introduction

This privacy statement (“Statement”) provides information on the processing of personal data by Skirmante Solution Focus (“Coach”), located at Noordeinde 180, 2514 GR, The Hague, Netherlands, concerning the Coaching & Consulting service (“Service”). This service seeks to provide coaching & consulting for wellbeing to individuals and organizations. Further contact details of Skirmante Solution Focus are provided at the bottom of this Statement. This Statement applies to personal data processed by Skirmante Solution Focus concerning the (potential) clients (“Clients”) based on which they may be identified or become identifiable (“Personal Data”). The Clients are hereinafter collectively referred to as data subjects (“Data Subjects”). This Statement informs Data Subjects on the elements as stated in articles 13 and 14 of the General Data Protection Regulation (“GDPR”), such as the Personal Data processed, the purposes for processing, retention periods etc. Skirmante Solution Focus reserves the right to review and/or alter the Statement periodically, in order to comply with (local and/or EU) legislation, and for any other purpose deemed reasonably necessary by this Coach. For queries and inquiries about this Statement, please contact Skirmante Solution Focus privacy point of contact/data protection officer (“DPO”) Skirmante Sabataityte at: e-mail: [email protected] or telephone number: +31 633 926191.

Please find below an overview of the subjects included in this Statement.

• Categories of Personal Data, purpose, legal basis and data retention
• Security of Personal Data
• Transfer of Personal Data
• Rights in relation to Personal Data
• Questions and inquiries

1. Categories of Personal Data, purpose, legal basis, and data retention

Personal Data is any information about an identified or identifiable natural person. This means that information is either directly about someone or can be linked to this person. Below is described in which situation Skirmante Solution Focus collects different categories of Personal Data, for what purposes, on which legal bases and how long the Personal Data will be retained. In general, Skirmante Solution Focus does not store Personal Data longer than necessary for these purposes, unless the retention of the Personal Data is necessary to comply with a legal obligation.

1.1 Clients

Skirmante Solution Focus processes Personal Data on the legal basis of the performance of the Coaching agreement concluded between the Client and the Coach, for the purposes described below. For every purpose is indicated which Personal Data is processed. The Personal Data processing is necessary to: Contact the Client in order to schedule the Initial and Coaching Sessions and make Coaching Agreement as well issue invoices: Name; Address; E-mail; Phone number (optional); and Availability to schedule the appointments. The Personal Data as described above are provided by the Client when they reach out through email or Calendly form. The Personal Data will be retained for the coaching relationship period and after it ends deleted immediately.

1.2 Purpose limitation

Skirmante Solution Focus will only process Personal Data to the extent necessary for the described purposes. Personal Data may in principle not be processed for other purposes other than that for which the Personal Data were collected. If there is a necessity or need to process Personal Data for other purposes, it shall be investigated by Skirmante Solution Focus whether the purposes of the intended data processing is compatible with the original purposes. Skirmante Solution Focus shall provide the Data Subject prior to that further processing with information on that other purpose.

2. Security of Personal Data

Skirmante Solution Focus handles Personal Data carefully and confidentially and uses appropriate technical measures to preserve the integrity and security of the Personal Data. Our implemented, technical controls include: access controls, access on a ‘need to know’-basis available only by the Coach. coaching agreements for confidentiality

3. Transfer of Personal Data

Skirmante Solution Focus transfers Personal Data to the following recipients: Google Forms, to obtain information required to determine potential Client’s eligibility and contact details (as described in chapter 1.2). Skirmante Solution Focus transfers Personal Data outside of the European Economic Area (“EEA”), as Google is established in the United States. These transfers only take place in compliance with the Applicable Laws and where appropriate safeguards are in place that ensure the level of protection of Data Subjects as required by these Applicable Laws (e.g. transfers on the basis of an adequacy decision or standard EU Model clauses). Clients are asked to use Calendly to schedule the Coaching Sessions with the Coach. With created link to Coach’s calendar on Calendly Clients are asked to enter their e-mail address and date of online meeting. For a further explanation on the used transfer mechanism of Personal Data by Calendly please follow information in their privacy statement https://calendly.com/privacy .

4. Rights in relation to Personal Data

Data Subjects have the right of information, access, rectification, addition and erasure of Personal Data, and the right to object against or restrict the processing of Personal Data (or withdraw an earlier given consent), as well as the right to data portability. The procedure of Skirmante Solution Focus that enables Data Subjects to exercise these rights, is described below. Data Subjects may file a request for access with the Coach, and the Coach shall respond as soon as possible, and in any event within one (1) month, about: whether the Coach holds any Personal Data relating to the respective Data Subject; and, if so, information is provided on the purposes of the processing, the categories, the recipients (if applicable) the envisaged period for which the Personal Data will be stored, or the criteria used, the existence of the right to request rectification, erasure, restriction or to object to such processing, the right to lodge a complaint with a supervisory authority, the existence of automated decision-making, where the data is transferred to a third country, the appropriate safeguards and the source(s) of the Personal Data. Skirmante Solution Focus informs the Data Subject within one (1) month after receiving the request whether the request shall be complied with (in time), and if not, accompanied with the reasons for the delay or rejection. Information provided shall be free of charge. Data Subjects can exercise these rights at reasonable intervals. Data Subjects can exercise their rights by contacting the Privacy contact person in writing or per e-mail at (see address above). Skirmante Solution Focus will comply with a legitimate request of a Data Subject for rectification, addition and erasure, if the Personal Data are factually incorrect, incomplete, or irrelevant for the purpose(s) of the data processing, or otherwise processed in violation with the Applicable Laws. With regard to a request to erase Personal Data, it should be taken into account that Skirmante Solution Focus shall not comply with such request, if it is incompatible with any legal obligations of Skirmante Solution Focus. In the event of concerns about the handling of Personal Data, Data Subjects also have the right to lodge a complaint with a local supervisory authority. In the Netherlands, this is the Autoriteit Persoonsgegevens, located at Hoge Nieuwstraat 8 in Den Haag, reachable via telephone: 088 – 1805 250.

5. Questions and inquiries

For queries and inquiries about this Statement, please contact the DPO Skirmante Sabataityte at: e-mail: [email protected] and telephone number: +31 633 926191