Privacy Statement

Clear-Path processes privacy-sensitive data, also known as personal data, as part of its services. Clear-Path considers careful handling of personal data to be of great importance. Personal data is therefore processed and secured by us with care. In our processing, we adhere to the current privacy legislation known as the General Data Protection Regulation (GDPR). This means, among other things, that we:

  1. Clearly state the purposes for which we process personal data. We do this through this privacy statement;
  2. Limit our collection of personal data to only those personal data that are necessary for legitimate purposes;
  3. Ask for your explicit consent first before processing your personal data in cases where consent is required;
  4. Take appropriate security measures to protect your personal data and also require this from parties processing personal data on our behalf;
  5. Respect your right to provide you with access, correct or delete your personal data upon request.

Clear-Path, Chamber of Commerce registration number 84661275, located at van Vollenhovenlaan 58 in Rijswijk, is responsible for the processing of personal data as shown in this privacy statement. Clear-Path (hereinafter referred to as 'we') considers the protection of personal data to be of great importance. We process your data with the utmost care. With this privacy statement, we inform you about how we handle personal data.

Contact Details Clear-Path

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1. Personal data processed

We process personal data about you because you provide data to us in correspondence or by phone, when filling out a contact form, when entering into an agreement with us, as well as when you use our services and thereby provide us with data, or allow us to record data about your interests and preferences.

Execution of a contract: it is necessary to collect personal data for the execution of a contract or for the conclusion of a contract.

Below you will find an overview of the personal data we process:

Data provided to us

When you enter into an agreement with Clear-Path, we require the following personal data from you:

  • name and address (name, address, and contact information);
  • contact details (such as a (mobile) phone number and email address);
  • date of birth;
  • gender;
  • company details;
  • financial information (bank account details, quotes, invoices)

Data about your use of our services

If you use the services of Clear-Path or otherwise contact us, we process the following data as part of our service provision - depending on the exact use you make of it - which may be considered personal data:

  • If you receive emails from us, we record the interactions (opening and clicking behavior);
  • Browsing behavior, determined through our own observations or cookies;
  • Public data obtained from the internet and social profiles;
  • Position within the organization

The premise is that Clear-Path will not process more personal data than necessary for the purposes described below.

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2. Legal basis for the processing

The processing of personal data takes place based on the following legal grounds from Article 6 of the General Data Protection Regulation:

  1. Necessary for the performance of a contract with you
  2. Legal obligation
  3. Legitimate (marketing) interests of Clear-Path
  4. Consent of the user

Legitimate interests include: marketing, advertising, fraud prevention, research, analysis of our own services, legal matters. In the case of legitimate interests, we assess whether these interests outweigh your privacy interests. If you wish to object to the way we handle personal data, you can send an email to: privacy@clear-path.nl

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3. For what purpose and on what basis do we process personal data

Clear-Path processes your personal data for the following purposes:

  • Building and maintaining customer relationships, including maintaining a direct relationship between the data controller and (collaborative) partners, especially for commercial purposes [legal basis: 1, 2, 3].
  • Execution of the agreements concluded with you, including service provision and processing financial administration [legal basis: 1, 2].
  • Providing customer service, including service related to purchasing services and handling requests or (support) questions [legal basis: 1, 3, 4].
  • In specific cases, communicating with network-related collaborative partners (e.g., web developers and advertising agencies) to proactively contact customers for service inquiries and improving service performance [legal basis: 1, 3].
  • Conducting market research to improve our business operations and services [legal basis: 3].
  • Communicating through various channels (phone, email, social media, website, post) for both service and marketing purposes [legal basis: 1, 3, 4].
  • Contacting you with changes in service or other (commercial) information (sending our Newsletter). You always have the option to unsubscribe by clicking the unsubscribe link or raising objections. The communication will provide instructions on how to do so [legal basis: 1, 3].
  • Improving the content of our communication by tailoring it to your personal preferences [legal basis: 3].
  • (Further) developing and improving new and existing services [legal basis: 3].
  • Complying with legal obligations, settling disputes, and enforcing our rights and agreements [legal basis: 2, 3].
  • Analyzing cookies on our websites. We do this to tailor the content of our communication to your personal preferences as accurately as possible [legal basis: 3, 4].

Special and/or sensitive personal data that we process

Clear-Path processes the following special and/or sensitive personal data about you:

  • Not applicable

Automated decision-making

Clear-Path does not make decisions that have (significant) consequences for individuals based on automated processing. This refers to decisions made by computer programs or systems without human involvement (such as a Clear-Path staff member).

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4. How long we retain personal data

If you share personal data with us through the website, for example by filling out a contact form or sending us an email, Clear-Path will retain this data for as long as necessary based on the nature of the form or the content of your email, for the purpose of providing a complete response and handling the matter. Alternatively, this data may be retained for the execution of an agreement.

Clear-Path will not retain your personal data for longer than is strictly necessary to achieve the purposes for which the data is collected. We follow the following retention periods for the following (categories of) personal data:

Contact Form: Max. 2 years

Email Inquiry: Max. 2 years

Other Forms: Max. 2 years

Newsletter Subscription: Until the moment of unsubscribing from the newsletter

Customer Data: Max. 7 years (including data submitted via the above methods, only if a commercial relationship exists).

