Version privacy-1.0
Privacy statement AxonContinuity
Version 1.0, 26 October 2026
1. Who we are
AxonContinuity is a service of Axon Factory, a trade name of M. de Jager Holding B.V., Kweeklust 7, 2203 ZB Noordwijk, the Netherlands, Chamber of Commerce 60613319. Questions about your data go to support@axonfactory.ai.
2. Our two roles
2.1. Controller. For the data of your order, your session, the free backup check and the contact list, Axon Factory is the controller. That is what this privacy statement is about.
2.2. Processor. In the questionnaire you enter names and phone numbers of others: your staff and the contact persons of your suppliers, IT partner, insurer, bank and building manager. Your organisation is the controller of that data and Axon Factory is the processor. This is arranged in the AxonContinuity data processing agreement, which you accept together with the terms. We only use that data for your Plan and your Card, store it encrypted and separately, and delete it 30 days after delivery. If you are a staff member or contact person on a Card and have a question, please contact the organisation that had the Card made. If your request reaches us, we forward it to that organisation.
3. Which data, for what and on which legal basis
| For what | Which data | Legal basis |
|---|---|---|
| Carrying out the questionnaire and the order: putting together and delivering the Plan and the Card, resuming, and handling anything that goes wrong | E-mail address, company name, KVK number, the name and SBI code from the Trade Register, your answers about processes, systems, suppliers, backups and measures, and the language | Performance of the contract (art. 6(1)(b) GDPR). If you order on behalf of an organisation, it is our legitimate interest to perform the contract with that organisation (point f) |
| Payment, invoicing and refunds | Company name, KVK number, invoice address, e-mail address, amount, order number, voucher code | Performance of the contract and a legal obligation (points b and c): the tax retention obligation |
| Mails about your order: at payment, at delivery, on day 14 about going through the Plan and on day 50 about the call (not for a voucher). Every mail after delivery has a stop link | E-mail address, company name, order number, the three most important open points and the end date of the refund | Performance of the contract |
| Mails at your request or after an aborted payment: the link to resume the questionnaire later (at most 3 per hour), a new download link within 30 days of delivery, and once a mail with a link back to your overview if a payment was aborted or expired | E-mail address, company name, order number and the link | Performance of the contract, or at your request before entering into it (point b) |
| The mail after 6 months to review your Plan and check the numbers on the Card | E-mail address and company name | Legitimate interest (point f): a service message about the product you bought. It only contains an offer if you separately chose news. |
| Booking and holding the call, and refunding afterwards | What you enter when booking in Microsoft Bookings, such as name, e-mail address and order number, and the date of the call | Performance of the contract |
| Measuring through which channel orders come in and how long the questionnaire takes | The origin of the link you came in on (a short code, for example from a partner), and how long each step took, without the content | Legitimate interest (point f): knowing which channels work and making the questionnaire shorter. We do not build profiles with it |
| Limiting abuse | Your IP address, only briefly for the limit and not in our database, and a pseudonymised (hashed) version of your e-mail address | Legitimate interest (point f): keeping the service available |
| The free backup check (article 4) | See article 4 | At your request (point b) and, for news, consent (point a) |
| News and offers from Axon Factory, only if you tick that separately: when ordering "Occasionally send me an offer from Axon Factory (optional)", with the backup check the box for news | E-mail address and company name, with the time of your choice and the version and text of the box you saw | Consent (point a). You can withdraw it at any time, in every news mail or through support@axonfactory.ai. What we did before remains lawful |
| Answering questions | Your e-mail address, your name and what you write to us | Legitimate interest (point f). If you are a customer, also performance of the contract |
Where we write "hashed", we mean pseudonymised: the data is not stored in readable form, but can be traced back to you with additional information. It therefore remains personal data, and the periods and rights on this page apply to it too.
4. The free backup check
4.1. Your answers to the backup check stay in your browser (sessionStorage) until you close the tab. If you start the questionnaire in the same tab, they are filled in there. Our server calculates the verdict, but does not store your answers or the verdicts per question.
4.2. We only keep the overall verdict, the number of questions per verdict, the date, the language and the origin of the link. What you answered cannot be derived from that.
4.3. If you want the outcome by mail, we use your e-mail address only for that mail. After that we only keep a hashed version, for 30 days, for the limit of 3 mails per address per day.
4.4. If you also tick news (that box is unticked by default), we keep your e-mail address until you confirm it with the link in the mail. That link works for 30 minutes. If you do not confirm, we delete the address no later than one day after the confirmation link has expired. If you do confirm, we pass your e-mail address, its domain, the time and the version of the text on to Axon Factory's contact list, and delete the address at the backup check.
5. The language model and the residual risk
5.1. For systems and processes you can enter a name of your own. A language model by Anthropic assigns those free names to a fixed list of categories. The language model only receives those names (at most 20, of at most 80 characters) and a sequence number. It never receives your company name, KVK number, sector, location, e-mail address, the names or phone numbers of contact persons, your suppliers, policy details or your answers about backups. The language model writes no text in your Plan.
5.2. Before a name goes to the language model, we check it. If it looks like a phone number, e-mail address, IBAN or web address, we do not send it and it appears as "other" in the Plan.
5.3. Residual risk. A free name may still contain the name of a person, for example "payroll Jan". That check does not stop it. That is why we ask, at every free field, not to name people. If you do so anyway, that name goes to Anthropic in the United States.
6. Who receives the data
We do not sell data. These parties receive data, each only what they need. Processors work on behalf of Axon Factory, under a data processing agreement.
| Who | For what and which data | Where and with which safeguard |
|---|---|---|
| Microsoft Azure | Hosting of the website, the database, the Documents and key management. Processor; for the contact details of third parties, sub-processor | West Europe region (the Netherlands), within the EEA |
| Resend | Sends the mails. Receives the e-mail address and the content of the mail, never the Card or the phone numbers of contact persons. Processor | United States. Safeguard: the EU-US Data Privacy Framework or standard contractual clauses |
| Anthropic | Assigns free names of systems and processes (article 5). Processor | United States. Safeguard: standard contractual clauses. We only switch this on once the data processing agreement with Anthropic is in place; until then nothing goes to Anthropic |
| Mollie, through AxonHub | Payment and refund. Mollie is an independent controller for that; what Mollie does with your payment data is governed by Mollie's privacy statement. AxonHub is Axon Factory's own invoicing system and makes the invoice and the credit note | The Netherlands, within the EEA |
| Founders | Axon Factory's bookkeeping. Receives the invoices and credit notes. Processor | The Netherlands, within the EEA |
| Microsoft 365 and Microsoft Bookings | The support mailbox and booking the call. Receives what you mail us or enter when booking. Processor | Within the EU. For anything that does leave the EEA: the EU-US Data Privacy Framework or standard contractual clauses |
| Netherlands Chamber of Commerce (KVK) | Looks up the name and SBI code for your KVK number. Only receives that number | The Netherlands |
| Axon Factory's contact list | Only if you choose news (articles 3 and 4). Axon Factory manages that list itself, in AxonHub | Within the EEA |
7. Transfers outside the EEA
We keep your data within the EEA. Resend sends the mails from the United States, and Anthropic in the United States receives the free names of article 5. The safeguards in the table above apply to that. The contact details of third parties do not leave the EEA. You can request a copy of the safeguard through support@axonfactory.ai.
8. How long we keep data
| What | How long |
|---|---|
| Your answers, the contact details of third parties and the Documents | 30 days after delivery. Not paid: 30 days after you started the questionnaire. Paid but not yet delivered: 30 days after payment. As a safety net, the storage deletes the Documents in any case no later than 45 days after they were put together |
| Database backups | Deleted data remains in the backups until the end of their retention period: 7 days. They are only used to restore the service after a failure |
| The download link | 7 days. Within 30 days of delivery you can request a new link |
| Your e-mail address with the order | 6 months after delivery, until after the mail to review your Plan. Not paid: 30 days after you started the questionnaire. Paid but not delivered: 6 months after you started the questionnaire. After that only a hashed version remains, until the session is deleted |
| The session (company name, KVK number, status, order number, origin of the link, payment and invoice numbers, the versions of the terms and the data processing agreement you accepted, the dates of the call) | 12 months after delivery, or 12 months after you started the questionnaire if nothing was delivered |
| The free backup check | The overall verdict and the counts: 12 months. The hashed version of your e-mail address: 30 days. Your e-mail address itself: only with news, until you confirm and it has been passed on, or no later than one day after the confirmation link has expired |
| Your choice for news on the contact list | Until you unsubscribe |
| Sent mails at Resend | Resend's retention period |
| The appointment in Microsoft Bookings and mails to support | As long as needed to handle the call and the refund |
| Invoices and credit notes | 7 years (legal retention obligation), in AxonHub and at Founders |
A daily task in AxonContinuity deletes what is past its period.
9. Protection of the data
We store the contact details of third parties encrypted and separately; they are not in log files, mails or the admin environment. We only decrypt them to put the Documents together, to show them to you again in your own questionnaire, and to determine per block whether it has been filled in; of the latter only "filled in" or "empty" leaves the application. The Card is never attached to a mail: you download the Documents through a link that works for 7 days. Links in mails contain a one-time code of which we only keep a hash. More about the protection of the contact details is in the data processing agreement.
10. Your rights
You have these rights over your personal data:
- Access: knowing which data we hold about you and getting a copy of it.
- Rectification: having incorrect or incomplete data corrected or completed.
- Erasure: having your data deleted, except what we must keep, such as invoices.
- Restriction: having the processing paused temporarily, for example while we assess your request.
- Portability: receiving data you gave yourself, and that we use for the contract or with your consent, in a common file format.
- Objection: objecting to processing based on legitimate interest. We then stop, unless there are compelling reasons that prevail.
- Withdrawing consent: for news this is always possible, without changing anything about your order.
- Complaint: if you disagree with how we handle your data, you can lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, autoriteitpersoonsgegevens.nl).
Mail your request to support@axonfactory.ai. We respond within one month. After 6 months we only have a hashed version of your e-mail address; we then ask for your order number to find your session. If your request is about contact details on a Card, see article 2.2.
AxonContinuity puts together a plan for an organisation and takes no decisions about people based solely on automated processing. We do not build profiles.
11. Cookies
This site has no tracking or advertising cookies and no analytics. We only use a functional cookie that links your questionnaire to this browser, so you can continue where you left off. That cookie works for 30 days. We keep the origin of the link and the answers of the backup check only in your browser, until you close the tab.
12. Changes
If this privacy statement changes, we put the new version on this page, with a new version number and a new date.