PRIVACY AND COOKIE POLICY | ZENTRE

This is Zentre’s Privacy and Cookie Policy, which covers the online and offline processing of your Personal Data and the Cookies used on the Zentre Website. This document applies to all activities of Zentre unless explicitly agreed or stated otherwise in writing. Zentre respects the privacy of her Customers and Visitors to the Website. Zentre practices care and accuracy when processing your Personal Data and processes the Personal Data in accordance with the General Data Protection Regulation (hereinafter GDPR). Below you will find more information about which Personal Data Zentre processes, on what basis and for what purpose. Furthermore you will learn how Zentre handles your Personal Data.


DEFINITIONS

  1. Data Subject

An identified or identifiable natural person who is a Visitor to the Website or a Customer of Zentre.

  1. Visitor

A registered or unregistered user of the Website.

  1. Customer

The natural person or legal person who purchases a product or service from Zentre

  1. Personal Data
    Any information about an identified or identifiable natural person.
  2. Website
    The website of Zentre, <www.Zentre.nl> and any current and future website of Zentre.

PRIVACY

 

  1. Controller

Controller and processor of Personal Data in relation to the Website and when selling goods and performing services is, unless stated otherwise in writing, one-(wo)man business Zentre. This also includes third parties hired by Zentre.

  1. Applicability

This Privacy and Cookie Policy applies to all personal data of natural persons (hereinafter Data Subjects) which Zentre processes regarding online or offline contact, in any applicable way. This also includes information collected through your visit to or purchase from the Website (hereinafter Zentre services). In the event that our Website contains a link to the website of third parties and you choose to visit this Website, we encourage you to read the Privacy Policy of that third party. Zentre is not responsible for the content of these Third Party Websites or the applicable Privacy Policy.

 

  1. Personal Data
    Below you will find an overview of which Personal Data we may collect from you in which individual situation.

    Directly provided information

    1. When you visit the website, Zentre processes the following information:
      • Your anonymized IP-address
      • your (visiting) behavior on the website (internet browsers, location, device type)
    2. If you contact us online or offline, we may collect information from you such as first name, last name, telephone number and e-mail address.
    3. If you enter into an agreement or otherwise purchase services from Zentre, we may request the following information from you:
      • First and last name
      • E-mail address
      • Address details (street, number, zip code, city, country)
      • Telephone number (mobile and landline)
      • Financial personal details (payment details including bank account number)
      • Nationality
      • Age

Sensitive personal data

Zentre processes sensitive personal data of Students of The Zen Academy in the form of image and sound recording of (digital) group meetings via Zoom. Video and sound recordings are also made of the online meetings that are part of the Mindful Membership program. These recordings are only available to members of this program during the membership.

Before starting the training, consent of clients is asked and received. The recorded image and sound material are made available digitally to the entire group of Students within online platform LearnDash during the duration of the training. Other third parties and members of Zentre, who are not part of the particular training, do not have access to these recordings. No image or sound recordings are made of individual coaching sessions.

Criminal data and data of minors
Zentre does not process any criminal personal data and also does not intend to provide Services to or collect data about persons younger than 16 years of age, unless permission has been obtained from parents or guardians. However, Zentre cannot check whether a Visitor is older than 16 and therefore advises parents to be involved in the (online) activities of their children in order to prevent data about children being processed without parental consent. If you are convinced that Zentre has collected personal data about a minor without this permission, please contact hello@zentre.nl and Zentre will delete this data.

Automatically collected information
When visiting the Website of or in the case of online communication with Zentre and her affiliates, various technologies may be used that automatically or passively collect information about your online activities. This information may be collected in the following manners:

Cookies
Technologies such as cookies, web beacons and mobile device identifiers are active on the Zentre website in order to collect information about the use of our Website. For more information, including the types of cookies on the Zentre Website and how to manage and adjust settings of cookies, please see the Zentre Cookie Policy below.

Technical data
When you visit our Website, your Personal Data may be collected. This includes information such as your Internet Protocol (IP) address, your login details, the type of your (mobile) device, the operating system and browser type of your device, the settings for time zone and location, language, a unique identifier for your device, the address of a referring website, the path you take through our Website and other information about your session on our Website.

Information received from third parties
Zentre may collect Personal Data received from other companies and organizations, including social media. We may collect Personal Data which is publicly available. For example, we may collect data when you interact with us through social media. By collecting additional information, we are able to correct inaccurate information and provide you with appropriate advice. It is not possible to create an account on our website.

