Privacy Policy

1. Introduction

Pauly B.V. ("we," "our," or "us") is committed to protecting your privacy and handling your personal data responsibly. This Privacy Policy explains what personal information we collect, why we collect it, how we use and store it, and what your rights are regarding your data.

Pauly B.V. is a company registered in the Netherlands with its registered office at Gloriantstraat 17 H, 1055 CV Amsterdam, Netherlands. We serve participants throughout Canada with coaching and personal development education programs.

By using our website and services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the terms described here, please discontinue use of our website.

2. Data Controller

The data controller responsible for processing your personal data is:

If you have any questions about this Privacy Policy or your personal data, you may contact us at any time using the email address above.

3. What Personal Information We Collect

We may collect the following types of personal information when you interact with our website and services:

3.1 Information You Provide Directly

• Full Name – provided when you submit a contact or inquiry form.
• Email Address – provided when you submit a form or send us an email.
• Phone Number – provided optionally when you submit an inquiry form.
• Selected Program – the coaching or personal development program you express interest in.
• Preferred Learning Format – if you indicate a preference for a particular delivery format.
• Message Content – any additional information or comments you include in a form submission.

3.2 Information Collected Automatically

• IP Address – collected automatically when you visit our website.
• Browser Type and Version – information about the web browser you use.
• Device Information – type of device, operating system, and screen resolution.
• Pages Visited – which pages on our website you access and how long you spend on them.
• Referral Source – how you arrived at our website (e.g., search engine, direct visit).
• Cookies and Similar Technologies – as described in our Cookie Policy.

3.3 Information We Do Not Collect

We do not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health data, sexual orientation, genetic or biometric data, or criminal records. We do not collect financial information such as credit card numbers or bank account details through our website.

4. Why We Collect Your Information

We collect and process your personal information for the following purposes:

• Responding to Inquiries – to process and reply to your form submissions and questions about our coaching education programs.
• Providing Program Information – to send you details about program structure, schedule, format, preparation, and participation requirements.
• Improving Our Website – to understand how visitors use our website and to improve its content, functionality, and user experience.
• Legal Compliance – to comply with applicable laws, regulations, and legal obligations under Dutch and European Union law.
• Website Security – to protect our website against unauthorized access, abuse, and security threats.
• Communication – to contact you using the information you have provided, strictly in connection with your inquiry or request.

5. Legal Basis for Processing

Under the General Data Protection Regulation (GDPR), which applies to Pauly B.V. as a company registered in the Netherlands, we process your personal data based on the following legal grounds:

• Consent – when you explicitly agree to the processing of your personal data by submitting an inquiry form and checking the consent checkbox. You may withdraw your consent at any time by contacting us.
• Legitimate Interest – when processing is necessary for our legitimate interests, such as improving our website, ensuring security, and analyzing website usage, provided that these interests do not override your fundamental rights and freedoms.
• Legal Obligation – when processing is necessary to comply with a legal obligation under applicable Dutch or EU law.

6. How We Use Your Information

When you submit an inquiry through our contact form, your information is processed as follows:

1. Your form submission is transmitted securely over HTTPS.
2. The submission is received by our team at [email protected].
3. We review your inquiry and respond using the contact information you provided.
4. Your information is stored only for as long as necessary to fulfill the purpose for which it was collected.

We do not use your personal information for automated decision-making or profiling. We do not sell, rent, or trade your personal information to third parties for marketing purposes.

7. How We Store and Protect Your Information

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted through our website.
• Secure server-side processing of form submissions.
• Limited access to personal data on a need-to-know basis within our organization.
• Regular review of our data protection practices.
• Spam protection measures on our contact forms, including honeypot fields.

While we take reasonable precautions to protect your data, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security of your personal information.

8. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including:

• Inquiry Data – retained for up to 24 months after your last communication with us, unless you request earlier deletion.
• Website Analytics Data – retained according to the retention periods set by our analytics tools, typically not exceeding 26 months.
• Cookie Data – retained according to the periods described in our Cookie Policy.

After the applicable retention period expires, your personal data is securely deleted or anonymized. We may retain certain data for longer periods if required by law.

9. Sharing of Personal Data

We do not sell, rent, lease, or trade your personal information to third parties. We may share your data with the following categories of recipients only when necessary:

• Service Providers – third-party companies that help us operate our website, such as hosting providers and email service providers. These providers are contractually obligated to protect your data and process it only on our instructions.
• Legal Authorities – when required by law, court order, or government regulation under Dutch or EU jurisdiction.
• Professional Advisors – legal, accounting, or compliance advisors, only when necessary for legitimate business purposes.

Any third party receiving your personal data is required to comply with applicable data protection laws, including the GDPR.

10. International Data Transfers

Pauly B.V. is based in the Netherlands and serves participants throughout Canada. If your personal data is transferred outside the European Economic Area (EEA), we ensure that appropriate safeguards are in place, such as:

• Standard Contractual Clauses (SCCs) approved by the European Commission.
• Adequacy decisions by the European Commission for the receiving country.
• Other legally recognized transfer mechanisms under the GDPR.

11. Cookies

Our website uses cookies and similar technologies to improve your browsing experience. Cookies are small text files stored on your device when you visit our website.

We use the following types of cookies:

• Essential Cookies – necessary for the basic functioning of the website, such as remembering your cookie consent preference.
• Analytics Cookies – used to understand how visitors interact with our website, including pages visited, time spent, and referral sources.
• Preference Cookies – used to remember your settings and preferences for a better user experience.

For detailed information about the cookies we use and how to manage them, please refer to our Cookie Policy.

12. Your Rights

Under the GDPR, you have the following rights regarding your personal data:

• Right of Access – you have the right to request a copy of the personal data we hold about you.
• Right to Rectification – you have the right to request correction of inaccurate or incomplete personal data.
• Right to Erasure – you have the right to request deletion of your personal data when it is no longer necessary for the purpose for which it was collected, or when you withdraw consent.
• Right to Restriction of Processing – you have the right to request that we limit the processing of your personal data in certain circumstances.
• Right to Data Portability – you have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller.
• Right to Object – you have the right to object to the processing of your personal data based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent – when processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 30 days.

13. How Consent Is Collected Through Forms

When you submit an inquiry form on our website, you are asked to provide explicit consent by checking a consent checkbox. This checkbox is not pre-checked and requires an affirmative action on your part.

By checking the consent checkbox and submitting the form, you agree to:

• The collection and processing of the personal data you have provided in the form.
• Being contacted by Pauly B.V. in connection with your inquiry, using the contact details you have provided.
• The terms described in this Privacy Policy.

You may withdraw your consent at any time by contacting us at [email protected].

14. Children's Privacy

Our website and services are intended for adults. We do not knowingly collect personal information from individuals under the age of 18. If you believe that we have inadvertently collected data from a minor, please contact us immediately at [email protected], and we will take steps to delete such information promptly.

15. Third-Party Links

Our website may contain links to external websites or resources that are not operated by Pauly B.V. We are not responsible for the privacy practices or content of third-party websites. We encourage you to review the privacy policies of any external websites you visit.

16. Right to Lodge a Complaint

If you believe that your personal data has been processed in violation of applicable data protection laws, you have the right to lodge a complaint with a supervisory authority. For the Netherlands, the relevant supervisory authority is:

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. When we make changes, we will update the "Last updated" date at the top of this page.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information. Continued use of our website after changes to this Privacy Policy constitutes your acceptance of the updated terms.

18. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact us: