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Privacy Policy

1. General

This Privacy Policy applies to all services provided by Wendel Zwaal, CNVC Certified Trainer. I value the protection of personal data and process it in accordance with the EU General Data Protection Regulation (GDPR).
 

2. Data Controller

Name: Wendel Zwaal

Email: wendel@zwaal.com

Website: https://www.wendelzwaal.com

Chamber of Commerce (KvK): 74624806

Postal address: Meerkoethof 52, 1444 VN Purmerend, the Netherlands
 

3. Personal Data Collected

I only process data necessary to provide my services, such as:

  • First and last name

  • Address details (where relevant)

  • Email address and phone number

  • Invoice and payment details

  • Information you voluntarily share during trainings, mediations, or empathy sessions (which may occasionally include sensitive data you choose to disclose)
     

4. Purposes and Legal Bases

I process your data for the purposes below, based on the corresponding legal bases under Article 6 GDPR:

  • Registration and contract performance (managing sign-ups, scheduling, communication, delivery of services) → Contract (Art. 6(1)(b))

  • Billing and bookkeeping (invoicing, tax records) → Legal obligation (Art. 6(1)(c))

  • General communication and administration (handling enquiries, maintaining records) → Legitimate interests (Art. 6(1)(f): business operations and administration)

  • Newsletters and updates (only if you subscribed) → Consent (Art. 6(1)(a)); you may withdraw at any time
     

5. Retention Periods

I do not keep data longer than necessary. Typical retention periods are:

  • Contract and billing data: 7 years (tax and legal retention)

  • General enquiries (email or contact forms): up to 12 months after last contact

  • Training, mediation or empathy session notes (if kept): up to 2 years after the last session, unless a shorter or longer period is required or agreed for legitimate reasons

  • Newsletter subscription data: until unsubscribed (+ up to 3 months to process logs and backups)
     

6. Sharing with Third Parties (Processors)

I do not sell your data. I share data only where necessary, for example with:

  • Hosting and email provider, payment processor, newsletter service, video-conferencing provider (for online sessions), accountant.

    With each processor I have a Data Processing Agreement (DPA). Where processors are outside the EEA, appropriate safeguards such as Standard Contractual Clauses (SCCs) are used.
     

7. Security

I apply appropriate technical and organisational measures, such as access control, encryption in transit, least-privilege access, and limited retention with secure storage and backups.
 

8. Your Rights

You have the right to access, rectification, erasure, restriction, data portability, and to object to processing based on legitimate interests. Where processing is based on consent, you may withdraw it at any time (this does not affect prior processing).

To exercise your rights, email wendel@zwaal.com. I respond within 30 days and may ask for identification to verify your request. I do not use automated decision-making or profiling that produces legal or similarly significant effects.
 

9. Complaints

If you have concerns about how I handle your data, please contact me at wendel@zwaal.com. You can also file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at www.autoriteitpersoonsgegevens.nl.
 

10. Changes

I may update this Privacy Policy. The latest version is published on my website.

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