Aggregated Information
Anonymized and aggregated information does not identify a specific person and therefore cannot be traced back to a person. Zentre uses such information for, among other things, insight into website visits and data analysis.

  1. Justification for dataprocessing
    GDPR requires a legal ground of justification for processing Personal Data. Zentre processes your data on the basis of the following justifications:


Execution of the agreement

In order to execute the agreement between Zentre and her customers, it is necessary to process Personal Data in order to process your purchase or membership, send you the log in details or to meet each other at the agreed location.

Consent
Your consent is obtained through requests by e-mail or other social media, orders via the Website and when subscribing to our newsletter. If third parties process your data on behalf of Zentre (“sub-processors”), your explicit consent will be requested in writing and prior to this processing. Your given consent can be withdrawn at any time by emailing hello@zentre.nl. The processing of Personal Data before the moment of withdrawal remains lawful on the basis of previously given consent.

Legitimate interest

Zentre may have a legitimate interest in processing your Personal Data, such as marketing purposes but also to advise potential customers. Interests may differ per data processing. The interests of all concerned are weighed up fairly.

  1. Purposes of processing data
    Zentre processes Personal Data for practical reasons such as:

    • Executing the agreement and communication with her customers in the broadest sense of the word (Outlook);
    • Enable online payment (Mollie);
    • Keeping records of administration and invoicing;
    • Scheduling appointments in the agenda;
    • Organizing webinars (Webinar Geek);
    • Organizing (group) sessions (Zoom);
    • Offering an Online Academy (Learn Dash);
    • Keeping Zentre in good (legal) standing;
    • Sending newsletters and automated e-mail (ActiveCampaign);

Optimal use of the Website (Wordpress) is achieved through processing personal data, based on commercial considerations such as marketing purposes and gaining insight into (unique) visitor numbers and other statistics. Zentre also processes Personal Data to contact you and/or to respond to a question/request. For managing and optimizing (monitoring, posting messages and responding to comments) social media accounts and placing advertisements, for insight into website visitors and search behaviour, to optimize the Website.

Account
It is possible to create an account for The Zen Academy on the website. To this end, the information you provide such as name, address, e-mail address, telephone number is linked to an account. When logging in to your account, you can view the provided data for the duration of the course, as well as recordings of digital meetings. After closing the account, this data will be deleted immediately.

News letter
Zentre sends newsletters to her customers and persons who have registered for this service. We process your name and e-mail address and it is possible to unsubscribe at any time. Once unsubscribed, said data will be deleted immediately.

Other purposes may be

  • developing and improving new products and services;
  • assessing the effectiveness of our sales, marketing and advertising;
  • reporting to relevant authorities in case of a security or product problem;
  • complying with and reporting according to applicable law;
  • complying with legal obligations and our policies;
  • instituting or defending a legal claim.

 

  1. Storage
    Your Personal Data will be stored on our mailservers and in the backend of our website no longer than necessary to achieve the goals as set out above. Zentre may keep your Personal Data longer on the basis of a (legal) obligation and any statutory time limitations. Your Personal Data will be stored by Zentre for a minimum of two years and a maximum of seven years.
  • Data such as first and last name, address and e-mail address are used for administrative and financial purposes. This data will be kept for seven years as Zentre is legally obliged by tax authorities to do so. This also applies to e-mail addresses and the content of e-mails.
  • Out of commercial interest, Zentre uses data such as your (company) name, first and last name and e-mail address for direct marketing.
  1. Processing of Personal Data by third parties
    In certain circumstances your Personal Data will be provided to third parties, such as Google and social media companies. Your Personal Data may also be shared with suppliers who provide services to Zentre, such as business, professional or technical support functions. This includes payment processors, hosting parties and suppliers that support Zentre with information technology services, marketing and analysis services. Your personal information may also be shared with our partners or other third parties in connection with marketing, promotional and other offers, as well as product information. Zentre has entered into or will enter into a processor agreement with these parties in the event of new parties and does not allow these suppliers to process Personal Data for any purpose other than providing services on behalf of Zentre. Other data will not be provided to third parties unless mandatory provisions in laws and regulations make this necessary. Personal Data collected may be shared with the categories of recipients listed below.

