Privacy Policy

Who we are

Client Focused Coaching T/A TpEBO. The website address is: www.tpebo.com

Note:
You can browse the site without sharing your data with us. However, if you wish to set up an appointment, sign up for TpEBO updates or access services via our website, then the processing of personal data may be necessary and requires your consent. The purpose of this data protection policy is to inform you of the nature, scope, and purpose of the personal data we collect, use and process and summarise your rights relating to that data.

 

Privacy Policy
Updated: 28th May 2018

Data protection is a priority for TpEBO. The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject complies with the General Data Protection Regulation (GDPR), and in accordance with country-specific data protection regulations applicable to TpEBO (Client Focused Coaching T/A TpEBO).

We have put in place specific measures in place to ensure the protection of personal data processed through the TpEBO website.

It should be noted that Internet-based data transmissions can occasionally run the risk of and information or security gap, therefore, 100% protection cannot be guaranteed. For this reason, you are entitled to share personal data with us using alternative means such as in person or via the telephone or direct email.

1. Definitions

The definitions used in this policy document are based on the terms used for General Data Protection Regulation (GDPR) implementation in Europe and are as follows:

Consent
freely given, specific, informed and explicit consent by statement or action signifying agreement to the processing of their personal data

Data Controller
the entity that determines the purposes, conditions and means of the processing of personal data

Data Processor
the entity that processes data on behalf of the Data Controller

Data Subject
a natural person whose personal data is processed by a controller or processor

Personal Data
any information related to a natural person or ‘Data Subject’, that can be used to directly or indirectly identify the person

Processing
any operation performed on personal data, whether or not by automated means, including collection, use, recording, etc. (note: this can also include marking data so that it is deleted or limited for future use (restricted processing)

Profiling
any automated processing of personal data intended to evaluate, analyse, or predict data subject behavior

Pseudonymisation
the processing of personal data such that it can no longer be attributed to a single data subject without the use of additional data, so long as said additional data stays separate to ensure non-attribution

Recipient
entity to which the personal data are disclosed

2. Data Controller Name & Address

For the purpose of the General Data Protection Regulation (GDPR) relating to this site, the Data Controller is:

Client Focused Coaching (Trading as TpEBO)
WTC The Hague Business Center
Pr. Margrietplantsoen 33, 2595 AM Den Haag
The Netherlands
Phone: + 31 71 3020304
Email: sinead@tpebo.com
Website: www.tpebo.com

3. Usage of cookies

Cookies are text files that are stored in a computer system via an Internet browser which allows us to recognise website users so that the TpEBO website can be optimized with the user in mind. You (the data subject) can choose to accept or reject the use of cookies on the TpEBO site.

Note: When cookies are rejected, the site is accessible, some functions of the website may not be fully usable.

4. Data and information collection

The TpEBO site collects information when a data subject or automated system accesses the website. This information is needed to deliver & optimise the content of our website, and if necessary provide authorities with information in case of a cyber-attack. The statistical information collected is used to increase TpEBO’s levels of data protection and data security and optimise the level of protection of any personal data processed. The anonymised data of the server log files are stored separately from all personal data provided by a data subject (you).

The information collected includes the following:

  1. Browser type and version
  2. Operating system used to access the site
  3. Website from which an accessing system reaches the TpEBO site
  4. Date and time of access to the TpEBO site
  5. Internet protocol address (IP address)
  6. Internet service provider of the accessing system
  7. Data that may be used to compromise our technology systems.

5. Registration for company updates, webinars or a business consultation

TpEBO site users can subscribe through the site for company updates, webinars or a business consultation.

TpEBO communicates to its clients, customers, peers and partners through customised emails, webinars and newsletters using a permission-based encypted CRM system.

Contact is made when you (the data subject) have:

  1. Supplied a valid e-mail address and given permission that contact can be made by TpEBO
  2. Requested information from TpEBO
  3. Registers for TpEBO updates
  4. Requested a consultation.

A double opt-in process is used to confirm whether the owner of the e-mail address is correct and permission has been given to connect. During the registration process, the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration is logged (see point 4).

The personal data collected as part of a registration for a webinar or updates, will only be used to send information about the webinar or updates. There will be no transfer of personal data collected by TpEBO to third parties. The subscription to our webinars and updates may be terminated by the data subject (you) at any time as can the removal personal data stored. This can be completed by either unsubscribing to our updates or contacting the data controller directly (see point 2).

TpEBO uses Infusionsoft to manage contacts and communication to clients, peers and customers. The  company is based in the US and is GDPR compliant. It’s address is:  Infusionsoft Headquarters, 1260 South Spectrum Boulevard, Chandler, AZ 8528. Click here to read Infusionsoft’s updated data processing policy

6. Contact with TpEBO through the website contact form and / or  direct email

When you (data subject) contact TpEBO by e-mail or via a contact form, the personal data transmitted by you (the data subject) is automatically stored. Personal data transmitted on a voluntary basis by you to TpEBO are stored for the purpose of processing or contacting you to follow up on your request. There is no transfer of this personal data to third parties.

7. Comments function on the website

When visitors leave comments on the site, TpEBO collects the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection. When a data subject leaves a comment on the TpEBO website, the comments made by the data subject are stored, moderated and published if approved. The date, the users pseudonym and IP address is also logged. This collected personal data will not be passed to third parties, unless such a transfer is required by law or serves the aim of the defense of the data controller.

8. Routine erasure and blocking of personal data

TpEBO’s data controller shall process and store your personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to. Personal data shall be routinely blocked or erased in accordance with legal requirements.

9. Your (data subject) rights

If you have registered on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes

Access personal information
You have the right to obtain from the TpEBO controller information about your stored personal data stored at any time and request a copy of this information.

Under the GDPR  directive you can request access to the following :

1. the purpose of the processing and the categories of personal data accessed
2. the recipients or categories of recipients to whom the personal data have been or will be disclosed
3. the estimated time personal data will be stored and/or the criteria used to determine that period;
4. confirmation of the right to request from the controller correction or erasure of personal data, or restriction of
processing of personal data relating to the data subject, or to object to processing;
5. the existence of the right to lodge a complaint with a supervisory authority;
6. when personal data has not been collected from the data subject, to supply information on the source of the data;
7. the existence (if any) of automated decision-making referred to in Article 22(1) and (4) of the GDPR and meaningful
information about the logic involved, and envisaged consequences of such processing for the data subject (you).

Note: You have the right to request if your personal data has transferred to an international organisation or another country. You have the right to request the appropriate safeguards relating to the transfer. If you wish to avail of this right of access, you can, at any time, contact any employee of the controller.

Automated individual decision-making & profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which significantly affects you. When an automated decision is necessary for entering into, or the performance of, a contract between you and TpEBO, or based your consent, we shall safeguard your interests, with the right to a conversation with someone on behalf of the controller to discuss your situation. You may avail of this right at any time by contacting any employee.

Confirmation
You have right to obtain from the controller confirmation as to whether or not personal data is being processed. If you wishes to request this right of confirmation, you may, at any time, contact any employee of the TpEBO controller.

Correction / rectification / completion
You have the right to request the data controller to immediately correct inaccurate or incorrect personal data. You also have the right to complete incomplete personal data.  If you wish to avail of this right, you can, at any time, contact any employee of the controller.

Data portability
You have the right to receive the personal data which was provided to a controller, in a structured, machine-readable format. You have the right to transmit the data to another controller without hindrance from the controller to which the personal data has been provided and as long as the processing and the request is based on consent or included within a contract.  If you wish to avail of this right, you can, at any time, contact any employee of the controller.

Objection
You have the right to object and TpEBO will cease processing the personal data when an objection is received, unless there are legal grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims. If you wish to avail of this right, you can, at any time, contact any employee of TpEBO.

Restriction of processing
You have the right to obtain from the controller restriction of processing, this can be arranged at any time by TpEBO employees.

Right to be forgotten
You have the right to obtain from the controller the erasure of personal data and the controller shall have the obligation to erase personal data without undue delay as long as the processing is not necessary. This is arranged by TpEBO employees on a case by case basis.

Right to withdraw consent
You have the right to withdraw your consent to the processing of your personal data at any time, this can be arranged at any time by TpEBO employees.

10. Google Analytics usage

The TpEBO website uses Google Analytics for WordPress by MonsterInsights (with the anonymizer function) to analyse traffic to the site to help us understand the origin of visitors and clicks. Google Analytics is part of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

You can also object to a collection of data from this site by Google Analytics by downloading and installing this browser add-on . The installation of the browser add-ons is considered an objection by Google and needs to be updated. You also can prevent the setting of Google Analytic cookies on the site by rejecting the use of cookies (See point 3). Click to fo find out more about Monster Insights, Google Analytics, Google’s privacy policy and Google Analytics terms of service.

11. Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

12. Where we send your data

GDPR is the European legal framework which TpEBO is obliged to use to obtain consent to use your data. It facilitates the contractual and pre-contractual use of your data for the supply of goods and services and in some situations to fulfill our tax obligations. We have and always will careful with your data and treat the information you share in confidence and for ther well-being of you, our clients, our employees and the company. Registrations to the site are hosted on Infusionsoft (see points 4 & 5). Visitor comments and registrations on the site may be checked through an automated spam detection service. We do NOT use automated decision-making or profiling.

13. How long we store your personal data

Personal data is reviewed each quarter and held for a statutory retention period. Inactive contacts are routinely deleted after 24 months. In addition the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment or initiation of a contract.

14. Personal data use as a statutory or contractual requirement

The provision of accurate personal data is required to close a contract and by law (for example: to comply with VAT regulations). You are obliged to provide us with up to date personal data when our company signs a contract with you. When you contact one of our employees we will confirm if are oblicated to provide personal data as required by law or to close the contract  and the consequences of non-provision of the personal data.

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