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PRIVACY POLICY

1. INTRODUCTION

 

1.1 Based on Article 13 of the Swiss Federal Constitution and the data protection provisions of the Swiss Confederation (Data Protection Act, DPA), every person has the right to protection of their privacy as well as protection against misuse of their personal data. As the operator of this website, I ("I", "me", "my") take the protection of users' personal data ("user", "you", "your") very seriously. I treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

 

1.2 This Privacy Policy explains my practices regarding the collection, use and disclosure of your information through your use of my website when accessing the website through your devices.

 

1.3 Please read the Privacy Policy carefully and make sure you fully understand my practices regarding the use of your information before using my website. If you have read this policy, fully understand it and do not agree with my practices, you must stop using my website. By using my website, you agree to the terms of this Privacy Policy. Your continued use of the website constitutes your acceptance of this Privacy Policy and any changes to it.

 

1.4 In cooperation with my hosting providers, I strive to protect the databases as well as possible from unauthorised access, loss, misuse or forgery.

 

1.5 I would like to point out that data transmission on the Internet (e.g. communication by e-mail) can have security gaps. Complete protection of data against access by third parties is not possible.

 

2. COLLECTION OF DATA

 

2.1 Below is an overview of the data I can collect:

 

  • Non-identified and non-identifiable information that you provide during the registration process or that is collected through the use of my website ("non-personal data"). Non-personal data does not identify who it was collected from. Non-personal data that I collect consists primarily of technical and aggregate usage information.

  • Individually identifiable information, which is any information by which you can be identified or could reasonably be identified ("personal data"). Personally identifiable data that I collect through my website may include information that is requested from time to time, such as names, email addresses, addresses, telephone numbers, IP addresses and more. Where I am able to combine personal data with non-personal data, as long as they are in combination, they will be treated by me as personal data.

 

3. DATA COLLECTION METHODS

 

3.1 Below are the main methods I use to collect data:

 

  • I collect data when you use my website. So when you visit it and use services, I may collect, record and store usage, sessions and related information.

  • I collect data that YOU provide to me, for example, when you contact me directly through a communication channel (e.g. an email with a comment or feedback).

  • I may collect data from third party sources as described below.

  • I collect data that you provide to me when you log in to my website through a third-party provider such as Facebook or Google.

 

4. PURPOSE OF THE DATA COLLECTION

 

4.1 I may use your data for the following purposes:

 

  • to provide and operate my website;

  • to develop, customise and improve my website;

  • to respond to your feedback, enquiries or requests and to provide assistance;

  • to analyse request and usage patterns;

  • for other internal, statistical and research purposes;

  • to improve my data security and fraud prevention capabilities;

  • to investigate violations and enforce my terms and policies and to comply with applicable law, regulation or governmental request;

  • to provide you with updates, news, promotional materials and other information related to my services. In the case of promotional emails, you can decide whether you wish to continue receiving them. If not, simply click on the unsubscribe link in these emails.

 

5. SHARING AND DISCLOSURE OF DATA

 

5.1 I may share your data with my service providers in order to operate my services (e.g. storing data via third party hosting services, providing technical support, etc.).

 

5.2 I may also disclose your information in the following circumstances:

 

  1. to investigate, detect, prevent or take action regarding illegal activities or other misconduct;

  2. to establish or exercise my rights of defence;

  3. to protect my rights, property or personal safety or the safety of my users or the public;

  4. in the event of a change of control with respect to me or any of my affiliates (by way of merger, acquisition or purchase of (substantially) all of the assets, etc.);

  5. to collect, hold and/or manage your data through authorised third party providers (e.g. cloud service providers) where appropriate for business purposes;

  6. to work with third party providers to improve your user experience. For the avoidance of doubt, please note that I may transfer or disclose non-personal data to third parties or use it in any other way at my discretion.

