Privacy Policy – UGS Holding B.V. 

This Privacy Policy provides an overview of all information regarding the processing of personal data by UGS Holding B.V., a company registered under the laws of the Netherlands at Tinbergenlaan 84, 3045BJ Rotterdam, under company number 80924956 hereafter referred to as UGS Holding, we or us. UGS Holding strives to make you feel safe when we collect or share your data and we want to be transparent on how we collect, use, share and store the information about you and the choices available to you as data subject. The main two values inherent to this Privacy Policy are transparency and privacy as a default. As such, this Privacy Policy is about how we handle the personal information of clients and users of UGS Holding (the Privacy Policy). The Privacy Policy applies to the UGS Holding website, located at www.ugscoaching.com (the Website), as well as your use of or access to any of our online services.

We reserve the right to make changes to this Privacy Policy at any time and with or without specific notice. This may have to happen in the case of new developments, activities, online services or when applicable legislation is changed. We therefore recommend that you regularly check this Privacy Policy to ensure that you are aware of possible changes.

  1. When does this Privacy Policy apply?

This Privacy Policy applies to the processing of personal data of UGS Holding clients and users of the Website. This Privacy Policy also applies to all personal data of clients that are stored and/or processed by us on a server in the European Union (EU). This Privacy Policy does not apply to the processing of employee data in the context of their employment or contract relationship with UGS Holding. UGS Holding strives to adequately protect your personal data in accordance with applicable laws and regulations, regardless of your location and where we process the data. 

  1. What types of personal information do we collect and why?

  1. To offer you the functionalities of the Website and for the technical and functional management thereof.

  1. What is this purpose?

When you visit our Website, we want to offer you the best possible experience and functionalities. To this end, we process technical data of everyone who visits and uses our Website to manage and improve its performance. We also need to process your personal data so that you can save your data (or preferences) to configure your device to give you a personalized experience. UGS Holding uses this data in an aggregated form and this information can therefore not be traced to a computer or individual. 

  1. What legal basis justifies the processing of personal data for this purpose?

To the extent that it is necessary under applicable legislation, we process your personal data for this purpose based on your consent. Upon visiting our Website, you will be prompted to consent to the use of cookies. It is also possible to refuse all cookies. 

  1. Which personal data do we process for this purpose?

For this purpose, we process all personal data that you have entered on our website or that is generated by the use of our cookies, including your IP address and which internet browser you use. 

  1. How long do we keep your personal information?

We store personal data collected for this for a maximum of 1 year. After this period, we will permanently remove your personal information from our systems.

  1. To effectively handle communications on several platforms 

  1. What is this purpose?

UGS Holding maintains active accounts on various social media platforms, including Instagram and Facebook. When you contact UGS Holding through one of these platforms or become part of one of the groups ran on Facebook, we have to process your personal information to answer your questions, respond to messages or requests you may have.

  1. What legal basis justifies the processing of personal data for this purpose?

We process your personal data on the basis of a legitimate interest. Communication with (potential) clients is of vital importance for our company. It can also improve our overall marketing and communication efforts. We want to remain open to queries on our social media platforms while also retaining the secure and transparent way of handling customer data that we have employed on our own Website. The groups ran on Facebook are to create open and efficient communication, yet we want to ensure your privacy nonetheless. 

  1. Which personal data do we process for this purpose?

For this specific purpose we process the personal data that you have used to connect with us. This includes your (user) name, address, e-mail address, gender and any additional personal information that you have included in your message and/or on your profile.

  1. How long do we keep your personal information?

We keep this collected data as long as it takes to handle your query or complaint, plus an additional month. After this period, we will permanently remove all this data from our systems.

  1. For answering your questions and handling complaints

  1. What is this purpose?

If you contact us at our office or through a contact form on our Website, we will use your personal information to answer your question or to handle a complaint.

  1. What legal basis justifies the processing of personal data for this purpose?

We process your personal data based on consent and legitimate interest. Where possible, we will ask for you consent before you contact us, such as through the contact form. In any other case, our legitimate interest is formed by our intention to handle your complaints and questions carefully in order to properly run and improve our business.

  1. Which personal data do we process for this purpose?

For this purpose, we process your name, contact details, your correspondence with UGS Holding about your question or complaint and all other personal information that is required to answer your question or handle your specific query and/or complaint.

  1. How long do we keep your personal information?

We keep your personal data for as long as necessary to complete your request or handle the complaint, plus an additional month, after which the data will be removed from our systems.

  1. To reach out to you at events, conferences, and other group gatherings

  1. What does this goal entail?

UGS Holding may attend various events or similar gatherings in order to network and to allow potential clients to get to know UGS Holding. If you have shown interest in UGS Holding at such an event, we may offer you to leave some contact details with us so we can follow up and reach out at a later stage. 

  1. What legal basis justifies the processing of personal data for this purpose?

We process your personal data on the basis of consent. When leaving your contact details with us at an event, we will expressly ask for your consent to contact you afterwards. 

  1. Which personal data do we process for this purpose?

For this purpose we process very minimum details, including contact details such as your email address and telephone number, and personal data such as your name. 

  1. How long do we keep your personal information?

We keep this collected data for 1 year after collection, after which the details will be removed permanently from our records. 

  1. To ensure proper enforcement and respect for your rights contained in this Privacy Policy

  1. What is this purpose?

Section 7 of this Privacy Policy sets out all the rights granted to you by the GDPR. We respect these rights at all times. However, in order to do so, we must process your personal data to execute and manage your requests in connection with these rights. For example, if you want to exercise your right to be forgotten, we must record a minimum amount of data to ensure that we no longer contact you.

  1. What legal basis justifies the processing of personal data for this purpose?

The processing of this personal data is based on our legal obligation to provide a way for our data subjects to exercise their rights. In addition, we have a legitimate interest that we have is that we intend to respect your choices and therefore we want to ensure that if you exercise your right to forget, we will never contact you again for any purpose.

  1. Which personal data do we process for this purpose?

For this purpose, we process contact information such as your address and e-mail address and personal information such as your name.

  1. How long do we keep your personal information?

Due to the nature of this purpose, we must keep this information for an indefinite period.

  1. To perform consultancy services and other services as offered

  1. What is this purpose?

UGS Holding offers various consultancy services and services related thereto. As a result, we establish contractual relationships with UGS Holding clients, and we need to be able to perform our legal obligations under the applicable terms and conditions. This section includes all services offered by UGS Holding, either physically or electronically. It also covers the sale of online courses. We process your personal data to execute an agreement with you, as well as for administrative purposes, such as sending invoices. 

  1. What legal basis justifies the processing of personal data for this purpose?

We process personal data for this purpose based on our contract with you and our legitimate interest. We do this based on the contract you entered into with UGS Holding regarding the provision of services. Our legitimate interest in processing your data stems from our intention to comply with applicable law.

  1. Which personal data do we process for this purpose?

For this purpose, we process your contact details such as your (business) address, telephone number and e-mail address, personal data such as name and date of birth, gender, profession, payment and credit information, and other data stored in our database with all relations of UGS Holding. This section also covers any additional personal information you disclose to us while receiving the services. Confidential (business) information provided to UGS Holding within the context of the services is covered by a confidentiality obligation in the applicable terms and conditions. 

  1. How long do we keep your personal information?

Your personal information will be stored for up to 7 years after the end of our relationship with you. After this period your personal data will be deleted from our systems.

  1. For relationship management and marketing

  1. What is this purpose?

UGS Holding may use the information in the contractual relationships database to send you newsletters and to otherwise provide customer service. We also use your personal data for the development, execution and analysis of market research and marketing strategies. 

  1. What legal basis justifies the processing of personal data for this purpose?

We process your personal data for this purpose based on your consent. You can withdraw your consent at any time, without this having consequence for the lawfulness of processing based on permission before withdrawal. We may also process your data on the basis of legitimate interest. For example, if you are a previous client, we may provide you with additional marketing which we deem is relevant to you, even if you have not expressly consented thereto. 

  1. Which personal data do we process for this purpose?

For this purpose, we process your contact details such as your address and e-mail address and personal details such as your name and date of birth, contact preferences, payment information, and your history and former correspondence with us.

  1. How long do we keep your personal information?

Personal data is stored for a maximum of 10 years after the termination of our relationship. After this period your personal data will be deleted from our systems.

  1. Cookies

UGS Holding uses cookies on the Website. A cookie is a small and simple file that can be stored on the hard drive of a computer. The cookies from UGS Holding are only temporary, not permanent.

  1. Functional cookies

UGS Holding uses a cookie to see whether a visitor to our website accepts the cookies on our website or not. This functional cookie registers your consent. 

Futher, a “sessionID” is generated and is the only parameter stored in our servers. This is a session cookie that is generated when a user authorizes their login credentials. The main purpose of the cookie is to identify the type of user logged into our Website.

  1. Analytics cookies

Analytics cookies are used by UGS Holding to collect information about how our members use the platform. For example, we can track how long members stay on certain webpages, and what parts of the platform or website they visit. We use the information gathered by analytics cookies in aggregated form, which means that the information cannot be traced to a single individual.

We use analytics cookies to ‘remember’ you and your preferences. These cookies ensure a consistent and efficient experience for visitors. The Website has the WooCommerce plugin enabled. 

Most WooCommerce cookies do not store any personal information. The following three cookies do store personal information:

  • woocommerce_snooze_suggestions__[suggestion] – allows dashboard users to dismiss marketplace suggestions, if enabled.
  • woocommerce_dismissed_suggestions__[context] – count of suggestion dismissals, if enabled.
  • tk_ai – stores a randomly-generated anonymous ID. This is only used within the dashboard area and is used for usage tracking, if enabled.

We make use of AutomateWoo’s session tracking cookies to remember our customers when they are not signed into the website. This means carts can be tracked when the user is signed out. This cookie is not essential for the functioning of our website. 

