PRIVACY POLICY

Effective Date: 2026/8/8

果园外文出版社（Boomgaard Foreign Languages Publishing Company）（KVK42131222） ("we," "us," "our") is a sole proprietorship (eenmanszaak) registered in the Kingdom of the Netherlands, with its registered office at Goese Dieplaan 18, 4463LA, Goes, Zeeland, The Netherlands. We are the data controller responsible for the processing of personal data through our website www.boomgaard.org (the "Site") and any related services, features, or content (collectively, the "Service").

This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you visit our Site or interact with us. It also describes your rights under applicable data protection law, including the General Data Protection Regulation (GDPR).

1. What personal data do we collect?

We may collect and process the following categories of personal data:

Contact and identification data: When you communicate with us (e.g., via email to legal@boomgaard.org or office@boomgaard.org), we collect your name, email address, and any other personal data you choose to provide in your message. If you create an account for newsletters or other interactive features, we collect your registration details (e.g., email address, username).

Donation data: When you make a donation, we collect your name, bank account details (if you transfer directly), the donation amount, and any related correspondence. If you use a third-party payment processor, the processor may collect additional payment information; we typically receive only a confirmation of the donation and the amount, not your full payment card or bank credentials.

Technical and usage data: Like most websites, we automatically collect certain information when you visit the Site. This includes your IP address, browser type, operating system, referring URLs, pages visited, and the date and time of your visit. We may use cookies or similar technologies to collect this data (see Section 10 for details on cookies).

Communication and partnership data: If you submit a recommendation, inquiry, or partnership proposal, we retain the content of that communication and your contact details for the purpose of responding and maintaining a record of the interaction.

Social media data: If you engage with us via our official accounts on third-party platforms (Bluesky, Lemmy, Mastodon, Discord, GitHub, GitLab, 微信 (WeChat), 小红书 (Xiaohongshu), 微博 (Weibo), and QQ), we may receive limited personal data as determined by those platforms (e.g., your username, public profile information, and the content of your messages). How those platforms handle your data is governed by their own privacy policies.

We do not knowingly collect any special categories of personal data (sensitive data) unless you choose to provide such information voluntarily.

2. How do we use your personal data?

We use your personal data only for the following purposes and on the legal bases set out below:

Purpose Legal basis

To provide and maintain the Service, including responding to inquiries, recommendations, and partnership proposals Legitimate interest (to operate our business and further our educational mission)

To process donations and maintain financial records Performance of a contract (donation processing) and legal obligation (tax and accounting laws)

To send you newsletters or other information you have subscribed to Your consent (which you may withdraw at any time)

To improve and analyse the performance of the Site (e.g., visitor statistics) Legitimate interest (to understand how our Site is used and to enhance user experience)

To comply with legal obligations (e.g., tax reporting, responding to lawful requests from authorities) Legal obligation

To protect the rights, property, or safety of our business, our users, or the public Legitimate interest (to ensure the security and integrity of the Service)

To manage our social media presence and engage with the public Legitimate interest (to promote our mission and communicate with the community)

Where we rely on legitimate interests, we have balanced those interests against your rights and freedoms and concluded that the processing does not override your interests.

3. AI tools and personal data

We may integrate strictly regulated artificial intelligence (AI) tools on the Site to make our content more readable for people of all reading proficiency levels. These tools operate solely on our published content; they do not process, analyse, or access any personal data of our visitors or users. No personal data is used to train, prompt, or improve the AI models.

4. Who do we share your personal data with?

We do not sell, rent, or trade your personal data. We only share your data with third parties in the following circumstances:

Service providers: We may engage trusted third parties to assist in operating the Site or processing donations (e.g., web hosting providers, payment processors, email delivery services). These providers act on our instructions and are contractually bound to protect your data in accordance with the GDPR.

Financial institutions: When you donate via bank transfer, your data is processed by your bank and our bank as part of the normal banking process.

Government authorities and legal compliance: We may disclose personal data if required by law, regulation, or court order, or if necessary to protect our legal rights.

Social media platforms: If you choose to interact with us on third-party social media platforms, your data will be processed by those platforms according to their own privacy policies. We have no control over that processing. Please review the privacy policies of those platforms for details.

