This Privacy Policy provides an overview of all information regarding the processing of personal data by Senseful Mind, business registered under the laws of the Netherlands under Chamber of Commerce number 84684283, hereafter referred to as Senseful Mind, we or us.

 

Senseful Mind is strongly committed to protecting your privacy and complying with your choices. You will be in full control of all data relating to yourself. Both personal and non-personal data and information collected is safeguarded according to the highest privacy and data protection standards adopted worldwide. Specifically, we are in compliance with the EU General Data Protection Regulation (GDPR). We strive to make you feel safe when we collect or share your data and therefore, we want to be transparent on how we collect, use, share and store the information about you and the choices available to you as data subject.

 

This Privacy Policy is about how we handle the personal information of customers and users of Senseful Mind (the Privacy Policy). The Privacy Policy applies to the Senseful Mind website, located at www.sensefulmind.com (the Website), as well as your use of or access to any of our (online) services.

 

We reserve the right to make changes to this Privacy Policy at any time. We will notify you when updates are made to give you an opportunity to withdraw previously given consent or to deny further use of your data. We may have to update the Privacy Policy in case of new developments, activities, online services or when applicable legislation changes.

 

When does this Privacy Policy apply?

This Privacy Policy applies to the processing of personal data of Senseful Mind coaching clients and users of the Website. We will provide you with a high level of control over your personal data and will clearly inform you when information that personally identifies you is asked for.

 

Usage of personal data

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We use and collect your personal data for the following purposes:

• To offer you the functionalities of the Website and for the technical and functional management thereof: We strive to make our Website easily accessible and to offer you the best possible experience and functionalities. We process technical data of everyone who visits and uses our Website in order to manage it and improve its performance. We may also need to process your personal data so that you can save your data (or preferences) to configure your device to give you a personalized experience. The functionalities of the Website are largely made available through the use of functional cookies. You can read more about our use of cookies in our Cookie Policy.

• For relationship management and marketing: Senseful Mind uses the information in the contractual relationships database to send you updates you on developments within Senseful Mind. We also may use your personal data for the development, execution and analysis of market research and marketing strategies.

• To book a discovery session through the Website: Engaging in a discovery session is required in order to enter into any agreement with Senseful Mind. You can book the discovery session directly through the Website by filling out a form providing personal data. 

• To offer all of our coaching services: Our services are of a personal nature. As a result, all of the details, stories, and information you share regarding yourself is considered to be personal data. Depending on what you share, this may include highly sensitive personal data such as health or medical information. You are never required to disclose any personal data you are uncomfortable sharing. Participation in the services is completely voluntary and may be canceled at any time in accordance with the applicable Terms of Service.

• To provide client support: We want to offer you the best experience possible when using our services and Website. Therefore, we are ready to handle any questions or complaints you might have. When you get in touch with us at our office, via social media, via a contact form, or in any other way, we will use your personal data in order to reply to you, answer your question, or handle your complaint.

• To process your payment: In order to use our services, you will need to enter into an agreement for payment thereof. We will process your payment data in order to handle the payments, and for administrative purposes such as sending you invoices or refunds.

 

Legal bases for collecting your personal data

The legal basis we have in order to collect your personal data will depend on the type of data collected. In any case, it will be either of the following:

• We need to perform our obligations under a contract with you

• You have given us explicit consent

• It is in our legitimate business interest

• To comply with our legal obligations

 

Which personal data do we collect?

We collect the following types of personal data:

• Identifiers such as your first and last name and IP address;

• Contact details such as your phone number, email address and address;

• Financial details such as your payment method, bank details, card details, and payment history;

• Internet or other electronic network activity such as the device you use and the usage of our Website;

• Geolocation data such as your physical location; and

• Other data such as any personal details you choose to disclose in any coaching session or otherwise. This may include sensitive personal data such as:

  • your racial or ethnic origin;

  • your political opinions;

  • your religious beliefs;

  • your physical or mental health condition; or

  • your sexual life.

 

How long do we retain your personal data?

Your personal data will be retained by us for as long as necessary to serve the legitimate

business purposes as set out above. We may need to retain personal data longer to comply with applicable laws, such as those relating to tax and accounting. If there is no ongoing interest in retaining your personal data, we will promptly delete or anonymize it where possible.

 

Which parties have access to your personal data?

Within Senseful Mind, our employees, contractors, agents and directors have access to personal data, but only to the extent necessary to properly perform their individual tasks.

