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Privacy Policy

Last Updated: 12 February 2026

1. Introduction & Controller Identity

This Privacy Policy explains how Deltranik, operated by Fairfax Holding B.V. ("we," "us," or "our"), collects, uses, stores, and protects your personal data when you visit deltranik.site. Deltranik is an educational project focused on Western calligraphy. We provide informational content only and do not offer consulting, professional certifications, or regulated services of any kind.

Data Controller: Fairfax Holding B.V., Buizerdstraat 2, 4105 WH Culemborg, Netherlands.

Contact for privacy matters: [email protected]

Effective Date: 12 February 2026.

2. Personal Data We Collect

We collect personal data in the following categories, depending on how you interact with our site:

  • Identity & contact data: Your name, email address, and phone number — collected only when you voluntarily submit them through our contact form.
  • Form content: The message body and any project details you include in your contact submission.
  • Technical data: IP address, browser type and version, operating system, device type, screen resolution, and language preference.
  • Usage data: Pages visited, time spent on each page, referrer URL, click paths, and scroll depth.
  • Cookies & identifiers: Cookie values, session identifiers, and advertising identifiers as described in Section 4 below.
  • Conversion events: Form submission events, page view events, and button interaction events used for advertising measurement.

We do not collect special-category data (health information, religious beliefs, political views, biometric data), financial account details, or government-issued identification numbers.

3. Why We Process Your Data & Legal Basis

Under the General Data Protection Regulation (GDPR), we process personal data only where we have a valid legal basis. The following table summarises each processing purpose and its corresponding lawful ground:

  • Responding to your contact form submission: Art. 6(1)(b) — performance of a contract or pre-contractual steps at your request; and Art. 6(1)(a) — your consent, given by ticking the consent checkbox.
  • Website analytics (understanding how our site is used): Art. 6(1)(a) — your consent, obtained through our cookie banner before any analytics cookies are set.
  • Advertising remarketing and conversion measurement: Art. 6(1)(a) — your consent, obtained through our cookie banner before any marketing cookies are set.
  • Website security and fraud prevention: Art. 6(1)(f) — our legitimate interest in protecting the site and its users from malicious activity, spam, and abuse.
  • Compliance with legal and tax obligations: Art. 6(1)(c) — processing necessary to comply with Dutch and EU regulatory requirements.

Automated Decision-Making (Art. 22): We do not engage in automated decision-making or profiling that produces legal or similarly significant effects on individuals.

4. Cookies & Tracking Technologies

Our site uses cookies and similar technologies, organised into three categories. For a detailed table of specific cookies, their purposes, and retention periods, please see our Cookie Policy.

Essential Cookies (no consent required, always active)

These cookies are strictly necessary for the site to function. They include _site_session (session continuity, expires at session end) and cookie_consent (records your cookie preference, 12-month retention). We also use CSRF tokens where necessary for form security.

Analytics Cookies (consent required)

When you give consent, we may use Google Analytics 4 with IP anonymisation enabled. Specific cookies include _ga (GA4 user identifier, 2-year retention) and _ga_XXXXXXXXXX (GA4 session state with a 10-character GA4 measurement ID, 2-year retention). Analytics data retention is set to 14 months.

Marketing Cookies (consent required)

When you give consent, we may use advertising cookies for conversion tracking and remarketing. These include _gcl_au (Google Ads conversion linker, 90-day retention), _fbp (Meta Pixel browser identifier, 90-day retention), and _fbc (Meta Pixel click identifier, 90-day retention, set when a click ID is present in the URL).

Beyond cookies, we may use pixel tags (gtag.js, Meta Pixel), server-side tracking via Meta Conversion API or Google Server-Side Tag Manager (using hashed identifiers), and device fingerprints derived from IP address and User-Agent string combinations.

5. Consent for EEA and UK Users

Users located in the European Economic Area (EEA) and the United Kingdom receive a consent notice under the GDPR and UK GDPR respectively. Marketing and analytics cookies are activated only after you provide explicit, informed, and freely given consent (Art. 6(1)(a)). Your consent choice is recorded in the cookie_consent browser cookie, which is retained for 12 months.

You may withdraw your consent at any time by clicking "Manage Cookie Preferences" in the site footer, or by clearing your browser cookies. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

6. Sharing With Advertising & Service Partners

We share certain data with the following third-party service providers, strictly in connection with the purposes described above:

  • Google LLC (Google Analytics 4, Google Ads, Google Tag Manager, Remarketing): Cookie identifiers, usage data, conversion events, and remarketing list membership. Google's privacy policy is available at policies.google.com/privacy.
  • Meta Platforms, Inc. (Meta Pixel, Custom Audiences, Lookalike Audiences, Conversion API): Page view events, conversion events, audience membership, and hashed identifiers. Meta's privacy policy is available at facebook.com/privacy/policy.
  • Cloudflare, Inc. (CDN and security): IP-based threat detection and DDoS mitigation. Cloudflare's privacy policy is available at cloudflare.com/privacypolicy.

We do not sell personal data. These providers may not use data collected from our site for their own independent commercial purposes beyond the services they provide to us.

