1. Introduction
Byj Beheer B.V. ("we," "us," or "our"), a company registered in the Netherlands with its registered office at Rijssensestraat 15, 7642 CV Wierden, Netherlands, is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, store, and protect personal data when you visit our website or interact with our services.
This Privacy Policy applies to all visitors, users, and participants who access our website or engage with our coaching and personal development educational programs. By using our website, you acknowledge that you have read and understood this Privacy Policy.
We process personal data in compliance with the General Data Protection Regulation (GDPR) (EU Regulation 2016/679) and other applicable data protection laws of the Netherlands.
2. Data Controller
The data controller responsible for your personal data is:
If you have any questions about this Privacy Policy or how we handle your personal data, please contact us at the email address above.
3. Personal Data We Collect
We may collect and process the following categories of personal data:
3.1 Information You Provide Directly
- Contact Information: Full name, email address, phone number
- Program Preferences: Selected program, preferred contact method
- Communication Content: Messages, comments, or inquiries submitted through our contact form
- Consent Records: Records of consent given for data processing and communications
3.2 Information Collected Automatically
- Technical Data: IP address, browser type and version, operating system, device type
- Usage Data: Pages visited, time spent on pages, navigation paths, referring website or source
- Cookie Data: Information collected through cookies and similar tracking technologies as described in our Cookie Policy
4. Legal Basis for Processing
We process your personal data on the following legal grounds under the GDPR:
- Consent (Article 6(1)(a) GDPR): When you submit a contact form with the consent checkbox selected, you provide explicit consent for us to process your data and contact you regarding your inquiry or program interest.
- Legitimate Interest (Article 6(1)(f) GDPR): We may process certain data (such as technical and usage data) based on our legitimate interest in maintaining website security, improving user experience, and analyzing website performance, provided these interests do not override your fundamental rights and freedoms.
- Legal Obligation (Article 6(1)(c) GDPR): We may process personal data when necessary to comply with legal obligations under Dutch or European Union law.
5. How We Use Your Personal Data
We use the personal data we collect for the following purposes:
- To respond to your inquiries and provide information about our coaching and personal development programs
- To process program enrollment requests and communicate program details
- To maintain and improve our website functionality and user experience
- To analyze website traffic and usage patterns for improvement purposes
- To ensure the security and integrity of our website
- To comply with legal and regulatory obligations
- To send relevant program information when you have provided explicit consent
We do not sell, rent, or trade your personal data to third parties for marketing purposes.
6. Data Sharing and Third Parties
We may share your personal data with the following categories of third parties only when necessary and in accordance with applicable data protection laws:
- Service Providers: Third-party companies that assist us with website hosting, email delivery, analytics, and technical infrastructure. These providers process data on our behalf under data processing agreements.
- Legal Authorities: If required by law, court order, or other legal processes, we may disclose personal data to competent authorities in the Netherlands or the European Union.
- Professional Advisors: Legal, accounting, or compliance advisors when necessary for business operations or dispute resolution.
All third-party service providers are contractually obligated to handle your data securely and in compliance with the GDPR.
7. International Data Transfers
As our services are offered to individuals in Canada and our company is established in the Netherlands, personal data may be transferred between the European Economic Area (EEA) and Canada.
When personal data is transferred outside the EEA, we ensure that appropriate safeguards are in place, such as:
- Adequacy decisions by the European Commission (Canada has received a partial adequacy decision for commercial organizations subject to PIPEDA)
- Standard Contractual Clauses (SCCs) approved by the European Commission
- Other legally recognized transfer mechanisms under the GDPR
8. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws. The following retention periods generally apply:
- Contact Form Submissions: Retained for up to 24 months from the date of submission, unless a longer retention period is required for ongoing correspondence or legal obligations.
- Program Enrollment Records: Retained for the duration of the program and up to 36 months after program completion for administrative and follow-up purposes.
- Technical and Usage Data: Retained for up to 12 months for analytics and website improvement purposes.
- Consent Records: Retained for as long as the consent is valid, plus an additional period as required to demonstrate compliance.
Once the retention period expires, personal data is securely deleted or anonymized.
9. Your Rights Under the GDPR
As a data subject, you have the following rights under the GDPR:
- Right of Access (Article 15): You have the right to request a copy of the personal data we hold about you.
- Right to Rectification (Article 16): You have the right to request correction of inaccurate or incomplete personal data.
- Right to Erasure (Article 17): You have the right to request deletion of your personal data under certain circumstances ("right to be forgotten").
- Right to Restriction of Processing (Article 18): You have the right to request that we restrict the processing of your personal data under certain conditions.
- Right to Data Portability (Article 20): You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller.
- Right to Object (Article 21): You have the right to object to the processing of your personal data based on legitimate interests or for direct marketing purposes.
- Right to Withdraw Consent (Article 7): Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
To exercise any of these rights, please contact us at [email protected]. We will respond to your request within one month as required by the GDPR. In complex cases, this period may be extended by two additional months, and we will inform you if this is the case.
10. Right to Lodge a Complaint
If you believe that our processing of your personal data violates the GDPR, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens):
Autoriteit Persoonsgegevens
Hoge Nieuwstraat 8
2514 EL Den Haag
Netherlands
Phone: +31 70 888 8500
We encourage you to contact us first at [email protected] so we can address your concern directly.
11. Cookies and Tracking Technologies
Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyze website traffic, and improve our services. Cookies are small text files placed on your device when you visit our website.
For detailed information about the types of cookies we use, their purposes, and how to manage your cookie preferences, please refer to our Cookie Policy.
You may choose to accept or reject non-essential cookies through the cookie consent banner displayed when you first visit our website. You can also manage cookies through your browser settings at any time.
12. Data Security
We implement appropriate technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:
- HTTPS encryption (SSL/TLS) on all website pages
- Secure form processing with server-side validation
- Spam protection mechanisms on contact forms
- Access controls and limited data access for authorized personnel only
- Regular review of data processing practices and security measures
While we take reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security of your personal data.
13. Children's Privacy
Our website and programs are designed for adults. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that we have inadvertently collected personal data from a minor, we will take steps to delete such data promptly. If you believe that we have collected personal data from a minor, please contact us at [email protected].
14. Third-Party Links
Our website may contain links to external websites or services that are not operated by us. We are not responsible for the privacy practices or content of third-party websites. We encourage you to review the privacy policies of any external websites you visit. This Privacy Policy applies only to our website.
15. Changes to This Privacy Policy
We reserve the right to update or modify this Privacy Policy at any time. Any changes will be posted on this page with an updated "Last updated" date. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data.
Significant changes to this Privacy Policy may be communicated through a notice on our website or by other appropriate means.
16. Governing Law and Jurisdiction
This Privacy Policy is governed by and construed in accordance with the laws of the Netherlands and applicable European Union regulations, including the GDPR. Any disputes arising from or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the competent courts in the Netherlands.
17. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or how we process your personal data, please contact us: