Cookies and similar technologies

Last updated: 7 October 2026

Briefly: peakpromotion.nl itself does not set cookies. I do not use tracking or advertising cookies. The technologies the site does use are needed to operate and protect it, remember a choice you make yourself, or count visits without tracking you. That is why I do not ask for consent and you see no cookie banner.

This text applies to peakpromotion.nl and my CV and portfolio at joppealtingsiberg.peakpromotion.nl.

This text accompanies my privacy notice. That also explains which personal data I process, why, and what rights you have.

What does this cover?

The cookie rule (Article 11.7a of the Dutch Telecommunications Act) covers more than cookies. It applies to anything a website stores on or reads from your device. Examples include browser local storage (localStorage), temporary storage in memory, and scripts that read and send browser information. It does not matter whether it involves personal data.

That is why the list below also includes technologies that are not cookies.

Overview

What I do not use

• No cookies on peakpromotion.nl itself.
• No tracking, advertising or social media cookies, and no pixels.
• No Google Analytics.
• No YouTube or other external video platform. Videos come from my own domain.
• No fonts from Google or another external company. I host them myself.
• No sessionStorage and no IndexedDB.
• The chat session code is never stored in a cookie or in local storage.

Why no cookie banner?

A website does not need to ask for consent for two types of technologies (Article 11.7a(3)(b) of the Dutch Telecommunications Act):

1. Technologies that are strictly necessary for a service you request. I use Turnstile to protect the form, check and chat when you choose to use them. The session code is needed for the chat to work. A separate random security code helps protect the chat against repeated, paid AI requests. I only read it when you send a message, not on an ordinary visit. The theme preference is needed to remember that you chose light or dark mode.
2. Technologies to measure how the site works, with no or little impact on your privacy. I use Cloudflare Web Analytics for this.

That is why I do not ask for consent and you see no cookie banner. I do have to tell you what the site does. This page does that.

More about each technology

Turnstile (Cloudflare)

Turnstile checks whether a person or a bot is using the form, AI check or chat. It only loads when you start using one of these three features, not on every page.

• Turnstile reads browser characteristics, such as your IP address, secure connection (TLS) and browser type (User-Agent).
• Cloudflare may use cookies or local storage inside the Turnstile frame. These belong to challenges.cloudflare.com.
• Legal basis: strictly necessary (Article 11.7a(3), Dutch Telecommunications Act). For your IP address: my legitimate interest in preventing misuse (Article 6(1)(f) GDPR).
• Cloudflare processes this data for me as a processor. Cloudflare also uses the signals itself to improve its bot detection, for which it is responsible. Because Turnstile only loads when you use the form, check or chat, Cloudflare does not receive these signals on an ordinary visit. Read more in my privacy notice (part 2) and the Turnstile privacy policy.

Cloudflare Web Analytics

Web Analytics counts visits to the site and measures how quickly pages load.

• It sets no cookies and uses no local storage. It does not build a profile of you or recognise you on a later visit.
• The script reads loading times and basic visit information (page, referring site, browser type) and sends it to Cloudflare without cookies or local storage.
• I only use aggregated figures. I do not link them to other data.
• Legal basis: measurement with no or little impact on your privacy (Article 11.7a(3), Dutch Telecommunications Act). For your IP address, which technically passes through Cloudflare: my legitimate interest (Article 6(1)(f) GDPR).
• Cloudflare acts as my processor here.

My own daily totals

My website code also counts which fixed pages and buttons are used, for example the customer portal button. I only keep a date (UTC), a fixed event name and the total for that day. No IP addresses, browser information, full web addresses, referring sites, form contents, session codes or data per visitor. The totals remain for 31 days and are only available to me. This counts events, not unique visitors. The counter uses no cookies or local storage and respects Do Not Track and Global Privacy Control. I do not link these figures to customer data. I review and approve any improvements based on these figures myself.

Chat session code

When you use the chat, your browser receives a temporary code. This lets the server recognise messages from the same conversation and helps me prevent misuse.

• The code is only in your browser's memory. Not in a cookie or local storage.
• The code expires after 30 minutes. Reloading or closing the page removes it immediately.
• Legal basis: strictly necessary for the chat you open yourself (Article 11.7a(3), Dutch Telecommunications Act).

Chat security code

When you send a chat message, your browser generates a random 128-bit code or uses the existing valid code. It is stored under peakpromotion.chat.device.v1 in local storage and is valid for 30 days. An expired code is replaced on the next chat use; you can clear the storage earlier yourself. I do not use browser characteristics to create a fingerprint. This is a limit per browser, not guaranteed recognition of a physical device.

The server only keeps an HMAC of that code with a daily counter. It is deleted within three days at the latest. The code is not used for advertising, visit statistics or customer profiles and is not sent to the AI model. The necessity of this protection for the requested chat feature is part of the pre-publication check; the legal basis for the server data is my legitimate interest in preventing misuse.

Theme preference

At the bottom of each page, and in the mobile menu, you can choose Light, Dark or System. By default, the site follows your phone or computer (System).

• When you choose Light or Dark, your browser only stores that word (light or dark) in local storage under peak-thema. Nothing is sent to me or another company.
• On each page, the site checks for this preference so it immediately displays the right colours.
• Choosing System removes the preference again. You can also clear it yourself in your browser.
• My portfolio at joppealtingsiberg.peakpromotion.nl has the same preference, with the same name.
• Legal basis: necessary to remember a choice you request (Article 11.7a(3), Dutch Telecommunications Act).

Portfolio administration

Only I log in to manage my portfolio. My browser then stores a login code for 7 days or until I log out, and draft designs. Visitors never access that page and the site does not read this storage for them.

Cloudflare and the US

Cloudflare is a US company. Data may therefore be transferred to the US. Cloudflare is certified under the EU–US Data Privacy Framework (DPF). If that ceases to apply, the standard contractual clauses (SCCs) in my data processing agreement with Cloudflare apply. Read more in my privacy notice.

Managing it yourself

You can always delete or block cookies and local storage in your browser settings.

If you block Turnstile or Cloudflare scripts, the contact form, AI check and chat may not work. You can always reach me at info@peakpromotion.nl or through WhatsApp.

Changes

After each change to the site, I check what it stores on your device. If this list is no longer accurate, I update it and add a new date at the top.

If I ever add something that does require consent, I will ask first. Refusing will be as easy as agreeing. The site will also work if you refuse.

Questions or complaints

Have a question about this page? Contact me:

Peak Promotion (Joppe Alting Siberg) Address: Generaal Kraijenhoffstraat 36, 1411 BE Naarden info@peakpromotion.nl

If you are unhappy with how I handle your data, you can complain to the Dutch Data Protection Authority.