the request

• Job applications: 4 weeks after the end of the procedure (or up to 1 year with explicit consent)

• Website log files: maximum of 6 months

Where necessary, data may be retained longer to comply with legal obligations or to resolve disputes.

​

4. YOUR RIGHTS (ART. 15–22 GDPR)

You have the following rights under the GDPR:

• Right of access (Art. 15)
  You may request an overview of the personal data we process about you

• Right to rectification (Art. 16)
  You may request correction of inaccurate or incomplete data

• Right to erasure (Art. 17)
  You may request deletion of your personal data, subject to legal obligations

• Right to restriction and objection (Art. 18 & 21)
  You may request restriction of processing or object to certain uses of your data

• Right to data portability (Art. 20)
  You may receive your data in a structured, commonly used, machine-readable format

• Right to withdraw consent
  Where processing is based on consent, you may withdraw this at any time without affecting the lawfulness of prior processing

• Right to lodge a complaint
  With the Dutch Data Protection Authority: www.autoriteitpersoonsgegevens.nl

Requests can be submitted via the contact details below.

​

5. RECIPIENTS & TRANSFERS

We may share personal data with:

• Processors (under data processing agreements): IT providers, hosting providers, payment providers, and communication platforms

• Suppliers (e.g. hotels, drivers, security providers): only the data strictly necessary for the performance of the requested service

• Authorities: where required by law or court order

Where personal data is transferred outside the European Economic Area (EEA), this will only take place on the basis of an adequacy decision or appropriate safeguards such as Standard Contractual Clauses (SCCs).

​

6. SECURITY

We implement appropriate technical and organisational measures to protect personal data, including:

• Encryption of data in transit (TLS 1.2+) and, where applicable, at rest

• Access controls based on the need-to-know principle

• Regular security assessments and internal procedures

• A data breach response procedure in accordance with Art. 33 GDPR (including notification to the Dutch Data Protection Authority within 72 hours where required)

​

7. COOKIES & TRACKING

Our website uses cookies and similar technologies to ensure proper functioning, analyse usage, and improve user experience.
Where required by law, we will request your prior consent before placing non-essential cookies.

For more detailed information, please refer to our Cookie Policy.

​

8. PROFILING & AUTOMATED DECISION-MAKING

We may use personal data to provide personalised recommendations and tailor our services.
However, we do not make decisions based solely on automated processing that produce legal or similarly significant effects.

​

9. MINORS

Our services are not intended for individuals under the age of 18.
We do not knowingly collect personal data from minors without parental or legal guardian consent.

​

10. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. The most recent version will always be available on our website.
Material changes will be communicated where appropriate.

​

11. PRIVACY CONTACT

RAJI Concierge · Attn: Privacy 
Email: info@rajiconcierge.com

We aim to respond to all requests within 30 days, in accordance with Article 12 GDPR.