Privacy Statement for BlueDolphin B.V., 1 April 2026

To download a pdf of this document, please click here.

1. BlueDolphin

We are BlueDolphin B.V., a Dutch company that trades under the name “BlueDolphin”.

We operate in the European Economic Area (EEA) and we store our data on servers in the EEA, unless we indicate otherwise in this privacy statement.

2. General

In this privacy statement we summarize which data we process about you and how we process it (Sections 3 – 5). In this privacy statement you will also find more information about the rights you have in relation to your personal data and how to exercise them (Section 6). We may change provisions of this privacy statement. If we do that, we will let you know. Nevertheless, we recommend that you periodically check yourself whether the privacy statement has been changed.

If you have any questions, concerns or comments about this privacy statement or if you wish to exercise your rights, please contact us by email at support@bluedolphin.io.

3. Which personal data do we process?

If you use our services or visit our websites, we may process your personal data. Below we explain per role which personal data we may collect from you, why we process it and how long we store it.

3.1 You use BlueDolphin

A. In order to be able to offer you our service ‘BlueDolphin’ and to make the service workable for you, we process the personal data mentioned below up to 13 months after your account has been terminated, your Session ID is kept for one day after your visit. We receive or generate the personal data mentioned below from you directly (for instance when you contact us or use our services). We use the data to create an account for you, to authorize you and to correspond with you about the service, your questions and any tickets you may submit. Our processing basis is the performance of an agreement. If you refuse to share your personal data with us for these purposes, we cannot provide you with our services.

• Name
• E-mail address
• Phone number
• Content of any communications you have with us
• Function
• Organization
• User ID
• Session ID
• BlueDolphin tenant name
• Password (encrypted)
• Role within the BlueDolphin software
• Powers and rights within the BlueDolphin software
• Language
• Information about the customer’s IT architecture, its processes and data
• Device information
• Support requests
• IP address
• Cookie ID
• Log details
• Time of the visit
• Information with regards to the handling of any tickets

If you contact us via the Intercom chat function, your data may be stored by our processor Intercom outside the EEA. Intercom guarantees to comply with European privacy legislation.

B. To secure our service, we process the personal data mentioned below up to 2 years after collecting it. Our processing basis is our legitimate interest to be able to adequately secure the service. We receive or generate the personal data mentioned below from you directly (when using our service).

• Name
• E-mail address
• IP address
• Date and time of logging in and out
• Role within the BlueDolphin software
• Powers and rights within the BlueDolphin software
• Actions performed on BlueDolphin

C. To improve our services, we process the personal data mentioned below up to 2 years after collecting it. Our processing basis is our legitimate interest to be able to improve our services. Your interests are safeguarded because the data processing is limited. We receive or generate the personal data mentioned below from you directly (when using our services).

• Name
• User ID
• Session ID
• BlueDolphin tenant name
• IP address
• Browser information
• Location data (country / province level)
• Actions performed on BlueDolphin
• Using BlueDolphin and problems encountered
• Language
• Device information
• Internet Service Provider (ISP)
• Length of the session

For more information on the placement of cookies when using the BlueDolphin software, please refer to our cookie statement: https://www.bluedolphin.io/cookie-policy.

D. If you use BlueDolphin, we can send you marketing material such as newsletters and offers. To this end, we process the personal data mentioned below up to 4 years after we last had contact with you or, if that is later, you last performed an action on BlueDolphin. We send such marketing communications in accordance with the applicable ePrivacy legislation. As such, the conditions for lawful processing laid down in the GDPR do not apply. We receive or generate the personal data mentioned below from you directly (when signing up for or using our services).

We may also send you surveys, interactive forms, evaluations or feedback requests. Our processing basis is our legitimate interest to be able to improve our services.

• Name
• E-mail address
• Phone number
• Content of communications you have with us
• Function
• Organization
• User ID
• Browser ID
• IP address
• Browser information
• Location data (country / province / city level)
• Role within the BlueDolphin software
• Actions performed on and use of BlueDolphin
• Language
• Demographic data
• Your personal lead score (see 3.4 (prospects) and 3.7 (customers) for further information)

You can unsubscribe from receiving these (marketing) messages by following the unsubscribe instructions included in each newsletter or by contacting us via support@bluedolphin.io. If you unsubscribe from receiving (marketing) materials, it will not affect our ability to send you emails about important matters and your account.

E. If you use BlueDolphin, you can choose to fill in optional fields voluntarily. If you do this, our processing basis to process the entered personal data is our legitimate interest (in order to be able to improve our services or to personalise your account). We receive the personal data mentioned below from you directly. This concerns the following personal data.

Improving our services, processed up to 2 years after collection:

• Name (via completed questionnaires)
• Function (via completed questionnaires)
• Organization (via completed questionnaires)
• Answers provided (via completed questionnaires)
• Reviews given (processed for up to 13 months after account termination)

Other:

• Profile photo, for personalizing the personal profile, processed up to 13 months after termination of the account

3.2 You are a visitor to our website

A. To ensure that you can use our website, we process the personal data mentioned below during your visit to our website. We receive this personal data directly from you. Our processing basis is our legitimate interest to be able to show you a website that works.

