Privacy Policy

• Contact form: your name, email address, phone number (optional), company (optional), budget, the services you select, your project description and whether you'd like an NDA.
• Email and phone: whatever you choose to share when you email or call us.
• Clients: contact details, billing details (company name, address, VAT number) and the information needed to deliver your project.
• Website visits: our hosting provider automatically logs technical data such as your IP address, browser type and the pages you request. We don't use these logs to identify you.

We don't use analytics, advertising trackers or social media pixels on this website.

• To answer your enquiry and prepare a quote, based on your consent (the checkbox on the contact form) and on steps you ask us to take before a contract (GDPR article 6.1.a and 6.1.b).
• To deliver projects and support you as a client, based on our contract (article 6.1.b).
• To invoice and keep our accounts, based on our legal obligations (article 6.1.c).
• To keep this website secure and working, based on our legitimate interest (article 6.1.f).

We never sell your data and never use it for marketing without asking you first.

This website sets a single cookie, semper-theme, which remembers whether you prefer dark or light mode. It is strictly necessary for that feature, contains no personal data and expires after one year. Because we use no tracking or analytics cookies, we don't need to ask for cookie consent.

For AI projects we work with Anthropic (Claude), OpenAI (GPT), Google (Gemini) and Mistral AI. When we use them:

• We only use their business API services, under terms that don't allow them to train their models on the data we send.
• We only send the data a project actually needs, and remove or pseudonymise personal data where we can.
• We agree with each client in advance which provider is used, and prefer EU hosting where it's available.
• Data from this website and the contact form is never sent to an AI provider.

Aerial footage can show recognisable people, vehicles or property. We plan flights to avoid filming people where possible, follow EASA rules and the requirements of the Belgian Civil Aviation Authority, and only deliver footage to the client who ordered it.

If you recognise yourself in footage we made, email gentian@semper-code.com and we'll blur or remove you.

When we build or maintain an app, website, webshop or AI system for a client, we may have access to personal data of that client's customers or users. In that case the client is the data controller and we act as their processor. We only process that data on the client's instructions and under a data processing agreement, and we keep it confidential and secure. The client's own privacy policy applies to their users.

We only use service providers that need the data to do their job, under a data processing agreement:

• Microsoft 365 (Microsoft Ireland) for email and file storage.
• Resend for delivering contact form messages to our inbox.
• A hosting provider within the EU for running this website.
• Our accountant for bookkeeping and tax obligations.
• The AI providers listed above, only within client projects.

We don't share your data with anyone else unless the law requires it.

Some of these providers (Anthropic, OpenAI, Google, Resend and, for some services, Microsoft) are based in the United States. Transfers to them are protected by the EU-US Data Privacy Framework and the European Commission's standard contractual clauses. Where we can choose, we use data centres in the EU.

• Enquiries that don't lead to a project: 12 months after our last contact.
• Client and project communication: as long as the collaboration lasts, and up to 5 years after it ends to handle follow-up questions or warranty claims.
• Invoices and accounting records: 10 years, as required by Belgian law.
• Server logs: only as long as our hosting provider needs them for security, normally a few weeks.

We protect your data with encrypted connections, strong passwords and two-factor authentication on our accounts, up-to-date devices and access limited to what's needed. Because Semper Code is one person, nobody else has access to your data.

Under the GDPR you have the right to:

• see the data we hold about you;
• have incorrect data corrected;
• have your data deleted;
• restrict or object to how we use it;
• receive your data in a portable format;
• withdraw your consent at any time, without affecting what we did before.

Email gentian@semper-code.com to use any of these rights. We'll reply within one month and may first ask you to confirm your identity.

If you're not happy with how we handle your data, please contact us first so we can fix it. You also have the right to file a complaint with the Belgian Data Protection Authority, Drukpersstraat 35, 1000 Brussels (www.dataprotectionauthority.be).

We may update this policy when our services or the law change. The date at the top of this page always shows the latest version.