Commencement date: 5th of December 2021
Your privacy is of great importance to Marieke Zwinkels (‘mariekezwinkels.com, ‘us’). Your details are safe with us and we will always use those details properly, in keeping with the relevant legislation and regulations on privacy, including the General Data Protection Regulation (‘GDPR’).
This privacy statement sets out what we do with the information that we obtain about you. Specifically the types of information we collect about you when you use the website ‘www.mariekezwinkels.com’ (‘Website’) or our Material (paid or free of charge) and how we use that information.
If you have any questions or if you would like to know exactly what personal data we gather, please contact Marieke Zwinkels. We can always be reached at firstname.lastname@example.org.
Capitalised words in this privacy statement have the same definition as those in the General Terms. We refer you to Article 1 of those General Terms for a more detailed description of the definitions.
WHICH DATA DO WE COLLECT?
When you enter into a Contract with us, place an order on our Website, create an account, have access to the Online Learning Environment, subscribe to one or more newsletters or programmes, when you fill out a form or enter answers, we may process one or more items of personal data such as your name, company name, email address, postal address, invoicing address, bank account details or other payment information, a portrait and/or alias or IP address.
We get most of this information because you give it to us yourself. For example, when creating an account, you will enter your name, address and email. You provide us with other personal data by using our services. It should be noted that you can always visit the Website anonymously.
WHAT ARE THE GROUNDS FOR PROCESSING YOUR PERSONAL DATA?
> Performance of the contract: if you enter into a Contract with us, purchase Materials or otherwise participate in a programme or place an order, there is a contract between us. In order to give you access to those free Materials and to be able to fulfil our agreements under the Contract, we need your details.
> Consent: in some cases you give us your consent to process your details. The conditions attached to that can be found on the website of the Dutch Data Protection Authority. In any event, we will keep a log of your consent and you can revoke your consent at any time.
> Legitimate interest: we may have a compelling interest in processing your personal data. Thus your interests and our interests will always have to be weighed up.
WHAT DO WE USE YOUR DATA FOR?
The data we collect about you may be used for the following purposes:
When you enter into a Contract with us, purchase Materials or otherwise participate in a programme or place an order, we will use your personal data to handle the above properly, i.e. to provide the correct Materials, to inform you about the Materials, make appointments for coaching sessions or to process payments.
To do so, we may process your name and address details, invoice address, email address, payment details, order details and/or IP address. We do that so that we can carry out our Contract with you. We will save this data until your Contract, access to the Materials, programme or order has been completed. We may keep some data for longer because of the tax retention obligation, or – in case of any dispute about the fulfilment of our obligations – until an irrevocable decision has been reached or the limitation period has expired.
Account and Online Learning Environment
Some elements of our services require you to first register through an account and that personal account then gives you access to our Online Learning Environment.
We use your name and address details, your email address, your IP address and/or your order details for this. We need those details to carry out our Contract with you. We store this information until you delete your account. You may change the information through your account whenever you wish.
In the following cases we will delete your account ourselves:
> If you do not use your account or do not log onto the Online Learning Environment for six months;
> If you unsubscribe from the mailing list that forms part of the Material under the Contract;
That means that you will no longer have access to the Online Learning Environment. The reason is that we want to minimise the processing of personal data and we do not want to process your details for a longer than necessary. Naturally you can always ask us to create a new account for you and to put the previously purchased Materials back in your Online Learning Environment. Article 156 of our General Terms has more information about this.
Functionalities in the Online Learning Environment
The Online Learning Environment offers us and our Customers various functionalities such as bulletin boards, weblogs, chatrooms and email services with which we can contact each other or you can contact other Customers. These functionalities allow you to send messages, publish posts or other materials, for example. If you use these, we may process the personal data belonging to your account. We may also use your photo (for example, if you use a Gravatar) or alias.
We offer these functionalities as part of our Contract and we process your details to fulfil our obligation under the Contract. You are free to choose not to use one or more of these functionalities, simply by not actively sharing messages, posts or other materials. In that case, we will not process data for the above purposes.
The data that we process through these functionalities is retained indefinitely. We have a legitimate interest in doing so, because these functionalities are part of the use of the Materials and programmes by other Customers. However, you and we both have the right to remove your message, post or other materials.
We use two types of newsletter and we will explain which personal details we process for each below.
Firstly, we use a separate newsletter for each Material:
> If you enter into a Contract with us or if we give you access to our Online Learning Environment, you will automatically be added to the mailing list the relevant Material(s).
> To be able to send those newsletters, we process your name and email address.
> We will store those details until you unsubscribe from the newsletter(s).
> We process your details because we have a legitimate interest in doing so – the newsletter is used to inform you about everything connected to changes to your Material or the Contract, including how we provide the Material or any amendments of the General Terms.
> You can unsubscribe from the newsletter(s) at any time. Each newsletter includes an unsubscribe link.
> Please note: unsubscribing from the newsletter(s) is at your own risk and expense, because unsubscribing from the newsletter means that we assume you wish to delete your account. Incidentally it is always possible to re-subscribe. Articles 2.4 and 15.5 of our General Terms have more information about this.
In addition, we also have a general newsletter:
> You are not automatically registered for this newsletter, you can only do that yourself through our Website.
> We will store those details until you unsubscribe from the newsletter.
> We do that based on your consent, which you may revoke at any time.
> The general newsletter is distributed without any fixed regularity and is sent by email. The newsletter has news, tips and information about new Materials, provides an overview of our calendar, etc.