• Language
• User-ID (allowing use of the Intercom chat function and allowing you to review earlier conversations)

This information can be shared with LinkedIn to set the language preference correctly. LinkedIn may process the data in the U.S., but uses standard contractual clauses approved by the European Commission. If you contact us via the Intercom chat function, your data may be stored by our processor Intercom outside the EEA. Intercom guarantees to comply with European privacy legislation.

B. To improve our websites, we process the personal data mentioned below up to 2 years after collecting it. The personal data listed below is generated when you use our website. Our processing basis is our legitimate interest to improve our websites. Your interests are safeguarded because data processing is limited and you can choose not to share the data by unchecking the “analytical cookies” box.

• Browser information
• Location data at country / province level
• Google user ID
• Device information
• The duration of your website visit and how you use our websites
• Demographic data

The above data can be shared with Google Analytics, which can store data outside the EEA but guarantees to continue to comply with European privacy legislation.

C. To secure our website, we process the personal data mentioned below up to 2 years after collecting it. The personal data listed below is generated when you use our website. Our processing basis is our legitimate interest to improve our website.

• IP address
• Browser and device information
• Log details
• Cookie ID
• Network and traffic data

D. We place tracking and advertising cookies if you visit our website and give us permission to do so in the cookie banner. The personal data listed below is generated when you use our website. The cookies process the information mentioned below up to 2 years after the collection of the data.

• IP address
• Device information
• The duration of your website visit and how you use our websites
• Google advertising ID
• Browser ID
• Hubspot user ID
• Demographic data
• Location data
• Cookie preferences
• Cookie ID

The tracking cookies are placed by Hubspot, Meta Platforms, Google and LinkedIn. They can store the data outside the EEA, but guarantee to comply with European privacy legislation.

You can amend your settings via the cookie banner. For further information on the placement of cookies by our website, please refer to our cookie statement: https://www.bluedolphin.io/cookie-policy.

E. If you ask us a question or make a request, we will process the personal data listed below up to 4 years after we last had contact with you. We receive or generate this personal data directly from you, when using our services or by contacting us. We process your data to be able to respond to your question or request and to improve our services. Our processing basis is our legitimate interest to be able to respond to your questions and requests and to improve our services.

• Name
• E-mail address
• Phone number
• Content of any communications you have with us
• User ID
• Organization
• Language
• Conversation assessment (to improve our services)
• Date of registration and first visit (to improve our services)
• Date of last seen and last contact (to improve our services)
• Number of active web sessions (to improve our services)

We store the above personal data at Intercom. This party stores your data outside of the EEA, but they guarantee compliance with European privacy legislation.

F. If you register yourself for a newsletter on our website, we will process the data mentioned below until you unsubscribe from the newsletter. Our processing basis is consent, because you voluntarily sign up for the newsletter.

• Name
• E-mail address

You can unsubscribe from these newsletters by following the unsubscribe instructions included with each newsletter. If you unsubscribe from the newsletter, it will not affect our ability to send you emails about important matters and your account.

3.3 You apply for a job at BlueDolphin

A. If you apply for a job at BlueDolphin, we will process the personal data mentioned below up to 4 weeks after completing the application or up to 1 year if you request it. We receive the personal data mentioned below from you directly (for instance when you provide us with your curriculum vitae and other documents and when we communicate with you). We may also receive your personal data from other sources (such as your LinkedIn profile, your previous employer(s), educational institutions you attended, etc.). Our processing basis is our legitimate interest to process your application.

• Name
• Address
• E-mail address
• Phone number
• Your employer
• Your function
• Curriculum vitae and motivation letter
• Your profile picture
• Information about your availability and employability for work
• Information provided in the appropriate open fields and information you provide to us during an interview
• Information included on your LinkedIn profile
• Information provided to us by referees (such as your previous employer and/or educational institution)

3.4 If you work for a party with whom we intend to enter into a business relationship (prospects)

A. We approach interesting parties, such as potential customers, with the aim of establishing a business relationship with them. If you act as contact person for such a party, we will process the personal data mentioned below up to 4 years after we last had contact with you. We receive or generate this personal data directly from you and/or from the organisation you work for. Our processing basis is our legitimate interest to be able to promote and grow our business by approaching and maintaining contact with prospective customers, suppliers and other business partners, and to manage and document those (potential) business relationships. You can always opt-out or object to such processing by contacting us via support@bluedolphin.io.

• Name
• E-mail address
• Phone number
• Content of communications you have with us
• Function
• Organization
• Language
• Preference with respect to the receiving of marketing materials
• Your personal lead score (see below)

B. We may use certain information about you to determine or generate a “personal lead score”, which helps us assess how interested you (or the organisation you work for) may be in our products and services and how relevant our offerings are to you. We receive or generate this personal data directly from you. Our processing basis is our legitimate interest to optimise and focus our sales and marketing efforts by assessing the likelihood that a contact person (or their organisation) is interested in our products and services, and to prioritise and tailor our follow‑up accordingly. We will process the personal data mentioned below up to 4 years after we last had contact with you.

• Your personal lead score
• IP address
• Browser ID
• Browser information
• Location data at country / province level
• Device information
• The duration of your website visit and how you use our websites
• Demographic data
• Number of actions performed, such as page views, downloads, and completed forms, to determine the lead score

3.5 You follow a course via the BlueDolphin Academy

A. In order to be able to offer you our service ‘BlueDolphin Academy’ and to make the service workable for you, we process personal data mentioned below up to 2 years after your account has been disabled (except for payment and invoice details, which are stored for 7 years). We receive or generate the personal data below from you directly (e.g., when you sign up for a course or make use of our services). You can disable your account via the account settings and your account will be automatically be disabled after 1 year of inactivity. We use the personal data below to create an account for you, to authorize you, to provide you with the learning functionalities of our software and to correspond with you about the service and your questions. Our processing basis is the performance of an agreement. If you refuse to share your personal data with us for these purposes, we cannot provide you with our services.

• Name
• Email address
• Organization
• User ID
• Session Data
• Course activity (e.g., progress, timestamps, completion status, certifications)
• Password (encrypted)
• Language
• Course scores 

We make use of Docebo, a cloudplatform for managing, offering, and tracking training courses and e-learning. The BlueDolphin Docebo platform is hosted in the AWS data center located in the EEA. However, a limited amount of personal data may be accessed outside the EEA by Docebo sub-processors (e.g., in the U.S., Canada, Australia, United Kingdom).

B. If you want to personalize your account, you can voluntarily upload an avatar for your BlueDolphin Academy account. If you upload such avatar in which you can be recognized, we will process your avatar on the basis of our legitimate interest to personalize your account at your request. 

3.6 You attend our webinars

A. When you attend one of our webinars, and in order for us to be able to provide you with this service. Our processing basis is the performance of an agreement. If you refuse to share your personal data with us for these purposes, we cannot provide you with our services. We receive or generate this information directly from you when you sign up for or attend a webinar.

• Name
• Email address
• IP address
• Organization
• Function
• Watch behaviour
• Chat and Q&A messages

3.7 We conduct business with the organization you work for (customers and suppliers)

A. If the organization you work for entered into a contract with us (as customer or supplier), we may process the personal data below (i) for invoicing and payment processing purposes and to (ii) comply with accounting and tax obligations. We receive this personal data directly from you or from the organization you work for. Our processing basis are (i) to perform the agreement we concluded with your organization and (ii) to comply with legal obligations to which BlueDolphin is subject. We keep this personal data for 7 years from the date of payment/invoice date.

• Identification and contact information for the billing contact person
• Invoice and payment details
• Correspondence
• Signature

B. If the organization you work for entered into a contract with us (as customer or supplier), we may process the personal data below for communication purposes, contract management, relationship management, account management and customer relationships purposes (“customer relationship management”). We receive or generate this personal data directly from you in the context of our customer relationship or from the organization you work for, certain data is generated by us. Our processing basis is our legitimate interest to be able to effectively maintain our customer relationships.

• Name
• E-mail address
• Phone number
• Signature
• Content of communications you have with us
• Function
• Organization
• Language
• Preference with respect to the receiving of marketing materials
• Your personal lead score (see below)

C. We may use certain information about you to determine or generate a “personal lead score”, which helps us assess how interested you (or the organisation you work for) may be in our products and services and how relevant our offerings are to you. We receive or generate this personal data directly from you. Our processing basis is our legitimate interest to optimise and focus our sales and marketing efforts by assessing the likelihood that a contact person (or their organisation) is interested in our products and services, and to prioritise and tailor our follow‑up accordingly. We will process the personal data mentioned below up to 4 years after we last had contact with you.

• Your personal lead score
• IP address
• Browser ID
• Browser information
• Location data at country / province level
• Device information
• The duration of your website visit and how you use our websites
• Demographic data
• Number of actions performed, such as page views, downloads, and completed forms, to determine the lead score

3.8 AI Functionality

A. We may process your personal data if our customer, which is in most cases your employer, uses the AI functionality within BlueDolphin. Under our terms and conditions, users of BlueDolphin are not permitted to enter personal data into the AI functionality, but we cannot guarantee that this will never happen. Also, personal data may be contained in the output generated by the AI at the request of the user, for the purpose of providing and operating the AI service. Our processing basis is our legitimate interest to provide AI functionality to our customers.

• Content of prompts submitted to the AI functionality
• Personal data contained in AI-generated output, which will be limited to personal data entered into the BlueDolphin service (e.g. your name and job title when creating a schematic)

3.9 Internal operations

A. We may use your personal data (for instance when it is contained in certain documents) for internal knowledge management and collaboration purposes (for example, for recording and sharing information among BlueDolphin teams), tracking statistics and performance, work and project management, structuring workflows and tasks, and planning and prioritizing product roadmaps. Our processing basis is our legitimate interest in organising and improving our internal operations. These activities help us to operate efficiently, maintain and improve the quality, security and continuity of our services, and develop our products in line with customer needs.

