The following privacy notice sets out our policy for processing your personal data that we collect through our website at True-me Breakthrough Coaching.
WHAT PERSONAL DATA DO WE PROCESS AND WHY?
We process personal data collected via the Website. Personal data shall mean any information relating to an identified or identifiable natural person (in the sense of the General Data Protection Regulation).
1. Website visits
We collect the following personal data when you visit the Website, whether you are a registered user of the Website or not:
• IP address
• information on your device (e.g. screen size)
• (social) network user ID, if you use social network plug-ins (e.g. “Like” button)
• Website’s usage (i.e. how you interact with our Website)
We will use your IP address, as well as cookies, to collect this personal data:
You will not be requested to log in or provide personal details in order to access the Website. You can be required to log in to access certain features.
2. Special features, options and other purposes
We also process the following personal data in addition to that specified here for the purposes described hereafter:
• basic personal details (first name / surname / age)
• address for dispatch
• Marketing communications’ usage (e.g. whether you open them or not, on which links you click)
• email address
• telephone no.
We use your personal data for the following purposes:
a. Respond to your requests / Administrative interactions
• Respond to your inquiries, questions and comments, and fulfil your requests
You have the option of contacting us via the Website. If you send us a message via the Website, we will use your personal data to help us deal with any enquiries, suggestions and complaints you may have.
We will not generally forward any requests or enquiries to third parties.
Legal basis for processing: our legitimate interests to answer your queries.
• To send administrative information to you, for example, information regarding the Website and changes to our terms, conditions, and policies
We use your personal data to provide you with important information relating to the Website, your transactions and any changes in our terms and conditions, our policies or this Privacy Notice.
Legal basis for processing: our legitimate interests to inform you by email about the evolution of our Website, our terms and conditions, our policies, and this Privacy Notice.
b. Sending of marketing communications
We use your personal data to send you direct marketing communications by email and push notifications. Direct marketing communications inform you about our news, our programs, or other similar activity, about True-me Breakthrough Coaching. Among our marketing communications is our newsletter, to which you can subscribe. We use a “double opt-in” system for registering for our newsletter. This means that we will send a confirmation to the email address you give asking you to confirm that you wish to subscribe to the newsletter. If you fail to confirm within 48 hours, your application will be automatically deleted. You will need to provide your email address and age before we can send you our newsletter. This information will only be used in this regard. We will use your age information to check that you are over 16 (art. 8 (1) EU General Data Protection Regulation). Unfortunately, we cannot send our newsletter to anyone under the age of 16. Your age information will be deleted immediately after you have registered. We will store your email address until such time as you unsubscribe from the newsletter, and delete it afterwards.
Legal basis for processing: your Consent
If you have registered for marketing communications using the “double opt-in” system, you can withdraw your consent to receive direct marketing communications, by clicking on the link “Unsubscribe” at the bottom of every marketing email.
You can also let us know that you wish to withdraw your consent by email, by calling us or writing to us using the contact information listed in section VII of this Privacy Notice.
c. Data analytics to derive trends & improve True-me Breakthrough Coaching Services. We collect your personal data in an aggregated form, to measure your engagement with the Website (e.g. to know how you use our Website, when do you use them, using what device) and with our marketing communications (e.g. whether you open them or not, on which links you click), and derive general consumption trends and patterns from this analysis. This analysis helps us to know the Website’ users better and adapt our Website to the identified preferences of the users, but also more generally to adapt True-me Breakthrough Coaching services to users’ general preferences.
Legal basis for processing: your consent
You can accept or refuse this collection and use of your personal data for the purpose of performing data analytics to derive trends and improve our Website and more generally True-me Breakthrough Coaching products and services by contacting us using the contact information listed in this Privacy Notice.
You can also withdraw your consent to the collection and use of your personal data for the abovementioned purpose using the contact information listed in this Privacy Notice.
You can also let us know that you wish to withdraw your consent by using the contact information listed in this Privacy Notice. Once you withdraw your consent, we will stop the processing for the concerned purpose.
d. Competitions, prize draws, surveys and other special offers/promotions
We will offer competitions, prize draws, surveys and similar special offers/promotions via the Website which can require online registration (including your email address, user ID and password). We will generally ask you for certain personal information if you register for or win a competition, prize draw, survey or other special offer/promotion, in order to carry out the event until its completion, and keep you informed about it.
Legal basis for processing: the processing of the personal data that you provide us to register to competitions, prize draws, surveys and other special offers/promotions for the purposes stated above is based on performance of the relevant promotion terms and conditions.
You should carefully read the terms and conditions (including any data protection provisions) for any competitions, prize draws, surveys or other special offers/promotions you may take part in via the Website as they may contain other important information on the use of your personal data by us or any sponsor. If those terms and conditions and personal data provisions are not consistent with those set out in this Privacy Notice, those other provisions shall take precedence.
We use your personal data to diagnose server problems, administer the Website and check that it properly functions.
Legal basis for processing: our legitimate interests to administer our IT systems and networks and ensure the Website technically functions.
MANAGING THE INFORMATION WE COLLECT
We do not share personal information with companies, organizations, and individuals other than True-me Breakthrough Coaching unless one of the following situations occurs:
• Your own consensus
We share personal information with companies, organizations, and individuals outside True-me Breakthrough Coaching when we have your consent to that.
• External processing
We will share personal information with companies, organizations, or individuals outside of True-me Breakthrough Coaching if we believe in good faith that accessing, using, maintaining or disclosing information is reasonably necessary in order to:
• complying with any applicable laws, regulations, legal procedures or enforceable claims by organizations.
• Imposing applicable Terms of Service, including investigating possible violations.
• detect, prevent, or otherwise address fraud related to addresses and security issues or technical issues.
• protect the rights, property or security of True-me Breakthrough Coaching, its users or the public as required or permitted by law from imminent harm.
We may share non-personally public information with our partners – such as publishers, advertisers, or linked sites. For example, we may share public information to show trends in the general use of our services.
Other important notes concerning our data protection compliance
We have instituted a number of security measures and tools for ensuring that personal data under our control is protected against loss, misuse or modification. Even though we do our best to protect your personal data, we cannot guarantee the safety of all of the information you provide via the Website or in connection with it. If you have reason to believe that your interaction with us is no longer secure (e.g. if you are worried about the security of any user account you have with us), you will need to inform us immediately about any issues you may be experiencing by contacting us using any of the options under “Contact Us” in the Website. Please note that contacting us by post will delay us in dealing with the problem and may therefore also delay our response.
The data privacy policies of those networks provide further information on the purpose and scope of their collection, processing and use of data, on your rights and on settings which may help you protect your privacy.
CHANGES TO THIS PRIVACY NOTICE
This Privacy Notice is governed by and shall be construed in accordance with the laws of Belgium and any other applicable laws in the European Union.