Privacy Policy

 

Oliver Wirth, Business & Executive Coach (Dubai Development Authority Sole Practitioner Permit No. 95865, with business address at Premises No. SD 1-264, Ground Floor, Block No. 9, Dubai Knowledge Park, Dubai, United Arab Emirates (hereinafter “OW Business & Executive Coach”, “we”, “us”, “our”) operates the website www.owirth.com (hereinafter referred to as the "Service").  OW Business & Executive Coach is the data controller of any personal information provided to us, via this website or otherwise.

We are committed to respecting your privacy. In this privacy policy, we describe how we collect and use your personal information when you use the Service, and the rights you have in relation to such information.

Unless otherwise provided in this policy, this policy does not apply to information that you share with us in the course of a coaching-client relationship, and which has not been shared by you previously, notably in connection with using the Service. The treatment of such information, notably in the context of confidentiality, will be subject to our applicable Terms and Conditions for Coaching Services and/or a separate specific coaching service agreement or other titled agreement, as the case may be.

By using the Service, you agree to the collection and use of information in accordance with this policy.

1. Data Collection

We collect several different types of information for various purposes to provide and improve the Service.

1.1 Personal Data

While using the Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). For instance, you will be required to provide certain Personal Data for using the booking tool on our Contact page. Personal Data may include, but is not limited to:

  • First name and last name

  • Email address

  • Phone number(s)

  • Postal address

  • Physical address

Data processing and usage for the purpose of getting into contact with us will on the basis of the consent voluntarily provided by you.

We do not sell, rent otherwise make, your Personal Data commercially available to any third party. We will delete the collected personal data as soon as their retention is no longer necessary.

1.2. Usage Data

We, directly or indirectly through third-party service providers, may also collect information how the Service is accessed and used ("Usage Data"). Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), access status/HTTP status code, website from which the access is made (referer URL), browser type, browser version, the pages of the Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic and/or statistic data.

Usage Data will be processed by us for the following purposes:

  • for ensuring a smooth set-up of the website;

  • for ensuring a comfortable use of our website;

  • for assessing system security and stability, as well as

  • for further administrative purposes.

 

We also use Google Analytics; see section 1.1.4 of this Policy.

Our legitimate interest can be derived from the aforementioned data collection purposes. The collected data will not be used by us for drawing conclusions as to you as an individual.

1.3 Cookies

We, directly or indirectly, use cookies and similar tracking technologies to track the activity on our website and hold certain information. Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

 

Examples of cookies we use:

  • Session Cookies -  to operate our Service.

  • Preference Cookies - to remember your preferences and various settings.

  • Security Cookies - for security purposes.

 

In general, one can distinguish between session (transient) cookies and persistent (permanent or stored) cookies:

Session (transient) cookies are erased when site visitors close their browsers and are not used to collect information from their computers. They typically store information in the form of a session identification that does not personally identify the user.

Persistent (permanent or stored) cookies are stored on a site visitor's hard drive until they expire (at a set expiration date) or until they are deleted. These cookies are used to collect identifying information about the user, such as web surfing behavior or user preferences for a specific site.

Our website is hosted on the Wix.com platform (refer to section 6 below). You may find information about which cookies Wix.com places on Wix sites here. We also use Wix business solutions (notably Wix Bookings) that may use cookies that are not listed at the aforementioned Wix.com site. You can check which cookies are used by each business solution using Chrome's built-in cookie view. While in incognito mode, click the Lock icon   next to the URL bar and then select cookies.  

 

1.4 Google Analytics:

We also utilize Google Analytics, a web analysis service provided by Google, to better understand your use of the website and Service. Google Analytics collects information such as how often users visit the website, what pages they visit and what other sites they used prior to visiting. Google uses the data collected to track and examine the use of the website, to prepare reports on its activities and share them with other Google services. Google may use the data collected on the website to contextualize and personalize the ads of its own advertising network. Google’s ability to use and share information collected by Google Analytics about your visits to this website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Google offers an opt-out mechanism available here.

 

2. Use of Data

In addition to the purposes mentioned elsewhere in this Policy, we use the collected data for various purposes:

  • To communicate with you

  • To provide and maintain the Service

  • To market our professional services

  • To notify you about changes to our Service

  • To allow you to participate in interactive features of our Service when you choose to do so

  • To provide customer care and support

  • To provide analysis or valuable information so that we can improve the Service.

