Overview

Sebuda’s Privacy & Cookie Policy explains how Sebuda collects, uses, stores, shares, protects, and otherwise processes Personal Data when you access or use the Sebuda website, Platform, software, communication systems, tools, features, and related services.

Sebuda respects your privacy and is committed to handling Personal Data responsibly, transparently, securely, and in accordance with Applicable Law.

This Privacy & Cookie Policy also explains how Sebuda uses Cookies and Similar Technologies, including Google Analytics, the choices available to Users, and the privacy rights that may apply.

This Privacy & Cookie Policy should be read together with Sebuda’s Terms of Service and any other policies applicable to a specific Platform feature or service.

Nothing in this Privacy & Cookie Policy limits any privacy, data-protection, or consumer right that cannot lawfully be excluded, restricted, or waived under Applicable Law.

 

Table of Contents

  1. Who We Are and Data Controller

  2. Scope of This Privacy & Cookie Policy

  3. Definitions

  4. Personal Data We Collect

  5. Information You Provide Directly

  6. Information Collected Automatically

  7. Information Received From Third Parties

  8. Publicly Available Information

  9. How We Use Personal Data

  10. Legal Bases for Processing

  11. Identity, Security and Compliance Verification

  12. Fraud Prevention and Platform Protection

  13. Communications and Customer Support

  14. Marketing Communications

  15. Automated Tools and Risk Analysis

  16. Sharing Personal Data

  17. Service Providers and Processors

  18. Legal Disclosures

  19. International Data Transfers

  20. Data Retention

  21. Data Security

  22. Your Privacy Rights

  23. Right to Object to Direct Marketing

  24. Exercising Your Rights

  25. Children and Minors

  26. Third-Party Websites and Services

  27. Cookies and Similar Technologies in This Privacy & Cookie Policy

  28. Types of Cookies We Use

  29. Strictly Necessary Cookies

  30. Preference and Functionality Cookies

  31. Google Analytics

  32. Third-Party Cookies and Technologies

  33. Cookie Consent

  34. Changing or Withdrawing Cookie Consent

  35. Cookie Duration and Current Cookie Information

  36. Browser and Device Controls

  37. Changes to This Privacy & Cookie Policy

  38. Complaints and Supervisory Authorities

  39. Contact Us

  40. Final Privacy & Cookie Policy Notice

 

1. Who We Are and Data Controller

For the purposes of applicable data-protection law, including the General Data Protection Regulation (“GDPR”) where applicable, the controller responsible for the Personal Data described in this Privacy & Cookie Policy is:

Sebuda B.V.

For privacy-related questions, requests, complaints, or concerns, please contact:

Email: Admin@sebuda.com

 

2. Scope of This Privacy & Cookie Policy

This Privacy & Cookie Policy applies to Personal Data processed by Sebuda in connection with:

  • visiting the Platform;

  • creating or managing a Sebuda Account;

  • using Platform features;

  • communicating through Sebuda;

  • contacting customer support;

  • participating in verification procedures;

  • using payment-related Platform functionality;

  • submitting Content or information;

  • interacting with Platform security systems;

  • receiving communications from Sebuda;

  • responding to surveys or feedback requests;

  • using Cookies or Similar Technologies;

  • using services that interact with Google Analytics;

  • participating in promotions where applicable; and

  • otherwise interacting with Sebuda.

This Policy does not govern independent third-party websites or services that maintain their own privacy policies.

 

3. Definitions

For purposes of this Policy:

Sebuda, we, us, or our means Sebuda B.V.

User, you, or your means any individual accessing or using the Platform.

Platform means the Sebuda website and any related software, interfaces, communication systems, tools, features, applications, or services operated under the Sebuda name.

Account means a registered Sebuda user account.

Personal Data means information relating to an identified or identifiable natural person.

Processing means any operation performed on Personal Data, including collection, recording, organization, storage, use, disclosure, analysis, alteration, restriction, deletion, or destruction.

Content means text, images, files, messages, communications, documents, or other material submitted to, transmitted through, or displayed on the Platform.

Cookie means a small text file or similar identifier stored on or accessed from a User’s device.

Similar Technologies may include local storage, pixels, tags, scripts, software development kits, device identifiers, and comparable technologies.

