Privacy Policy
1. Introduction
1.1 Re-Humanise, a Dutch company, having its registered office in the Netherlands, and all its affiliated companies (we, us, or our) provides coaching, consultancy and education (“Services”) to individuals, teams and organisations (“Clients”)
1.2 Re-Humanise respects the privacy of our clients and the individuals whose data we handle in the course of our services ("you"). This Privacy Policy describes how we collect, use, and disclose your personal information and data.
1.3 We may change the provisions of this privacy statement from time to time. The most recent version can be found on our websites at all times. We advise you to check for an updated version periodically.
2. Information We Collect
We may collect two main types of information:
2.1 Client Information:
Contact information (name, email, phone number, postal address).
Demographic information (age, gender, occupation, location).
Coaching Information: goals, challenges, number of sessions, dates of sessions, types of coaching, progress notes (with your consent).
Company details, and any information necessary to complete our agreed-upon Services as outlined in a proposal.
Website Usage Data: We may use cookies and other tracking technologies to collect information about your activity on our website, such as the pages you visit, the links you click, and the searches you perform.
2.2 Data for Analysis: This is the data you provide directly for analytics purposes, which may include website traffic data, customer information, financial data, or any other relevant information as defined in the project scope.
3. How We Use Your Information
3.1 We process your personal data based on the following legal grounds defined in European privacy legislation:
Consent;
Execution of an agreement with you;
Legal obligation;
Legitimate interest of Re-Humanise or a third party;
By legitimate interests, we mean among other things: advertising, marketing, security, auditing, fraud detection, (crime)prevention, (market) research and analysis, improvement of our Services, internal management, legal affairs, and business administration.
We use the data in the following ways:
3.2 Client Information:
Provide coaching, consultancy and education Services.
Acquire and manage professional coaching accreditations.
Send you information about our Services, promotions, and events.
Respond to your inquiries and requests.
Improve our website and Services.
Comply with legal and regulatory requirements.
Communicate project updates.
Send invoices.
Manage our client relationships.
3.3 Data for Analysis:
We use data for analysis solely for the purposes outlined in the project proposal. This data is de-identified whenever possible and will not be used to identify any individual.
We may aggregate anonymised data for industry reports or research purposes, but this data will not contain any personally identifiable information (PII).
4. Retention period of personal data
4.1 We are committed to retaining your personal data only for the period necessary to fulfil the purposes outlined in this privacy statement unless a longer retention period is mandated or permitted by law.
4.2 Client Information Data: For any data required to deliver our Services, it will be kept for as long as you actively engage with our website or Services. Should you decide to unsubscribe, remain inactive, or end your engagement with Re-Humanise your personal data will be retained for an additional period of 2 years. This duration ensures that we can address any issues or concerns related to past transactions or interactions, support possible legal claims, and accommodate potential reactivation of your engagement.
4.3 In the case of Coaching Information data, specifically name, email address, dates or number of coaching sessions, and type of sessions (group or individual, paid or pro bono), this data will be retained indefinitely unless a request for deletion is received. This is to enable an ongoing calculation of the Coach’s coaching experience hours for submission to the relevant coaching regulatory board in the pursuit of industry recognised coaching accreditations.
4.4 Financial Records: In accordance with tax laws, any data related to financial transactions, invoices, and payments will be retained for a period of 7 years.
4.5 After the expiration of the retention periods mentioned above, we will securely delete or anonymise your personal data, so it can no longer be linked back to you. Notwithstanding the foregoing, we may retain data in an aggregated and anonymous form indefinitely for (market) research, analysis, and fraud protection purposes.
4.6 Should you have further inquiries about the specific retention periods for certain types of personal data or if you require more clarity on our data retention practices, please reach out to us through the contact details provided below.
5. Sharing Your Information
We will not share your information with third parties without your consent, except in the following cases:
5.1 Service Providers: We may use third-party service providers for data storage, processing, or analysis tools. These providers are chosen based on their strong security practices and are contractually obligated to protect your data. It is possible that these third parties process your personal data on our behalf, but only to the extent necessary for the provision of the Services to you.
5.2 Legal Requirements:
We may disclose information if required by law or to prevent harm to you or others. We will notify you if a government agency makes a request that relates to your personal data, to the extent permitted by law.
We may be required to process your personal data for purposes other than those set out in this privacy statement, for example for law enforcement and in case of a court order.
5.3 Bankruptcy, merger or sale (part) of the company: We may transfer your personal data to third parties in the event that our organisation is subject to a merger, acquisition, reorganisation, sale of business units or bankruptcy. In this case we will ask for your prior consent, to the extent required under applicable law.
With your consent:
5.4 Coaching Certification: We may disclose information such as name, email address, type of coaching, number of sessions and progress notes to the relevant coaching regulatory board in the pursuit of industry recognised coaching accreditations.
