NBmove Counselling, Coaching and Training
This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and webshop clients; in other words, where we determine the purposes and means of the processing of that personal data.
In this policy, “we”, “us” and “our” refer to NB Move / ICCI
How we use your personal data
In this section we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
We process data about your use of our website (“usage data”) and the use of our webshop training.theicci.com (“digital trainee data”).
The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data is processed for the purposes of analysing the use of the website. The legal basis for this processing is your consent.
The digital trainee data may include all the above usage data plus payment data, purchases, quiz and test data and completed training certificates.
We process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is your consent. We process the digital trainee data for training and professional purpose.
We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
In addition to the specific purposes for which we may process your personal data set out in this section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject.
Legal bases of the digital training information retention is the purchase contract with the trainee.
International transfers of your personal data
The hosting facilities for our website are situated in Israel, Israel is considered to be a secure country by the European Union, we have a DPA with the hosting provider. All log files are retained for a maximum period of 2 years.
Retaining and deleting personal data
This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We will retain your personal data as follows:
Usage data will be retained for a minimum period of 1 year following the date of collection, and for a maximum period of 2 years after which it will be deleted or anonymized;
Digital trainee data will be retained for as long as the contract between The ICCI and the trainee is in place. After this the training content will be anonymized after one year. The financial data is retained for 7 years as this is required by the Dutch tax authorities.
Notification data will be retained for a period of 1 year following the date that we are instructed to cease sending the notifications;
Your principal rights under data protection law are:
The right to access – you can ask for copies of your personal data;
the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
the right to erasure – you can ask us to erase your personal data;
the right to restrict processing – you can ask use to restrict the processing of your personal data;
the right to object to processing – you can object to the processing of your personal data;
the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details below.
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
We use a facebook pixel for tracking in order to advertise on facebook.
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies on the company’s websites:
Zoom video meetings and webinars
There will only be video recordings of a session when on forehand communicated. These recordings will be kept for the maximum of 1 year after contract, or as long as needed for legal purposes. The ICCI host may take notes of the zoom conversation and file them for future use. If you have any questions please do not hesitate to contact us.
We may update this policy from time to time by publishing a new version on our website.
Last updated: April 7, 2020
The ICCI / NB Move
2260 BA Leidschendam