PRIVACY POLICY

PRIVACY POLICY FOR KIM CUPPING, OWNER TRANSFORMATIONAL CUPPING

General, Kim Cupping OÜ
Thank you for reading this document. Because we would like to inform you how your (personal) data are processed and/or used by us. In this way, we comply with our obligations under the General Data Protection Regulation (AVG) and the Telecommunications Act.

This statement applies exclusively to the services provided by Kim Cupping OÜ. Therefore, please be aware that we are not responsible for the privacy and/or cookie policies of any listed other organisations and companies on the website www.transformationalcupping.com (hereinafter: the website).

Kim Cupping OÜ is based in Talinn, Estonia and is registered there under number EE102368747. Do you have questions about privacy and the protection of your (personal) data? If so, please contact us at kim@kimcupping.com.

Use of (personal) data
On the website, you can leave your (company) (personal) data. As a (possible future) customer, we also collect a number of your (personal) data. It is good that you are aware of what is done with these (personal) data, which rights you have and how you can indicate your wishes regarding your (personal) data.

We respect the privacy of all our customers, stakeholders and website users. This means that the (personal) data we receive from you is treated confidentially so that it does not fall into the wrong hands. It sometimes happens that your (personal) data are shared with others, because they support our business operations. Think for example of the bank or hosting party.

Personal data we may collect.
Below is an overview of the (personal) data we may process about you:
o your first and/or last name;
o your address and/or PO Box details;
o your company name & Chamber of Commerce number;
o your e-mail address and e-mail messages;
o your payment details;
o your date of birth;
o your social media account names;
o Your reactions on social media;

The above details you have given yourself or can be deduced from public records or social media.

Why is processing personal data necessary?
Processing personal data is not just allowed. To do so, we must have defined purposes, which we have done. For example, we may process personal data about you because you provide this personal data yourself (e.g. by filling in the contact form). Those purposes of the aforementioned processing of the personal data we collect must be justified. The AVG therefore establishes six bases:
1. the public interest;
2. legitimate interest;
3. vital interests;
4. on the basis of an agreement;
5. on the basis of a legal duty;
6. by consent.

Privacy&cookie statement
Kim Cupping OÜ
Version 1.2. 10 August 2023

Target

Basis

  1. For handling your payment

Because it is necessary for the performance of an agreement

  1. To be able to contact you (by phone, in writing, e-mail) as necessary to carry out our services

Because it is necessary for the performance of an agreement

  1. To process your (information) request

Because there is a legitimate interest in doing so

  1. To answer your question (online)

Because it is necessary for the performance of an agreement

  1. To refine the offer and make a more targeted offer

Because there is a legitimate interest in doing so

  1. In the event of a legal obligation, such as tax returns

For complying with a legal obligation

Special and/or sensitive personal data
We do not process sensitive personal data of customers, data subjects or website visitors other than as indicated in this statement. We do not intend to collect data on website visitors who are under the age of 18, unless they have parental or guardian consent. However, we cannot always verify whether a visitor is over 18. If you are convinced that we have collected personal data on a minor without consent, please contact us and we will delete this information. We do collect your health data in some cases. These are special personal data. We need them to form a good picture of your complaints and adjust treatment accordingly. You have given permission for this.

How long your data is kept
We do not retain your personal data for longer than is strictly necessary to fulfil the purposes for which the data is collected. We use the following retention periods:

Personal data

Term

Reason

First name and surname

7 years (Tax law) 

To meet legal obligation

Address and/or post office box details

7 years (Tax law)

To meet legal obligation

Phone number

As long as the agreement runs

To be able to contact you

Payment details

7 years (Tax law)

To meet legal obligation

Mail address 

As long as the agreement is in place and for up to 1 year after our agreement ends 

To inform or contact you after filling in an online contact form

(Mail) messages

For as long as the agreement runs and for up to 1 year after our agreement ends.