Google Analytics means Google’s website analytics service used by Sebuda to help measure and understand Platform usage and performance.

Applicable Law means applicable privacy, data-protection, electronic-communications, consumer, cybersecurity, regulatory, and other legally binding requirements.

 

4. Personal Data We Collect

The categories of Personal Data Sebuda collects depend on how a User interacts with the Platform.

Sebuda may collect the following categories where relevant:

  • identification information;

  • Account information;

  • contact information;

  • verification information;

  • communications;

  • payment-related information;

  • Platform activity information;

  • device information;

  • browser information;

  • IP address;

  • approximate geographic information derived from technical data;

  • security information;

  • fraud-prevention information;

  • customer-support records;

  • Content submitted through the Platform;

  • preference information;

  • Google Analytics information;

  • Cookie and Similar Technology information; and

  • other information voluntarily provided by a User.

Sebuda seeks to collect only Personal Data that is reasonably relevant to legitimate service, security, legal, compliance, technical, operational, or Platform-related purposes.

 

5. Information You Provide Directly

You may provide Personal Data directly to Sebuda when you:

  • create an Account;

  • update Account information;

  • provide contact details;

  • communicate through the Platform;

  • communicate with customer support;

  • submit verification information;

  • upload documentation;

  • complete forms;

  • submit reports or complaints;

  • provide feedback;

  • respond to requests from Sebuda; or

  • otherwise provide information through the Platform.

Such information may include:

  • name;

  • username;

  • email address;

  • telephone number;

  • country or general location;

  • business or organizational information;

  • identification information where required;

  • verification documents;

  • communications;

  • screenshots;

  • files;

  • customer-support information; and

  • other information voluntarily provided.

Users should avoid submitting Personal Data that is unnecessary for the relevant purpose.

 

6. Information Collected Automatically

When you access or use Sebuda, certain information may be generated or collected automatically.

This may include:

  • IP address;

  • browser type;

  • browser version;

  • device type;

  • operating system;

  • language settings;

  • approximate geographic region;

  • referring website or page;

  • pages accessed;

  • features used;

  • session information;

  • timestamps;

  • login activity;

  • security events;

  • technical errors;

  • diagnostic information;

  • interaction data;

  • Google Analytics identifiers; and

  • Cookie or Similar Technology information.

Sebuda may use this information for purposes including:

  • Platform operation;

  • authentication;

  • security;

  • fraud prevention;

  • troubleshooting;

  • analytics;

  • performance monitoring;

  • service improvement;

  • identifying technical issues; and

  • enforcing Platform rules.

 

7. Information Received From Third Parties

Sebuda may receive Personal Data or related information from third parties where permitted by Applicable Law and reasonably necessary to operate, secure, administer, or improve the Platform.

Such third parties may include:

  • identity-verification providers;

  • fraud-prevention providers;

  • cybersecurity providers;

  • payment service providers;

  • hosting and infrastructure providers;

  • communication providers;

  • Google Analytics;

  • professional advisers;

  • publicly available sources; and

  • competent governmental, judicial, regulatory, or law-enforcement authorities.

Information received from third parties may be combined with information already held by Sebuda where there is an appropriate legal basis for doing so.

 

8. Publicly Available Information

Certain information intentionally made publicly visible through Platform functionality may be accessible to other Users or members of the public.

Depending on the relevant feature, this may include:

  • username;

  • profile information;

  • profile image;

  • publicly posted Content;

  • ratings;

  • reviews;

  • feedback; or

  • other information intentionally published by the User.

Users should carefully consider what Personal Data they make public.

Information made publicly available may be copied, shared, indexed, archived, or otherwise processed by third parties outside Sebuda’s direct control.

Sebuda is not responsible for independent processing performed by third parties after they obtain information lawfully made public by a User.

 

9. How We Use Personal Data

Sebuda may process Personal Data where reasonably necessary to:

  • create and administer Accounts;

  • provide Platform functionality;

  • authenticate Users;

  • provide customer support;

  • respond to requests;

  • provide service-related communications;

  • verify identity where necessary;

  • prevent fraud;

  • detect unauthorized access;

  • protect Platform security;

  • investigate abuse or misuse;

  • enforce Platform rules;

  • resolve complaints;

  • maintain infrastructure;

  • improve Platform functionality;

  • diagnose technical issues;

  • conduct analytics;

  • measure website performance;

  • understand Platform usage;

  • comply with legal obligations;

  • respond to lawful authority requests;

  • establish, exercise, or defend legal claims;

  • maintain appropriate business records;

  • prevent financial crime; and

  • send marketing communications where legally permitted.

