Effective date: 27 October 2026
This privacy policy is also available in Dutch. Choose "Nederlands" at the bottom of the page to switch language.
1. Who we are
Lemo-Design (“we”, “us”) provides branding, design, and software services, including a client portal. This privacy policy explains how we process personal data in connection with that work.
Privacy contact: info@lemo-design.com Lemo-Design, Turfmarkt 7, 8911KS Leeuwarden, Friesland, The Netherlands +31 (0)58 266 42 42
Lemo-Design does not appoint a dedicated Data Protection Officer (DPO).
2. Scope
This policy covers personal data we process as Lemo-Design — especially portal customer data managed on our LemoDesign systems. Client end-user data processed only for a client project belongs in that project’s documentation and the client’s own privacy policy, not in this Trust Center.
3. Data we collect
Personal
- First and last name
- Company name
- Company address
- Personal address
- Phone numbers
- Email addresses
- Social media handles and usernames from Facebook, Instagram, Messenger, WhatsApp, LinkedIn and X, when you contact us through those platforms
- Language preference
Business
- Chamber of Commerce (KvK) number
- VAT number, where the customer has one and it is needed for invoicing
Portal and operations
- Product and service documentation and estimates
- Some financial information and account information
- Custom session recording at login (in BacksterOS, stored on the LemoDesign server)
- Portal logs: login times, invoice views, and payment tracking only — no page-view analytics
- IP addresses, recorded in server and portal logs
- Content of email and support messages you send us
Not collected
We do not collect newsletter signups, and we do not use page-view analytics in the portal.
4. Why we process data (legal bases)
- Contract — data needed to deliver our services and run the client portal, including the content of email and support messages about the work
- Legal obligation — financial records such as invoices, payments and the customer details on them, which Dutch tax law requires us to keep for seven years
- Legitimate interest — our own business records, and keeping our systems secure: portal and server logs, IP addresses, and the session recording at login; and improving our AI system: we train on agent logs after scrubbing out client code and all personal data, and keep the remaining non-personal pattern data indefinitely
5. How long we keep data (retention)
- Customer data on the LemoDesign server — kept for the duration of our relationship and deleted five years after the last project, unless the customer asks for earlier deletion
- Financial records (invoices, payments and related customer details) — kept for seven years, as required by Dutch tax law
- Session recordings at login — kept for seven years, unless the user requests earlier deletion
- Email, support and WhatsApp messages — kept for seven years, unless the user requests earlier deletion
- AI agent logs — kept indefinitely after client code and all personal data are scrubbed out, and used to train our AI
- Server logs — rotated automatically with a size limit (about 15 to 35 MB per server), so older entries are overwritten
- Backups — nightly encrypted backups to a private Cloudflare R2 bucket, keeping 14 daily and 8 weekly copies; older copies are removed automatically
- Production (client projects) — follows retention rules agreed with the client at kickoff
6. Deletion
To request deletion, email info@lemo-design.com. We send a hand-assembled, AI-assisted overview of the information we hold; you confirm what to delete. There is no formal automated process.
Deleted data is removed from live systems right away. It is not removed from existing backups immediately, but drops out automatically within about eight weeks as older backup copies expire. Financial records we are legally required to keep (seven years under Dutch tax law) are retained until that period ends.
7. Your rights
In addition to deletion, you may request access, correction, portability, and objection regarding personal data we hold. Contact info@lemo-design.com.
You also have the right to lodge a complaint with the Dutch Data Protection Authority, the Autoriteit Persoonsgegevens.
8. Who we share data with (subprocessors)
We use vendors and subprocessors for hosting, domains, payments, email, storage, and related tooling. Details — including US transfer notes where relevant — are listed on the Subprocessors tab of this Trust Center.
Examples include Hetzner (servers), Cloudflare (domains and R2 object storage), Stripe and Moneybird (payments and finances), AgentMail (email, with its own documented subprocessors), TransIP and Hostnet (Dutch domain registration, and Microsoft Office 365 through Hostnet; no websites are hosted there), DreamHost and GitHub (US services with transfer implications), and BacksterOS (session recording and breach-task workflows on the LemoDesign server). Customers can also contact us through Meta's platforms (Facebook, Instagram, Messenger and WhatsApp), LinkedIn and X. We manage those conversations in BacksterOS, and the platforms process the messages under their own terms, which can include transfers to the United States.
WhatsApp: we use a WhatsApp Business account on our company phone number, only for communication with clients and never for internal team chat. We use it both to answer incoming messages and to send project updates and files. The account is connected to Chatwoot, which is self-hosted on our own server and passes every WhatsApp message into BacksterOS, whether or not it is linked to a known customer. Only Remon de Vries reads these conversations. Our AI agents can also read them and may reply on our behalf. We keep WhatsApp messages for seven years (see Retention under Resources). When we delete a conversation, we can only remove it from our own systems. Meta stores message data under its own terms, and copies may also remain on the phones involved. We clear chat history from the company phone by hand, not on a fixed schedule.
AI: our AI agents run on Cursor (Anysphere, Inc., a SpaceX subsidiary) and use models from OpenAI, Anthropic, Google, SpaceXAI, Meta and other suppliers for development. Grok (SpaceX) handles agent support, email replies, client support and documentation, and is never used for development (see AI governance under Controls).
International transfers: some subprocessors are based in the United States, including AgentMail (San Francisco), Stripe, Cloudflare, and the AI providers Cursor (Anysphere, Inc., a SpaceX subsidiary), OpenAI, Anthropic, Google and SpaceXAI. Where personal data is transferred outside the European Economic Area, we rely on safeguards such as the EU Standard Contractual Clauses or equivalent mechanisms, such as the EU-US Data Privacy Framework.
9. Security
Access to systems is limited to Remon de Vries, using API key authentication with annual key rotation, and two-factor authentication on all key accounts. Our AI agents also have access to these systems on Remon's behalf. They can read data such as support and WhatsApp conversations, and they may reply for us. How we use and oversee AI is explained under AI governance in Controls. Data is encrypted in transit with HTTPS (TLS), and administrative access runs only over Tailscale's encrypted network. Backups are encrypted with GPG before upload and stored in Cloudflare R2, which encrypts all data at rest with AES-256 by default. Our server disks are not encrypted at present; disk encryption is planned. Secrets are stored in 1Password. See Controls. Automated decisions: some decisions, such as replies to your messages and steps in our workflows, are made with the help of AI. Remon de Vries remains responsible for every one of them. If you have a question about a decision or want it reviewed by a person, contact Remon at info@lemo-design.com.
10. Breach and incident response
If a personal data breach occurs, we notify affected customers without undue delay, and at the latest within 48 hours of becoming aware of it. When a breach is a risk to people's rights and freedoms, we also notify the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) within 72 hours of becoming aware, and inform affected individuals directly when the risk is high. Minor incidents below that threshold are recorded in an internal log. See Breach and incident response for the full process.
11. Changes
We may update this policy as our practices change. Material updates will be reflected in this Trust Center, including the Updates tab when used.
12. Contact
Questions about this policy or your personal data: info@lemo-design.com, +31 (0)58 266 42 42, or Lemo-Design, Turfmarkt 7, 8911KS Leeuwarden, Friesland, The Netherlands.
13. Data deletion for Meta apps
If you used one of our apps on Facebook or another Meta platform and want the data we received through it deleted, email info@lemo-design.com with the subject "Meta data deletion request". Mention the app you used and the name or email address on your Meta account, so we can find your data. We confirm the request with you, delete the data, and let you know once it is done, within one month of your request. Data in backups drops out automatically within about eight weeks.