To retrieve data from you

Health data

As long as our agreement is in place

Necessary for the performance of the agreement

Reaction on social media

Indefinite time

When you comment on an article, the comment remains as long as the article is online. This is indefinitely, unless you decide that your comment should be deleted. When a comment is deleted, all personal data is removed. Nothing is done with the comments received, which we regard as enthusiastic involvement 

Social media account names

Indefinitely, unless you delete this data yourself

To respond to your comments on social media accounts

Other personal data you actively provide

For as long as the agreement runs and for up to 1 year after our agreement ends.

Necessary for the performance of the agreement

 

Sharing data with third parties/others
Your data will not be sold to third parties and your information will only be provided if this is necessary for the execution of the agreement with you, because you have given your consent or to comply with a legal obligation. With companies that process data on our behalf (processors), we conclude a processing agreement to ensure the same level of security and confidentiality of your data. However, we remain responsible for these processing operations. We do not need to enter into an agreement with third parties who are themselves responsible for processing (processors).

We share personal data with the following third parties:

Third

Category

Share target

Which data

Hosting party Dlogic

Processor

For backing up the website

Full website backup

Website provider Dlogic

Processor

To host the website

Encrypted data

Email provider Dlogic webmail

Processor

For hosting e-mails

Encrypted data

Bank Wise

Controller

To generate payments for me

Bank account number, (company) name, address details, mail address

Accountant

Processor

To assist me with accounting

Bank account number, (company) name, address details, mail address

Transfer to third countries
We try to process personal data as much as possible within the EEA, but sometimes we cannot avoid using services from outside the EEA. These companies are based in an appropriate country designated by the European Commission. A processor agreement has been concluded with all processors, inside and outside the EEA. In any case, the Parties adhere to the 'Privacy Shield principles' and are members of the US Department of Commerce's Privacy Shield programme. This means that there is an adequate level of protection for the processing of any personal data.

Your right to view, amend or delete data
You have the right to access, correct or delete your personal data. You can e-mail such requests to kim@kimcupping.com. We will respond to your request as soon as possible, but in any case within one month. If your request is disproportionate or very specific, the period may be extended by two months. Your rights to withdraw, object and data portability You have the right to withdraw your possible consent to data processing or object to the processing of your personal data by me and you have the right to data portability. This means that you can make a request to send your personal data in a computer file to you or another organisation named by you.

Secure
We take the protection of your data seriously. Therefore, we take adequate and appropriate measures to prevent, for example, misuse, loss, unauthorised access, unwanted disclosure and unauthorised modification, including physical, administrative, organisational and technical measures. No physical copies of your personal data are made. For example, the website uses a reliable SSL Certificate to ensure that your personal data do not fall into the wrong hands. This also means that your connection to the website is private. You can tell this by the 'https' address bar and the padlock in the address bar.

Furthermore, we always use only known secure Wifi networks, unless this is not possible for weighty reasons. Website security is regularly updated and there is an anti-virus system on incoming and outgoing e-mails. The number of devices that can access your data is limited to only the necessary ones. These are a laptop and smartphone with login security by password and/or access code and/or fingerprint. In addition, the systems used are also all secured with a password and/or access code and/or fingerprint. No proper security or misuse of your data? If you have the impression that your data is not properly secured or there are indications of misuse, or if you would like more information about the security of personal data, please contact us at kim@kimcupping.com.

Your right to file a complaint
Please note that you have the option to lodge a complaint with the national supervisory authority if you believe that we are not complying with the privacy regulations referred to in the AVG. The national regulator is the Personal Data Authority. You can submit a complaint here.  

Changes
Website texts may be modified at any time due to ongoing developments. This also applies to this privacy statement. This version is dated 10 August 2023 and if there are changes to the privacy statement, we will always post the latest version on the website. If changes directly affect you, we will inform you directly as much as possible.

Cookies
The website uses various cookies. By having this cookie declaration, we not only comply with the obligations of the Telecommunications Act & Cookie Act (future e-Privacy Regulation), but you also know exactly how to deal with these cookies.

What is a cookie
A cookie is a small text file that is stored on your computer, tablet or smartphone the first time you visit the website. Cookies ensure in particular that the website works properly. For example, cookies remember your settings and cookies also allow the website to be optimised. Functional and social media-related tracking cookies. The website uses functional cookies and social media-related tracking cookies that do not infringe your privacy. When setting the functional cookies, no permission needs to be requested from you. When setting the social media related tracking cookies, we ask for your permission. The website does not use any other cookies.

