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GDPR Privacy Policy IN PERSON

Privacy Policy

General Data Protection Regulation Compliant

Updated October 2020

This privacy policy outlines what information (“PERSONAL DATA”) is collected from you (“CLIENT”) and how that information is handled by Erna Stassen Coaching/Consulting (the “COMPANY”). All is done in accordance with the recent General Data Protection Regulation (GDPR).

Erna Stassen Coaching/Consulting (the “COMPANY”) respects your privacy concerns and provides this privacy statement to explain what information is gathered during your appointment with  the COMPANY and how such information may be used.

 

USE OF INFORMATION

To serve you, the COMPANY collects specific personally identifiable information (“PERSONAL DATA”), such as your name, address, so that it can provide coaching and or consulting, mentoring or education to the CLIENT.

PERSONAL DATA is information that specifically identifies you (name, email address, ship to/bill to address, phone number) and can be used to specifically locate you from within the COMPANY’S database and or filing system.

The COMPANY collects this information from you:

  • Name,
  • Email,
  • Phone number (if it is an appointment by phone)
  • Other relevant personal information: address, employment, marital status, date of birth (not mandatory)
  • Intake assessment: Questionnaire

Information provided by CLIENT at time of appointment is used to:

  • To provide CLIENT with quality, personal coaching, mentoring, consulting, education
  • Keep CLIENT file in good standing;

 

PERSONAL DATA submitted voluntarily by the CLIENT is held:

  • In a file folder in a filing cabinet that can be locked; in a folder on a secure computer
  • It is held for 1 year after the last session
  • Only the COMPANY’S coach providing the service has access to it
  • CLIENT can request copies and or deletion at any time by emailing [email protected]

LEGAL BASIS FOR USE OF INFORMATION

The COMPANY is legally processing CLIENT’S PERSONAL DATA based on the following:

  • The CLIENT has given his or her explicit and voluntary consent to the COMPANY;
  • The CLIENT has a contract (coaching Agreement) with the COMPANY that necessitates the COMPANY having his or her PERSONAL DATA;
  • There is a vital interest that necessitates the COMPANY processing CLIENT’S PERSONAL DATA;

 

USE TO THIRD PARTIES

PERSONAL DATA is never sold, leased, or shared with any third parties. A third party is a COMPANY outside of the CLIENT - COMPANY relationship.

 

USE TO CREDIT CARD INFORMATION

The COMPANY does not store any credit card information it may receive in regard to a specific transaction and/or billing arrangement except as necessary to complete and satisfy its rights and obligations with regard to such transaction, billing arrangement, and/or as otherwise authorized by a user.

All credit card information is handled by Stripe.

USE LEGAL OBLIGATIONS

The COMPANY may disclose CLIENT information in special cases when required by legal and or law enforcement and only when required by law.

If the COMPANY has reasonable reason(s) to believe that disclosing PERSONAL DATA held by the COMPANY is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with the COMPANY’S rights or property, other users of the SITE, and or anyone else that could be harmed by such activities, then the COMPANY will work with the appropriate and legitimate law enforcement and or legal authorities to make sure that the PERSONAL DATA is handled in accordance with the applicable laws.

 

CLIENTS RIGHTS

As a CLIENT and or user of the SITE, you have the following rights:

  • Transparent information from the COMPANY regarding how they communicate and interact with the CLIENT;
  • The right to hear back from the COMPANY regarding any inquiry into CLIENT’S PERSONAL DATA;
  • To request correction of PERSONAL DATA from the COMPANY;
  • Access to CLIENT’S PERSONAL DATA including knowing the purposes that the data is used for;
  • To request erasure from the COMPANY’S records provided that there are not overriding legal, public interest, or legitimate interests;
  • To a restriction on the processing of the PERSONAL DATA;
  • Data portability of PERSONAL DATA (having a record provided to you that is readable and commonly used that outlines the PERSONAL DATA the COMPANY has on you)
  • To object to processing of PERSONAL DATA - the COMPANY shall no longer process the CLIENT’S PERSONAL DATA unless the COMPANY demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the CLIENT or for the establishment, exercise or defense of legal claims.
  • To file a complaint with the supervisory authority;
  • The right to unsubscribe at any time (withdraw consent)

PROFILING PERSONAL DATA

Profiling means any form of automated processing of PERSONAL DATA consisting of the use of PERSONAL DATA to evaluate certain personal aspects relating to a CLIENT, in particular to analyse or predict aspects concerning that CLIENT’S performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;

The COMPANY DOES NOT ENGAGE IN ANY SORT OF PROFILING OF ITS CLIENTS BASED ON PERSONAL DATA.

CHILDREN AGE 13 AND UNDER

The COMPANY recognizes the special obligation to protect PERSONAL DATA obtained from children age 13 and under. Any data collected from children age 13 and under will be done in a signed writing by the parent and or guardian of the child.

CONTACT INFORMATION

If you have any complaints or concerns about the COMPANY or about this privacy statement, please let the COMPANY know directly.

SECURITY

Security for all PERSONAL DATA is extremely important to the COMPANY.

Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure.

As a result, while the COMPANY strives to protect CLIENT’S PERSONAL DATA, the COMPANY cannot ensure or warrant the security of any PERSONAL DATA the CLIENT transmits via the internet. By transmitting any such information to the COMPANY, CLIENT accepts that he or she does so at their own risk.

TRANSFER OF CUSTOMER INFORMATION

Customer lists and information are properly considered assets of a business. If COMPANY merges with another entity, or if it sells its assets to another entity, the COMPANY’S customer list and information would be included among the assets transferred.

  • CLIENT would be given the opportunity to object before any such transfer would occur.