Engramora
Privacy and Cookies
This notice explains how personal data is handled when you visit the Engramora website, apply for testing or send an investor enquiry.
Last updated:
Who is responsible?
Engramora is a project operated by Merdan IT Solutions, a sole proprietorship in the Netherlands. Merdan IT Solutions is responsible for the personal data processed through this website. Privacy questions and requests can be sent to the email address below.
Test applications
When you apply for testing, we collect the information entered in the form: your name, email address, any organisation or agent name provided, and your intended use case. We also record the submission time, selected language and review status. We use this information to assess your application and communicate about possible participation. Submitting an application does not automatically grant access. Please do not include sensitive personal data or information about other people that is unnecessary for your application.
Investor enquiries
When you send an investor enquiry, we collect your name, email address, any organisation provided, your message and any optional indicative investment amount. We also record the submission time, selected language and review status. We use this information to review and respond to your enquiry. An indicative amount is not an investment commitment.
Website and security logs
Website logs may contain your IP address, access time, page path, browser information, referring page without its query string, and approximate country and city derived from your IP address. Firewall logs may also record the request method, matched rule, action and score. We use logs to understand website activity, investigate problems and protect the website against abuse. IP-based location is an estimate, not your precise location. Daily visit totals contain only a date and a page-view count.
Why we process personal data
We rely on legitimate interests to handle enquiries, organise the testing programme, understand website activity and maintain website security, while taking account of your rights and reasonable expectations. Where processing is necessary to take steps towards a contract at your request, that may provide a separate legal basis. Providing required contact information is necessary for us to handle a submitted form. Optional information can be left blank.
Cookies and browser storage
The website uses functional cookies for form security and submission confirmation. The administrator area also uses a login cookie. These cookies support the operation and security of the website. Page-visit logging is performed on the server. The current website does not include advertising cookies or third-party marketing analytics. Blocking functional cookies may prevent forms or administrator sign-in from working correctly. Any future tracking functionality will be assessed separately before it is introduced.
Cloudflare Turnstile
Application and investor forms use Cloudflare Turnstile to help detect automated submissions. When the widget loads, your browser communicates with Cloudflare, which processes technical information such as your IP address and browser signals. Our server sends the verification token and may send your IP address to Cloudflare to validate the submission. Form message content is not included in that verification request. Cloudflare describes its processing in the notice linked below.
Access and service providers
Submitted information is available to the authorised website administrator. Hosting and email providers may process information as needed to provide their services, and Cloudflare processes information for Turnstile verification. Service providers may process data outside the European Economic Area. The applicable providers, processing locations and transfer safeguards will be confirmed before public launch.
Retention periods
The intended policy is to review test applications and investor enquiries after 12 months and delete information that is no longer needed. Necessary information may be retained while testing or substantive discussions continue. For ongoing investor discussions, the intended review period is 12 months after the last substantive contact. The intended retention periods are 90 days for ordinary page-visit details and 180 days for firewall event details. Necessary records relating to an ongoing investigation or legal obligation may be retained longer for that specific purpose. Daily totals without personal identifiers may be retained for historical statistics. Backup expiry arrangements and the operational deletion process will be finalised before launch.
Your privacy rights
Depending on the circumstances, you may request access, correction, deletion or restriction of your personal data, object to processing based on legitimate interests, or request data portability where that right applies. Contact us using the address below. We may ask for information necessary to verify your identity; please do not send an identity document unless specifically requested. Applications and investor enquiries are reviewed by a person.
You may also submit a complaint to the Dutch data protection authority, Autoriteit Persoonsgegevens .
Changes to this notice
We will update this notice when the website or its data-processing arrangements change. The date at the top indicates the latest revision. This notice covers the public website and its forms; any future cloud service will require information about its own data processing.