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Privacy Policy of Averqelle

A legal disclaimer

Last updated: 10 August 2026


1. Who we are

This Privacy Policy explains how Averqelle, a trade name of Paauwer Products (“Averqelle”, “we”, “us” or “our”), collects, uses, stores and protects personal data when you visit our website, contact us, place an order or use our services.


For the processing described in this Privacy Policy, the data controller is:

  • Registered business name: Paauwer Products

  • Trade name: Averqelle

  • Registered address: Kanaalstraat 18B, 4417AJ Hansweert, the Netherlands

  • Chamber of Commerce (KvK) number: 75207672

  • VAT identification number: NL002347252B47

  • Email address: info@averqelle.com


2. To whom this policy applies

This Privacy Policy applies to website visitors, prospective customers, customers, representatives of business customers and other people who communicate with us or whose personal data is included in materials supplied for a project.

Our services are not directed at children. We do not knowingly collect personal data directly from children. If project materials contain identifiable children, the Customer is responsible for ensuring that there is a valid legal basis and that any required parental or guardian permission has been obtained.


3. Personal data we collect

Depending on how you interact with us, we may process the following categories of personal data:


3.1 Contact and identity information

  • name;

  • business or organisation name;

  • job title or role;

  • email address;

  • telephone number;

  • billing and business address; and

  • other contact details you provide.


3.2 Order and payment information

  • products or services ordered;

  • order number, date and status;

  • invoice and VAT details;

  • payment status and transaction references;

  • correspondence about your order; and

  • information required to prevent fraud or process refunds.


Payments may be processed by an external payment provider. We do not normally receive or store complete payment-card details.


3.3 Project information and content

  • links to property listings;

  • property information, preferences and production instructions;

  • photographs, video footage, logos, text, music and other files supplied for a film;

  • comments, feedback and revision requests; and

  • names, images, voices or other personal data appearing in supplied project materials.


3.4 Website and technical information

  • IP address;

  • browser and device information;

  • approximate location derived from an IP address;

  • pages viewed, links clicked and visit duration;

  • cookie identifiers and consent preferences; and

  • website security and diagnostic information.


3.5 Communications and marketing information

  • emails and other messages sent to or received from you;

  • contact-form submissions;

  • requests for quotations or information;

  • newsletter or marketing preferences; and

  • records of consent, objections or unsubscribe requests.


We ask you not to provide sensitive personal data unless it is strictly necessary and has been expressly agreed in advance.


4. How we obtain personal data

We obtain personal data:

  • directly from you when you contact us, complete a form, place an order, make a payment or supply project materials;

  • from a business or representative acting on your behalf;

  • from property listings and other public sources that you ask or authorise us to use;

  • automatically through our website and permitted cookies or similar technologies; and

  • from service providers that help us operate our website, process payments, communicate with customers or provide our services.


5. Why we use personal data and our legal bases

We process personal data only where we have a valid legal basis under applicable data-protection law.


PurposePersonal data generally usedLegal basis


Responding to enquiries and preparing quotationsContact details, communications and project informationTaking steps at your request before entering into a contract and, where applicable, our legitimate interest in responding to business enquiries

Accepting, managing and delivering ordersContact, order, payment and project informationPerformance of a contract or taking pre-contractual steps

Creating, reviewing and delivering property filmsProject materials, instructions, communications and limited contact informationPerformance of a contract; for personal data relating to others in Customer-supplied content, our legitimate interest in delivering the requested service, subject to the Customer having a lawful basis to supply it

Invoicing, bookkeeping and tax administrationIdentity, contact, order, invoice and payment informationCompliance with legal obligations


Customer service, complaints and dispute handlingContact details, communications, order and project informationPerformance of a contract, compliance with legal obligations and our legitimate interest in establishing, exercising or defending legal claims

Website operation, security and fraud preventionTechnical, usage, order and transaction informationOur legitimate interest in protecting our website, customers and business, and compliance with legal obligations where applicable


Website analytics and non-essential cookiesCookie, device and usage informationConsent, where consent is legally required


Sending newsletters and promotional communicationsName, email address and marketing preferencesConsent, or another lawful basis permitted for communications to existing customers; you may object or unsubscribe at any time


Improving our services and understanding customer needsFeedback, aggregated usage data and limited order informationOur legitimate interest in improving our services, provided your rights and interests do not override that interest

Where processing is based on consent, you may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.


Where processing is based on our legitimate interests, you may object as described in section 11.


6. When you must provide personal data

Certain information is necessary to prepare a quotation, process payment, comply with legal requirements or deliver the ordered film. If you do not provide the required information or materials, we may be unable to enter into or perform the agreement.

Fields that are mandatory will normally be identified when information is collected.


7. Sharing personal data

We do not sell your personal data.