Sebuda will not intentionally process Personal Data for a materially incompatible new purpose without an appropriate legal basis.

 

10. Legal Bases for Processing

Where GDPR or another applicable law requires a legal basis for Processing, Sebuda may rely on one or more of the following. For additional general guidance, Users may consult the European Commission’s official information on legal grounds for processing Personal Data:

10.1 Performance of a Contract

Processing may be necessary to provide Platform functionality requested by a User or to take steps requested before providing a service.

10.2 Legal Obligation

Sebuda may process Personal Data where necessary to comply with a legal, regulatory, judicial, or governmental obligation.

10.3 Legitimate Interests

Sebuda may process Personal Data where necessary for legitimate interests and where those interests are not overridden by the rights and freedoms of the relevant individual.

Legitimate interests may include:

  • Platform security;

  • fraud prevention;

  • cybersecurity;

  • service administration;

  • protecting Users;

  • preventing misuse;

  • improving Platform reliability;

  • enforcing Platform rules;

  • technical monitoring;

  • preventing financial crime; and

  • establishing or defending legal claims.

10.4 Consent

Where consent is legally required, Sebuda will seek consent before carrying out the relevant Processing.

Where Processing is based on consent, the User may withdraw consent at any time.

Withdrawal does not affect the lawfulness of Processing carried out before consent was withdrawn.

10.5 Vital Interests

In limited circumstances, Personal Data may be processed where necessary to protect the vital interests of an individual.

 

11. Identity, Security and Compliance Verification

Sebuda may process information for identity, security, fraud-prevention, and compliance purposes.

Depending on the circumstances, verification information may include:

  • identity information;

  • identification documents;

  • business information;

  • proof of authority;

  • contact information;

  • Account information;

  • technical information;

  • security information; or

  • other information reasonably necessary for the relevant review.

Sebuda may use specialized service providers to assist with verification procedures.

Verification information will be processed only where supported by an appropriate legal basis.

Completion of a verification process does not constitute a continuing guarantee concerning a User’s identity, conduct, or future activity.

 

12. Fraud Prevention and Platform Protection

Sebuda may process Personal Data to identify, investigate, prevent, and respond to:

  • fraud;

  • attempted fraud;

  • identity misuse;

  • unauthorized access;

  • malicious activity;

  • suspicious Account activity;

  • cybersecurity incidents;

  • Platform abuse;

  • policy violations;

  • false documentation;

  • manipulation of systems;

  • security threats; or

  • other activity creating material legal, technical, financial, or operational risk.

Information used for these purposes may include:

  • Account activity;

  • device information;

  • IP addresses;

  • technical records;

  • security logs;

  • verification information;

  • communications;

  • payment-related indicators;

  • timestamps; and

  • risk indicators.

Relevant information may be retained where reasonably necessary for fraud prevention, security, compliance, or legal claims.

 

13. Communications and Customer Support

When a User communicates with Sebuda, Sebuda may process information including:

  • contact details;

  • Account information;

  • message content;

  • uploaded attachments;

  • support history;

  • technical information;

  • timestamps; and

  • other information relevant to the request.

Such information may be used to:

  • respond to the User;

  • investigate issues;

  • provide support;

  • protect security;

  • maintain support records;

  • improve customer service;

  • enforce Platform policies; or

  • comply with legal obligations.

 

14. Marketing Communications

Sebuda may send promotional or marketing communications where permitted by Applicable Law.

Where consent is legally required, Sebuda will obtain the appropriate consent before sending such communications.

Users may unsubscribe from marketing communications at any time using:

  • an unsubscribe link included in an email;

  • available Account settings; or

  • another method provided by Sebuda.

Opting out of marketing does not prevent Sebuda from sending necessary:

  • security notices;

  • Account communications;

  • service notices;

  • legal notices;

  • verification requests; or

  • other non-marketing communications.

Sebuda does not sell Personal Data to third parties for their independent direct-marketing purposes.

