Privacy Policy

This Privacy Policy explains how we handle the personal data of visitors to pretrain.com. We have built this website to collect as little personal data as possible.

1. Who we are (the controller)

For the personal data described in this policy, the controller is:

2. Data Protection Officer

We have not appointed a Data Protection Officer, as we are not legally required to do so. For any privacy question or request, contact us at wesley@axonn.ai and we will handle it directly.

3. What we collect, why, and on what legal basis

We process personal data only for the purposes below. Each purpose lists its legal basis under Article 6(1) of the GDPR.

Booking a call (Calendly)

If you book a call, we process the name, email address, scheduling details and anything you type into the booking form. Purpose: to arrange and conduct the requested meeting. Legal basis: taking steps at your request prior to entering into a contract and/or our legitimate interest in responding to enquiries (Art. 6(1)(b) and (f)). The Calendly scheduler loads only after you accept it in our cookie bar, which we treat as your consent to connect to Calendly (see our Cookie Statement).

If you email us

If you contact us by email, we process your email address and the contents of your message. Purpose: to respond to you and follow up. Legal basis: our legitimate interest in handling correspondence and/or pre-contractual steps at your request (Art. 6(1)(f) and (b)).

The scan and the playbook form

If you fill in a form on this site, we process your name, email address, telephone number, role and the answers you gave. Purpose: to send you what you asked for and to follow up on your enquiry. Legal basis: steps taken at your request prior to a contract and our legitimate interest in responding to enquiries (Art. 6(1)(b) and (f)). We keep the enquiry in our own CRM so we know what was discussed.

Separately, and only if you accepted cookies, our server also sends a conversion event to Meta containing your email address, name and phone number in hashed form plus your IP address and user-agent, so we can measure which advertisement produced the enquiry. Legal basis: your consent (Art. 6(1)(a)). Decline, or leave the cookie bar unanswered, and this event is not sent; the rest of the handling is unaffected.

Server and hosting logs

Our hosting provider (Vercel) processes standard technical log data such as your IP address, timestamp and browser user-agent. Purpose: to operate and secure the website. Legal basis: our legitimate interest in a secure, functioning site (Art. 6(1)(f)). Any visitor analytics we may use through Vercel is cookieless and does not track you across sites.

Analytics, advertising and company recognition

If, and only if, you accept in our cookie bar, we load Google Analytics, the Meta Pixel, Microsoft Clarity and Leadinfo. Together they tell us how many people read a page, where they came from, where a page confuses them, what our advertising produces, and which company a visit came from. Legal basis: your consent (Art. 6(1)(a)), which you can withdraw at any time. Full detail per service is in our Cookie Statement.

Our typefaces load from Google Fonts on every visit, which sends your IP address to Google. Legal basis: our legitimate interest in a legible website (Art. 6(1)(f)).

4. Who receives your data (processors and recipients)

The personal data we hold from website visitors is minimal. We share it only with the service providers that help us run the site and respond to you:

• Vercel — website hosting and cookieless visitor counts (US parent company).
• Resend — sending the email you asked for.
• Calendly — scheduling, only after you accept cookies (United States).
• Google — Analytics, only after you accept cookies; and Google Fonts on every visit (United States).
• Meta — advertising measurement through the Pixel and, on form submissions, the Conversions API. Only after you accept cookies (United States).
• Microsoft — Clarity usage analytics, only after you accept cookies (United States).
• Leadinfo — recognising the visiting company from its IP address, only after you accept cookies (Netherlands).

We do not sell your data. We do share the advertising measurement described above with Meta, and only with your consent. If you become a client of Pretrain, our processing of your customers' personal data on your behalf is a separate matter governed by our Data Processing Agreement, not by this policy.

5. International transfers

Because several providers are based in the United States (Vercel, Calendly, Google, Meta, Microsoft), your data may be transferred outside the European Economic Area. Where that happens, the transfer relies on the EU‑U.S. Data Privacy Framework adequacy decision for DPF-certified recipients, backed by EU Standard Contractual Clauses where the Framework does not apply. Copies of the relevant safeguards are available on request.

6. How long we keep it

We keep booking and email data only for as long as needed for the contact or relationship it relates to, and then delete it. In practice, enquiry and booking data is kept up to 24 months after our last contact with you, unless a client relationship continues (in which case it is governed by that engagement). Technical server logs are kept only short-term for security and operational purposes.

7. Your rights

Under the GDPR you have the right to:

• access the personal data we hold about you;
• have inaccurate data rectified;
• have your data erased;
• restrict our processing;
• data portability;
• object to processing based on legitimate interest; and
• withdraw your consent at any time, where processing is based on consent.

To exercise any of these rights, email wesley@axonn.ai. We will respond within one month. Withdrawing consent does not affect the lawfulness of processing done before withdrawal.

8. Complaints

If you believe we handle your data unlawfully, you have the right to lodge a complaint with the Dutch supervisory authority, the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl, Postbus 93374, 2509 AJ Den Haag). We would appreciate the chance to resolve your concern first, so please consider contacting us at wesley@axonn.ai before doing so.

9. Automated decision-making

We do not carry out automated decision-making or profiling of website visitors that produces legal or similarly significant effects. Any lead-scoring or AI systems we build for clients are separate and are governed by that client's own privacy notices and our Data Processing Agreement with them.

10. Changes to this policy

We may update this Privacy Policy from time to time. The current version is always shown here, dated at the top.

See also: Cookie Statement · Terms of Use · Data Processing Agreement.