Privacy Policy

Last updated: February 17, 2026

1. Introduction
Mulder Strategies operates the website mulderstrategies.com and the associated newsletter (“Mulder Strategies Newsletter”).
I am committed to protecting your privacy and handling your personal data in a transparent and secure way in accordance with the General Data Protection Regulation (GDPR) (EU) 2016/679 and other applicable data protection laws.This Privacy Policy explains what personal data I collect, how I use it, on what legal basis, with whom I share it, how long I keep it, and what rights you have.


2. Who is the Data Controller?
The data controller is:
Sonny Mulder
Email: MulderStrategies@gmail.com

I collect only the minimum necessary data:

  • Email address — when you subscribe to the newsletter via the form on mulderstrategies.com.

  • Name (optional) — if you choose to provide it in the subscribe form.

  • Technical data — such as IP address, browser type, device information, and approximate location (collected automatically by Beehiiv when you interact with the form or emails).

  • Engagement data — opens, clicks, and unsubscribes from newsletter emails (via Beehiiv analytics).

I do not collect sensitive personal data (special categories under GDPR).


3. How Do I Collect Your Data?

  • Directly from you when you fill out the subscribe form on mulderstrategies.com.

  • Automatically through Beehiiv when you open emails or interact with links.


4. Why Do I Process Your Data?
I only process the personal data that is strictly necessary to provide the Mulder Strategies newsletter and related communications. This includes the following:

  • Your name (which is optional) and email address: I collect these when you subscribe via the form on mulderstrategies.com. I use them to send you the newsletter, manage your subscription, and respond to any inquiries you may have. The legal basis for this processing is your consent (Article 6(1)(a) GDPR) for sending marketing/newsletter content, and the performance of a contract (your subscription) for managing your account. I keep this data until you unsubscribe, plus up to 6 months afterward to prevent accidental re-addition to the list.

  • IP address, device and browser information, and engagement data (such as whether you open emails or click links): These are collected automatically by Beehiiv when you interact with the subscription form or the newsletter emails. I use this data to analyse how the newsletter performs and to improve its content and delivery. The legal basis for this is my legitimate interests (Article 6(1)(f) GDPR), which are balanced against your rights and freedoms. These data are retained according to Beehiiv’s standard retention periods, typically aggregated statistics for 2–5 years.

  • Communication data (for example, the content of emails you send to me or replies to newsletter-related messages): I process this to answer your questions, handle complaints, or provide feedback. The legal basis is either legitimate interests or the performance of our subscription-related agreement. I keep these data for 2 years after the matter is resolved.

You can withdraw consent at any time (e.g., by unsubscribing) without affecting the lawfulness of processing before withdrawal.6. Who Do I Share Your Data With?

  • Beehiiv (beehiiv.com) — my email service provider and data processor. They host the subscriber list, send emails, and provide analytics. Beehiiv is based in the US but uses Standard Contractual Clauses (SCCs) or EU adequacy mechanisms for data transfers. See Beehiiv’s privacy policy: https://www.beehiiv.com/privacy

  • No other third parties, unless required by law (e.g., court order) or if you explicitly request sharing.



5. International Data Transfers
Data may be transferred to the United States (Beehiiv servers). These transfers are protected by appropriate safeguards, such as EU Standard Contractual Clauses.8.

How Long Do I Keep Your Data?

  • Subscriber data: Until you unsubscribe or withdraw consent.

  • After unsubscribe: I keep minimal data (email + unsubscribe record) for up to 6 months to prevent accidental re-subscription and for legal defense.

  • Analytics data: Retained per Beehiiv’s retention policy (typically 2–5 years for aggregated stats).


6. Your GDPR Rights
Under GDPR you have the right to:

  • Access your data

  • Rectify inaccurate data

  • Erase your data (“right to be forgotten”)

  • Restrict processing

  • Object to processing (especially legitimate interests)

  • Data portability

  • Withdraw consent

  • Lodge a complaint with your supervisory authority (e.g., Dutch DPA – Autoriteit Persoonsgegevens if in NL, or your national authority).

    To exercise any right, email me at MulderStrategies@gmail.com. I will respond within one month (free of charge in most cases).


7. Security

I take reasonable technical and organizational measures to protect your data (e.g., Beehiiv uses encryption, secure servers). However, no transmission over the internet is 100% secure.11. Changes to This Policy
I may update this policy. Changes will be posted here with an updated “Last updated” date. Significant changes will be notified via email if you are a subscriber.


8. Contact
For questions: MulderStrategies@gmail.com