Permanent cookie
A permanent cookie allows the website to recognise you when you visit the website again. This is a so-called functional cookie. It allows the website to be tailored to your preferences. Even if you have given permission for cookies to be placed, the website can remember this by means of a cookie. This saves you having to repeat your preferences, which saves time and makes the website more pleasant to use. Permanent cookies can be removed via your browser settings.

Session cookie
A session cookie allows us to see which parts of the website you have viewed with this visit. This is a so-called functional cookie. It allows the website to be tailored to your preferences. This enables us to adapt our service as much as possible to the surfing behaviour of visitors. These cookies are automatically deleted as soon as you close your web browser.

Social media related tracking cookie
Social media-related tracking cookies such as social media pixels, track website visits in order to build a profile of website visitors. They do this via the buttons Instagram and Facebook place on your device.

Google reCAPTCHA
In addition, the website uses Google reCAPTCHA. First, reCAPTCHA checks whether a Google cookie has already been set on the computer. It then adds a cookie to your browser and takes a full snapshot of the browser window. Each pixel is captured in the process. For proper analysis, Google collects browser and user information and this includes:

  • All cookies that Google has placed on your system in the last 6 months;
  • How many mouse clicks you make (or tap if on a touch device) in the browser window;
  • Your scrolling behaviour 
  • The CSS of the web page
  • The system date and time;
  • IP address;
  • Whether you are currently logged into your Google account;
  • The set language of your browser;
  • All add-ons installed in your browser;
  • All Javascript objects;
  • The speed with which you fill in the form.

The information collected by Google is transferred to and stored by the parties on servers in the United States. They claim to adhere to the 'Privacy Shield principles' and are members of the US Department of Commerce's Privacy Shield programme. This implies (again) an adequate level of protection for the processing of any personal data. We have not allowed Google to use the information obtained through the website for other (Google) services. The retention period is 26 months and we have no influence on this. You can read more about this in Google Analytics' privacy policy.

Refusing, blocking and deleting cookies
You can refuse cookies, you can block cookies and you can opt out of cookies. You do this by configuring your internet browser to stop storing cookies. You can always easily block and delete cookies via your internet browser. You can also set your internet browser to notify you when a cookie is placed. You can also indicate that certain cookies may not be placed. Check the help function of your browser for these options. Because how you can adjust the settings varies from one browser to another. If necessary, consult your browser's help function or click one of the links below to go directly to your browser manual.

o Google Chrome: https://support.google.com/chrome/answer/95647?co=GENIE.Platform=Desktop&hl=nl
o Internet Explorer: https://support.microsoft.com/nl-nl/kb/278835
o Safari on smart phone: https://support.apple.com/nl-nl/HT201265
o Safari on Mac: https://support.apple.com/nl-be/guide/safari/sfri11471/mac

Please note that deleting cookies in your browser may affect your enjoyment of this website. So please be aware that if you do not want cookies, we cannot guarantee that the website will work completely properly. Some functions of the site may be lost or you may not be able to visit the website at all. Also, refusing cookies does not mean that you will no longer see any advertisements at all. The
ads are then just no longer tailored to your interests and they may therefore be repeated more often. Some tracking cookies are set by third parties that display ads to you, among other things, via website tracking.

Unforeseen cookies
Cookies may also be set via the websites by others, of which we are not always aware. Do you come across unforeseen cookies that you cannot find in the overview? Please let us know by e-mail. You can also contact the third party directly and ask what cookies they set, what the reason for this is, what the cookie's lifespan is and in what way they have guaranteed your privacy.

Opt-out
About the use of the above cookies, consent is requested on the website (where necessary). If you do not want your data to be tracked, we recommend that you do not consent (opt-out) or install privacy-enhancing browser plug-ins.

Changes
Website texts may be modified at any time due to ongoing developments. This also applies to this cookie statement. This version is from 10 August 2023 and if there are any changes, we will always post the latest version of this on the website.

privacy policy
Contact via Mail? send to: online @ transformationalcupping.com