 

5.3 Please note that my website allows social interaction (e.g. posting content, information and comments publicly and chatting with other users). I advise you that any content or data you provide in these areas (e.g. the blog area) may be read, collected and used by others. I discourage you from posting or sharing information that you do not wish to make public. If you upload content to my website or otherwise make it available as part of using a service, you do so at your own risk. I cannot control the actions of other users or members of the public with access to your data or content. You acknowledge and hereby confirm that copies of your data may remain retrievable even after it has been deleted from cached and archived pages or after a third party has made a copy/stored your content.

 

6. COOKIES AND SIMILAR TECHNOLOGIES

 

6.1 When you visit or access my website, I authorise third parties to use web beacons, cookies, pixel tags, scripts and other technologies and analytics services ("Tracking Technologies"). These Tracking Technologies may allow third parties to automatically collect your information to improve the navigation experience on my website, optimise performance and provide a tailored user experience, as well as for security and fraud prevention purposes.

 

6.2 I may provide advertisements through my website that may also be tailored to you, such as ads based on your recent browsing behaviour on websites, devices or browsers.

 

To serve these ads to you, I may use cookies and/or JavaScript and/or web beacons (including translucent GIFs) and/or HTML5 Local Storage and/or other technologies. I may also use third parties, such as network advertisers (i.e. third parties who display ads based on your website visits) to serve targeted ads. Third-party ad network providers, advertisers, sponsors and/or website traffic measurement services may also use cookies and/or JavaScript and/or web beacons (including translucent GIFs) and/or Flash cookies and/or other technologies to measure the effectiveness of their ads and customise advertising content for you. These third party cookies and other technologies are governed by the specific privacy policy of the third party provider and not this one.

 

7. DATA STORAGE

 

7.1 Non-personal data

Please note that my business and trusted partners as well as service providers are located around the world. For the purposes explained in this Privacy Policy, I store and process any non-personal data I collect in different jurisdictions.

 

7.2 Personal data

Personal data may be maintained, processed and stored in the United States, Ireland, South Korea, Taiwan, Israel and to the extent necessary for the proper provision of my services and/or required by law (as further explained below) in other jurisdictions.

 

8. DURATION OF DATA RETENTION

 

8.1 Please note that I will retain the data collected for as long as necessary to provide my services, to comply with my legal and contractual obligations to you, to resolve disputes and to enforce my agreements.

 

8.2 I may correct, amend or delete incorrect or incomplete data at any time at my own discretion.

 

9. DATA PROTECTION

 

9.1 The hosting service for my website provides me with the online platform through which I can offer my services to you. Your data can be stored via my hosting provider's data storage, databases and general applications. It stores your data on secure servers behind a firewall and it provides secure HTTPS access to most areas of its services.

 

9.2 All payment options offered by me and my hosting provider for my website adhere to the PCI Security Standards Council's PCI-DSS (Credit Card Industry Data Security Standard) regulations. This is the collaboration of brands such as Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card data (including physical, electronic and procedural measures) by my online store and service providers.

 

9.3 Regardless of the measures and efforts taken by me and my hosting provider, I cannot and do not guarantee absolute protection and security of the information you upload, post or otherwise disclose to me or others. For this reason, I would ask you to establish strong passwords and, where possible, not to provide me or others with confidential information that you believe could cause you significant or lasting harm if disclosed. In addition, since email and instant messaging are not considered secure forms of communication, I ask that you do not share confidential information through either of these communication channels.

 

10. DEALING WITH MINORS

 

10.1 Children can use my website. However, if they want access to certain features, they may have to provide certain information. The collection of some data (including data collected via cookies, web beacons and other similar technologies) may be automatic. If I knowingly collect, use, or disclose information collected from a child, I will provide notice and obtain parental consent in accordance with applicable law. I do not condition a child's participation in an online activity on the child providing more contact information than is reasonably necessary to participate in that activity. I will only use the information I collect in connection with the services the child has requested.

 

10.2 I may also use a parent's contact details to communicate about the child's activities in the services. Parents can view data I have collected from their child, prohibit me from collecting any more of their child's data and request that any data I have collected be deleted from my records.

