Privacy notice.

Version 1.0 · working draft. To be reviewed and adopted by counsel before public launch.

1. Controller

J. van Huuksloot Asset Management B.V. ("JvHAM", "we"), registered in the Netherlands under KvK 76675602, with registered office at Nieuwe Looiersstraat 48H, 1017 VD Amsterdam, is the controller of personal data processed via jvham.com. Contact: inquiries@jvham.com.

2. What we collect

When you submit the enquiry form we collect: the legal and registration details of the merchant entity, contact details of the named representative (name, role, email, phone), details of the regulated PSP counterparty, the merchant services agreement metadata, an estimate of the amount in dispute, the heads of claim asserted, the documentary completeness of the file, and any free-text information you provide.

Server logs (IP address, user-agent, request path) are processed by our hosting provider for security and operational purposes.

3. Purpose and legal basis

• Initial fit assessment of the prospective recovery file — legitimate interest (Art. 6(1)(f) GDPR) and, where you have provided the data, performance of pre-contractual steps at your request (Art. 6(1)(b) GDPR).
• Communications with you in response to the enquiry — same basis.
• Anti-spam verification via Cloudflare Turnstile — legitimate interest in protecting the service.
• Compliance with legal obligations — where applicable.

4. Recipients and processors

We use the following processors:

• Cloudflare, Inc. — hosting, CDN, anti-spam (Turnstile), email routing, and database (D1). Data may be processed in the EU and other regions where Cloudflare operates.
• Resend, Inc. — transactional email delivery.

Data may be disclosed to external counsel, supervisory authorities, courts and tribunals to the extent strictly necessary for the conduct of a recovery file, after a separate Claim Assignment and Recovery Agreement has been executed.

5. International transfers

Where personal data is transferred outside the EEA, transfers are subject to appropriate safeguards under Chapter V GDPR (Standard Contractual Clauses or equivalent).

6. Retention

Enquiry submissions assessed as not a fit are retained for up to twenty-four (24) months from receipt to permit follow-up and to maintain an audit trail. Submissions leading to executed engagement are retained for the duration of the engagement and for seven (7) years thereafter consistent with professional record-keeping obligations.

7. Your rights

Under the GDPR you have the right to access, rectification, erasure, restriction, objection, and data portability in respect of your personal data, subject to applicable exceptions. To exercise these rights, write to inquiries@jvham.com. You also have the right to lodge a complaint with a supervisory authority — in the Netherlands, the Autoriteit Persoonsgegevens.

8. Cookies

jvham.com does not use analytics or marketing cookies. Strictly necessary cookies may be set by Cloudflare for security purposes (anti-bot challenge tokens).

9. Changes

We may update this notice from time to time. Material changes will be flagged on this page.