Privacy Policy
Last updated: 26 October 2026
This policy explains what happens to your personal data when you visit cloakdots.com, sign up for email updates, or send us a message through this site.
It covers this website only. The CloakDots app for iPhone and Android, and the app's support pages on app.cloakdots.com, have their own privacy policy: app.cloakdots.com/privacy/
1. Who we are
This website is run by Digital Commerce Guild, which is the controller of the personal data described in this policy. In this policy, "we" and "us" mean Digital Commerce Guild.
Digital Commerce Guild (eenmanszaak), Vlierweg 12, 1032 LG Amsterdam, the Netherlands. KVK: 94972036. VAT number (btw-id): NL005122477B37. Privacy questions: stealth@cloakdots.com
Correspondence address: Postbus 79055, 1070 NC Amsterdam, the Netherlands.
The name of the proprietor is recorded in the Dutch Commercial Register and is given on request.
2. What we collect
What you type into a form on this site and, only if you accept, statistics about how you use it (see Cookies and statistics). There are three forms, and this is all each one takes:
- Email updates. Your name, your email address, and the date and time you gave and confirmed your consent.
- General enquiries. Your name, your email address, what your message is about, and the message itself.
- Partnership and investment enquiries. Your name, your email address, and your note.
Section 3 explains what we do with each.
When you visit, Cloudflare, Inc., which hosts this site for us as our processor, receives your IP address, your browser description and the page requested, to deliver the pages. Messages you send through our forms pass through Cloudflare on their way to us and to Mailjet.
The fonts on this site are served from this site itself, not from Google or any other third party.
3. How we use your details
Email updates.
- Why: to send you the CloakDots updates you asked for. Nothing else.
- Legal basis: your consent (Article 6(1)(a) GDPR). We first send you a confirmation link, and we add you only once you open it.
- Who processes it: Mailjet SAS (France), our email provider, as our processor under a data processing agreement. Mailjet keeps your details in the European Union.
- How long: for as long as you stay subscribed. When you unsubscribe, we delete your name and email address within 28 days. We keep a record of your consent (your email address and when you gave, confirmed and withdrew it) for 2 years after you unsubscribe, so that we can show we had your consent.
- Your choice: every email has an unsubscribe link. You can also write to us.
General enquiries and partnership and investment enquiries.
- Why: to read and answer your message, and to keep a record of what was agreed.
- Legal basis: our legitimate interest in answering the people who write to us (Article 6(1)(f) GDPR). Where your message is about a possible agreement with us, such as a partnership or an investment, the steps you asked us to take before entering into a contract (Article 6(1)(b) GDPR).
- Who processes it: Mailjet SAS delivers your message to our mailbox at EuroDNS S.A. (Luxembourg), and keeps your name, your email address, and the form and topic you chose as a contact in our Mailjet account, so that we know who has written to us. Both act for us as our processors.
- How long: for as long as we need it to deal with your message, and no longer than 24 months after our last contact; the contact in our Mailjet account is deleted at the same time. Messages that lead to an agreement are kept for as long as Dutch law requires us to keep business records (7 years).
- Separate from email updates: asking us a question never adds you to our mailing list. That happens only if you tick the box that says so, and confirm the link we send you.
4. What we do not do
We do not sell your data, share it for advertising or monetise it. We do not use advertising tools, advertising pixels or session recording on this site. We use Google Analytics for statistics only if you accept, as described in Cookies and statistics. We do not collect biometric data of any kind.
We do not make decisions about you by automated means that have legal or similarly significant effects for you. We do not knowingly collect data from children under 16. If you are under 16, please do not use our forms.
5. Cookies and statistics
Your choice. When you first visit, we ask whether you accept statistics. Until you choose Accept, no analytics code is loaded, no analytics cookies are set and nothing is sent to Google. If you choose Reject, it stays that way. You can change or withdraw your choice at any time with the "Cookie settings" button on every page.
Statistics, only if you accept. If you choose Accept, we use Google Analytics to learn how this site is used, so we can improve it. Google Analytics then records which pages you view, how long you stay and how far you scroll, which links and files you open (including links to other websites), the page that brought you here, when and how often you visit, your browser and operating system (including their exact versions), your device type, brand and model, your screen size and language, and your approximate location (country, region and city), which Google works out from your IP address. It never records what you type into our forms. According to Google, Google Analytics does not store IP addresses. It sets two cookies on cloakdots.com (_ga and one starting with _ga_) that contain a random identifier for your browser. We do not use Google Analytics to identify you or for advertising, and we do not combine it with other data, including the statistics of app.cloakdots.com. Google signals, advertising features and the settings that would let Google use the statistics for its own products and services are switched off.
Who provides it. Google Ireland Limited provides Google Analytics to us as our processor, under Google's data processing terms. Google may process the data in the United States, through Google LLC. Transfers to the United States rely on the EU-U.S. Data Privacy Framework (and, for Switzerland and the United Kingdom, the Swiss-U.S. Data Privacy Framework and the UK Extension to it), with the European Commission's Standard Contractual Clauses as a fallback. The Google Analytics account is ours. We keep the statistics for this site in a separate property and use them only to improve this site. Only people we authorise can see them. Google's privacy policy: policies.google.com/privacy
Legal basis and withdrawal. We use Google Analytics only with your consent (Article 6(1)(a) GDPR and Article 11.7a of the Dutch Telecommunications Act). You can withdraw it at any time, as easily as you gave it, with the "Cookie settings" button on every page. The analytics cookies are then deleted from cloakdots.com and nothing more is sent. Withdrawing does not affect the lawfulness of measurement before you withdrew. If the button is not shown, for example because the banner could not load, no statistics are being collected. You can also delete the cookies for cloakdots.com in your browser settings, or write to us.
