2. When I say ‘Sevenbirds’ or ‘I’ it’s because I own and run this business and website.
The type of personal information Sevenbirds collects
4. I collect certain personal information about my clients as well as the visitors of the Sevenbirds’ website.
5. The most common types of information I collect include:
- First and last name
- email addresses
- telephone numbers
- mail addresses
- transactional details
- information you give about yourself during coaching processes (think of personal about yourself and your situation, maybe CV, etc.)
- information you give about yourself when filling in diagnostic instruments (think of personal characteristics, preferences and traits)
- information you give about yourself during an assessment center (think of CV and interview)
- survey responses (e.g. evaluation questionnaire)
- testimonials about Sevenbirds
- IP addresses and other web analytics data
How Sevenbirds collects personal information
6. I collect personal information directly when you provide it to me, through other people (e.g. HR responsible, line manager), or automatically as you navigate through the website.
7. I collect your personal information when you provide it
- when contacting me regarding my services
- when agreeing to a coaching or assessment contract
- when working with me during a coaching process (one on one, coaching programs, workshops)
- when using diagnostic instruments (e.g. Myers-Briggs Type Indicator®, BIP)
- during an assessment center
- when filling out a survey
- when sending me an email, letter, short message, etc.
How Sevenbirds uses personal information
8. I use your personal information:
- to fulfil the contract we have and to deliver the related services
- where this is necessary for purposes which are in Sevenbirds’ legitimate interests. These interests include:
– providing you with services described on Sevenbirds’ website
– managing my relationship with you, e.g. by responding to your comments or queries submitted to me per email or asking for your feedback
– managing Sevenbirds’ legal and operational affairs
– improving Sevenbirds’ services
– providing general administrative and performance functions and activities
– operating the Sevenbirds website
- for purposes which are required by law
- for responding to requests by government, a court of law, or law enforcement authorities conducting an investigation
When Sevenbirds discloses your personal information
9. I will disclose personal information to the following recipients:
- subcontractors and service providers who assist Sevenbirds in connection in providing its services, in particular: website hosting provider which is located in Germany; mobile phone cloud which is located in the US; and service providers who I use to provide diagnostic services which are located in Germany, the Netherlands, and UK; other coaches, consultants, trainers I work with to deliver my services who are located in the Netherlands and Germany
- my professional advisers (lawyers, accountants, financial advisers etc.) which are located in the Netherlands
- regulators and government authorities in connection with compliance procedures and obligations
- a third party to respond to requests relating to a criminal investigation or alleged or suspected illegal activity
- a third party in order to enforce or defend Sevenbirds’ rights, or to address financial or reputational risks
- other recipients where I am authorized or required by law to do so.
Where Sevenbirds stores and/or transfers your personal information
10. Sevenbirds is based in then Netherlands so your data will be mainly processed locally in the Netherlands. Some of the recipients I have mentioned in section 9 above, and to whom I disclose your personal information, are based outside the Netherlands in places like Germany, UK, and US. I do this based on your consent to this policy. To protect your information, I take care where possible to work with subcontractors and service providers who I believe maintain an acceptable standard of data security compliance.
How long Sevenbirds keeps your personal information
11. I retain your personal information for as long as is necessary to provide the services to you and others, and to comply with legal obligations.
12. In line with the Dutch regulations, I need to keep my administration for seven years. This means that a copy of contracts and invoices I send you will stay in my system for seven years. Probably longer, since it’s a part of my business administration paperwork.
13. If requested by you, I delete all my notes and working documents after a coaching process or assessment center is finished.
How Sevenbirds keeps your personal information secure
14. I store personal information on locally on secured hard drives, and occasionally hard copy files that are kept in a secure location in the Netherlands. Personal information that I store or transmit is protected by security and access controls, including username and password authentication and data encryption where appropriate.
How you can access your personal information
15. You have the right to make a request to receive the personal information I hold about you and to request corrections of any errors in that data. To make an access or correction request, please contact me per email.
16. You can also request to delete your personal information. Due to Dutch regulations, I need to keep some information for a certain amount of time (see #11).
What about cookies and web analytics
18. My website is hosted with Hetzner Online AG in Germany. The information you enter through my website lives, within my sites database, on their servers in Germany and Finnland. The host also automatically collects and saves information in so-called server log files, which your browser automatically transmits. These are:
- IP address
- Operating system
- Referrer URL
- Time of server request
- Pages visited
- Duration of visit
This data cannot be attributed to specific people. This data is not merged with other data sources. Sevenbirds reserves the right to check these data at a later date, if I am aware of any concrete indications for unlawful use.
19. If you feel that my compliance with privacy legislation is not correct, please let me know so I can fix it. If you are not happy with my response, you have every right to complain, the official body to do so in The Netherlands is the “Autoriteit Persoonsgegevens”.