Cookie Policy

Last updated: March 2026

This cookie policy explains how 7EMPLE ("we", "us", "our") uses cookies and similar tracking technologies on our website at 7emple.nl. This policy is provided in accordance with Article 11.7a of the Dutch Telecommunications Act (Telecommunicatiewet, "Tw"), which implements Article 5(3) of the ePrivacy Directive (2002/58/EC), and the General Data Protection Regulation (EU) 2016/679 ("GDPR") where the processing of personal data is involved.

1. What Are Cookies

Cookies are small text files that are placed on your device (computer, smartphone, or tablet) when you visit a website. Cookies are widely used to make websites function correctly, to improve user experience, and to provide website owners with information about how their site is being used.

Similar technologies such as pixels, local storage, and fingerprinting techniques are covered by the same rules under Article 11.7a Tw. Where this policy refers to "cookies", it includes these similar technologies unless otherwise stated.

2. Legal Framework

Under Article 11.7a of the Dutch Telecommunications Act, storing or reading information on a user's device is only permitted if:

1. The user has been clearly and completely informed about the purposes of the cookie; and

2. The user has given prior consent (as defined in Article 4(11) GDPR: freely given, specific, informed, and unambiguous).

There are two statutory exceptions where consent is not required:

• Technical necessity (Article 11.7a(1)(a) Tw): The cookie is strictly necessary for the transmission of a communication over an electronic communications network.
• User-requested service (Article 11.7a(1)(b) Tw): The cookie is strictly necessary for providing an information society service explicitly requested by the user.

Additionally, the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) has confirmed that analytics cookies with minimal privacy impact may be placed without consent, provided certain conditions are met (see Section 4 below).

3. Categories of Cookies We Use

3.1 Strictly Necessary Cookies

These cookies are essential for the basic functioning of our website. They enable core features such as page navigation and secure access. These cookies do not collect information that identifies you and do not require your consent under Article 11.7a(1)(b) Tw.

3.2 Analytics Cookies

We use PostHog to collect anonymised data about how visitors use our website. This data helps us understand which pages are visited, how long visitors stay, and where improvements can be made.

PostHog configuration and consent exemption:

The Dutch Data Protection Authority allows analytics cookies to be placed without prior consent if the following conditions are met:

1. The data is used only to generate aggregate statistical information about website usage;

2. The data has minimal impact on the privacy of the visitor;

3. IP addresses are anonymised or truncated;

4. Data is not shared with third parties for unrelated purposes;

5. The website provides clear information about the use of these cookies.

PostHog is configured on our website with the following privacy-respecting settings:

• PostHog processes data on servers located within the European Union (EU region: eu.i.posthog.com)
• Person profiles are set to "identified_only", meaning anonymous visitors are not assigned persistent person profiles
• We do not combine analytics data with other personal data sources
• We do not use PostHog for cross-site tracking, remarketing, or advertising purposes

Based on this configuration, we consider our use of PostHog analytics cookies to fall within the exemption for low-impact analytics cookies as described by the Autoriteit Persoonsgegevens. We nonetheless inform you of their use in this policy.

3.3 Cookies We Do Not Use

For transparency, we confirm that we do not use:

• Advertising or remarketing cookies
• Social media tracking cookies (Facebook Pixel, LinkedIn Insight Tag, etc.)
• Third-party cookies for behavioural targeting
• Cross-site tracking cookies

4. Third-Party Services

The only third-party service that places cookies on our website is PostHog, as described in Section 3.2 above. PostHog acts as a data processor on our behalf and is bound by a data processing agreement in accordance with Article 28 of the GDPR.

PostHog's privacy policy is available at: https://posthog.com/privacy

5. Managing and Deleting Cookies

You have the right to accept, refuse, or delete cookies at any time. You can manage your cookie preferences through your browser settings.

Instructions by browser:

• Google Chrome: Settings > Privacy and security > Third-party cookies
• Mozilla Firefox: Settings > Privacy & Security > Cookies and Site Data
• Apple Safari: Preferences > Privacy > Manage Website Data
• Microsoft Edge: Settings > Cookies and site permissions > Manage and delete cookies

Please note that disabling strictly necessary cookies may affect the functionality of the website. Disabling analytics cookies will not affect your ability to use the website.

You can also opt out of PostHog tracking specifically by using a browser extension that blocks JavaScript tracking, or by enabling "Do Not Track" (DNT) in your browser settings if supported by PostHog's configuration.

6. Your Rights

Where cookies involve the processing of personal data, your rights under the GDPR apply. These include the right to access, rectify, erase, restrict processing, data portability, and object. For full details, see our Privacy Statement at 7emple.nl/privacy.

7. Changes to This Cookie Policy

We may update this cookie policy from time to time to reflect changes in the cookies we use, applicable law, or guidance from the Autoriteit Persoonsgegevens. The "Last updated" date at the top of this page reflects the most recent revision.

8. Contact

For any questions about this cookie policy:

7EMPLE

Email: info@7emple.nl

Website: 7emple.nl

If you believe we are not handling cookies in compliance with applicable law, you have the right to lodge a complaint with the Autoriteit Persoonsgegevens at https://www.autoriteitpersoonsgegevens.nl.