7. International Data Transfers

Some of our service providers (notably Google and Meta) are based in the United States and process data outside the EEA and the United Kingdom. We rely on the following transfer mechanisms to ensure adequate protection of your data:

  • EU-US Data Privacy Framework (primary mechanism, effective since July 2023)
  • UK Extension to the EU-US Data Privacy Framework
  • Swiss-US Data Privacy Framework
  • Standard Contractual Clauses (EU 2021/914) as a fallback mechanism
  • UK International Data Transfer Agreement (IDTA) as a fallback for UK transfers

8. Data Retention

We retain personal data only for as long as is necessary for the purpose for which it was collected. Our retention schedule is as follows:

  • Contact form submissions: 2 years from the date of your last interaction with us.
  • Analytics data: 14 months (configured within Google Analytics 4).
  • Marketing cookies: Per individual cookie lifetime (see Section 4 above; maximum 2 years).
  • Email correspondence: Duration of the relationship plus 1 additional year.
  • Server logs: 90 days.
  • Cookie consent records: 3 years (retained for audit and compliance documentation purposes).
  • Legal and tax records: As required by applicable Dutch law (typically 7 years for financial and tax documentation under Dutch fiscal regulations).

9. Your Rights Under GDPR & UK GDPR

Depending on your location, you may exercise the following rights with respect to your personal data:

  • Right of Access (Art. 15): You may request a copy of the personal data we hold 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 where there is no compelling reason for its continued processing.
  • Right to Restriction of Processing (Art. 18): You may request that we restrict the processing of your data in certain circumstances.
  • Right to Data Portability (Art. 20): You may request to receive your data in a structured, commonly used, machine-readable format.
  • Right to Object (Art. 21): You may object to processing based on legitimate interests or direct marketing.
  • Right to Withdraw Consent (Art. 7(3)): Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.
  • Right to Lodge a Complaint (Art. 77): You may lodge a complaint with a supervisory authority.

To exercise any of these rights, please email us at [email protected] with the subject line "Privacy Rights Request." We will respond within 30 calendar days, extendable by an additional 60 days for complex or voluminous requests, in which case we will inform you of the extension and reasons.

Lead Supervisory Authority: As Fairfax Holding B.V. is established in the Netherlands, our lead supervisory authority is the Autoriteit Persoonsgegevens (Dutch Data Protection Authority) — autoriteitpersoonsgegevens.nl. UK residents may also contact the Information Commissioner's Office (ICO) at ico.org.uk.

10. Children's Privacy

This site is not directed at individuals under the age of 16. We do not knowingly collect personal data from minors. If we become aware that we have inadvertently collected data from a child under 16 without verifiable parental consent, we will take prompt steps to delete that data from our records. If you believe a minor has provided us with personal data, please contact us at [email protected].

11. Do Not Track Signals

This website does not respond to "Do Not Track" (DNT) browser signals. There is no industry-wide standard for DNT compliance. However, you can control tracking through our cookie consent banner. Third-party providers such as Google and Meta may have their own DNT handling policies, which are described in their respective privacy policies linked in Section 6.

12. Account & Data Deletion

Deltranik does not maintain user accounts. If you have submitted information through our contact form and wish to have that data deleted, please email us at [email protected] with the subject line "Data Deletion Request." We will complete your request within 30 calendar days of verifying your identity. Limited retention may continue only where required by Dutch law (for example, financial and tax records that must be kept for 7 years under the Algemene wet inzake rijksbelastingen).

13. Business Transfers

In the event of a merger, acquisition, asset sale, financing arrangement, or insolvency involving Fairfax Holding B.V., personal data may be transferred to a successor entity as part of the transaction. In such a case, we will notify users via a prominent notice on our website if the transfer materially changes how your personal data is used or handled. The successor entity will remain bound by this Privacy Policy until a revised policy is published with at least 14 days' notice.

14. California Residents (CCPA / CPRA)

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA).

Categories of personal information disclosed in the preceding 12 months:

  • Identifiers (name, email address, IP address, device identifiers) → disclosed to service providers and advertising partners.
  • Internet or other electronic network activity information (browsing history, interactions with our site) → disclosed to analytics and advertising providers.
  • Inferences (interests, preferences derived from browsing behaviour) → disclosed to advertising partners for audience targeting.

We do not sell personal information as defined by the CCPA. We do share personal information for cross-context behavioural advertising. California residents may opt out of this sharing via our cookie preferences panel, accessible through the "Manage Cookie Preferences" link in the site footer.

Your California rights: Right to Know, Right to Delete, Right to Correct, Right to Opt-Out of sale or sharing, and the Right to Non-Discrimination. To exercise these rights, please email us with the subject line "California Privacy Request." We may request identity verification before processing your request. Authorised agents may submit requests on your behalf with written proof of authorisation.

15. Virginia Residents (VCDPA)

If you are a Virginia resident, you have rights under the Virginia Consumer Data Protection Act (VCDPA), including the right to access, correct, delete, and obtain a portable copy of your personal data, and the right to opt out of targeted advertising.

To exercise these rights, please email us with the subject line "Virginia Privacy Request." We do not sell personal data, and we do not engage in profiling that produces legal or similarly significant effects.

If we refuse your request, you may appeal by emailing us with the subject line "Appeal of Refusal — Privacy Request." We will respond to your appeal within 60 days. If the appeal is not resolved to your satisfaction, you may contact the Virginia Attorney General.

16. Nevada Residents

Nevada residents may submit a verified opt-out request by emailing us with the subject line "Nevada Do Not Sell Request." We do not currently sell personal information as defined under Nevada Revised Statutes Chapter 603A.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or operational needs. Material changes will be announced via a prominent banner on our homepage at least 14 days before the revised policy takes effect. The "Last Updated" date at the top of this page will be refreshed with every revision. We encourage you to review this page periodically.

18. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, you may reach us through any of the following channels:

We aim to respond to all privacy-related enquiries within 5 working days.