Privacy Policy

 

Azkua is a business registered at the Dutch Chamber of Commerce with number 55038867. This privacy policy sets out how we handle your personal information if you’re a client of Azkua or a visitor of the Azkua website.

When we say ‘Azkua’ or ‘we’ it’s because we own and run this business and website.

If we say ‘policy’, we’re talking about this privacy policy. It contains the rules for working with us and when using Azkua’s services.

 

The type of personal information Azkua collects

We collect certain personal information about our clients as well as the visitors of the Azkua website. The most common types of information we collect include:

  • first and last name
  • email address
  • telephone number
  • mail address
  • transactional details
  • information you give about yourself during taking part in our programs (think of personal information about yourself and your situation, maybe CV, etc.)
  • information you give about yourself when filling in diagnostic instruments (think of personal characteristics, preferences and traits)
  • survey responses (e.g. preparatory and feedback questionnaires)
  • testimonials about Azkua
  • IP addresses and other web analytics data

 

How Azkua collects personal information

We collect personal information directly when you provide it to us, through other people (e.g. HR responsible, line manager), or automatically as you navigate through the website.

We collect your personal information when you provide it:

  • when contacting us regarding our services
  • when signing in for a program, course, retreat or any other event organised by Azkua
  • when working with us in a program, course, retreat or any other event organised by Azkua
  • when filling in diagnostic instruments (e.g. StandOut Assessment, Myers-Briggs Type Indicator®)
  • when filling out a survey
  • when sending us an email, letter, short message, etc.

 

How Azkua uses personal information

We use your personal information to fulfil the contract we have and to deliver the related services, and where this is necessary for purposes which are in Azkua’s legitimate interests. These interests include:

  • providing you with services described on Azkua website
  • managing our relationship with you, e.g. by responding to your comments or queries submitted to us per email or asking for your feedback
  • managing Azkua’s legal and operational affairs
  • improving Azkua’s services
  • providing general administrative and performance functions and activities
  • operating the Azkua website

Furthermore, we use your personal information for purposes which are required by law, or for responding to requests by government, a court of law, or law enforcement authorities conducting an investigation.

 

When Azkua discloses your personal information

We will disclose personal information to the following recipients:

  • subcontractors and service providers who assist Azkua in providing its services, in particular: website hosting provider which is located in Canada; mobile phone cloud which is located in the US; and service providers who we use to provide diagnostic services which are located in Germany, the Netherlands, and UK; other coaches, consultants, trainers we work with to deliver our services who are located worldwide
  • our professional advisers (lawyers, accountants, financial advisers etc.) which are located in the Netherlands
  • regulators and government authorities in connection with compliance procedures and obligations
  • a third party to respond to requests relating to a criminal investigation or alleged or suspected illegal activity
  • a third party in order to enforce or defend Azkua’s rights, or to address financial or reputational risks
  • other recipients where I am authorized or required by law to do so.

 

Where Azkua stores and/or transfers your personal information

Azkua is based in the Netherlands so your data will be mainly processed locally in the Netherlands. Some of the recipients we have mentioned above, and to whom we disclose your personal information, are based outside the Netherlands in places like Canada, Germany, UK, and US. We do this based on your consent to this policy. To protect your information, we take care where possible to work with subcontractors and service providers who we believe maintain an acceptable standard of data security compliance.

 

How long Azkua keeps your personal information

We retain your personal information for as long as is necessary to provide the services to you and others, and to comply with legal obligations.

In line with the Dutch regulations, we need to keep our administration for seven years. This means that a copy of contracts and invoices I send you will stay in our system for seven years. Probably longer, since it’s a part of our business administration paperwork.

If requested by you, we delete our notes and working documents relating to you after a program or other event you’ve participated in is finished.

 

How Azkua keeps your personal information secure

We store personal information locally on secured hard drives, and occasionally hard copy files that are kept in a secure location in the Netherlands. Personal information that we store or transmit is protected by security and access controls, including username and password authentication and data encryption where appropriate.

 

How you can access your personal information

You have the right to make a request to receive the personal information we hold about you and to request corrections of any errors in that data. To make an access or correction request, please contact us per email.

You can also request to delete your personal information. Due to Dutch regulations, we need to keep some information for a certain amount of time.

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What about cookies and web analytics

The Azkua website doesn’t use cookies.

Our website is hosted with HostPapa in Canada. The information you enter through our website lives, within our sites database, on their servers in Canada. The host also automatically collects and saves information in so-called server log files, which your browser automatically transmits. These are:

  • IP address
  • browser
  • operating system
  • referrer URL
  • country
  • time of server request
  • pages visited
  • duration of visit
  • downloads

This data cannot be attributed to specific people. This data is not merged with other data sources. Azkua reserves the right to check these data at a later date, if we am aware of any concrete indications for unlawful use.

 

Not happy?

If you feel that our compliance with privacy legislation is not correct, please let us know so we can fix it. If you are not happy with our response, you have every right to complain, the official body to do so in The Netherlands is the “Autoriteit Persoonsgegevens”.