We may share personal data only where reasonably necessary with:

  • our website and e-commerce provider, including Wix where used;

  • payment, invoicing and bookkeeping providers;

  • email, communication and customer-support providers;

  • cloud storage, file-transfer and hosting providers;

  • carefully selected editors, production partners, freelancers and other subcontractors involved in creating or delivering your film;

  • analytics, advertising or cookie providers, but only in accordance with your consent where required;

  • professional advisers, such as accountants, insurers or legal advisers;

  • public authorities, regulators, courts or law-enforcement bodies where required by law; and

  • a buyer, successor or adviser in connection with a proposed sale, restructuring or transfer of all or part of our business, subject to appropriate confidentiality safeguards.


Service providers and subcontractors may process personal data only for agreed purposes and must protect it appropriately. Where required, we enter into data-processing or confidentiality arrangements with them.


8. International transfers

Some service providers or production partners may be located outside the European Economic Area (“EEA”), or may store or access data from outside the EEA.

Where personal data is transferred to a country that has not been recognised as providing an adequate level of data protection, we use an appropriate transfer mechanism where required, such as the European Commission’s Standard Contractual Clauses, together with additional safeguards where appropriate.

You may contact us for more information about the safeguards used for relevant international transfers.


9. How long we retain personal data

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected and to comply with legal, tax, accounting and dispute-resolution obligations.

Unless a different period is required or justified in a particular case, we generally apply the following periods:

  • enquiries that do not result in an order: up to 12 months after the last meaningful contact;

  • customer correspondence and contractual records: for the duration of the customer relationship and up to 5 years afterwards where reasonably necessary for claims or dispute handling;

  • invoices, transaction records and legally required financial administration: generally 7 years, or longer if required by law;

  • project source materials, previews and final delivery files: normally up to 90 days after final delivery, unless a longer period is agreed or reasonably required to deal with revisions, complaints or legal claims;

  • cookie and analytics information: according to the periods stated in our cookie settings or cookie policy; and

  • marketing data: until you unsubscribe, withdraw consent or successfully object, after which we may retain minimal suppression information to ensure that we honour your request.


We may retain information for longer where necessary to comply with law, establish or defend legal claims, investigate fraud or resolve an active complaint. When personal data is no longer needed, we delete or anonymise it.


10. Security

We use appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.


These measures may include access controls, account security, secure storage, limited staff or contractor access, confidentiality obligations and appropriate supplier arrangements. No internet transmission or storage system is completely secure, but we take reasonable steps appropriate to the nature and risk of the data involved.


11. Your privacy rights

Subject to the conditions and exceptions in applicable law, you may have the right to:

  • receive information about how we process your personal data;

  • access your personal data;

  • correct inaccurate or incomplete personal data;

  • request deletion of your personal data;

  • request restriction of processing;

  • receive certain data in a structured, commonly used and machine-readable format and transmit it to another organisation;

  • object to processing based on legitimate interests;

  • object at any time to the use of your personal data for direct marketing;

  • withdraw consent at any time where processing is based on consent; and

  • lodge a complaint with a competent data-protection authority.


To exercise a right, email info@averqelle.com. Please specify your request clearly. We may ask for information needed to verify your identity and prevent unauthorised disclosure. We will respond within the period required by applicable law.

These rights are not absolute. We may refuse or limit a request where permitted or required by law and will explain the reason where legally required.


12. Complaints

If you have a concern about how we process your personal data, please contact us first at info@averqelle.com so that we can try to resolve it.

You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) through its official website: www.autoriteitpersoonsgegevens.nl.


If you live in another EEA country, you may also contact the data-protection authority in your country of residence, work or where the alleged infringement occurred.


13. Cookies and similar technologies

Our website may use functional, preference, analytics and marketing cookies or similar technologies.


Strictly necessary cookies may be used without consent where permitted by law. We will request consent before using non-essential cookies where consent is required. You can accept, refuse or adjust non-essential cookie categories through our cookie banner or settings. Refusing non-essential cookies should not prevent access to the basic website.

You may change or withdraw your cookie consent as easily as you gave it. More detailed and current information—including cookie names, providers, purposes and retention periods—should be displayed in our cookie settings or a separate Cookie Policy generated from the cookies actually active on the website.


14. Third-party websites and platforms

Our website or communications may link to property listings, social media platforms or other third-party websites. Those third parties determine their own processing activities, and their privacy policies apply when you use their services. We are not responsible for third-party privacy practices outside our control.


15. Automated decision-making

We do not use personal data to make decisions based solely on automated processing that produce legal effects or similarly significant effects on individuals.


16. Customer-supplied personal data

If you supply personal data relating to property owners, guests, employees, models or any other person, you are responsible for ensuring that:

  • you have a valid legal basis for supplying and using that data;

  • you have provided any legally required privacy information;

  • all required permissions or releases have been obtained; and

  • the data is relevant and limited to what is necessary for the project.


Where Averqelle processes such data solely on documented instructions for a Business Customer, the parties may enter into a separate data-processing agreement if required by law.


17. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes in our services, suppliers or legal obligations. The current version will be published on our website with the date of the latest update. Material changes may also be communicated through an appropriate additional notice.


18. Contact

For questions, requests or complaints about this Privacy Policy or our use of personal data, contact:

Averqelle / Paauwer Products
Kanaalstraat 18B, 4417AJ Hansweert, The Netherlands
Email: info@averqelle.com

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