Website Privacy Notice

Short version

The Positive Culture Academy is committed to protecting the privacy and security of your visits to this website. Personal information will be treated confidentially and will never be sold to third parties.

The Positive Culture Academy will use your data for the purpose of rendering the following services:
The email address you fill in to receive updates on positive culture and leadership will only be used for the services as agreed. We will update you via our mailing list about our blog posts and about our offerings.
In order to enroll in The Positive Culture Academy online classes, we need your complete contact details. We’ll only use these to provide a correct invoice, to create your login details to access our online classes and to reach you with updates, other offers, and advice.

We do nothing else with your contact details. Your personal information is safe with The Positive Culture Academy.
We appreciate your trust and confidence in The Positive Culture Academy and will, therefore, underscore our commitment to protect your privacy.

Extended Privacy Notice

1. INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data through your use of our site https://www.positive-culture.com including any information you may provide through our site when you purchase a product or service, and/or sign up to our newsletter.

By providing us with your data, you warrant to us that you are over 13 years of age.

The Positive Culture Academy, belonging to the company registered as Kikker Groep, owned by Marcel Lamers and Marcella Bremer, is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

Contact Details
Full name of legal entity: Kikker Groep V.O.F.
Email address
Postal address: Vrouwenlaan 106, 8017 HS, Zwolle, The Netherlands

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Dutch supervisory authority for data protection issues (https://autoriteitpersoonsgegevens.nl/en/node/1930). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you. It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us.

2. WHAT DATA DO WE COLLECT ABOUT YOU

Personal data means any information capable of identifying an individual. It does not include anonymized data. We may process certain types of personal data about you as follows:

• Identity Data may include your first name, last name, username.
• Contact Data may include your billing address, delivery address, email address and/or telephone numbers.
• Transaction Data may include details about payments between us and other details of purchases made by you.
• Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
• Profile Data may include your username and password, purchases or orders, your feedback and your progress in the Academy (completing modules) and test responses after each module.
• Usage Data may include information about how you use our website, products and services.
• Marketing and Communications Data may include your preferences in receiving marketing communications from us and your communication preferences.
We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.

Sensitive Data

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

3. HOW WE COLLECT YOUR PERSONAL DATA

We collect data about you through a variety of different methods including:

• Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
• order our products or services;
• create an account on our site;
• subscribe to our service or publications;
• request resources or marketing be sent to you;
• give us feedback.
• Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies.

• Third parties: We may receive personal data about you from various third parties as set out below:

• Technical Data from the following parties: KnownHost (outside the EU but GDPR compliant).

• Analytics providers such as Google based outside the EU;

• Contact and Transaction Data from providers of payment and delivery services such as the online payment intermediaries PayPal, Ogone, Stripe, and Quaderno (all with offices inside and outside the EU), and the email delivery service ActiveCampaign (outside the EU but GDPR compliant).

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when legally permitted. The most common uses of your personal data are:

• Where we need to perform the contract between us.
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us or by following the UNSUBSCRIBE link at the bottom of all our emailings.

Purposes for processing your personal data

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

We specify the Purpose/Activity, in the next line(s) the Type of data, in the last line the Lawful basis for processing:

To register you as a new customer
(a) Identity
(b) Contact
Performance of a contract with you

To enable your access to the Positive Culture Academy as a student
(a) Identity
(b) Contact
(c) Technical
(d) Usage
Performance of a contract with you or your employer, contractor, consultant or other party who asked you to join the Positive Culture Academy

To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Transaction
(d) Marketing and Communications
Performance of a contract with you, and/or Necessary for our legitimate interests to recover debts owed to us

To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy, and/or Asking you to leave a review
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
Performance of a contract with you, and/or Necessary to comply with a legal obligation, and/or Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services

To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise, and/or Necessary to comply with a legal obligation

To deliver relevant content to you and measure and understand the effectiveness of our communications
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy

To make suggestions and recommendations to you about goods or services that may be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests to develop our products/services and grow our business

Data collection when you follow courses in the Positive Culture Academy

The Positive Culture Academy is committed to protecting the privacy and security of your visits to this website. Personal information will be treated confidentially. We will not sell personal information to third parties.
The Positive Culture Academy will use your data to measure your progress in the curriculum.
* The system will record your progress in watching the video lectures.
* The system will record your responses to the quizz after each module.
* We will assess the assignments and answers that you submit to us, either in the dialogue group or by email or uploading your assignments.

Marketing communications

You will receive marketing communications from us if you subscribed to our mailing list and thus:

(i) requested information from us or purchased goods or services from us; or
(ii) ticked the box at the point of entry of your details for us to send you marketing communications; and
(iii) in each case, you have not opted out of receiving that marketing.

We will not share your personal data with any third party for marketing purposes. You can ask us to stop sending you marketing messages at any time by following the UNSUBSCRIBE link at the bottom of all our emailings. Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us. If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing. We may process your personal data without your knowledge or consent where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the Netherlands and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria. Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
• Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
• Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

You can read more about these rights in English at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
Dutch speakers, please read more at: https://autoriteitpersoonsgegevens.nl/nl
If you wish to exercise any of the rights set out above, please email us.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

11. COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
We use cookies to better understand how our visitors use our site, to improve its value, and to customize your experience. Our cookies contain personally identifiable information.

If you have any questions about our Privacy Policy, please send us an email via the contact form . If you wish to access information or request the correction of any inaccurate information collected from you through this website, our client services department is here to help you.

We may revise this online Privacy Policy from time to time. If we make any changes, we will notify you by posting those changes to this privacy statement.

Latest revision: August, 2018

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