 

10.3 Please contact me to view, update or delete your child's details. For the protection of your child, I may ask you for proof of your identity. I may deny you access to the data if I believe your identity is questionable. Please note that certain data cannot be deleted due to other legal obligations.

 

11. USE OF PERSONAL DATA

 

11.1 I will only use your personal data for the purposes set out in the Privacy Policy and only if I am convinced that:

 

  • the use of your personal data is necessary to perform or enter into a contract (e.g. to provide you with the services themselves, customer care or technical support);

  • the use of your personal data is necessary to comply with relevant legal or regulatory obligations; or

  • the use of your personal data is necessary to support my legitimate business interests (provided that at all times this is done in a way that is proportionate and respects your data protection rights).

 

11.2 As an EU resident, you can:

 

  • Request confirmation as to whether or not personal data concerning you is being processed and access to your stored personal data as well as certain additional information;

  • request to receive personal data that you have provided to me in a structured, commonly used and machine-readable format;

  • request the correction of your personal data stored by me;

  • request the deletion of your personal data

  • object to the processing of your personal data by me;

  • request the restriction of the processing of your personal data, or

  • lodge a complaint with a supervisory authority.

 

However, please note that these rights are not unlimited and may be subject to my own legitimate interests and regulatory requirements. If you have any general questions about the personal data I collect and how I use it, please contact me as set out below.

 

11.3 In the course of providing the services, I may transfer data across borders to affiliates or other third parties and from your country/jurisdiction to other countries/jurisdictions worldwide. By using the services, you consent to the transfer of your data outside the EEA.

 

11.4 If you are located in the EEA, your personal data will only be transferred to locations outside the EEA if I am convinced that there is an adequate or comparable level of protection for personal data. I will take appropriate steps to ensure that I have adequate contractual arrangements in place with my third parties to ensure that appropriate safeguards are in place so that the risk of unlawful use, alteration, deletion, loss or theft of your personal data is minimised and that these third parties act at all times in accordance with applicable laws.

 

11.5 Rights under the California Consumer Protection Act

If you are a California resident using the services, you may be entitled to request access to and deletion of your information under the California Consumer Privacy Act ("CCPA").To exercise your right to access and delete your information, please see below on how to contact me.

 

11.6 I do not sell users' personal data for the intentions and purposes of the CCPA.

 

11.7 Users of the services who are California residents and under the age of 18 may request and obtain removal of their Posted Content by emailing me at the address provided in the "Contact" section below. These requests must all be marked "California Removal Request". All requests must include a description of the content you wish to have removed and sufficient information to enable me to locate the material. I do not accept requests that are not marked or properly submitted, and I may not be able to respond if you do not provide sufficient information. Please note that your request does not ensure that the material will be fully or completely deleted. For example, material posted by you may be republished or re-posted by other users or third parties.

 

12. UPDATE OR AMENDMENTS TO THE PRIVACY POLICY

 

12.1 I may update this Privacy Policy from time to time at my sole discretion, the version posted on the website will always be current (see the date below). I encourage you to review this Privacy Policy periodically for changes. In the event of substantial changes, I will post a notice to that effect on my website. Your continued use of the services following notification of changes to my website will constitute your acknowledgement and acceptance of the changes to the Privacy Policy and your agreement to be bound by the terms of those changes.

 

13. CONTACT

 

13.1 If you have any general questions about my website or the information I collect from you and how I use it, please contact me at:

 

Name:                   Laurence Bovet

Email address:    laurence@laurencebovet.com     

 

14. DISCLAIMER

 

14.1 The information contained herein is not a substitute for legal advice and you should not rely on it alone. Specific requirements relating to legal terms and guidelines may vary from canton to canton, country to country and/or legal system to legal system. It is your responsibility to ensure that your services are permitted under the law applicable to you and that you comply with it.

 

To ensure that you fully comply with your legal obligations, I strongly recommend that you seek professional advice to better understand which requirements specifically apply to you.

 

Bovet Coaching Services, April 2023

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