Analysis and Tracking Tools

Zentre uses third-party analytics and tracking tools, such as Google Analytics, to track, segment and analyze the use of the Zentre services. Among other things, demographics and interest are hereby determined. Based on this, Zentre gains a better insight into visitor preferences, on the basis of which the website and services can be improved. These tools may use technologies such as cookies, web beacons, pixel tags, log files, flash cookies, and/or other technologies to collect and store non-personal information. Usage data about visits to the Zentre Website is collected and shared with Zentre. Page usage is measured. Zentre has no access to or control over the use of these cookies or other tracking technologies by these third parties. We strongly advise you to read the Privacy Policy of these individual parties for information about cross-device tracking and disconnection from your devices.

Other
In certain other cases, Zentre may share your personal data with third parties, for example when Zentre is acquired by a third party or when Zentre believes that a legal obligation requires that your personal data must be disclosed or to protect Zentre its own rights, property and safety of its employees and customers, Zentre may disclose your personal information.

  1. Transfer to third countries

It may be necessary for Zentre to transfer your Personal Data to countries outside the European Union (hereinafter: EU). For example, if Zentre requires the assistance of companies established in a country outside the EU to provide or support its services. These countries do not always have an adequate level of protection. Passing on your Personal Data to such companies in the context of performing Services is only possible with your explicit consent.


The Court of Justice of the EU has declared the EU-US privacy shield invalid in the Schrems II judgment. As a result there is uncertainty about the practical consequences of this ruling when using providers in the United States. This might apply to Zentre as we use, among others, Instagram and Facebook. We investigate how we can comply with legislation and regulations with our business operations and also keep up with developments. As soon as the European Data Protection Board (EDPB) issues guidance with additional measures, our Privacy and Cookie Policy will be adjusted where necessary. If you have any questions, please contact us at hello@zentre.nl.

 

  1. Your rights
    At any time you have the right to file a complaint or objection about processing your Personal Data by Zentre. Other rights are to access, oblivion, rectification, addition, data portability, limitation of the processing or deletion of your Personal Data. To do so, send an email to hello@zentre.nl. We will ask you to provide us with specific information so that we can confirm your identity. This is a security measure to ensure that your personal information is not passed on to anyone who has no right to receive it. Below you can read what the aforementioned rights entail

 

  • Access

You have the right to inspect your personal data at any time. The right of access only concerns access to your own Personal Data. You can request access to your Personal Data including a copy of the personal data that Zentre has processed or is still processing about you. In the case that  your data has been deleted, made anonymous or is no longer available due to legislation and regulations, Zentre will immediately inform you

  • Oblivion

If there is no longer a legal basis for Zentre to keep your Personal Data, you may submit a request to erase your Personal Data. You also have the right to ask Zentre to erase or delete your data when you have successfully exercised your right to object to processing, when you are under the age of 16 and the personal data was collected through our Website, when Zentre may have processed your data unlawfully or when we need to delete your personal data to comply with laws and regulations. It is also possible to delete your data if you withdraw your previously given consent. Please note that due to specific legal reasons we may not always be able to (fully) comply with your erasure request. Where applicable, we will notify you at the time of your request.

  • Rectification and addition

If you believe that your Personal Data held by Zentre is incorrect or incomplete, you can submit a request to adjust. Zentre will make reasonable efforts to adjust them where necessary and possible.

  • Data portability

You have the right to request Zentre to transfer your Personal Data to you or a third party providing the same type of service. Zentre will provide this data in a structured and machine-readable manner. The portability only applies to automated data for which we have received your consent in the past or which has been processed under an agreement between Zentre and you.

  • Objection

In certain circumstances you may have the right to object processing of Personal Data by Zentre. For example if you believe your rights and freedoms are at stake when processing your Personal Data on the basis of a legitimate ground or when the processing is related to a legal claim. Zentre will weigh both your interests and those of Zentre in order to be able to assess whether the dataprocessing should be discontinued.

  1. Security
    Zentre makes sure that appropriate technical and organizational measures to secure Personal Data are obtained. Online programs are secured with passwords. The plug-ins used for the Website are always up to date. Regular backups are also made.

 

  1. Complaint Dutch Data Protection Authority
    Complaints about the use of your Personal Data can be submitted to the Dutch Data Protection Authority (“Autoriteit Persoonsgegevens”) by using the form made available for this purpose on their website.

 

COOKIES

As soon as you visit our Website, a cookie bar with an explanation about cookies pops up. When you click  “accept”, you agree on using all cookies and plug-ins as described in this Cookie Policy. Via your browser you may want to disable the placing of cookies. Please keep in mind that by doing so, our website may then no longer work optimally.