  • To monitor the usage of the Service

  • To detect, prevent and address technical issues

  • To comply with any applicable laws and regulations

3. Legal bases for collecting and using information

Legal processing bases: As far as the EU General Data Protection Regulation (GDPR) is applicable, our legal basis for information collection and use depends on the personal information concerned and the context in which we collect it. Most of our information collection and processing activities are typically based on (i) contractual necessity, (ii) one or more legitimate interests of OW Business & Executive Coach or a third party that are not overridden by your data protection interests, or (iii) your consent. Sometimes, we may be legally required to collect your information, or may need your personal information to protect your vital interests or those of another person.

Withdrawal of consent: Where we rely on your consent as the legal basis, you have the right to withdraw your consent at any time, but this will not affect any processing that has already taken place.

4. Disclosure of Data

As a general rule, but subject to any separate confidentiality agreement that we have agreed or will agree separately with you, we may disclose your Personal Data to third parties only if:

  • you have given your consent;

  • their disclosure necessary for asserting, exercising or defending legal claims and if there is no reason to assume that you have an overriding legitimate interest in a non-disclosure of data;

  • the respective data must be disclosed by virtue of a statutory requirement, law or upon request of a relevant governmental authority or agency; and/or

  • a disclosure is permitted by law and necessary for handling contractual relationships with you.

 

5. Security of Data

The security of your data is important to us,but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

6. Service Providers

  • Wix.com: We use Wix.com as our domain host. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. Wix.com Privacy Policy is available here. Please refer in particular to the provisions concerning “Users-of-users’ information” as this may relate to you and the information collected from you.

  • Zoho: We use Zoho Mail as our e-mail provider as well as Zoho Books as a cloud-based accounting solution for our book keeping and accounting, contact management, invoicing, and expense management, among other things. We may transfer, capture and store your Personal Data on Zoho Books and may use it for and/or within the features provided by Zoho Books, notably for, but not limited to, contact management, vendor management, providing you with proposals or other communications, preparing and issuing invoices. This applies to Personal Data that you share with us when using the Service as well to Personal Data that you may share with us in preparation for establishing and/or in the course of an established coach-client relationship. However, aside from Personal Data we will not capture, transfer, save or otherwise keep on any Zoho product any confidential information that you may share with us in the course of an established coach-client relationship.  For further information about Zoho’s relevant policies and related efforts please refer to Zoho Privacy Policy, Zoho Security Practices, Policies & Infrastructure and information about Zoho’s efforts towards GDPR compliance available here.

  • We may employ other third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

 

7. Your Rights

You have the right:

  • to request us to provide you with information on your personal data processed by us. You may particularly request information on the purposes of processing, the category of personal data, the categories of recipients to whom your personal data have been or will be disclosed, the envisaged retention period, the existence of a right to rectification, erasure, restriction of processing or of a right to object, the existence of a right to lodge a complaint, the source of your data in case that they were not collected by us as well as on the existence of automatic decision-making including profiling and, when appropriate, conclusive information as to its details;

  • to request us to immediately rectify inaccurate personal data stored with us with respect to your person or, as the case may be, to complete them;

  • to request us to delete your personal data stored with us, unless their processing is necessary for exercising the right of freedom of expression and information, for complying with a legal obligation, for reasons of public interest or for asserting, exercising or defending legal claims;

  • to request us to restrict the processing of your personal data if you contest their accuracy or if the processing is unlawful but you reject their erasure and we no longer need them, while you are in need of them in order to be able to assert, exercise or defend legal claims;

  • to obtain your personal data made available to us in a structured, commonly used and machine-readable format or to request us to transmit them to another controller;

  • to give us at any time notice of your revocation of your consent once granted to us, with the result that we will in future no longer be permitted to continue any data processing activities which were based on such consent, and

  • to exercise any further or other rights that you have in accordance with the EU General Data Protection Regulation (GDPR) if and to the extent the GDPR is applicable.

 

8. Children's Privacy

The Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child under the age of 18 has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children under the age of 18 without verification of parental consent, we take steps to remove the information we hold about that child.

9. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

10. Contact Us

If you have any questions about or requests pertaining to this Privacy Policy, please contact us by email: ow@owirth.com.

© 2019 by OLIVER WIRTH.