Where we use your personal data for these purposes, we do so only to the extent reasonably necessary and proportionate, and we take steps to minimise the use of directly identifiable information where possible (for example by redacting or aggregating data).

3.10 Legal proceedings

A. We may use and retain your personal data to establish, exercise or defend legal claims in legal proceedings (for example, in the context of a dispute with the organization you work for). All personal data described in this privacy statement may be processed and retained in the case of a claim or legal proceedings. Our processing basis is our legitimate interest to be able to defend BlueDolphin in such case. We may retain your personal data for as long as necessary to establish, exercise or defend actual or potential legal claims. This means that, where relevant, we may keep your personal data until the expiry of the applicable statutory limitation periods for bringing claims; and for the duration of any legal proceedings and until such proceedings are finally concluded.

3.11 Government requests and court orders

A. We may receive requests from government authorities or court orders which oblige us to share certain personal data we process of you with them or a party designated in the order. We will inform you of such orders prior to sharing your personal data, unless the order forbids us from doing so. All personal data described in this privacy statement may be included in the request, but only insofar BlueDolphin is obliged to provide the personal data. Our processing basis is to comply with such legal obligation. We store the personal data until the order has been fulfilled and any terms of appeal or objection have expired.

3.12 Mergers and acquisitions

A. If we process your personal data, we may process your personal data (as included in this privacy statement), if we merge with another company, if we acquire another company or if we are acquired by another company. Your personal data will only be processed if this is strictly required for the transaction or the due diligence investigation. In such cases, we will anonymize and pseudonymize your personal data where possible. Your personal data may be shared with the target company or purchaser, involved lawyers and accountants and other parties involved in the transaction. Due to the confidential nature of the processing activity, you will not be informed separately prior to your personal data being processed for this purpose. Insofar we are allowed to do so, we will inform you afterwards. Our processing basis is our legitimate interests to operate our business, to be able to comply with contractual agreements concluded with other parties, to comply with legislation and to prevent unnecessary risks and damages from occurring to BlueDolphin or other parties. We store the personal data for up to 5 years after the transaction has been completed or for the duration of relevant indemnities and warranties for which your personal data is crucial to be able to invoke or defend against such warranties and indemnities.

3.13 Audits

A. We may be subject to audits for certifications or by our customers or conduct internal audits to verify if we comply with our various requirements. If we process your personal data, this personal data may be processed by the auditor if this is strictly necessary for the audit. We will anonymise or pseudonymize your data as much as possible before sharing it with the auditor. Your personal data may be shared with the auditor. All personal data described in this privacy statement may be included in the audit, but only insofar necessary. Our processing basis is compliance with a legal obligation to conduct audits or our legitimate interest to operate our business, to be able to comply with contractual agreements with customers, to (verify that we) comply with legislation, to gain certifications and to verify that we comply with modern security requirements. We store the personal data for up to 3 years after the expiration date (or another internally established deadline)

3.14 Complying with GDPR requests

A. You may exercise your rights under the GDPR (see Section 6). We must process your personal data, such as your identification details, when complying with your request. We will only process the personal data which is necessary to comply with your request. Our processing basis is to comply with a legal obligation to comply with GDPR-requests. In case your personal data is processed for this purpose, the processed personal data will be stored until 5 years after the request has been handled.

4. Sharing your personal data

4.1 Our data processors

We may ask others to assist us in providing our services and websites. These “processors” can therefore process your personal data on our behalf. We agree with these processors that they may only use your personal data to enable our services.

We may use the following types of processors:

• parties that host our services and websites, store data and manage and maintain our servers and databases;
• developers and suppliers of software and questionnaires;
• research agencies and analytical software suppliers to improve our services;
• ticket managers for user support;
• subscription management and billing tools;
• recruitment and applicant tracking systems;
• marketing agencies, and;
• providers of relationship management software.

4.2 Sharing your personal data with third parties

We only share your personal data with third parties if this:

1. is described in this privacy statement and we have a valid basis for this;
2. is reasonably necessary or appropriate to comply with legal obligations;
3. is necessary to comply with legal requests from authorities;
4. is necessary to respond to any claims;
5. is necessary to protect the rights, property or safety of us, our users, our employees or the public;
6. is necessary to protect ourselves or our users from fraudulent, offensive, inappropriate or unlawful use of our services.

We will notify you immediately if a government agency makes a request relating to your personal data, unless we are not allowed to do so by law.

Our websites may also contain links to websites of others. If you provide your personal data on these third party pages, the privacy policy of this third party applies. We are not responsible for the content of the privacy policy of these parties and the way in which these parties process your personal data. We encourage you to review their privacy policy before providing any personal information to them.

5. International data transfers

Some of the processors (and their sub-processors) and other recipients with whom we share your personal data are established outside the European Economic Area (“EEA”) or otherwise process your personal data outside the EEA. For example, in the context of the services they provide us (such as security, hosting, support, cloud storage, software development, customer relationship management tools and maintenance or other platform services). Where a Processor or other third party offers the option to host or store personal data within the EEA, BlueDolphin will in principle select this option.

