Privacy Policy

We are From the Well. We respect your privacy, but we sometimes need your personal data. By Personal Data, we mean information by which you can be identified, directly or indirectly, as a person. This definition is in accordance with the General Data Protection Regulation (the GDPR).

In this statement you can read which Personal Data we use and why (the Privacy Policy). You can also read how we process, store and protect this Personal Data. Finally, we set out which rights you have when we process your Personal Data.

This Privacy Policy applies to our website www.fromthewell.io (the Website), our online application (the App) and the services or products we offer (the Services). We treat your Personal Data in accordance with the GDPR and other relevant laws and regulations on the protection of Personal Data, such as the Telecommunications Act for the use of cookies (the Relevant Legislation).

Under 16 years of age

If you are under 16 years of age, you need the consent of your parents or legal guardian to use our Website, App and Services.

Processing of Personal Data

In order to offer you our Website, App and Services, we process your Personal Data.

How do we obtain Personal Data?

Personal Data received directly from you:

We receive Personal Data directly from you when you create an account and enter your details there.

Who is responsible for the processing of your Personal Data?

We are the controller for the processing of your Personal Data within the meaning of the Relevant Legislation. You can find our contact details at the bottom of this Privacy Policy.

Which Personal Data do we process, for which purpose(s), and on which legal basis?

When you use our Website, Apps and Services, we may need your Personal Data for this.

We are permitted to process your Personal Data because we comply with the Relevant Legislation. We do this by, among other things:

• Having legal grounds to process your Personal Data;
• Informing you about the processing; and
• Only processing data for specific purposes, and no more than is necessary for that.

The bullet points below set out which Personal Data, for which purposes, and on which legal bases we process.

We will only use your Personal Data for the purposes set out below or for a purpose closely related to these. This means your Personal Data is never used by us in an unexpected way.

• Contact details: We collect contact details consisting of company name, first and last name, e-mail address, address, telephone number, Chamber of Commerce (KvK) number and VAT number. We use this data to contact you, to correspond with you and to be able to perform or provide our Services. We process this data on the basis of performance of the contract and consent.
• Payment details: We also collect payment details consisting of invoices and an overview of purchases of the Services. We use this data to send invoices and to maintain our financial administration. We process this data on the basis of performance of the contract and consent.
• Data for marketing and promotional purposes: For marketing and promotional purposes we collect data consisting of first and last name and e-mail address. We use this data for marketing and promotional purposes and to send you our newsletter/updates. You can unsubscribe from the newsletter/updates at any time. We process this data on the basis of performance of the contract and consent.
• Website usage data: If you allow analytical cookies, we measure which pages you visit, which buttons you click, via which source you arrived at the Website, and the type of device and browser you use to access the Website. Using a random identification code, we can link your visit to fromthewell.io to your subsequent visit to create.fromthewell.io. If you create an account or log in there, your earlier visit may as a result be linked to that account. We use this data to understand which information leads to a trial account and to improve the Website. We ask for your consent for this. We do not use this data for advertising purposes and we do not sell it.
• App usage data: If you allow analytical cookies, we measure which pages and features you visit in the App and in what order. We link this to your account and your organisation to see where users get stuck and to improve the App. The same choice applies to the Website and the App. You can change your choice at any time via Cookie settings. This has no consequences for your account or the use of our Services.
• Data from linked social media accounts: If you choose to link a social media account to the App (for example a LinkedIn, Facebook or Instagram account), we process the data from that account that is necessary to give you insight into your own content. This concerns the posts you have published and the associated text, media and publication dates, the statistics of those posts (such as views, reach, comments and reposts/shares), and the name and account identification of the linked account. We use this data solely to show you how your own content is performing and to give you advice about it. We process this data on the basis of your consent.

Analytical cookies on the Website and the App

We use PostHog to analyse the Website and the App. For as long as you have not given consent, we do not store analytical cookies and PostHog does not send any usage events or session recordings. After your consent, the analytical cookie applies to fromthewell.io and its subdomains. The cookie expires after six months at the latest. We will also ask you to make a new choice again after six months at the latest. Session recordings in PostHog are switched off on both the Website and in the App.

You can change your choice at any time via Cookie settings. You can also change this choice within the App. Withdrawing consent has no consequences for the use of the Website or the App.

Linked social media accounts

Linking a social media account is always voluntary. The App also works without it. Because we want to handle data originating from a personal account with care, the following arrangements apply:

• We only retrieve data from accounts that you have linked yourself and for which you have given consent on the relevant platform yourself. We do not collect data about people who have not given consent for this, and we do not collect data by scraping websites or profiles.
• We do not use this data for advertising, sales or recruitment purposes. We therefore do not use it to find sales opportunities or candidates, not for lead generation, not to supplement customer data in a CRM, not to build audience lists and not to target advertisements.
• We do not sell this data and do not pass it on to third parties for their own purposes. We do engage processors, such as providers of AI models, who process this data solely on our instructions (see ‘With whom do we share your Personal Data?’ below). It is not used to train general-purpose AI models.
• The data is intended for you. Within the App, the owner of the linked account determines who may view the data from a personal account.
• You can undo the link at any time within the App, and you can also withdraw your consent with the platform itself. From that moment on, we no longer process any new data from that account and we delete the data we have retrieved from it.