 

15. Automated Tools and Risk Analysis

Sebuda may use automated systems, algorithms, artificial intelligence, or similar tools to assist with:

  • fraud detection;

  • cybersecurity;

  • risk assessment;

  • identity verification;

  • suspicious-activity detection;

  • abuse detection;

  • Platform monitoring;

  • technical analysis; or

  • administrative review.

Where automated Processing produces legal effects or similarly significantly affects an individual and Applicable Law provides additional rights, Sebuda will apply the safeguards required by law.

Automated tools may support human review and do not necessarily make all Platform decisions independently.

 

16. Sharing Personal Data

Sebuda may share Personal Data only where there is a lawful and legitimate reason to do so.

Recipients may include:

  • service providers;

  • processors;

  • hosting providers;

  • infrastructure providers;

  • cybersecurity providers;

  • identity-verification providers;

  • payment providers;

  • communication providers;

  • Google Analytics;

  • professional advisers;

  • affiliated entities where appropriate;

  • competent authorities; or

  • other parties where disclosure is lawfully required or permitted.

Sebuda does not disclose Personal Data merely because another party requests it.

 

17. Service Providers and Processors

Sebuda may use third-party service providers where reasonably necessary to operate, maintain, secure, or improve the Platform.

Such services may include:

  • cloud hosting;

  • infrastructure;

  • cybersecurity;

  • authentication;

  • identity verification;

  • communication and email delivery;

  • customer support;

  • payment-related infrastructure;

  • data storage;

  • fraud prevention;

  • technical operations; and

  • website analytics through Google Analytics.

Where a service provider processes Personal Data on behalf of Sebuda, Sebuda will seek to use appropriate contractual, technical, and organizational safeguards as required by Applicable Law.

Service providers may process Personal Data only for purposes consistent with their authorized role and applicable legal obligations.

 

18. Legal Disclosures

Sebuda may disclose Personal Data where reasonably necessary and permitted or required by Applicable Law to:

  • comply with a court order;

  • comply with regulatory requirements;

  • respond to a valid governmental request;

  • cooperate with law enforcement;

  • investigate suspected fraud;

  • protect Platform security;

  • protect the rights or safety of Users;

  • establish, exercise, or defend legal claims; or

  • enforce applicable agreements or policies.

Where legally permitted, Sebuda may evaluate the validity, scope, and proportionality of a request before disclosure.

 

19. International Data Transfers

Sebuda may use service providers, technical infrastructure, or systems located outside the country where a User resides.

As a result, Personal Data may be transferred internationally.

Where GDPR applies and Personal Data is transferred outside the European Economic Area to a country not covered by an applicable adequacy decision, Sebuda will seek to use an appropriate transfer mechanism required by Applicable Law.

Such mechanisms may include:

  • Standard Contractual Clauses;

  • an applicable adequacy decision;

  • another legally recognized transfer mechanism; or

  • a statutory exception permitted by Applicable Law.

Additional safeguards may be implemented where required.

 

20. Data Retention

Sebuda retains Personal Data only for as long as reasonably necessary for the purposes for which it was collected or where longer retention is required or permitted by law.

Retention periods may depend on:

  • the category of Personal Data;

  • the purpose of Processing;

  • Account status;

  • legal requirements;

  • security requirements;

  • fraud-prevention requirements;

  • regulatory obligations;

  • applicable limitation periods;

  • dispute or complaint history;

  • potential legal claims; and

  • technical requirements.

Different categories of information may therefore be retained for different periods.

When Personal Data is no longer reasonably necessary, Sebuda may delete, anonymize, aggregate, or otherwise securely dispose of it in accordance with Applicable Law.

 

21. Data Security

Sebuda uses reasonable technical and organizational measures designed to protect Personal Data against:

  • unauthorized access;

  • unlawful Processing;

  • accidental loss;

  • unauthorized disclosure;

  • alteration;

  • destruction;

  • misuse; or

  • compromise.

Security measures may include, where appropriate:

  • authentication controls;

  • access controls;

  • encryption;

  • security monitoring;

  • system logging;

  • restricted staff access;

  • infrastructure protections;

  • security reviews; and

  • internal security procedures.

Access to Personal Data should be limited to persons who reasonably require such access for legitimate purposes.

No online or electronic system can guarantee absolute security.