In that context, your limited personal data can in principle be transferred worldwide, or more specifically is or may be transferred to the countries outside the EEA as listed below. Please note that most (onward) international data transfers to countries outside the EEA only occur in specific circumstances, for example when a support request or question is submitted to the relevant Processor or third party. The countries to which your personal data is or may be transferred include:

• United Kingdom, United States, Canada, Japan, Switzerland, Australia.

Where your personal data is transferred to a country outside the EEA, we will ensure that appropriate safeguards are in place to protect your personal data in accordance with the GDPR, including via concluded data processing agreements. Such safeguards may include:

• The European Commission has issued an adequacy decision for the country in question;

• • More specifically, this is relevant when your personal data is transferred to Japan, Switzerland, and/or the United Kingdom.
  • With respect to the United States, the European Commission has adopted an adequacy decision for organizations certified under the EU-U.S. Data Privacy Framework (“DPF”).
  • With respect to Canada, the European Commission has adopted an adequacy decision for Canada in respect of commercial organizations subject to the Personal Information Protection and Electronic Documents Act (PIPEDA).

• In the absence of such adequacy decision, we (and, where relevant, our sub-processor) have entered into Standard Contractual Clauses approved by the European Commission with the recipient; or
• another appropriate safeguard as referred to in the GDPR applies.

You may request further information about the specific safeguards applied to international transfers of your personal data by contacting us via support@bluedolphin.io.

6. Protection of your personal data

We have taken appropriate technical and organizational security measures to protect your personal data. We have in any case taken the following measures:

• We have physically and digitally secured our servers so that people cannot view your personal data without our consent.
• We use security to ensure that data is sent encrypted between our services, the websites and our servers.
• We make backups of your personal data.
• Vulnerabilities in the services and on the websites are addressed as quickly as possible.
• We have implemented physical and electronic measures designed to prevent unauthorized access, loss or misuse of personal data as much as possible.
• We store your passwords encrypted.

We would like to point out that the internet is never completely secure. So be careful what you share via the internet. If in doubt, contact us first.

7. Your rights

You have certain rights regarding your personal data. The rights that we describe below are not absolute rights. We will always consider whether we can reasonably meet your request. If this is not possible, or if it would, for example, be at the expense of the privacy of others, we can refuse your request. If we refuse a request, we will let you know with reasons.

Right to access

You have the right to request which personal data we process about you. You can also ask us the following:

• to provide insight into the reasons why we process your personal data;
• what types of personal data we process about you;
• what types of parties we share your personal data with;
• how long we store your personal data;
• where the personal data comes from, and;
• whether we use automated decision-making.

You may also request a copy of your personal data processed by us. Do you want additional copies? Then we can charge a reasonable fee for this.

Right to rectification

If the personal data processed by us is incorrect or incomplete, you can request us to adjust or supplement your personal data. You can also amend certain personal data we hold about you via your account.

If we approve your request, we will, insofar as this is reasonably possible, inform the parties to whom we have provided your personal data.

Right to erasure of data

Do you no longer want us to process certain personal data about you? Then you can request us to delete some or all of your personal data.

If we have accidentally processed data unlawfully or a specific law prescribes that we must delete personal data, we will delete the personal data. If the personal data is necessary for the settlement of a legal procedure or a (legal) dispute, we will only delete the personal data after the procedure or dispute has ended.

If we approve your request, we will, as far as is reasonably possible, inform the parties to whom we have provided your personal data.

Restriction of processing

If you think that we are not processing the correct personal data about you, or if you believe that we are processing your personal data unlawfully or no longer need it, you can request us to restrict the processing of that personal data. For example, during the time that we need to assess your request, or if there is no lawful basis (anymore) but you still have an interest in us not deleting the personal data yet. If we restrict the processing of your personal data at your request, we may still use that personal data for the settlement of legal proceedings or a (legal) dispute.

Right to data portability

You have the right to receive the personal data which you have provided to us, in a structured, commonly used and machine-readable format and have this personal data transmitted to another party (where technically feasible). You only have this right to data portability when the processing is based on your consent or when this is necessary for the performance of an agreement, and the processing is carried out by automated means. We refer to Section 3 of this privacy statement for further information on our processing activities.

Right to object

When the processing of your personal data is based on our ‘legitimate interest’ (see Section 3 of this privacy statement for more information), you have the right to object to such processing on grounds relating to your particular situation. When exercising your right to object, we will review the processing of your personal data. We must stop with the processing of your personal data on this ground, unless we have very good reasons to continue the processing which outweighs your interests, or that relate to a legal claim.

When you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

Automated individual decision-making

We do not make decisions based solely on automated processing.

Withdrawal of consent

You may withdraw your consent at any time by clearing voluntarily completed fields, amending your account settings or by contacting us. Please note that when you withdraw your consent, this does not affect the lawfulness of the processing based on consent before its withdrawal. Our contact details are described below.

Exercising your rights

You can send the above requests to support@bluedolphin.io.

Before we respond to your request, we must first make sure that it is your personal data. We usually do this by having you log in to your BlueDolphin or BlueDolphin Academy account. If you do not have an account or if we cannot confirm your identity in this way, we will try to verify your identity by email or telephone. If that also fails, we can ask for a copy of a valid ID. In that case, do not forget to shield your social security number (BSN), MRZ (Machine Readable Zone) and passport photo. For example, by using the ‘KopieID-app’ of the Dutch Government (https://www.rijksoverheid.nl/onderwerpen/identiteitsfraude/vraag-en-antwoord/veilige-kopie-identiteitsbewijs).

We aim to deal with your request or complaint within one month. If it is not possible to make a decision within one month, we will notify you (within one month) of the reasons for the delay and when the decision is expected to be provided. This can never be longer than 3 months after receipt of the request.

Dutch Data Protection Authority / Autoriteit Persoonsgegevens 

Do you have a complaint about our processing? Then contact us. We would of course be happy to help you. Should we nevertheless not come to an agreement, you also have the right to file a complaint with the privacy supervisor, the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). You can contact the Dutch Data Protection Authority via https://autoriteitpersoonsgegevens.nl/.

8. Contact

If you have any questions, concerns or comments about this privacy statement, please contact us by email at support@bluedolphin.io.

Privacy Statement for BlueDolphin Solutions Inc.

Effective Date: May 2026

To download a pdf of this document, please click here.

This policy (“Privacy Policy”) describes how BlueDolphin Solutions Inc. with an address at 228 East 45^th Street Suite 9E New York, NY 10017-3337 (“BlueDolphin Solutions” or “we”), collects and uses personal information from users across various platforms, including bluedolphin.io, the SaaS solution offered through the BlueDolphin application, other websites, mobile sites, services, applications, and platforms operated by BlueDolphin Solutions where this Privacy Policy is featured or referenced, or where no separate Privacy Policy is provided, as well as from customers who interact with us through other channels (collectively, the “Sites”). The words “user”, “you” and “your” in this Privacy Policy refer to a user of the Sites.

The Sites are operated by BlueDolphin Solutions. The words “user”, “you” and “your” in this Privacy Policy refer to a user of the Sites.

Please read this Privacy Policy carefully, as it applies each time a user accesses the Sites and uses their services.

By using the Sites, you represent that you have read, understood and agree to be bound by this Privacy Policy and our Terms and Conditions (collectively, the “Website Policies”). If you do not agree with the Website Policies, please do not access or use the Sites.

1. Types of Information We Collect from Users and How We Collect it

When you use the Sites, we may collect your personal data (any information relating to an identified or identifiable natural person), and information concerning your use of the Sites and your account activity (e.g., number and times of logins, most frequently visited pages, IP address, etc.). This data may be aggregate, without the possibility of identifying you.

We collect the categories of personal information outlined below from the following sources:

A. Information Provided by You

The categories of personal information we may collect from you include:

• Account Information.We collect personal information that you provide when you register for an account to use our services and purchase our products, which may include your name, email, password, company name and role, account preferences, such as preferred language, and any other information necessary to set up your account;
• Inquiries. We collect personal information that you provide when you contact us and inquire about our services and products, such as your name, email, phone number, dates of contact, and any other information you provide;
• Billing and Relationship Management. If your company entered into a contract with us (as customer or supplier), we may process certain personal information such as your name, email, billing information and any other information you provide (i) for invoicing and payment processing purposes and to (ii) comply with accounting and tax obligations. We may also process we may process personal information, such as your name, email, phone number, company name and role, for communication purposes, contract management, relationship management, account management and customer relationships purposes
• Marketing Communications. If you sign up to receive news or alerts from us, via email, we collect your email, phone number and applicable interests and communication preferences in order to send you regular updates about the products and services we provide. You will not receive marketing communications from us unless you opt-in to receive such communications.
• E-Learning Platforms. If you access and use our service “BlueDolphin Academy” or our webinars, we collect your name, email address, company name, user ID, password, session data, course activity (e.g., progress, timestamps, completion status, certifications), language, course scores, and any other information necessary for you to use the courses, as specified in the relevant sections of the platforms.

Please be aware that if you do not allow us to collect certain personal information from you, we may not be able to deliver certain services to you, and some of our services may not be able to take account of your interests and preferences. If collection of personal information is mandatory, we will make that clear at the point of collection so that you can make an informed decision whether to provide your information.

B. Automatically Collected Information

When you access or use our Sites, some information not associated with specific users, such as device type, location information, IP address, cookie identifiers, webpage traffic, and access time is automatically collected in order to ensure the Sites’ functionality. Once your user profile is created, anytime you log in, we will collect additional information and add it to your user profile, such as the products you have ordered, and any other information that may be available from time to time.

Cookies.  The Sites use cookies. A cookie is a small text file that is stored on a user’s computer for record keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our Site. A persistent cookie remains on your hard drive for an extended period of time.

