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Privacy Policy

Version 1.4 — effective 29 September 2026

Who we are

Migreat! is a product of Promigion B.V. ("Promigion", "we", "us"), Computerweg 22, 3542 DR Utrecht, the Netherlands, registered with the Dutch Chamber of Commerce (KvK) under number 63056607. This privacy policy applies to migreat.nl and to the trial environment you can request through this domain.

Questions about this policy or about your data? Email privacy@promigion.com.

What data we collect

Through a trial account request: your company name, email address, and the subdomain you choose for your trial environment. We never ask for a payment method to start a trial account.

Through a demo appointment: you book it with HubSpot's scheduler (see "Booking a demo through HubSpot" below). There you enter your first name, last name and email address. We use this data to prepare for the conversation and to schedule the appointment.

Through the contact form: your name, your email address, optionally your company name, and the message you write yourself. We use this data solely to answer your question.

migreat.nl has no database of its own. A trial account request or a contact message is forwarded directly, server-side: to the Migreat! application (trial account) or to our email system (contact form). A demo appointment does not pass through migreat.nl: what you enter in the scheduler goes straight to HubSpot.

What happens when you request a trial account

Your request is forwarded automatically to the Migreat! application, which creates your own, isolated environment: a database environment, a subdomain, and a temporary password you can use to log in straight away. That password also arrives by email; the first time you log in, we ask you to set a new one yourself.

From that point on, you fall under the Migreat! application's own regular data processing — see "Roles" below.

Roles: who is responsible for what

For the data you leave with us — with a trial account request, a contact message or a demo appointment booked through HubSpot — Promigion B.V. is the data controller.

Once your organisation has a trial account or subscription and starts recording its own data in Migreat! (projects, ideas, plans, users), your organisation is the data controller for that data, and Promigion B.V. acts as a data processor on your organisation's behalf. For business customers we arrange a data processing agreement for this — contact us at privacy@promigion.com.

Retention

We keep data in a Migreat! environment, including a trial environment, for up to two years after your subscription or trial period ends, unless your organisation asks for earlier deletion. If a trial is not converted into a paid subscription, the environment is deactivated; the underlying data then falls under the same retention period.

A demo appointment, and the details you enter for it in the scheduler, are kept by HubSpot on our behalf for up to two years after our last contact with you; the same period applies to the appointment in our calendar. We do not keep a contact-form message ourselves — it exists only in our email system, where our normal email retention period applies.

Who else can access your data

  • Microsoft Azure (Netherlands/Western Europe) — hosting for migreat.nl and the Migreat! application.
  • Mollie B.V. (Netherlands) — payment processing, only for a paid subscription.
  • Microsoft 365 — sending transactional email (such as your temporary password), handling contact-form messages, and the calendar that a demo appointment you book through HubSpot is added to.
  • Azure OpenAI — for AI functionality within Migreat!.
  • Tavily — for automatically completing organisation details within Migreat!.
  • Cloudflare — bot detection (Turnstile) on the trial and contact forms; processes your IP address and browser data for this.
  • HubSpot (EU data centre in Germany) — the scheduler for demo appointments, only once you load it yourself; processes your IP address, browser data and what you enter in the scheduler. HubSpot is part of the US-based HubSpot, Inc., and some processing may take place in the US. Transfers to the US rely on the EU-US Data Privacy Framework, under which HubSpot is certified, supplemented by the European Commission's Standard Contractual Clauses in HubSpot's data processing agreement.
  • Plausible Analytics (Estonia, processed in Germany) — website statistics; uses your IP address and browser data only briefly to compute a daily-rotating count, and does not store them.

These parties process your data on our instructions. In addition, HubSpot places its own cookies once you load the scheduler — see "Booking a demo through HubSpot" below.

Cookies and similar technologies

migreat.nl uses Plausible Analytics to measure how many people visit the site and which pages they view. Plausible does not place cookies. To count visitors, Plausible uses a key that changes every day, so no persistently recognisable visitor profile is built up and you are not tracked across different websites. Plausible is EU-owned (Estonia); the measurement data is processed in Germany.

For this limited analytical measurement we do not ask for consent, but rely on our legitimate interest (Art. 6(1)(f) GDPR) in knowing whether migreat.nl works well. The Dutch Data Protection Authority (Autoriteit Persoonsgegevens) itself named Plausible, in its April 2025 guidance, as an example of a privacy-friendly alternative to intrusive analytics tools — guidance, not a binding ruling on this specific use. Want to object to this? That is different from withdrawing consent, since none was asked here — email privacy@promigion.com.

If the link that brings you to migreat.nl carries a campaign parameter (a so-called UTM parameter, for example from an advertisement), we pass that parameter on to Plausible when you request a trial account, so we know which channel a request came through. We never store that parameter in a cookie ourselves — it only travels along in the link and in the form you fill in.

Beyond this measurement, migreat.nl does not place cookies and does not use tracking technologies before you have given consent.

Booking a demo through HubSpot

The scheduler on the demo page is provided by HubSpot. It only loads when you click to load it yourself; that click counts as your consent, for that one page visit only — we do not remember your choice. From then on your browser connects to HubSpot, HubSpot receives your IP address and browser data, and HubSpot places and reads cookies, including for analytics. The same happens if you open the scheduler on HubSpot in a new tab.

Rather not have HubSpot's cookies? Then request a demo through the contact form. You can remove cookies HubSpot has already placed in your browser settings. See also HubSpot's cookie policy.

Security

We take appropriate technical and organisational measures to protect your data, including encryption of data in transit and limited, controlled access to our systems.

Your rights

You have the right to access, rectify, erase and restrict your data, the right to object, and the right to data portability. Contact us at privacy@promigion.com to exercise these rights. You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

Changes

We may update this policy. When you request a trial account, we record which version of this policy applied at the time of your request.