Privacy Policy
Termijn B.V.
1. Who we are and what this policy covers
Termijn B.V. (“Termijn”, “we”, “us”) runs a pay-later platform for B2B checkouts and lends to the business buyers it approves. Through an API and a checkout widget built into a B2B marketplace’s or software vendor’s checkout, its decision engine decides within seconds whether a business buyer registered in Sweden, Denmark, Finland, Germany, the Netherlands or France can pay for an order in thirty, sixty or ninety days. We pay the seller the invoice amount the next working day and collect from the buyer on the due date. The decision engine reads the buyer’s record in its national company register and its filed accounts, takes the partner’s own order history with that buyer and sets a limit with a model, and we carry the credit risk ourselves. We are not a bank, we hold no deposits or client money, and we are not a payment institution. The lending is funded by committed facilities from institutional lenders, and every buyer contract is under Dutch law.
Registered at Keizersgracht 268, 1016 EV Amsterdam, Netherlands.
We handle personal data in two different situations, and different rules apply to each:
| Whose data | Our role | What applies | |
|---|---|---|---|
| Part A | People who visit this website, ask about the service or write to us | Controller: we decide why and how the data is used | This policy |
| Part B | The partner: legal name, registration number, registered address, the identity and ownership documents required from its signatories, the account its share is paid to, and its named contacts. The buyer: the country and registration number the partner sends, the register record and filed accounts we look up, the limit and terms we set, every financing with its amount, currency, seller, dates and status, the direct-debit mandate or account it pays from, and the names and contact details of the people who accept the terms and get the reminders. The seller: legal name, registration number and the account we pay. The partner’s order and payment history with each buyer, as sent in the check. And the decisions: every automatic limit, every underwriter decision with its reason, every field a person corrected, and every repayment outcome. Together these form the record we train on. | Set out in B.1, because it depends on the data | This policy and the data processing agreement we sign with each customer |
If the data processing agreement (“DPA”) and this policy ever disagree about Part B, the DPA wins.
2. Part A: this website and our contact with you
This part covers the personal data we collect for our own purposes: running this website, answering requests, and staying in touch with people who are or might become customers.
A.1 What we collect
What you give us. When you send the form on this site, we collect what you type into it, such as your name, email address, phone number or company, and the fact that you agreed to be contacted. If you email or talk to us, we keep that correspondence and any contact details in it.
What is collected automatically. Our web server records the IP address a request came from, the browser used, the pages requested, the page you came from and the time. These logs exist to keep the site running and secure.
We don’t ask for sensitive data (the “special categories” in Article 9 GDPR) through this website, so please don’t send any through the form.
A.2 Why we use it, and what allows us to
| Why | What | Legal basis (GDPR Art. 6) |
|---|---|---|
| Answering your request and working out whether the service fits | What you sent in the form, our correspondence | Art. 6(1)(b): steps you asked for before a contract |
| Looking after customers, billing and support | Contact details, correspondence | Art. 6(1)(b): carrying out a contract |
| Keeping the site running, secure and free of abuse | Server logs | Art. 6(1)(f): our legitimate interest in running a secure service |
| Contacting you about the service | Email address, company | Art. 6(1)(f): our legitimate interest in business-to-business marketing. You can object at any time |
| Meeting tax, accounting and legal duties | Billing and contract records | Art. 6(1)(c): a legal obligation |
Where we rely on legitimate interest, we have weighed that interest against your rights, and you can ask to see the assessment.
A.3 How long we keep it
- Requests from people who don’t become customers: 12 months from our last contact, then deleted.
- Customer contact and contract records: for the length of the agreement plus 6 years, to cover legal claims and accounting rules.
- Server logs: 30 days.
- A record that you objected or opted out: kept indefinitely, so we can keep respecting it.
A.4 Your rights
If you are in the EEA or the UK, you can ask to see your data, correct it, have it deleted, limit or object to how we use it, get a copy you can take elsewhere, and withdraw consent where we rely on it. Write to [email protected] and we will answer within one month.
You can also complain to a data protection authority. If you are in the EEA, that can be the authority where you live or work.
3. Part B: data inside the service
Three parties appear in our data. The partner is our customer: it builds our API into its checkout, sends the buyer check and receives its share. The buyer is our borrower: a business we lend to and, where it is a sole trader, a person whose data we hold as the lender. The seller is who we pay. This part covers all three, in that order. Where a person appears, as a sole trader, a signatory or a named contact, that person’s rights are described at the end.
B.1 What we handle, and in what role
For the credit decision, the financing and its collection we are the controller. The decision is ours, the loan is ours, and no partner instructs it. For the partner’s order history sent in the buyer check we are also the controller, because we use it for our own decision. The partner agreement records that purpose and its legal basis. The partner remains the controller of its own checkout and buyer accounts, and what it shows the buyer there is its responsibility. Register records and filed accounts come from public sources, and we are the controller of the copies we hold. For the training records, stripped as described below, we are the controller.
- The register record. The buyer’s legal name, legal form, registration date, status, insolvency flags and registered address. The decision engine looks them up live in Bolagsverket, CVR, YTJ, the Handelsregister, KvK or Sirene when the check arrives, keeps them for twenty-four hours, and refreshes them on the next call after that. Rules read the record to answer three questions: does the buyer exist, is it active, and is it old enough to borrow.
- Filed accounts. The latest annual accounts the register holds come with the record. Where they are structured, from CVR or Bolagsverket, rules read the figures. Where they are a scan or a web page, from YTJ, the French register, KvK or the Bundesanzeiger, a document model reads equity, turnover, short-term debts and the auditor’s opinion, with a confidence score per field. A field below 0.85 is left for a person.
- The partner’s order history. The number, value and payment record of the buyer’s past orders with the partner, sent in the check. Only the classifier that sets the limit uses them. They are kept for a rolling twenty-four months and never shown to another partner.
- The financing and its collection. For each financing: the amount, currency, seller, order reference, term, due date, status, the daily charge so far, the mandate or account the buyer pays from, the reminders sent and the collection steps taken. It names the people who accept the terms and get the reminders. This is the ledger, and the buyer’s statement and the partner’s monthly statement are built from it.
- The partner account. The partner’s registration, its signatories’ identity and ownership documents, and the account its share is paid to. We read them to open the partner account, as the anti-money-laundering rules require of a lender, and keep them for the length of the agreement and five years after.
We never hold a buyer’s bank login and never ask a buyer to connect its bank. Every decision is made from the public register, the filed accounts and the partner’s own history, and nothing else.
The partner sees a limit, a status and a reason for each buyer. It never sees the register extract, the accounts we read or the score behind the limit.
The seller sees a payment and its order reference. It sees nothing about the buyer’s limit, terms or payment record.
A collections agent in the buyer’s country sees the financing it is collecting and the buyer’s contact details, and nothing about any other buyer.
B.2 What we do with it
Frankfurt to run it and to train it. The ledger, the register copies, the filed accounts, the order histories, the decisions and the partner accounts run on cloud infrastructure in Frankfurt. The document reader and the classifier answer calls on cloud GPU capacity we control there. Their training runs there too. No register record, account, order history or financing leaves the EU for processing.
No hosted model provider. No register record, filed account, order history or financing is sent to a third-party model API. The models are ours and run on capacity we control. The third parties involved are the cloud providers named on our subprocessor list, the six national registers as public sources, the bank we pay sellers and collect from buyers through, and one collections agent per country. All are named on the same page.
A rule declines, the model sets a limit, a person decides the rest. A rule declines a dissolved or insolvent company at the cart, from the register’s own status, and gives the reason. The model declines no one. A limit is set automatically only for a company, never for a person, and only when the register rules pass and the classifier is confident enough. A company less than a year old, a sole trader in any country, any case below the threshold and any buyer with a field read below 0.85 is not shown terms on that order. An underwriter in Amsterdam decides it, with a written reason, by the next working day. No model takes a collection step beyond a reminder.
Collection stays in the buyer’s country. A financing more than fourteen days overdue goes to a collections agent registered in the buyer’s country, who acts under that country’s rules and our instruction. The agent gets the financing and the buyer’s contact details, and reports back what it collected and learned. It gets no register extract, no accounts and no score.
Decisions are stripped before we keep them. When an underwriter decides a case, when a person corrects a field the reader got wrong, and when a financing is repaid or reaches ninety days overdue, we keep the company’s age, its sector, the figures with their corrections, the term, the outcome and the decision. The buyer’s name, registration number, address and contacts, and the partner’s identity, are removed. These records train our own models only. They are never given to anyone else, and they are deleted with the partner’s record on request.
B.3 AI models: where they run and what they learn from
Where models run. All live model use runs on cloud GPU capacity we control in Frankfurt. A document model reads equity, turnover, short-term debts and the auditor’s opinion out of filed accounts that arrive as a scan or a web page from YTJ, the French register, KvK or the Bundesanzeiger, with a confidence score per field. A classifier sets a limit from the company’s age, its sector, those figures and the partner’s own history with the buyer. The API, the ledger, the register cache and the filed accounts run on cloud infrastructure in the same city. No register record, filed account, order history or financing is sent to a third-party model API, and there is no hosted model provider on our subprocessor list. Training, meaning the reader’s fine-tuning on corrected fields and the classifier’s retraining, runs on cloud GPU capacity in Frankfurt. Frankfurt is inside the EU, and the cloud providers are named on our subprocessor list. From Q1 2027 the classifier is retrained per country on our own repayment outcomes. From Q3 2027 the reading pipeline runs on GPU capacity reserved in advance in Frankfurt.