Users remain responsible for maintaining reasonable security over their own:

  • Account;

  • credentials;

  • devices;

  • email accounts; and

  • communications.

 

22. Your Privacy Rights

Under this Privacy & Cookie Policy, and depending on Applicable Law and individual circumstances, Users may have rights concerning their Personal Data.

These may include the right to:

  • obtain information about Processing;

  • request access to Personal Data;

  • request correction of inaccurate information;

  • request completion of incomplete information;

  • request deletion in eligible circumstances;

  • request restriction of Processing;

  • object to certain Processing;

  • request portability of eligible Personal Data;

  • withdraw consent where consent is relied upon;

  • object to direct marketing;

  • raise concerns regarding certain automated decisions; and

  • lodge a complaint with a competent supervisory authority.

These rights are not absolute and may be subject to statutory limitations, exceptions, or verification requirements.

 

23. Right to Object to Direct Marketing

Users may object to the Processing of Personal Data for direct-marketing purposes at any time.

Once a valid objection is received, Sebuda will stop using the relevant Personal Data for direct marketing as required by Applicable Law.

A marketing opt-out does not prevent Sebuda from providing essential communications concerning:

  • Platform security;

  • Account administration;

  • legal notices;

  • service functionality;

  • verification;

  • policy updates; or

  • other non-marketing matters.

 

24. Exercising Your Rights

To exercise an applicable privacy right, contact Sebuda at:

Admin@sebuda.com

Sebuda may request reasonable information to verify the identity of the person making the request.

Identity verification helps prevent unauthorized access to, disclosure of, alteration of, or deletion of Personal Data.

Where legally required, Sebuda will respond within the applicable statutory period.

Sebuda may refuse or limit a request where Applicable Law permits or requires it, including where:

  • identity cannot reasonably be verified;

  • the request affects another person’s rights;

  • retention is required by law;

  • information is necessary for legal claims;

  • a statutory exemption applies; or

  • the request is manifestly unfounded or excessive where recognized by Applicable Law.

Where required, Sebuda will explain the relevant reason.

 

25. Children and Minors

Sebuda is not intended for individuals who do not satisfy the minimum age or legal-capacity requirements applicable to the Platform.

Users must not intentionally provide false age information to circumvent eligibility requirements.

Where consent is relied upon in connection with an online service offered directly to a child and Applicable Law requires authorization from a parent or guardian, Sebuda will seek to comply with the relevant legal requirements.

If Sebuda becomes aware that Personal Data relating to a child has been processed contrary to Applicable Law, Sebuda may delete the information or take other appropriate protective action.

 

26. Third-Party Websites and Services

The Platform may contain links to or technical integrations with independent Third-Party Services.

Sebuda is not responsible for the privacy practices of independent third parties.

Where a User interacts directly with a third-party website or service, that provider’s own privacy policy and terms may apply.

Users should review third-party privacy information before providing Personal Data.

 

27. Cookies and Similar Technologies in This Privacy & Cookie Policy

Sebuda uses Cookies and Similar Technologies to operate, secure, analyze, and improve the Platform.

These technologies may be used for purposes including:

  • maintaining sessions;

  • authentication;

  • Account security;

  • storing preferences;

  • fraud prevention;

  • cybersecurity;

  • Platform functionality;

  • technical performance monitoring;

  • Google Analytics;

  • usability analysis; and

  • improving User experience.

Sebuda does not necessarily use every category of Cookie described in this Policy at all times.

The technologies in use may change as Platform functionality develops.

 

28. Types of Cookies We Use

Sebuda may use the following categories of Cookies:

Strictly Necessary Cookies

Required for essential Platform functionality, security, authentication, session management, and similar technical purposes.

Preference and Functionality Cookies

Used to remember User choices or preferences where applicable.

Analytics Cookies

Used through Google Analytics to understand Platform usage and website performance.

Sebuda does not currently identify a separate advertising or behavioral-tracking Cookie service in this Policy.

 

29. Strictly Necessary Cookies

Strictly Necessary Cookies are used where required to provide essential Platform functionality.

They may support:

  • Account authentication;

  • security;

  • session continuity;

  • fraud prevention;

  • technical operation;

  • load balancing;

  • Cookie preference storage; and

  • other essential Platform functions.

