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:
- Browser type and version
- Operating system used to access the site
- Website from which an accessing system reaches the TpEBO site
- Date and time of access to the TpEBO site
- Internet protocol address (IP address)
- Internet service provider of the accessing system
- 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 encrypted CRM system.
Contact is made when you (the data subject) have:
- Supplied a valid e-mail address and given permission that contact can be made by TpEBO
- Requested information from TpEBO
- Registers for TpEBO updates
- 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 KEAP (T/A Infusionsoft) to manage contacts and communication to clients, peers and customers. The company is based in the US and is GDPR compliant. Address: KEAP (T/A 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.
