Privacy Policy
Last updated: June 11, 2018

Elsa Razborsek Consulting understands that your privacy is important to you. We are committed to protecting the privacy of your personally-identifiable information as you use this website. Elsa Razborsek Consulting is the data controller and we are responsible for your personal data.

“We,” “our” means Elsa Razborsek Consulting and its affiliates. “You,” “your,” visitor,” or “user” means the individual accessing this site.

This Privacy Policy tells you how we protect and use information that we gather from you. By using this website, you consent to the terms described in the most recent version of this Privacy Policy. You should also read our Terms of Use accessible at https://www.elsarazborsek.com/terms to understand the general rules about your use of this website, and any additional terms that may apply when you access particular services or materials on certain areas of this website. 

Elsa Razborsek Consulting may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 11/06/18.


PERSONAL AND NON-PERSONAL INFORMATION
 
Our Privacy Policy identifies how we treat your personal and non-personal information.

Non personal information is information that cannot identify you. If you visit this web site to read information, such as information about one of our services, we may collect certain non-personal information about you from your computer’s web browser. Because non-personal information cannot identify you or be tied to you in any way, there are no restrictions on the ways that we can use or share non-personal information. 

Personal information is information that identifies you as an individual, such as your name, mailing address, e-mail address, telephone number, and fax number. We may collect personal information from you in a variety of ways: 
• When you send us an application or other form 
• When you conduct a transaction with us, our affiliates, or others 
• When we collect information about in you in support of a transaction, such as credit card information 
• In some places on this web site you have the opportunity to send us personal information about yourself, to elect to receive particular information, to purchase access to one of our products or services, or to participate in an activity.


INFORMATION THAT WE COLLECT, WHY AND HOW WE PROCESS IT

In running and maintaining our website we may collect and process Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content, marketing communications and advertisements to you (including Facebook adverts or other display advertisements), as well as to measure or understand the effectiveness of the advertising we serve you. 

Communication Data including any communication that you send to us through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

Customer Data including data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services that you have purchased, and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

User Data including data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

Technical Data including data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business, and to grow our business and decide our marketing strategy.

Marketing Data including data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as free giveaways, to deliver relevant website content and advertisements to you, and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests in studying how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.


HOW WE HANDLE SENSITIVE DATA

We often carry out surveys and quizzes to better understand you / our audience, so we can help you improve your performance and productivity. Some of the questions we ask may provide us with sensitive data about you. We will also collect sensitive data from you if you join any of our coaching programmes.

We require your explicit consent for processing sensitive data.

Where we are required to collect personal data by law or under the terms of the contract between us, and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you do not provide us with the requested data, we may have to cancel a product or service you have ordered, in which case, we will notify you at the time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at support@elsarazborsek.com.

In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
 

PUBLIC DISCUSSIONS
 
This site may provide public discussions on various business topics. Please note that any information you post in these discussions will become public, so please do not post sensitive information in the public discussions. Whenever you publicly disclose information online, that information could be collected and used by others. We are not responsible for any action or policies of any third parties who collect information that users disclose in any such forums on the web site. Elsa Razborsek Consulting does not agree or disagree with anything posted on the discussion board. Also remember that you must comply with our other published policies regarding postings on our public forums.


USE OF COOKIES

We may use cookies and related technologies, such as web beacons, to collect information on our website. 

A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you register with us, a cookie helps Elsa Razborsek Consulting to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same Elsa Razborsek Consulting website, the information you previously provided can be retrieved, so you can easily use the features that you customized. 

A web beacon is a small graphic image that allows the party that set the web beacon to monitor and collect certain information about the viewer of the web page, web-based document or e-mail message, such as the type of browser requesting the web beacon, the IP address of the computer that the web beacon is sent to and the time the web beacon was viewed. Web beacons can be very small and invisible to the user, but, in general, any electronic image viewed as part of a web page or e-mail, including HTML based content, can act as a web beacon. We may use web beacons to count visitors to the web pages on the web site or to monitor how our users navigate the web site, and we may include web beacons in e-mail messages in order to count how many messages sent were actually opened, acted upon or forwarded.
 
Third party vendors also may use cookies on our web site. For instance, we may contract with third parties who will use cookies on our web site to track and analyze anonymous usage and volume statistical information from our visitors and members. Such information is shared externally only on an anonymous, aggregated basis. These third parties use persistent cookies to help us to improve the visitor experience, to manage our site content, and to track visitor behaviour. We may also contract with a third party to send e-mail to our registered users.
 
To help measure and improve the effectiveness of our e-mail communications, the third party sets cookies. All data collected by this third party on behalf of Elsa Razborsek Consulting is used solely by or on behalf of Elsa Razborsek Consulting and is shared externally only on an anonymous, aggregated basis. From time to time we may allow third parties to post advertisements on our web site, and those third-party advertisements may include a cookie or web beacon served by the third party. This Privacy Policy does not cover the use of information collected from you by third party ad servers. We do not control cookies in such third party ads, and you should check the privacy policies of those advertisers and/or ad services to learn about their use of cookies and other technology before linking to an ad. We will not share your personal information with these companies, but these companies may use information about your visits to this and other websites in order to provide advertisements on this site and other sites about goods and services that may be of interest to you, and they may share your personal information that you provide to them with others.
 
You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer by adjusting the settings on your computer. For more information please read the advice at AboutCookies.org.

If you choose to decline cookies, you may not be able to fully experience the interactive features of the Elsa Razborsek Consulting websites you visit.


THIRD-PARTY LINKS

This site contains links to other sites that provide information that we consider to be interesting. Clicking on those links may enable third parties to collect and share information about you.

Elsa Razborsek Consulting is not responsible for the privacy practices or the content of such third-party websites. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
 

MARKETING COMMUNICATIONS

We may contact you periodically by e-mail, mail or telephone to provide information regarding programmes, products, services and content that may be of interest to you. 

In addition, some of the features on this web site allow you to communicate with us using an online form. If your communication requests a response from us, we may send you a response via e-mail. The e-mail response or confirmation may include your personal information. We cannot guarantee that our e-mails to you will be secure from unauthorised interception.

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely in growing our business).

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications, and in each case you have not opted out of receiving such communications since. 

You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in every email we send.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.

 
DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set-out below:
(i) Service providers who provide IT and system administration services.
(ii) Professional advisers including lawyers, bankers, auditors and insurers
(ii) Government bodies that require us to report processing activities.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

These third parties are data processors, and they have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
 
INTERNATIONAL DATA TRANSFERS  

Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:
(i) We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
(ii) Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
(ii) If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
 

DATA SECURITY

We have implemented generally accepted standards of technology and operational security in order to protect personally-identifiable information from loss, misuse, alteration, or destruction. 

Only authorised personnel and third party vendors have access to your personal information, and these employees and vendors are required to treat this information as confidential. 

Despite these precautions, we cannot guarantee that unauthorized persons will not obtain access to your personal information.
 

DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding how long to keep the data for, we consider its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure and its processing purposes.

For tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they stop being customers.

In some circumstances, we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
 

YOUR LEGAL RIGHTS  
Under data protection laws, you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
 

HOW TO ACCESS, CHANGE, AND/OR DELETE YOUR PERSONAL INFORMATION

If you wish to exercise any of the rights set out above, you may access, correct, update, and/or delete any personally-identifiable information that you submit to the website by emailing us at support@elsarazborsek.com.

You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data or to exercise any of your other rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Autoriteit Persoonsgegevens, the Dutch Data Protection Authority (https://autoriteitpersoonsgegevens.nl). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

You may also unsubscribe from mailing lists or any registrations on the website. To do so, please either follow instructions on the page of the website on which you have provided such information,subscribed or registered, or contact us at support@elsarazborsek.com.
If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.
 

CHILDREN’S PRIVACY

Elsa Razborsek Consulting will not intentionally collect any personal information (such as a child’s name or email address) from children under the age of 18. If you think that we have collected personal information from a child under the age of 18, please contact us at support@elsarazborsek.com.
If we become aware that we have collected Personal Information from a child under age 18 without verification of parental consent, we take steps to remove that information from our servers.
 

CHANGES

Elsa Razborsek Consulting reserves the right to modify this statement at any time. Any changes to this Privacy Policy will be listed in this section, and if such changes are material, a notice will be included on the homepage of the web site for a period of time. 

If you have any questions about privacy at any websites operated by Elsa Razborsek Consulting or about our website practices, please contact us at: support@elsarazborsek.com.
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