Where legally permitted, Strictly Necessary Cookies may be used without consent because they are required to provide functionality requested by the User or to maintain essential service operation.

Blocking Strictly Necessary Cookies may prevent important Platform functionality from operating correctly.

 

30. Preference and Functionality Cookies

Preference or Functionality Cookies may be used to remember settings such as:

  • language;

  • interface preferences;

  • display choices;

  • previously selected settings; or

  • other optional functionality.

Where Applicable Law requires consent for such Cookies, they will be activated only after the required consent has been obtained.

 

31. Google Analytics

As explained in this Privacy & Cookie Policy, Sebuda uses Google Analytics to understand how Users interact with the Platform and to measure and improve website performance.

Google Analytics may collect or generate information concerning Platform usage, including:

  • pages viewed;

  • approximate session duration;

  • navigation between pages;

  • referral sources;

  • browser information;

  • device information;

  • operating-system information;

  • approximate geographic information derived from technical information;

  • interaction events;

  • timestamps; and

  • pseudonymous identifiers associated with website usage.

Google Analytics may use first-party Cookies and Similar Technologies to distinguish Users and sessions.

Depending on the technical configuration in use, Google Analytics Cookies may include:

_ga

Used to distinguish pseudonymous Users for analytics purposes.

_ga_*

Used to maintain information associated with a particular Google Analytics property or session.

Google Analytics information may be used by Sebuda for purposes including:

  • measuring Platform traffic;

  • understanding how Users navigate the Platform;

  • identifying popular or underused pages or features;

  • detecting usability issues;

  • identifying technical problems;

  • measuring website performance;

  • analyzing general usage trends; and

  • improving Platform functionality and User experience.

Sebuda does not intentionally use Google Analytics to collect passwords, authentication credentials, or other confidential security information.

Where Applicable Law requires consent before Google Analytics Cookies or Similar Technologies may be activated, Sebuda will request that consent through its Cookie consent mechanism.

Where consent is required and has not been granted, the relevant optional analytics functionality will be handled in accordance with the User’s applicable Cookie preferences.

Users may change or withdraw Analytics Cookie preferences through Sebuda’s Cookie Settings where available.

Google Analytics is provided by Google.

Google may process certain information in accordance with its own applicable privacy terms, policies, and legal obligations.

For more information about Google Analytics and how Google handles analytics data, Users may review Google’s official Google Analytics privacy documentation.

 

32. Third-Party Cookies and Technologies

Sebuda currently uses Google Analytics as its identified third-party website analytics service.

Google Analytics may use Cookies and Similar Technologies as described in this Policy.

Other third-party technologies may be used where reasonably necessary for essential Platform functions such as:

  • hosting;

  • infrastructure;

  • security;

  • authentication;

  • communications;

  • payment functionality; or

  • similar operational services.

Where Sebuda introduces another non-essential third-party Cookie or tracking technology in the future, this Policy and the applicable Cookie information will be updated where required by Applicable Law.

Where a third party independently determines the purposes or means of Processing, that third party’s own privacy policy may also apply.

 

33. Cookie Consent

Sebuda may use Strictly Necessary Cookies without consent where such use is legally permitted and necessary for essential Platform functionality.

Where Applicable Law requires consent before Google Analytics or another non-essential Cookie or Similar Technology may be activated, Sebuda will seek consent before activating the relevant technology.

Where applicable, the Cookie consent interface should allow Users to:

  • accept optional Analytics Cookies;

  • reject optional Analytics Cookies;

  • review the purpose of Analytics Cookies;

  • select available Cookie categories; and

  • change their choices later.

Rejecting optional Analytics Cookies will not prevent use of Strictly Necessary Cookies required for essential Platform operation.

Sebuda will not treat continued browsing alone as valid consent where affirmative consent is required by Applicable Law.

 

34. Changing or Withdrawing Cookie Consent

Where a Cookie or Similar Technology is based on consent, Users may change or withdraw that consent at any time using Sebuda’s Cookie Settings or applicable consent-management mechanism.

Withdrawing consent should be reasonably as accessible as granting consent.

Withdrawal does not affect the lawfulness of Processing that occurred before consent was withdrawn.

Changing optional Cookie preferences may affect certain non-essential functionality but should not prevent access to functionality that does not reasonably depend on the refused Cookie.