 

Senseful Mind only shares personal information with third parties if it is necessary to serve the applicable purpose as set out above. When a third party processes your personal data, this is only possible according to the instructions of Senseful Mind. They therefore act as our data processor. In all cases, we will ensure that third parties with access to your personal information have implemented appropriate technical and organizational measures to maintain our intended level of privacy and security. We will conclude the necessary agreement with the data processor(s), whereby we include obligations to ensure that your personal data is only processed so that the data processor can fulfil his duty to provide services to us.

 

Under these conditions, the following third parties will have access to your personal data. Please click on the relevant links to review their respective privacy policies:

• Information regarding your use of the website and other information gathered through cookies is shared with web analytics, session recording, and online marketing services. Read more about the use of cookies in our Cookie Policy.

• Microsoft 365 is used for emailing and client relation management and to set up our online sessions.

• Wix is used as our Website provider and hosting service. They will get access to your IP address

• Moneybird is used as our online accounting tool.

• We may have professional advisors such as insurers, accountants, consultants, and legal professionals.

• As indicated in our coaching agreement with you, we are engaged in training and continuing education pursuing and/or maintaining International Coach Federation (ICF) Credentials. That process requires the names and contact information of all clients for possible verification by ICF. No personal notes will be shared with the ICF.

 

In all other cases, your personal information will not be provided to third parties, unless required by law. Senseful Mind will never sell your personal data.

 

Transfer of your personal information

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

 

Whenever we transfer your personal data to countries outside of the European Economic Area (EEA), we will do so in accordance with the GDPR. Any party located outside of the EEA will have to enter into the EU Standard Contractual Clauses alongside any data processing agreement they enter into.

 

Security

Your personal information is stored securely at all times. We value the protection of your privacy. We have taken strong security measures to protect your data from loss, misuse, unauthorized access, disclosure, alteration, or destruction. We further ensure that personal data is only accessible to those specific persons who are authorized based on their function.

 

We only select the third-party IT-service providers that have proper security facilities in place. In addition, we have implemented measures to guarantee your safe visit to and use of our Website. This way we prevent misuse of your data. These measures include computer security and protected files and facilities. Your connection to our Website is safe through activation of Secure Socket Layer (SSL). A firewall is enabled at all times. All critical interfaces and functions are only accessible through TLS v1.2.

 

Notes taken during sessions are stored with the highest level of security possible. They are saved with two-step authentication required for any access. The device on which the notes are stored is furthermore secured through password and fingerprint protection.

 

Senseful Mind has taken the necessary technical and organizational measures to prevent, identify, report and deal with data protection breaches. However, in the event that a data breach occurs, Senseful Mind will, without undue delay and where possible, not later than 72 hours after being notified, report the breach of personal data to the relevant Data Protection Authority.

 

Your rights

As the owner of the personal data, you have the following rights:

• Right of access: You have the right to receive a copy of the personal information we hold about you to verify that we are lawfully processing the data.

• Right to correction: You may request any incomplete or incorrect information that we may have about you to be corrected or supplemented.

• Right to be "forgotten": If there is no good reason to keep your personal information, we will stop processing. You also have the right to ask us to delete your personal information.

• Right to limit the processing of your personal data: You can submit a request not to process your personal data, either temporarily or permanently.

• Right to portability: You can submit a request to transfer your personal data to a person or institution designated by you.

• Right to object to processing: Under certain circumstances you can object to the processing of personal data altogether.

• Right to withdraw consent: You also have the right to withdraw your previously granted permission to process your personal data or to object to the processing of your personal data by Senseful Mind.

 

Every request is subject to applicable law, which means that we may have to store the personal information. We also want to remind you that you have the right to make a complaint to your national Data Protection Authority if you think we are not compliant with the applicable data protection legislation.

 

If you want to exercise any of your rights as set out above, you can do so here at any time:

Senseful Mind: elena@sensefulmind.com

 

Minors

We insist on not processing any personal data of children under the age of 16, unless this is explicitly consented to by a parent or legal guardian. However, as it is hard to detect whether we are doing so, we strongly encourage you to inform us if you have reason to believe we process the personal data of a minor. We will delete this personal data instantly.

 

External Links

Our Website may display links to other websites. Unless these other websites are affiliated with Senseful Mind, we are not responsible for the privacy policies that these other websites use, nor for their content and security. We advise you to inform yourself by reading the privacy policies on these websites.

 

Questions or comments?

If you still have questions after reading this Privacy Policy or if you have suggestions or comments about its content, you can always contact us via: elena@sensefulmind.com

 

Please let us know if, for any reason, you believe we have not adhered to the principles in this Privacy Policy. We will do our best to promptly make corrections.