We use cookies to identify you when you access the Sites, to personalize your experience on the Sites, to provide ads, marketing communications and social media features, to analyze our traffic and customers’ interactions with advertising banners, and to identify repeat visitors for statistical purposes.

When you first visit our Sites, we provide you with a choice to either accept or deny certain cookies. If you choose to decline cookies, please note that some of the features and services of the Sites may not function as well as intended. Even if you choose to accept cookies, you are always free to change your mind and revoke that consent. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. Please note that the Sites use certain cookies that are fundamentally necessary for the Sites to work and allow you to use the functions of our services. Without this type of cookies, you cannot receive the requested services. These cookies enable services that you have specifically requested and allow you to use the Sites’ features (e.g., logging in). We need these cookies to provide you with our services and you cannot deny necessary cookies.

C. Third-Party Sources

Social Media. When accessing the Sites through a third-party social media site and/or application, we may access some of your information from your social media account, such as name, email address, and profile picture. Please note that some aggregate information, that does not personally identify you, such as content viewed on the social media site/application, may also be collected by us if you access the Sites through a third-party social media site. Further, if you have consented on a third-party social media site to sharing your personal information with other third parties, we may collect your personal information that is part of your profile or that you post publicly, such as your basic account information and any other additional information or activities that you permit the third party social network to share with third parties or that you post publicly on a BlueDolphin Solutions social networking page.

Please note that this Privacy Policy does not apply to third-party social media sites, and you should always refer to the privacy policies of the relevant social media sites for information concerning their collection and processing of information.

D. Communications with BlueDolphin Solutions

Customer Service. If you fill out a questionnaire or contact our Customer Service department by phone or by email, we will collect certain personal information from you, such as your name, address, email address and phone number, along with the conversations with our Customer Service department. We may need to use your personal information to further contact you to respond to your inquiry or request.

2. How We Use Your Information

Your information is processed using primarily electronic means and is used, without limitation, for the following purposes:

• Service Offerings. We use information collected to provide our services and to follow up with you about your satisfaction with the same;
• Customization. We may use information collected to monitor and analyze trends, usage, and activities in connection with our products and services in order to manage and optimize your browsing experience. Further, we may use the information collected to provide you with product recommendations, offers, content and rewards that are tailored to your interests and profile, and to target advertisements to you on third-party platforms and websites. We may use also information collected to personalize your experience and save you time when you visit our Sites (e.g., by remembering your login ID and password);
• Marketing. If you have signed up to receive our newsletter, we may use this information to send you marketing communications, such as email communications. These communications may inform you about new products, special discounts and other news and special offers
• Product and Site Development. We may use personal information to create non-identifiable information that we may use, alone or in the aggregate with information obtained from other sources, in order to help us optimally deliver our existing products and services, develop new products and services, or conduct statistical analyses to the functioning of the Site. From time to time, BlueDolphin Solutions may perform research (online and offline) via surveys (directly or through third parties) to help us better serve our customers by learning more about their needs and the quality of the products and services we provide. Anonymized and aggregated information is used for a variety of functions, including the measurement of Sites visitors’ interest in and use of various portions or features of the Site;
• Customer Service. If you have requested further information, contacted customer service or in any other way requested that we contact you, we will use your personal information to respond to such a request. We may also use your information to ensure we are providing the highest level of customer service, and to identify any potential gaps or potential improvements to the same. Further, we may use information collected to send you security alerts, support messages, and other transactional messages;
• E-Learning Services. We may use information collected to grant you access to “BlueDolphin Academy” and our webinars, to perform contractual obligations, to manage the credentials assigned to each user for access and connection to such e-learning platforms, to enable the access and use of the training content, and to carry out all activities related to such services;
• General Business Purposes. We may use information collected for other general business purposes, such as to maintain the day-to-day operation and security of our Site, to protect the integrity of our business, and for analytics, auditing and technical assistance purposes. Further, we might use the information collected to secure online transactions, prevent fraud and payment incidents, and manage debt collection
• Corporate Purposes. We may use information collected to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of BlueDolphin Solutions’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by BlueDolphin Solutions about our Sites users is among the assets transferred; and
• Legal Purposes. We may collect and use personal information to enforce our contracts, including our Website Policies, to resolve disputes, to carry out our obligations and enforce our rights, in connection with audits we may be subject to, and to protect our business interests and the interests and rights of third parties. We also collect information in order to comply with certain legal rules and regulations that we are subject to, and as required by law enforcement and/or regulatory authorities.

3. How We Protect Your Information

Only employees, contractors and agents of the Sites operator may access user information on a need-to-know basis and only for the purposes set forth in this Privacy Policy.

While we make reasonable efforts to ensure your information is processed and stored in a secure manner, we cannot guarantee the security of data transferred over the Internet and you assume the risk of any such transfer.

4. Where We Store Your Information

Your information will be collected and stored in the United States.

5. Sharing Your Information

We will not sell or otherwise disclose your information, except as described in this section and other relevant sections of this Privacy Policy.