Our website keeps track of visitor records and statistics, such as most visited pages. This allows UGS Holding to optimize the layout of the website. To this end, we use Google Analytics and use this data to improve our website, compile statistics and measure the popularity of various aspects of our website. UGS Holding uses this data in an aggregated form and can therefore not be traced to a computer or individual. To prevent this, you can install the « Google Analytics Opt-out Browser Add-on » to prevent our websites from informing Google Analytics about your visits. This cookie is owned by Google and will be deleted after a maximum of two years.

  1. Third-party cookies

Certain features on our website are provided by a third party. We will always make you aware of this by clearly stating the name of the third party. Some of these features make use of their own cookies. 

You can set your browser to inform you as soon as you receive a cookie or to deactivate cookies. This might mean that our websites may not function optimally.

We give you the possibility to give your consent to the use of cookies when you first access the Website. If you, at a later point in time, wish to disable these cookies, you can follow the instructions below. You can also set your browser to notify you as soon as you receive a cookie or to deactivate cookies. In doing so, it is possible that our websites will not function optimally. 

Here we offer some specific information about cookies for the most commonly used browsers, and more specifically, how to disable these:

Cookies and Internet Explorer, see: https://privacy.microsoft.com/en-us/privacy#maincookiessimilartechnologiesmodule

Cookies and Firefox, see: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Cookies and Google Chrome, see: https://policies.google.com/technologies/managing?hl=en

Cookies and Safari, see: https://www.apple.com/legal/privacy/en-ww/cookies/

Cookies and Opera, see: https://help.opera.com/en/latest/web-preferences/

  1. Special personal data

We insist on not processing any personal data of minors, unless this is explicitly consented to by a parent or legal guardian. However, as it is hard to detect whether we are doing so, we strongly encourage you to inform us if you have reason to believe we process the personal data of a minor. We will delete this personal data instantly. 

  1. Which parties have access to your personal data?

UGS Holding undertakes every effort to protect your personal data and has taken the necessary steps to this end. Only our employees have access to personal data, and only to the extent necessary to properly perform their individual tasks.

UGS Holding only shares personal information with third parties if it is necessary to serve the applicable purpose as set out above. When a third party processes your personal data, this is only possible according to the instructions of UGS Holding. They therefore act as our data processor. In all cases, we will ensure that third parties with access to your personal information have implemented appropriate technical and organizational measures to maintain our intended level of privacy and security. We conclude the necessary agreement with the data processor(s), whereby we include obligations to ensure that your personal data is only processed so that the data processor can fulfil his duty to provide services to us.

Under these conditions, the following third parties will have access to your personal data:

  • Information regarding your payments and the provision of services may be shared with payment processors, fraud detection and prevention services, accounting and financial advisors, and legal advisors.
  • Information regarding your use of our Website and other information received from cookies and similar technology is shared with web analytics, session recording, and online marketing services.
  • If UGS Holding makes use of subcontractors to perform (part of) the services, these subcontractors will have access to your personal data insofar as necessary to perform their work. UGS Holding will enter into the relevant processing agreements with these parties to ensure the safety and integrity of your data. 

In all other cases, your personal information will not be provided to third parties, unless required by law. UGS Holding will never sell your personal data. 

  1. Security

Your personal information is stored securely at all times. We value the protection of your privacy. As such, we ensure that the personal data is only accessible to those specific persons who are authorized based on their function. In addition, we have implemented measures to guarantee your safe visit to and use of our Website. This way we prevent misuse of your data. These measures include computer security and protected files and facilities. We have also ensured that your connection to our Website is safe by activating Secure Socket Layer (SSL). 

UGS Holding has taken the necessary technical and organizational measures to prevent, identify, report and deal with data protection breaches. However, in the event that a data breach occurs, UGS Holding will, without undue delay and where possible, not later than 72 hours after being notified, report the breach of personal data to the relevant Data Protection Authority.

  1. Access to, correction or deletion of personal data

You have the right to view, correct or delete your personal data that we have stored. You also have the right to withdraw your previously granted permission to process your personal data or to object to the processing of your personal data by UGS Holding. Finally, you have the right to have a file sent to you with details of which of your personal data we have stored. You can send us a request to receive such a file in writing. Every request is subject to applicable law, which means that we may have to store the personal information.

We also want to inform you and remind you that you can file a formal complaint with the national data protection authority.

If you object to the use of your personal data by UGS Holding, you want your personal data to be forgotten, to withdraw your previously given permission to process your personal data, or if you have another request regarding your personal data information, you can request it here at any time:

UGS Holding

Julie Francioli

Tinbergenlaan 84, 3045BJ Rotterdam

06-18689697

ugscoaching@gmail.com

External Links

Our Website could display links to other websites. We are not responsible for the privacy policies that these other websites use, nor for its content. If you use any of the third-party links on our website, we strongly advise you to inform yourself by reading the privacy policies on these websites.

Any Questions?

If you still have questions after reading this Privacy Policy or if you have suggestions or comments about its content, you can always contact us via: ugscoaching@gmail.com.