Training. We don’t train any model on a buyer’s financing, its contact people, a partner’s identity or a seller’s payments, and no third party receives any of them to train on. There is one narrow exception. When an underwriter decides a case, when a person corrects a field the reader got wrong, and when a financing is repaid or reaches ninety days overdue, we keep the company’s age, its sector, the figures with their corrections, the term, the outcome and the decision. The buyer’s name, registration number, address and contacts, and the partner’s identity, are removed. Those records train our own reader and classifier only. They are pooled across partners, because a balance sheet’s layout and a sector’s payment habits are not personal to anyone. They hold no name and no buyer identifier, and each is deleted with the partner’s record on request.
Where a person decides. The model sets a limit. It declines no one. The only automatic no comes from a rule: a dissolved or insolvent company is declined at the cart, from the register’s own status, with the reason. A limit is set automatically only for a company, never for a person, and only when the register rules pass and the classifier is confident enough. A company less than a year old, a sole trader in any country, any case below the threshold and any buyer whose accounts the reader couldn’t read above 0.85 on every field is not shown terms on that order. An underwriter in Amsterdam decides it, with a written reason, by the next working day, and until then the buyer is not told no. A sole trader who disputes a decision gets a second underwriter, and the second decision replaces the first. No model takes a collection step beyond a reminder, or any decision with a legal or similarly significant effect on a person.
B.4 Where the data is kept
The API, the ledger, the register cache, the filed accounts and all live model use run on cloud infrastructure and cloud GPU capacity we control in Frankfurt. The document reader and the classifier are trained there too. Frankfurt is inside the EU, and the cloud providers are named on our subprocessor list.
No register record, filed account, order history or financing is sent to any hosted model API. No third party runs a model on this data.
Seller payments and buyer collections travel over SEPA in EUR, and over the Swedish and Danish domestic systems in SEK and DKK, through the bank named on our subprocessor list. A collections agent in the buyer’s country holds the financings it is collecting, under that country’s rules.
The suppliers that handle data in the service are named on our subprocessor list, which comes with the data processing agreement and which we send to anyone who asks: write to [email protected].
B.5 How long we keep it, and what deleting can’t remove
The ledger of financings, payments, charges and collection steps: seven years from the end of the financial year they fall in, because Dutch bookkeeping law requires it. The buyer and the partner can export them at any time in that period.
Register records and filed accounts: kept twenty-four hours after a lookup and refreshed on the next call. The copy read for a decision is kept with that decision for as long as the financing is kept, and deleted with it.
The partner’s order history with a buyer: a rolling twenty-four months from the date each order was sent, and deleted earlier if the partner ends the agreement.
Partner registration, signatory identity and ownership documents: for the length of the agreement and five years after, as the anti-money-laundering rules require.
Names and contact details of people who accept terms and get reminders: until the buyer’s last financing is closed and twelve months after, then deleted. The financing stays in the ledger under the buyer’s registration number.
Training records, stripped as described: until the partner’s record is deleted, and deleted with it on request.
B.6 Requests from people whose data is in the service
A partner can read and export every financing its checkout started, and its own account, from the partner console at any time without asking us. A buyer can get every financing it owes and every decision made about it, with the reason, by writing to us, within ten working days. A sole trader, a signatory or a named contact who asks for access, correction, deletion, objection or a portable copy gets an answer within thirty days, within the limits the bookkeeping and anti-money-laundering rules put on deletion. A person who objects to reminders is contacted through the buyer’s registered address instead. A sole trader who disputes a decision made about them has it reviewed by a second underwriter within ten working days, and the second decision replaces the first.
For everyone
4. Moving data between countries
Termijn B.V. is a company in the Netherlands, inside the EEA. Section B.4 says where the data in the service is kept. If any personal data we control ever has to leave the EEA, for example because a supplier named on our subprocessor list handles it elsewhere, it is protected by the European Commission’s Standard Contractual Clauses or another safeguard the GDPR accepts. You can ask us for a copy.
5. Security
We protect data in line with the risk. That includes encryption in transit and at rest, access limited to the people and systems that need it, each customer’s data kept separate from every other’s, and a log of every access to production systems.
If a personal data breach affects you, we tell you without undue delay, and at the latest within 36 hours of finding out, with the information you need to meet your own reporting duties.
6. Children
The service is sold to businesses and is not meant for children. We don’t knowingly collect personal data from anyone under 16.
7. Changes to this policy
We may update this policy. If a change matters, we email customers at least 30 days before it takes effect. The version number and date at the top of this page change every time.
8. Contact
Privacy questions and anything else: [email protected]
By post: Termijn B.V., Keizersgracht 268, 1016 EV Amsterdam, Netherlands