Generally, we share your personal information as necessary to provide the services or products you request. We also may share your personal information when required by law, to protect your rights and safety, and with your consent. Specifically, we may share your personal information with third parties, including:

• Authorized Service Providers. We may retain third-party service providers in order to process your data in connection with the services provided on the Sites. These services may include but are not limited to IT support, website hosting, customer service, marketing communications, analytics and logistics. Third parties who perform these operations are only permitted to use the information provided to them to perform their function and for no other purpose;
• Data Aggregators. We may disclose aggregated or de-identified information that cannot reasonably be used to identify you, to data aggregators. We process, maintain, and use this information only in a de-identified fashion and will not attempt to re-identify such information, except as permitted by law;
• Successors in Interest. In the event there is a change in the corporate structure of BlueDolphin Solutions including, without limitation, by merger, consolidation, sale, liquidation, transfer of substantial assets, or in the unlikely event of bankruptcy, we may, in our sole discretion, transfer, sell or assign users’ information collected on and through the Sites to one or more affiliated or unaffiliated third parties or successor in interest;
• Professional Advisors. We may disclose personal information to our legal, financial, insurance and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests; and
• Law Enforcement. We may disclose a user’s information when required to do so to comply with applicable law or legal process or to respond to a request from law enforcement and/or regulatory authorities. We may also provide your information in situations where we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing, to protect and defend the rights, property, or safety of our company, our consumers, our employees, or others, or to enforce our Website Policies or other agreements or policies.

6. How Long We Store Your Personal Information For

BlueDolphin Solutions retains your personal information for as long as necessary to fulfill the purpose(s) for which it was collected, provide our services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. When we are no longer required to retain the personal information as described above, we will destroy, erase, or de-identify it, unless we are legally required to maintain it for longer.

7. Links to Third-Party Sites

The Sites may contain links to third-party websites. We do not operate, control, monitor, endorse or guarantee those third-party websites. This Privacy Policy does not apply to the collection and use of information by such third-party websites. We suggest that you carefully read the privacy policy and other policies of all third-party websites.

We provide hyperlinks to third-party websites only for the convenience of our users and it is not a recommendation that users access such third-party websites. We do not guarantee the services or goods provided and sold by such third-party websites to Internet users. YOU AGREE THAT YOUR USE OF ANY THIRD-PARTY WEBSITE IS AT YOUR SOLE RISK AND WITHOUT WARRANTIES OF ANY KIND BY BLUEDOLPHIN SOLUTIONS, EXPRESS, IMPLIED OR OTHERWISE, INCLUDING, BUT NOT LIMITED TO, WARRANTIES OF TITLE, FITNESS FOR A PARTICULAR PURPOSE, MERCHANTABILITY OR NONINFRINGEMENT. UNDER NO CIRCUMSTANCES SHALL BLUEDOLPHIN SOLUTIONS BE LIABLE FOR DAMAGES ARISING FROM ANY TRANSACTION BETWEEN YOU AND ANY THIRD-PARTY WEBSITE OR FOR ANY INFORMATION APPEARING ON THIRD-PARTY WEBSITES.

8. Changing, Updating, or Removing Your Information

You may update, correct or remove your personal information at any time and free of charge by emailing us at support@bluedolphin.io. We may ask that you identify yourself and the information you wish to access, change or delete for security purposes, and we will comply with your request as soon as reasonably practicable. By removing some of your information, you may not be able to access some of the Sites’ features. We may keep some of your personal information if required by law and/or for recordkeeping purposes.

9. Opting-Out of Our Marketing Communications

Email. You may unsubscribe from any marketing email communications by clicking on the “Unsubscribe” button included in all of our marketing communications or by contacting us at support@bluedolphin.io. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding BlueDolphin Solutions and our services and, to the extent permitted by law, you will not be able to opt out of those communications (e.g., communications regarding updates to our Website Policies).

10. Do Not Track Settings

Our Sites do not recognize Do Not Track signals. Some third parties may collect aggregate information about the users’ online activities over time and across websites when they use the Sites. While this information does not include personally identifiable information, certain processing activities that combine aggregate information with other information in possession of such third parties could result in the identification of users.

11. Rights of California Residents

Pursuant to California Civil Code Sec. 1789.3, California resident users are entitled to know that they may file grievances and complaints with the California Department of Consumer Affairs, 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834; or by telephone at (800) 952-5210; or by email to dca@dca.ca.gov. For more information about protecting your privacy, you may wish to visit: www.ftc.gov.

12. Children’s Rights

We do not sell products for purchase by children. If you are under 18 years old, you may use the Sites only under the supervision of a parent or guardian. In accordance with the Federal Children’s Online Privacy Protection Act of 1998 (COPPA), we do not knowingly collect, solicit or use personal information of children under the age of 13 provided without parental consent. Should we become aware that a user under the age of 13 has registered without verifiable parental consent, any such information will be deleted.

13. Updates to Our Privacy Policy

BlueDolphin Solutions may amend or update all or any portion of this Privacy Policy, at any time, without notice, in its sole discretion. Please access this section regularly to verify if any changes were made to our Privacy Policy and to review the updated Privacy Policy.

14. Contact Information