Are you obliged to share your Personal Data with us?

In some cases, the processing of your Personal Data is necessary. For example, when we offer our Services to you or need to perform a contract with you. Without your Personal Data we cannot provide our Services to you.

How do we secure your Personal Data?

We do everything we can to protect your Personal Data against loss, destruction, use, alteration or disclosure by unauthorised persons. We ensure that those who have no business with your Personal Data cannot access it. We do this by means of the following measures:

• Access to the Personal Data is restricted to those persons who need the Personal Data

We continuously monitor our security measures for effectiveness and adjust our process where necessary. In this way your Personal Data is always protected and accessible in the event of any (technical or physical) disruption.

How long do we retain your Personal Data?

We will not retain your Personal Data for longer than we need it for the purposes described above. We delete the Personal Data as soon as it is no longer needed for the purposes for which we process it. Below is a list of the categories of Personal Data and the (functionally described) retention periods:

• Contact details: We retain your contact details for as long as necessary to provide our Services.
• Payment details: We retain your payment details for as long as necessary to meet our financial and tax-related requirements and obligations.
• Data for marketing and promotional purposes: We retain data for marketing and promotional purposes for as long as you wish to make use of these Services.
• Website usage data: The analytical cookie and your consent expire after six months at most. We retain the associated website events for as long as necessary to compare Website usage over time. We assess annually whether older data is still needed.
• Data from linked social media accounts: We retain this data for as long as the link exists and your consent remains valid. If you remove the link or withdraw your consent, we delete the data we retrieved from that account. We ask for your consent again at least annually.

With whom do we share your Personal Data?

We engage a limited number of service providers who process your Personal Data solely on our instructions and under a data processing agreement (processors). They may not use the data for their own purposes. These are:

• Hosting and storage: Supabase, for our database, file storage and application logic (processed and stored in Frankfurt, Germany).
• AI models: Anthropic and Google (United States) and Mistral AI (France, via OpenRouter in the United States), for the analysis of your own content and statistics and the advice the App provides about them.
• Monitoring and quality assurance: Sentry, for error tracking, and Langfuse, for monitoring the quality of our AI features (both within the EEA).
• Usage statistics: PostHog, for measuring the use of the Website and the App after your consent. PostHog does not use session recordings (processed and stored within the EEA).
• CRM and e-mail: Pipedrive, for the data you share with us via the contact form or newsletter sign-up.

We will send you an up-to-date overview of our processors on request.

In addition, we will share your Personal Data if we have a legal obligation to do so. This is the case, for example, if the police ask us for your Personal Data.

Other provisions

• Transfer: We store your Personal Data within the European Economic Area (EEA). For the AI analysis of your content, we use providers in the United States (Anthropic, Google and OpenRouter); Pipedrive may also process data outside the EEA. This transfer takes place on the basis of the EU-US Data Privacy Framework, insofar as the provider is certified for it, and otherwise on the basis of the standard contractual clauses approved by the European Commission. We are working on the possibility, at an organisation's request, of having the AI processing of its data within the App take place solely within the EEA; please contact us about this. Outside the cases mentioned above, we do not transfer your Personal Data to other countries or parties.
• Third-party websites: Our Website and App may contain links to other websites. This Privacy Policy does not apply to those websites. We are not responsible for the privacy protection of these websites. We therefore advise you to read the privacy policy of the relevant website before using it.

Your rights

You have the following rights:

• Right of access: You may ask us for access to your Personal Data;
• Right to rectification: You may ask us to correct, restrict or erase your Personal Data. In the case of fraud, non-payment or other unlawful acts, we may retain relevant Personal Data about you in a register or on a blacklist;
• Right to data portability: You may ask us for a copy of your Personal Data. At your request, we can also pass this copy on to other parties, so that you no longer have to do this yourself;
• Right to object: You may object to the processing of your Personal Data;
• Right to complain: You may lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) if you believe that we are processing your Personal Data unlawfully;
• Right to withdraw consent: You may withdraw your consent to the processing of your Personal Data at any time. From the moment you withdraw consent, we may no longer process any Personal Data about you.

Changes to the Privacy Policy

We may amend the Privacy Policy. If we make significant changes to the Privacy Policy, we will post a notification on our Website and in our App together with the new Privacy Policy. We will notify users who are registered with us using their e-mail address of any changes. If you are not registered as a user, we advise you to check the Website and the Privacy Policy regularly.

Contact

If you have questions or comments about the Privacy Policy, you can contact us using the details below.