Publication Date: 25 May 2018
1. What is this Privacy Notice? We are committed to protecting the privacy and security of your personal information and this privacy notice describes how we collect and use your personal information when you enroll in the coaching program (“Program”).
It is important that you read this notice so that you are aware of how and why we are using such information. We may update this notice at any time and, where required, will notify you of these updates.
We are required under applicable data protection legislation to notify you of the information contained in this privacy notice.
We may also collect personal information about your family members for the purposes of delivering the Program. When you disclose information about your family members, please ensure that you have their consent to share such information and please provide a copy of this Privacy Notice to them.
2. Who are we? Alexandra Rachel Chaffanjon (the Coach, we, us, our) is a "data controller" which means that we are responsible for deciding how and why we hold and use personal information about you. Our contact address is 1196 Gland, Switzerland (exact address can be provided upon request).
References in this notice to you and your shall mean you if you are enrolling in the coaching program (the Program), engaging with the Coach in market research, complimentary coaching sessions, browsing or using the landing page or website of the Coach.
3. What are the data protection principles? We will comply with applicable data protection legislation which provides that personal information must be:
1. Used lawfully, fairly and in a transparent way. 2. Collected only for specified, valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes. 3. Adequate, relevant and limited to the purposes we have told you about. 4. Accurate and, where necessary, kept up to date. 5. Kept only as long as necessary for the purposes we have told you about. 6. Kept securely.
4. How do we collect your personal information? We collect personal information directly from you when you provide us with the information that we need to enroll you on the Program. We might also collect your personal information from third parties that you pass personal information to for the purposes of enrollment of the Program.
5. What kinds of personal information do we collect from you? Personal data, or personal information, means any information relating to an identifiable person who can be directly or indirectly identified from the information. Some of the personal information we collect is particularly sensitive and is called "Sensitive Information" which requires a higher level of protection. We will collect, store, and use the following categories of personal information about you:
Contact Information ♦ Email address ♦ Home address ♦ Phone number ♦ Skype identification ♦ Facebook identification
Identification Information ♦ Name ♦ Gender ♦ Age ♦ Birthday anniversary
Account Information ♦ Bank account details
Sensitive Information ♦ Health condition (including any information you may choose to disclose concerning your current medical, therapeutic and nutritional situation) ♦ Sleep condition ♦ Food and lifestyle information
Analytical Information ♦ Internet Protocol (IP) address ♦ Uniform Resource Locators (URL) ♦ Cookies ♦ Google Analytics
6. What is our legal basis for using your personal information? We will only use your personal information when we have a lawful basis on which to do so and where:
1. We need to comply with a legal obligation. 2. It is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. 3. Where you have given us consent to use your personal information. 4. We need to protect your vital interests (or someone else's interests). 5. It is needed in the public interest.
We will only use your Sensitive Information where you have given us your explicit consent or we need to protect your vital interests (or someone else's). We will only use your personal information to the minimum extent necessary, and our purposes for using all of your personal information, including Sensitive Information, are set out below.
7. How do we use your personal information? We will only use your personal information for the purposes for which we originally collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an incompatible purpose, we will notify you and we will explain the legal basis which allows us to do so.
We will use your Contact Information to communicate with you, to deliver content of the Program , to conduct market research interviews, to provide complimentary coaching assessments and we will use your Identification Information to create your personal profile. We will only collect and use your Account Information in case a refund is carried out.
We will use your Analytical Information to understand how you engage with our website, to distinguish you from other users of the website, to provide a high quality experience, customizing offerings, identifying and fixing issues that may arise and to promote our products that are relevant to your interests.
8. How do we use sensitive information? Sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We will use your Sensitive Information to allow us to create your tailor made progress plan of the Program, for example to ensure that your habits and personal circumstances are taken into account when designing your step plan and goals.
9. What are your responsibilities? It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us. Please note that if you fail to provide certain information when requested, you may not be able to complete the Program.
10. Who do we share your personal information with? We will share your personal information with third parties, including third-party service providers (and their designated agents) where that is necessary:
(a) to assist with the organization and delivery of the Program, for example, processing payments, documents sharing, online registrations and webinar platforms;
(b) where required by law;
(c) where it is necessary to administer our relationship with you; or
(d) where we have another legitimate interest in doing so. We require third parties to respect the security of your personal information and to treat it in accordance with the law.
We may also share your personal information with third parties for regulatory and legal reasons or with third parties in the event that our business or substantially all of its assets are acquired by a third party.
11. Will we transfer your personal information outside of the European Union? Dependent on the location of the service providers we use, we may need to transfer your personal information to countries which may not have data protection laws providing the same level of protection as those in the European Economic Area. For example, if we are hosting a coaching session through a webinar provider in the US, we would need to transfer your personal information to the US.
We shall ensure that any such transfers are lawful and backed by contractual obligations approved by the relevant regulators and that your personal information is always kept secure.
12. How long will we keep your personal information for? We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Normally, we will keep your personal information up until the end of the contractual relationship you have with us and to the extent permitted, after the end of that relationship for as long as necessary to perform the purposes set out in this policy. We will delete Account Information, Sensitive Information and Analytical Information within 3 months after the completion of the Program.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
13. What are your privacy rights? By law you have the right to:
♦ Access your personal information. Please send all data subject access requests in writing. You will not have to pay a fee to access your personal information, however, we may charge a reasonable fee if your data subject access request is clearly unfounded or excessive. We may need to request specific information from you to help us confirm your identity.
♦ Rectification of your personal information that we process about you. This enables you to have any incomplete or inaccurate information we process about you corrected.
♦ Erasure of your personal information. This enables you to ask us to delete or remove personal information.
♦ Oject to processing of your personal information pursuant to this notice.
♦ Restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy.
♦ Portability of your personal information. You may ask us to provide you with the personal information that we hold about you in a structured, commonly used and machine-readable format to another party.
♦ Withdraw consent if you have given us consent to use your personal information, you can withdraw your consent at any time.
♦ Make a complaint about our data processing activities by contacting us using the details located at section 17 of this notice. Alternatively, you may make a complaint to the data protection supervisory authority in your country. For a full list of supervisory authorities, please visit http://ec.europa.eu.
If you want to exercise any of your rights in respect of your personal information, please contact us using the details located at section 17 of this notice.
14. How will we keep your personal information secure? We will treat all of your personal information in strict confidence and we will take all reasonable steps to keep your personal information secure once it has been transferred to our systems. We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction of your personal information. Please note that we cannot guarantee the security of any data you disclose to us online. You accept the inherent security risks of providing information and dealing online and will not hold us responsible for any loss or damage that you incur.
15. How will we communicate with you? We will communicate with you using your Contact Information.
16. Changes to this privacy notice We reserve the right to update this privacy notice at any time, so please review it regularly. We will let you know when we make any material changes to the privacy notice by means of notice on our site homepage or if appropriate, by contacting you directly.
17. Contact us If you have any questions about this privacy notice or how we handle your personal information, please contact us by email at firstname.lastname@example.org or by calling +41 76 647 36 02.