Basegrow B.V. Privacy Statement

Last updated: 19 October 2026

1. Who we are

Basegrow B.V. ("Basegrow", "we", "us") is based at Papaverweg 34, 1032 KJ Amsterdam, the Netherlands, and is registered with the Dutch Chamber of Commerce under number 56577869. We build and run email audiences for travel brands and B2B outreach systems.

We are the controller of the personal data described in this statement, unless we say expressly that we work on behalf of a client.

Questions, a request or a complaint about your data? Email dennis@basegrow.com (D.A. Klompalberts, director).

2. Who this statement is for

People whose email address we use to send travel and holiday offers, or whose address we pass on to travel companies (section 3).
Business contacts that we or a client of ours approach (section 4).
Visitors to basegrow.com (section 5).

3. Travel and holiday offers by email

What data we process

Your email address.
As far as you provided them yourself: first and last name, gender, date of birth, address, postcode, town or city, and phone number.
Proof of your consent: the date and time, your IP address and the source where you signed up.
What happens to our messages: delivered, opened, clicked, not delivered (bounce), complaint or unsubscribe.
The country and the email provider that belong to your address.
A score for how active you are on our messages. We use it to decide how often we email you and when to stop.

Where the data comes from

From source partners: websites and data suppliers where you signed up to receive travel and holiday offers. For every address we record which source it came from, when, and on what legal basis.
From our own newsletters, such as Travelwhale and Favotrip, which you signed up for yourself.

What we use it for, and the legal basis

Purpose	Legal basis (GDPR)
Sending you travel and holiday offers by email	Consent, art. 6(1)(a)
Passing your email address to travel companies so they can send you travel and holiday offers	Consent, art. 6(1)(a)
Tracking how messages arrive and are read: this lets us decide how often to email, stop mailing addresses that do not receive our messages, and stop emailing people who never respond	Legitimate interest, art. 6(1)(f): good delivery and no nuisance
Keeping an opt-out list so that we do not email you again after you unsubscribe or object	Legitimate interest and legal obligation, art. 6(1)(f) and (c)
Being able to show your consent	Legal obligation, art. 7(1) GDPR, art. 6(1)(c)
Security, preventing abuse and handling complaints	Legitimate interest, art. 6(1)(f)
Legal obligations, such as a request from a supervisory authority	Legal obligation, art. 6(1)(c)

You can withdraw your consent at any time. This does not affect anything that happened before.

Travel companies (our partners). We pass your email address to selected travel companies. Only your email address, no other data. We receive a fee for this. After receipt, a partner becomes responsible for its own use of your address. We have agreed with our partners that they:

use your address only for travel and holiday offers;
state in their emails that they received your address from Basegrow;
include an unsubscribe link in every email and process unsubscribes immediately and permanently;
do not resell your address without our consent.

Want to know which parties we passed your address to? Email us and we will tell you.

Service providers (processors). Companies that work for us, for example for hosting, sending email and security. They may use your data only for us and on our instructions.

Authorities and advisers, when the law requires it or when we need to defend a legal claim.

Our own servers are located in the European Economic Area (Frankfurt, Germany). If we ever transfer data to a party outside the EEA, we do so only with appropriate safeguards, such as standard contractual clauses or the EU-US Data Privacy Framework.

How long we keep your data

For as long as your consent applies and we need your address for this purpose.
If you do not respond to our messages for 24 months, we stop emailing you and permanently delete your data.
After an unsubscribe or objection we keep your email address on our opt-out list for 12 months. During that time we do not email you again and do not pass your address on. After that we permanently delete all your data, including your email address.
We keep the proof of your consent for as long as we use your address, and afterwards for as long as needed to defend a claim.

4. Business contacts

For B2B outreach we use business data: name, job title, company and business email address. It comes from public sources such as company websites and business registers. For each contact we record where it came from and when. The legal basis is our legitimate interest, or that of our client, in approaching companies with a relevant business offer (art. 6(1)(f)). You can object at any time; we will then stop emailing you and delete your data within the period in section 3. When we work on behalf of a client, that client's privacy statement also applies.

5. The website basegrow.com

We place no cookies on basegrow.com and use no analytics or tracking tools.
The website runs on GitHub Pages (GitHub, Inc.). On every visit GitHub technically records your IP address in log files. This is needed to show you the page.
We load fonts through Google Fonts. Your browser connects to Google for this, and your IP address is shared.
If you email us, we use your name, email address and message to reply (legitimate interest). We keep it while the conversation lasts and afterwards no longer than needed.

6. Your rights

You have the right to access, rectification, erasure, restriction of processing and portability of your data. You can object to processing based on legitimate interest, and you can withdraw your consent.

Unsubscribing: use the unsubscribe link in every email, or email us. If you unsubscribe with us, we put you on the opt-out list and stop passing your address on. If a partner already has your address, you also need to unsubscribe with that partner through the link in their email. Email us if you want us to pass that on.
Other requests: email dennis@basegrow.com. We respond as soon as possible and within one month at the latest. To make sure it is you, we may ask you to confirm from the email address concerned.
Origin: want to know where we got your data? We will tell you.

7. Security

We protect your data with appropriate technical and organisational measures: encrypted storage and connections, access only for those who need it (with two-step verification for administrators), and logging of access and changes. In the event of a data breach we notify the supervisory authority and, where required, you.

8. Complaints

If we cannot resolve it together, you can file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, autoriteitpersoonsgegevens.nl). If you live in Belgium, you can contact the Data Protection Authority (GBA/APD). In another EU country you can contact the supervisory authority of your country of residence.

9. Changes

We may update this statement. The latest version is always on this page, with the date at the top.