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5. Sharing Personal Data with Third Parties

Clear-Path does not sell your data to third parties and will only provide it if necessary for the execution of our agreement with you or to comply with a legal obligation. We enter into data processing agreements with companies that process your data on our behalf to ensure the same level of security and confidentiality of your data.

Clear-Path also uses services from third parties that act as 'processors' (for example, hosting service providers). These service providers will process personal data only in accordance with Clear-Path's instructions.

Privacy Policy of other websites

On the Clear-Path website, you can find links to other websites of organizations. Clear-Path cannot be held responsible for the use of your data by those organizations. It is recommended to read the privacy policy of the respective website in such cases.

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6. Cookies, or similar techniques, that we use

Clear-Path only uses technical, functional, and analytical cookies that do not infringe on your privacy. A cookie is a small text file that is stored on your computer, tablet, or smartphone when you visit this website for the first time. The cookies we use are necessary for the technical operation of the website and for your ease of use. They ensure that the website works properly and remember your preferences, for example. Additionally, they allow us to optimize our website.

You can opt out of cookies by adjusting your internet browser settings to no longer store cookies. You can also delete all information that was previously stored through your browser's settings. For further clarification, please refer to:

https://www.veiliginternetten.nl/themes/situatie/cookieswat-zijn-het-en-wat-doe-ik-ermee/

On this website, third-party cookies are also placed. These could include our CRM system, analysis tools, advertisers, and/or social media companies. Below is an overview of the third-party cookies as of August 10, 2023, totaling 23:

Cookies:

  • Cookieyes-consent
  • Zoho and its applications
  • Google Analytics
  • Hotjar

Clear-Path uses statistical tools and analytical cookies to measure where our visitors come from, how many people read certain blogs, and more. This information is crucial for us. Based on these data, we can optimize the website and make it more user-friendly.

Due to the nature of how the internet and websites work, we might not always have visibility into the cookies placed by third parties through our website. If you come across cookies on our website that fall into this category and are not mentioned above, please let us know.

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7. Social media and WhatsApp

You have the option to get in touch with us through our social media pages such as Facebook, Twitter, Instagram, LinkedIn, WhatsApp, etc. When you follow us on any of these social media channels or reach out to us, we may gain access to a portion of your profile information. The data we receive from you through these platforms is subject to this privacy policy. The use of social media itself is your own responsibility. This privacy policy does not apply to how social media platforms handle the data you provide. Therefore, it's advisable to review the privacy policy of the respective social media channel.

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8. Newsletter

Clear-Path publishes a newsletter to keep coachees and interested individuals informed about news related to business coaching, mentoring, personal coaching, our services, and related matters. If you use our services or sign up for our newsletter on the website, your information will be automatically added to the list of subscribers. At the bottom of each email, you'll find the option to update your contact information or unsubscribe from our newsletter. You can unsubscribe at any time by sending an email to privacy@clear-path.nl.

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9. Right to access, modify, or request the deletion of your personal data

You have the right to access, correct, or delete your personal data. Additionally, you have the right to withdraw your consent for data processing or object to the processing of your personal data by Clear-Path. You also have the right to data portability, meaning you can request us to send the personal data we have about you in a computer file to you or another organization you specify.

You can send a request for access, correction, deletion, data portability of your personal data, or a request to withdraw your consent or object to the processing of your personal data to privacy@clear-path.nl.

Identification

To ensure that the request for access has been made by you, we ask you to provide a copy of your identity document along with the request. In this copy, please black out your passport photo, MRZ (machine-readable zone, the strip with numbers at the bottom of the passport), passport number, and Citizen Service Number (BSN) for privacy protection. We will respond to your request as soon as possible, but within four weeks.

Clear-Path also wants to inform you that you have the right to file a complaint with the national supervisory authority, the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). You can do so using the following link:

https://www.autoriteitpersoonsgegevens.nl/nl/contact-met-de-autoriteit-persoonsgegevens/tip-ons

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10. How we secure personal information/data

Clear-Path takes the protection of your data seriously and implements appropriate measures to prevent misuse, loss, unauthorized access, unwanted disclosure, and unauthorized modification. The Clear-Path website uses a reliable SSL Certificate, which you can recognize by the address bar displaying 'https' and the padlock icon. Access to personal data is encrypted. Devices are equipped with up-to-date security software.

If you have any concerns that your data is not adequately secured or if you suspect any misuse, please contact us at privacy@clear-path.nl.

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11. Liability and Responsibility

The information on this website is not legally binding. Changes and typographical errors are reserved. We strive to make this website as accurate and complete as possible. The information on this website may be changed or removed without prior notice. Clear-Path accepts no liability for the content of the website.

You are responsible for your own choice to use this website. Similarly, you are responsible when using the information found on www.clear-path.nl.

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12. Changes in the Privacy Policy

The way we process personal data, as well as the composition or amount of data we process, may change. Clear-Path reserves the right to modify this privacy policy. Any changes will be announced on this page. Clear-Path also advises to regularly review this page for any updates.

The current privacy policy was updated on August 10th, 2023. If you have any questions or comments, please let us know. Rest assured, we handle your data with care.