> You can unsubscribe from the newsletter at any time. Each newsletter has an unsubscribe link. Because we provide our general information in a separate newsletter, you can always opt to only unsubscribe from the general newsletter but retain the Material-specific newsletter(s).
DO WE GIVE YOUR PERSONAL DATA TO THIRD PARTIES?
In no way do we sell, exchange or provide your personal details, unless we are legally obligated to do so (for example when demanded by the police in a suspected crime).
There are third parties involved at Marieke Zwinkels who help us to make the Website operational, to carry out the programmes, to provide the related financial matters concerning Marieke Zwinkels or otherwise provide our Materials and/or fulfil the Contracts. Examples include website construction/hosting, WordPress, our marketing advisor who has access to the data collected using the advertising cookies, the tax advisor, providers of the software we use, payment services such as iDEAL, etc. Where necessary, we enter into processing agreements with these third parties.
We try to have your personal data processed within the EEA as far as possible. In addition it is our aim to work as much as we can with parties – whether processors or controllers – who also seek to reduce cross-border flows of personal details. However in some cases your personal data may be processed by third parties outside the EEA. In that case also we will ensure that that complies with the requirements set by law.
Cookies are small files in which we can store information so that you do not need to keep filling it out. But they also allow us to see that you are visiting us again. For an overview of the different types of cookies and information on current legislation, we refer you to the Netherlands Authority for Consumers & Markets and ACM ConsuWijzer websites.
Enabling and disabling cookies
When you visit our Website, only essential cookies are enabled. Those are cookies that ensure our Website does what it should. These cookies cannot be disabled for the simple reason that our Website would not function properly without them.
We may also use functional and analytical cookies to optimise your use of the Website, to measure Website visits and to examine and subsequently improve our Website’s functionality. In any event we use advertising cookies to be able to make as targeted and personalised offers as possible. All these non-essential cookies will only be used with your consent. You can indicate your consent on the cookie banner that pops us when you visit the Website and we log that consent.
If you do not wish to consent to functional, analytical and advertising cookies, that is not a problem. You are still very welcome on our Website! Have you given consent? You can revoke it at any time. At the bottom right of the Website, you will find a ‘cookie settings’ button with which you can change or reject your cookie settings in one go, with the exception of essential cookies of course. You can also remove all previously placed cookies through your browser. The website veiliginternetten.nl explains exactly how to do that.
The Website contains links to our social media profiles, including Instagram, Facebook and YouTube buttons. If you use those profiles, the administrators of these services may collect your personal data. If you wish to know more, please read these parties’ privacy statement carefully.
Facebook Pixel and Conversion API
We use two Facebook products – Facebook Pixel and Facebook Conversion API.
HOW DO WE PROTECT YOUR DATA?
The protection of personal data is very important to us. We ensure that your data is properly secured with us. To that end, we take both technical and organisation measures. We continuously change our security, if necessary because of changes to legislation, for example. We also look carefully at what could go wrong so that we can take appropriate measures to keep your personal data secure.
Below are a few, non-exhaustive, examples of the measures we take to protect your data:
> we make sure that as less people as possible have access to your data;
> we use the protected, secure server from Antagonist;
> all sensitive information is sent using Secure Socket Layer technology (SSL);
> we use the required certificates to protect your stored data; and
> your payment details and payments are made securely through the reliable parties Mollie and Moneybird.
HOW CAN WE CHANGE THIS PRIVACY STATEMENT?
When the Company or our activities change, we obviously need to amend the privacy statement as well. Please always note the date above and regularly check if there are new versions. We will do our best to inform you of any changes.
WHAT ARE YOUR RIGHTS?
If you have any questions or want to know which of your personal data we have, you can always get in touch. In any event, you have the following rights:
> To be given an explanation of which personal data we have and what we do with it;
> Access to the specific personal data that we have about you;
> To have errors corrected;
> To have outdated personal data deleted;
> To have your personal data transferred to another party;
> To revoke your consent;
> To restrict a certain form of processing;
> To object to a certain use.
Van deze rechten kun je in ieder geval op de volgende manieren gebruik maken:
> Newsletters: each email of every separate list to which you are subscribed contains an unsubscribe button and a button to view or change your personal details. As soon as you have been unsubscribed from all email lists and you no longer follow any programme (paid or free), your data will be deleted in full.
> Account: you can view or change all your data on your account page. You can also terminate your account.
> Programmes: you can view all your purchases on your account page. You can also terminate your account.
> Payment details: you can view, change or delete your payment details by sending an email to email@example.com indicating what you want done. You will get an overview of the data you stored, alternatively your data will be changed or deleted, depending on the request you sent in your email.
Please be sure to indicate clearly who you are, so that we know for certain that we do not change or delete the data of the wrong person.
In principle we will comply with your request within a month. That term may be extended for reasons connected with the specific rights of the parties involved or the complexity of the request. If we extend the term, we will inform you promptly.
DO YOU HAVE A COMPLAINT, QUESTION OR CONCERN?
If you have a complaint, question or concern, please let us know through firstname.lastname@example.org. We will handle every complaint internally and discuss this with you further.
If you have a complaint about how we handle your personal data, you may file a complaint with the Dutch Data Protection Authority. Follow the instructions on the Dutch Data Protection Authority’s webpage accessible through this link: https://autoriteitpersoonsgegevens.nl/nl/zelf-doen/gebruik-uw-privacyrechten/klacht-over-gebruik-persoonsgegevens
WHAT ARE OUR PERSONAL DETAILS?
Company data (for information purposes)
Marieke Zwinkels h.o.d.n. Marieke Zwinkels
Lachappellestraat 53 C
4816 AJ Breda
KvK nummer: 54965349