Privacy statement

Last updated 6 September 2026

Data controller

Celso de Graaf, trading as CDG China Advisory

Hilversum, Netherlands

Chamber of Commerce (KvK) 42106674

VAT NL005498367B96

celso@cdgchina.nl

What data is processed

This is a static website. It carries no contact form, sets no cookies, and uses no analytics or tracking software. There is no cookie banner because there is nothing to consent to.

Two kinds of data are processed:

• Technical error logs. This website keeps no visitor statistics and does not record browsing traffic. The server writes technical error messages only, which may incidentally contain an IP address. An IP address counts as personal data under the GDPR, even when no name is attached to it.
• Email correspondence. If you write to me, your email address, your name and the contents of your message are processed, along with anything else you choose to include.

Purpose and legal basis

Error logs are used to diagnose faults and secure the server. The legal basis is legitimate interest (Article 6(1)(f) GDPR): a server that records no technical errors cannot be maintained or defended against abuse.

Email is used to answer your enquiry and, if it leads to an engagement, to carry that work out. The basis is performance of a contract or steps taken prior to entering one (Article 6(1)(b) GDPR), or legitimate interest in ordinary business correspondence.

Your data is not used for profiling, automated decision-making, advertising, or model training.

Retention

The server's system logs are capped in size and are overwritten automatically once that limit is reached. In practice this amounts to about a week.

Business correspondence is kept for as long as the relationship or engagement requires. Records with fiscal significance, such as invoices, are subject to the Dutch statutory retention period of seven years.

Recipients

The website runs on a server in Germany, within the European Economic Area, and is served directly from it without a CDN or advertising network in between. Email to celso@cdgchina.nl is handled by Zoho Mail, which hosts that mailbox on servers in the European Union (zoho.eu). No data is sold, and none is shared with third parties for commercial purposes.

Advisory work for clients may involve contact with parties in China. That happens within the scope of an engagement and on terms agreed with the client, not on the basis of this website.

External links

This site links to LinkedIn. Once you follow that link you leave cdgchina.nl, and LinkedIn's own terms and privacy policy apply. CDG China Advisory has no control over them.

Your rights

You have the right to access your data, and to its rectification, erasure, restriction of processing, objection to processing, and portability. Requests can be sent to celso@cdgchina.nl and will be answered within one month. If a request is complex, that period may be extended by a further two months, and you will be told within the first month if that happens.

If you are unhappy with how a request is handled, you may lodge a complaint with the Dutch data protection authority, the Autoriteit Persoonsgegevens, at autoriteitpersoonsgegevens.nl.

Changes

If the way this website works changes, this statement will be updated. The date at the top shows when that last happened.