 

35. Cookie Duration and Current Cookie Information

Cookies may be:

Session Cookies, which generally expire after a browser session ends; or

Persistent Cookies, which remain on a device for a defined period or until removed.

Sebuda may currently use Cookie identifiers including:

Cookie Provider Category Purpose      
_ga Google Analytics Analytics Distinguishes pseudonymous Users for analytics
_ga_* Google Analytics Analytics Maintains information associated with a Google Analytics property or session
Essential Sebuda Cookies Sebuda Strictly Necessary Authentication, security, session management and Cookie preferences

The exact name, configuration, and duration of Cookies may change as Sebuda’s technical configuration changes.

Where required by Applicable Law, the most current Cookie information may also be displayed through Sebuda’s Cookie Settings, consent interface, or Cookie declaration.

 

36. Browser and Device Controls

Most browsers allow Users to control or delete Cookies through browser settings.

Users may be able to:

  • delete stored Cookies;

  • block Cookies;

  • restrict third-party Cookies;

  • configure privacy preferences; or

  • receive alerts when certain Cookies are placed.

Browser-level controls operate independently from Sebuda’s Cookie consent interface.

Blocking all Cookies may interfere with essential Platform functionality.

Where Sebuda provides Cookie Settings, Users should use those settings to manage Sebuda-specific preferences in addition to browser-level controls.

 

37. Changes to This Privacy & Cookie Policy

Sebuda may update this Privacy & Cookie Policy where reasonably necessary because of:

  • changes in Applicable Law;

  • regulatory guidance;

  • changes to Platform functionality;

  • changes to Processing activities;

  • changes to Google Analytics configuration;

  • introduction of new technologies;

  • changes to service providers;

  • security developments; or

  • legitimate operational requirements.

The current Policy will display an updated Effective Date or Last Updated date.

Where a change materially affects Personal Data Processing and Applicable Law requires notice or renewed consent, Sebuda will take appropriate steps before the relevant change becomes effective.

Historical versions may be retained where reasonably necessary for legal, compliance, or administrative purposes.

 

38. Complaints and Supervisory Authorities

Users who have concerns regarding Sebuda’s Processing of Personal Data may contact Sebuda at:

Admin@sebuda.com

Sebuda will seek to review legitimate privacy concerns in Good Faith.

Where GDPR applies, a User may also have the right to lodge a complaint with a competent supervisory authority.

For matters falling within the jurisdiction of the Netherlands, the relevant supervisory authority is the:

Autoriteit Persoonsgegevens
Dutch Data Protection Authority

The right to lodge a complaint does not prevent a User from exercising other rights or remedies available under Applicable Law.

 

39. Contact Us

For questions, concerns, complaints, or requests relating to this Privacy & Cookie Policy, please contact Sebuda regarding matters such as:

  • the Processing of Personal Data;

  • Cookie preferences;

  • Google Analytics;

  • data access;

  • correction;

  • deletion;

  • restriction;

  • objection;

  • portability;

  • withdrawal of consent; or

  • other applicable privacy rights,

please contact:

Sebuda B.V.

Email: Admin@sebuda.com

You may also reach Sebuda through our Contact Us page.

Please provide sufficient information for Sebuda to understand and respond to your request.

Sebuda may request reasonable additional information where necessary to verify the identity of a person exercising a privacy right.

Do not send sensitive identity documentation through an unsecured communication method unless Sebuda specifically requests such documentation through an authorized verification procedure.

 

40. Final Privacy & Cookie Policy Notice

Sebuda’s Privacy & Cookie Policy reflects its commitment to Processing Personal Data in a lawful, fair, transparent, secure, and proportionate manner.

Users should review this Privacy & Cookie Policy periodically and use available privacy and Cookie Settings to manage applicable preferences.

General access to or use of the Platform does not constitute consent to every form of Personal Data Processing described in this Policy.

Where consent is legally required for a particular Processing activity, Cookie, or Similar Technology, Sebuda will seek the relevant consent separately.

Where Sebuda relies on another lawful basis, such as contractual necessity, legal obligation, or legitimate interests, Processing may take place without consent where permitted by Applicable Law.

Nothing in this Privacy & Cookie Policy excludes, restricts, or limits any privacy or data-protection right that cannot lawfully be excluded, restricted, or waived.