Effective date: 2 November 2025
1. Who We Are
Xconea is a trading name of BNK Foundation, a non-profit foundation registered in the Netherlands.
For the purposes of applicable data protection laws (including the GDPR), BNK Foundation, operating under the name Xconea, is the data controller responsible for processing your personal data.
Contact
Email: privacy@xconea.com
Location: The Netherlands (EU)
2. Personal Data We Collect
We may collect and process the following personal data:
- Name and contact information (e.g., email address)
- Professional details (e.g., role, organisation, industry — if provided)
- Information submitted through website or research forms
- IP address and device/browser metadata
- Email engagement and interaction metrics (where consented)
- Information you voluntarily provide to us in communication
We do not intentionally collect special category/sensitive personal data.
3. Purpose of Processing
We process personal data for the following purposes:
- Providing access to requested materials (e.g., whitepapers, research content)
- Managing communication and licensing relating to the Colour Experience System (CXP/CES)
- Operating newsletters and professional communications
- Conducting research and maintaining academic/industry networks
- Improving our services and user experience (with consent)
We do not sell personal data.
4. Legal Basis
Processing is based on one or more of the following legal bases:
| Processing Purpose | Legal Basis |
| Providing requested information or resources | Contract / Legitimate Interest |
| Professional and research communication | Legitimate Interest / Consent |
| Newsletter & marketing automation | Consent |
| Analytics & behaviour tracking | Consent |
| Security and compliance | Legal obligation / Legitimate Interest |
You may withdraw consent at any time.
5. Data Sharing
We may share personal data with trusted service providers where necessary to operate our services (e.g., hosting providers, IT tools, and email/automation systems such as ActiveCampaign).
We may also share personal data with related organisations, research partners, or program delivery entities.
Xconea is a trading name of BNK Foundation. We may share personal data with related organisations and foundations that operate under or in partnership with BNK Foundation, where necessary to manage licensing, educational programs, or communication relating to the Colour Experience System.
Such sharing only takes place where permitted by law, either on the basis of consent or our legitimate interest in ensuring consistent communication and service delivery within the Colour Experience ecosystem.
We do not sell personal data and do not share data with unrelated third parties for commercial marketing.
All partners and service providers operate under data-processing or data-sharing agreements and only process data in accordance with our instructions.
6. International Data Transfers
Where data is transferred outside the EU/EEA (for example, through service providers such as ActiveCampaign), we ensure appropriate safeguards, including:
- EU-US Data Privacy Framework participation, or
- Standard Contractual Clauses (SCCs)
7. Data Retention
We retain personal data only as long as necessary for:
- The purposes for which it was collected
- Compliance with legal requirements
- Maintaining essential business and research records
You may request deletion at any time (see "Your Rights").
8. Your Rights
Under GDPR, you have the right to:
- Access your data
- Correct inaccurate information
- Request deletion ("right to be forgotten")
- Restrict or object to processing
- Withdraw consent at any time
- Request data portability (where applicable)
Requests may be made via privacy@xconea.com.
9. Security
We implement suitable technical and organisational measures to safeguard personal data from loss, misuse, and unauthorised access.
10. Automated Decision-Making
We do not use automated decision-making that produces legal or similarly significant effects on individuals.
Email engagement analysis may be used to tailor communication, only where consent is given.
11. Cookies
If cookies or tracking technologies are used, a cookie notice and consent mechanism will be provided.
A separate cookie notice may apply.
12. Updates to This Policy
We may update this Privacy Policy as necessary. The most current version will always be available at xconea.com.
Contact
For privacy enquiries or to exercise your rights:
📧 privacy@xconea.com
📍 The Netherlands