  1. Cookies and their use
    Our Website uses scripts, web beacons and cookies. A script is a piece of program code, used to make the Website function properly and interactive. This code is executed on our server or on your device. A web beacon (also pixel tag) is a small, invisible piece of text or image that is used to map traffic on the Website. In order to do so, various Personal Data is stored.Cookies are small (text) files sent along with pages from this Website. Your browser stores them on the hard drive of your computer. The information stored therein can be sent back to our servers on a subsequent visit. Cookies are active on the entire Website. From the moment they are placed on your computer, cookies have a specific period of validity. After expiration, your browser will delete the cookies. In some cases, the validity period is the same as the browser session. In other cases, the cookies remain on your computer for a longer period so that they can be read when you visit our Website again. If Zentre uses these kind of cookies, the collected Personal Data will be processed in accordance with this Privacy and Cookie Policy. For convenience, the term “cookies” will be used hereinafter to refer to the above files.

 

  1. Type(s) of cookies used by Zentre
    There are many different cookies, such as functional, analytic, affiliate, session, tracking and social media cookies. Zentre uses the following types:

Technically necessary cookies (functional cookies)
Cookies that are strictly necessary for the Zentre Services to function and to simplify your visit by remembering your settings. Zentre uses these cookies to find out information about the number of (unique) Visitors. We may place these cookies without your consent.

Tracking cookies
We do not use tracking cookies on this Website.

Analytic cookies
Via our Website a cookie from Google is placed as part of the Analytics service. Zentre uses this service to keep track of visitors (demographics), the way they use the Website and to obtain other relevant information. Google may provide this information to third parties if Google is legally obliged to do so or if third parties process the information on behalf of Google. Zentre has no influence on this. Zentre did not allow Google to use the obtained analytics information for other Google services. The information that Google collects is anonymised as much as possible. Your IP address is expressly not fully provided. The names used for these cookies are _ga, _gat_gtag_UA_28532292_1, _gid and the information obtained is stored for 10 minutes, 2 days or 6 months. The information is transferred to and stored by Google on servers in the United States. Zentre has concluded a processor agreement with Google. Zentre does not use other Google services in combination with the Google Analytics cookies. For more information about Google’s cookies and their validity period, read more here. To opt out of data collection in the context of Google Analytics, click here. For general information about the use of cookies by Google, click here.

As mentioned before, Zentre is aware that the judgment of the Court of Justice of the EU of 16 July 2020 has implications for the transfer of personal data via Google Analytics and is looking for a solution for this. Privacy is very important to us and we do our utmost to protect it.

Social media cookies
Social media buttons are included on the Website to promote (“like”) or share (“share”) web pages on social such as Facebook and Instagram. These buttons work by using pieces of code from Facebook and Instagram themselves. Cookies are placed through this code. Zentre has no influence on this process and advises to carefully read the Privacy Statement of these companies (which can change regularly) to find out what they do with your Personal Data obtained through cookies and how they process it. We also use Instagram Shopping, a tool where a tag in the photo on Instagram links directly to the specific Product on our Website.
Privacy Statement of Instagram.
Privacy Statement of  Facebook.
Privacy Statement of LinkedIn.
Privacy Statement of Insight Timer.
Privacy Statement of YouTube.

  1. Adjust cookie settings

You may want to refuse the use of cookies by our Website and/or third party websites through your browser settings. You can also delete recently placed cookies or ensure that you first receive a warning before cookies are placed on your browser and/or device via these settings. You need to adjust the settings individually for each browser and device. The method of adjusting the settings differs per browser. You may want to consult the help function of your browser.
As mentioned below under ‘more information’, many websites provide more explanation about cookies (adjustments). You can disable cookies from specific parties via www.youronlinechoices.eu. Please note that the functionality and ease of use of the Website may be reduced if you adjust the settings.

 

  1. More information
    More information regarding your cookie settings: Chrome, Firefox, Internet Explorer, Safari (Desktop), Safari (Mobile), Opera, Opera Mobile and Android Browser

ADJUSTMENTS

If deemed necessary to be and remain compliant with laws and regulations or in case of (expansion of) Zentre Products and services, Zentre may adjust this Privacy and Cookie Policy without prior consent. Please consult our Policy regularly to stay up to date. The most current version can be found on the Website.