5.5 We may share your personal data with third parties if you give us permission to do so. For example, we can cooperate with third parties to offer you specific services or offers. If you register for these services or marketing offers, we may provide your contact information, if necessary to provide you the service or for them to contact you. You will always be asked for your consent.
6. Transfer of your personal data abroad
6.1 At the time of drafting this privacy statement, your personal data will not be transferred to a third party abroad (outside the European Economic Area or EEA). We adhere to the strict guidelines of the EEA's data protection regulations. However, as our operations evolve, should there ever arise a necessity to transfer data outside the EEA, we will ensure that all such transfers are compliant with the relevant data protection laws and regulations, and the data transferred will receive the same protection as it would within the EEA.
7. Data Security
7.1 We take industry-standard security measures to protect your information, including secure storage and access controls. We also maintain strict data retention policies and will only retain data for as long as necessary to complete the project or as required by law.
7.2 We would like to point out that absolute security for sending personal data via the internet or storing personal data cannot always be guaranteed. We advise you to take this into account when deciding whether or not to give consent for processing your personal data.
8. Links to third party sites
8.1 Our Services may include links to websites, applications, and services operated by third parties, as well as advertisements from third parties. Please be aware that these third-party sites and services may independently collect, use, and disclose information about you. We emphasise that when you provide personal data to third parties, it is subject to their respective privacy policies and practices. We do not have control over, nor are we responsible for, the content, privacy policies, or data handling practices of third-party sites and services.
8.2 While we offer links for convenience and informational purposes, the inclusion of such links does not imply endorsement or affiliation. We strongly recommend that you review the privacy policies and security measures of any third parties before sharing your personal data with them.
9. Your Choices and Rights
9.1 Privacy legislation gives you certain rights regarding your own personal data. These rights are not absolute rights. We will always consider whether we can reasonably meet your request. If we cannot meet your request, or if it would be at the expense of the privacy of others, we can refuse your request. If we refuse a request, we will let you know and explain our reasons.
9.2 You have the following choices regarding your information:
Client Information: You can request access to, or deletion of, your client information by contacting us. You can also ask us to provide insight into the processing grounds, relevant categories of personal data, the (categories of) recipients of personal data, the retention period, the source of the data and whether or not we use automated decision making. You may also request a copy of your personal data that we process.
If the personal data processed by us about you is incorrect or incomplete, you can request us to adjust or supplement the personal data. If we grant your request, we will, to the extent reasonably possible, inform the parties to whom we provide information.
Whether we will delete data depends on the processing ground. We only delete data that we process based on a legal obligation or for the performance of an agreement with you, if the personal data is no longer necessary. If we process data based on our legitimate interest, we will only delete data if your interest outweighs ours. We will make this assessment. If we process the data based on your consent, we will only delete the data if you withdraw your consent. Should we have accidentally processed data or does a specific law require that we delete the data, then we will delete it. If the data is necessary for the settlement of legal proceedings or a (legal) dispute, we will only delete the personal data after the end of the proceedings or the dispute. If we grant your request, we will, to the extent reasonably possible, inform the parties to whom we provide information.
Restriction of processing: If you dispute the accuracy of personal data processed by us, if you believe that we have processed your personal data unlawfully, if we no longer need the data or if you have objected to the processing, you can also request us to restrict the processing of that personal data. For example, during the time that we need to assess your dispute or objection, or if it is already clear that there is no longer any legal ground for further processing of the personal data, but you still have an interest in us not deleting the personal data. If we limit the processing of your personal data at your request, we may still use that data for the settlement of legal proceedings or a (legal) dispute.
Right of restriction of processing and withdrawal of permission: If we process data on the grounds of a legitimate interest, you may object to the processing. If we process data based on your consent, you may withdraw that consent.
Data for Analysis: You determine the data you provide for analysis. We will work with you to ensure anonymisation whenever possible. You can also request deletion of your data upon project completion, subject to any legal or contractual restrictions.
Marketing: You can opt out of receiving marketing emails from us by clicking the "unsubscribe" link at the bottom of our emails. You can decline cookies directly through the pop up when visiting our website.
10. Children's Privacy
10.1 Our services are not directed to children under the age of 18. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and you believe that your child has provided us with personal information, please contact us.
11. Changes to this Privacy Policy
11.1 We may update this Privacy Policy from time to time. We will post any changes on our website.
12. Exercising your rights
12.1 To exercise your rights, please contact us using the contact details below. We strive to process your request within one month.
13. Complaints
13.1 Do you have a complaint about our processing of your personal data? Please contact us using the contact details below. We are happy to assist you. Under the European privacy legislation, you are also entitled to submit a complaint directly to the Personal Data Authority. We strive to process your complaint within one month.
14. Contact Us
14.1 If you have any questions about this Privacy Policy, please contact us at katie@re-humanise.com
15. Effective Date
15.1 This Privacy Policy is effective as of 1st March 2024