Collaborating organisations and partners: With your explicit consent, we may share your contact information with partner organisations when you express interest in a specific joint project or collaboration.

We do not transfer personal data outside the European Economic Area (EEA) unless the recipient provides an adequate level of protection (e.g., through Standard Contractual Clauses approved by the European Commission) or you have explicitly consented to the transfer. Please note that some of the social media platforms we use are based outside the EEA; any data you share there is subject to that platform’s data transfer mechanisms.

5. How long do we retain your personal data?

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law:

Communication and inquiry data: Up to 2 years after the last interaction, to allow us to refer back to previous correspondence, unless you request earlier deletion.

Donation records: As required by Dutch tax law and accounting regulations (typically 7 years).

Newsletter subscriptions: Until you withdraw your consent or unsubscribe.

Technical logs: Typically a few months, unless longer retention is needed for security or legal reasons.

When data is no longer needed, we securely delete or anonymise it.

6. How do we protect your personal data?

We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures include, but are not limited to, encryption of data in transit, secure server configuration, access controls, and regular review of our data practices.

However, no internet transmission is 100% secure. While we strive to protect your data, we cannot guarantee absolute security. We encourage you to take precautions when sharing personal data online.

7. Your rights under the GDPR

As a data subject within the EEA, you have the following rights regarding your personal data:

Right of access: You may request a copy of the personal data we hold about you.

Right to rectification: You may ask us to correct inaccurate or incomplete data.

Right to erasure ("right to be forgotten"): You may request deletion of your data, subject to certain legal exceptions.

Right to restriction of processing: You may request that we limit how we use your data in certain circumstances.

Right to data portability: You may request that your data be transferred to another controller in a structured, commonly used, machine-readable format.

Right to object: You may object to processing based on legitimate interests, including profiling (we do not engage in profiling). You may also object to direct marketing (newsletters) at any time.

Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.

To exercise any of these rights, please contact us at legal@boomgaard.org or at the postal address below. We will respond within one month, as required by law. We may ask you to verify your identity before fulfilling your request.

You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) if you believe our processing of your data violates applicable law. We would, however, appreciate the opportunity to address your concerns first.

8. Children’s privacy

Our Service is not intended for individuals under the age of 16. We do not knowingly collect personal data from children under 16. If we become aware that we have inadvertently collected such data, we will take steps to delete it promptly. If you believe a child has provided us with personal data, please contact us.

9. Links to third-party websites and social media

Our Site may contain links to external websites and resources, including our official accounts on social media platforms (Bluesky, Lemmy, Mastodon, Discord, GitHub, GitLab, 微信 (WeChat), 小红书 (Xiaohongshu), 微博 (Weibo), and QQ). These third-party sites and platforms operate independently and have their own privacy policies. We are not responsible for their content or data practices. We encourage you to read the privacy statements of any website or platform you visit.

10. Cookies and similar technologies

We use essential cookies to ensure the proper functioning of the Site (e.g., session cookies). We do not currently use analytics cookies, advertising cookies, or third-party tracking cookies.

However, we reserve the right to introduce additional cookies in the future, including analytics, advertising, and tracking cookies, should our operational needs or funding model evolve. Any such changes will be reflected in our dedicated Cookie Statement, which provides comprehensive information about all cookies used on the Site, their purposes, and how you can manage your preferences. The Cookie Statement is available at the Cookies page.

You can control cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Site.

11. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices, the law, or the functionality of the Site. When we make material changes, we will post a notice on the Site and update the Effective Date at the top of this policy. We encourage you to review this page periodically. Your continued use of the Service after the Effective Date constitutes your acknowledgment of the updated Privacy Policy.

12. Contact information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

果园外文出版社（Boomgaard Foreign Languages Publishing Company）（KVK42131222）

Legal and Copyright Affairs: legal@boomgaard.org

Urgent Matters & Administrative Office: office@boomgaard.org

Postal address: Goese Dieplaan 18, 4463LA, Goes, Zeeland, The Netherlands

Last updated: 2026/8/5