How long. We keep the statistics for 14 months. Totals that no longer relate to any browser may be kept longer. The cookies expire 13 months after they are set, and a later visit does not extend them.
Your cookie choice. We remember your choice in your browser's local storage on cloakdots.com, not in a cookie, so that we don't ask again on every page. It holds only your choice, the date and the version of this banner, with no identifier, and it never leaves your browser. After 12 months we ask again, or sooner if what we ask your consent for changes. Storing it is necessary to respect your choice, so it needs no consent.
Hosting and the banner. Cloudflare, Inc. (United States) hosts this site, and app.cloakdots.com, for us as our processor, under a data processing agreement. Each visit shows Cloudflare your IP address, your browser description and the page requested. Cloudflare uses them only to deliver the pages, and we do not receive or keep logs of these requests. The banner and the "Cookie settings" button come from a small script on app.cloakdots.com, the site we run for the CloakDots app, which stores nothing on your device until you make a choice. The script also deletes any analytics cookies left by earlier versions of this site. Cloudflare also asks your browser to report to Cloudflare if a page fails to load (Network Error Logging). Your browser keeps this instruction for up to 7 days. A report contains the address of the page or script that failed to load and the type of error, and reaches Cloudflare with your IP address. Cloudflare's servers are located around the world, so a request may be handled outside the European Economic Area. Transfers to the United States rely on the EU-U.S. Data Privacy Framework (and, for Switzerland and the United Kingdom, the Swiss-U.S. Data Privacy Framework and the UK Extension to it), with the Standard Contractual Clauses as a fallback. Cloudflare may also keep limited technical records under its own privacy policy to secure and operate its network: www.cloudflare.com/privacypolicy/. Legal basis: our legitimate interest in delivering this site securely, and in showing you this choice and respecting it (Article 6(1)(f) GDPR).
Separate from app.cloakdots.com. The support pages of the CloakDots app on app.cloakdots.com ask for their own choice and keep their own statistics. A choice you make here does not apply there. The CloakDots app has its own privacy policy: app.cloakdots.com/privacy/
6. Who receives your data
| Recipient | What they do for us | What they receive | Where |
|---|---|---|---|
| Cloudflare, Inc. | Hosts this site and app.cloakdots.com, delivers the cookie banner, and passes on messages from our forms | Your IP address, browser description and the page requested; form messages in transit | Worldwide, including the United States (section 7) |
| Mailjet SAS | Sends our email updates, delivers enquiries to us, and keeps a record of who has written to us | Name, email address, consent record; enquiries, and the form and topic you chose | European Union, with support access from the United States (section 7) |
| EuroDNS S.A. | Runs our mailbox | Your message and contact details | European Union |
| Google Ireland Limited, with Google LLC | Statistics, only if you accept | As described in Cookies and statistics | European Union and United States (section 7) |
Each of them acts for us as our processor, under a data processing agreement, and only on our instructions. We do not sell your data and we do not share it for advertising. We give it to authorities only when the law requires us to.
7. Transfers outside the European Economic Area
Cloudflare, Inc. and Google LLC are based in the United States. Transfers to them rely on the EU-U.S. Data Privacy Framework (and, for Switzerland and the United Kingdom, the Swiss-U.S. Data Privacy Framework and the UK Extension to it), with the European Commission's Standard Contractual Clauses as a fallback. Cloudflare's servers are located around the world, so a request to this site may be handled outside the European Economic Area.
Mailjet keeps your details in the European Union. Its support providers in the United States may access them when needed to support the service; these transfers rely on the European Commission's Standard Contractual Clauses or the EU-U.S. Data Privacy Framework, under Mailjet's data processing agreement.
8. How long we keep your data
- Email updates: for as long as you stay subscribed. After you unsubscribe, your name and email address are deleted within 28 days, and the record of your consent is kept for 2 years.
- Enquiries: no longer than 24 months after our last contact, including the contact in our Mailjet account. Messages that lead to an agreement: 7 years.
- Statistics: 14 months; the analytics cookies 13 months, or until you withdraw your consent. Your cookie choice: 12 months, in your browser.
- Visits: we do not receive or keep logs of requests to this site. Cloudflare may keep limited technical records under its own privacy policy.
9. Your rights
You have the right to access your data, to have it corrected or deleted, to restrict its use, and to receive it in a portable format. Where we rely on our legitimate interest, you can object. Where we rely on your consent, you can withdraw it at any time (see Cookies and statistics). Withdrawing does not affect what we did before you withdrew it. You can unsubscribe from our email updates at any time with the link in every email.
To use any of these rights, write to stealth@cloakdots.com. We reply within one month. We may ask you to confirm who you are, but only if we need to.
You can also complain to the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl), or to the data protection authority where you live or work.
10. Changes to this policy
If this policy changes, we publish the new version here with a new date. If a change affects how we use data you have already given us, and you are subscribed to our email updates, we tell you by email first.
Previous version: August 2026.
11. Contact
Privacy questions, data requests or concerns: stealth@cloakdots.com