The General Data Protection Regulation (GDPR) is a European Union (EU) law taking effect on May 25, 2018. The goal of GDPR is to give EU citizens control over their personal data.
- Who are we
- The types of personal data we process
- How we collect your data
- For which purposes we use your data
- Security and retention
- Your rights
- How we look after this policy
Please scroll to the relevant section below for futher information:
1. Who are we
We are the Straightness Training Cooperation with the office at:
Rijkstraatweg 269 – U
Leersum GLD 3956 CP
2. The types of personal data we process
We may collect and process the following categories of personal information:
a. Name and other identifying information
For example, we may record your first name, last name, your country of residence.
b. Your contact details and personal account or registration details
Your contact details may include your address, telephone number and email address. When you create a personal account, or register for a service, we may also record your sign in details and other information you fill out on your personal account or registration form.
c. Information about your purchases
When you purchase an online program or product with us, we process your buying information. This information may include details about your product, prices and the date of your purchase.
d. Your membership
When you become a member of our Straightness Training Academy, we process your membership number, type and level of membership, Free Touchstone Balance, Free Mastermind Session balance, and other information in relation to your membership.
e. Your horse and touchstones
When you start to submit Touchstones in the ST Evaluation Program, we process your Touchstone number (Entry ID), type and level of Touchstone, the name and gender of your horse, the score and star of a Touchstone, the feedback on the Touchstone, and other information in relation to your Touchstones.
f. Our communication with you
When you send us an email or chat with us online or via social media, we register your communication with us. We also register your communication preferences. For example when you unsubscribe from one of our newsletters . When you email us, our customer support will register your comments, questions, or complaints in our database.
g. Information we collect when you use our websites, and other digital media
When you visit our websites, and leave a comment, we may register your email address and IP address. We may receive an automatic notification when you open our emails or click on a link in such emails.
h. Information in relation to social media
i. Information you choose to share with us
You may choose to share information with us, for example when you share your interests and preferences with us, leave a comment for us on Facebook, fill out a customer survey, or submit an entry for a contest.
2.4 Specific services, or events.
Certain categories of personal information we collect and use, such as data concerning health, can be considered ‘special categories of personal data’ under applicable data protection law.
For example, to provide you with assistance or facilities during a clinic, which are appropriate to your health needs, such as special food or a special seat. We will ask you about this when you register for the specific service, or event.
3. How we collect your data
We collect the personal data in the following ways:
a. We collect data you provide to us
When you create an online account, register for one of our programs, purchase on of our products, contact our customer support, subscribe to receive our emails, register for one of our events, or participate in a promotional contest.
b. Through social network providers
Depending on your social network settings, we may receive information from your social network provider. Please see ‘The types of personal data we process’ above.
4. For which purposes we use your data
4.1. Main purposes
The main purposes for which we use your personal information are:
a. To provide our services to you
To fulfill your purchases, we need to process most of the information described above. For example, we need your name, address, postal code, and country to send you a product. To confirm your purchase, we need your email address. To coach you through the Mastery Program, we need your email address.
b. To facilitate our programs
To let you benefit from the coaching program, the free Touchstones, the free Mastermind Sessions, and discounts under our programs, we use your membership information.
c. To provide our online services to you
• For example, we use your name and email address when you login to our membership area; We use your email to send you the steps from the coaching programs.
d. For statistical research
• General. We use tools to perform statistical research into general trends regarding the use of our services, programs, websites, and social media and the behavior and preferences of our customers and users.
• Categories of data. To perform our research, we may use the categories of personal data described above, including your Touchstone data (such as date of submission, date of evaluation, type of the Touchstone, score), purchased products (whips, reins), and personal details (country). We also use customer surveys to measure customer satisfaction and to understand what is important for our customers so we can improve our service.
• Legal basis. We process your personal data for our legitimate interests to develop better services and offers for our customers, to improve our programs, to provide more responsive customer support, and to improve the design and content of our websites.
• Right to object. You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data for statistical research (please see below ‘Your rights’).
e. To send you updates and special offers tailored to your interests
• Communication. When you request our free training or ebook, or purchase a product, we send you personalized ads and special offers for related products and services in our emails (unless you unsubscribe). For example, before a Mastermind sessions will start, we will send you an email to help you prepare for this session. In this email we may include special offers for joining another session. You may also subscribe to receive special coaching emails, with steps to walk you through our programs. You may also subscribe to receive emails with updates and special offers tailored to your interest. For example, you can subscribe to the ST newsletter which keeps you informed on updates, special offers, and the latest news. We may also use other communication channels to send you personalized ads and special offers, such as postal mail or, with your consent, social channels (such as Facebook Messenger, WhatsApp).
• Opt-in and opt-out, unsubscribe, and right to object. We only send you emails with updates and special offers with your prior opt-in. You can opt-out from receiving emails and unsubscribe from these emails any time by clicking the unsubscribe link in the email, by adjusting your communication preferences in your account (if available), or by contacting us (please see ‘Your Rights’ below). You may object to the use of your personal data for direct marketing purposes anytime (please see below ‘Your rights’).
f. For other direct marketing purposes
g. To communicate with you
We use your contact details to communicate with you in relation to our services or programs, to answer your questions, or to handle your complaints.
h. For record keeping and to comply with statutory obligations
We collect, store and use your data for internal business purposes, such as record keeping and to comply with our legal and fiscal obligations.
4.2 Legal basis
We collect, use and store your personal data to provide services and our program to you, to comply with the legal obligations we are subject to, if necessary for our legitimate interests or the interests of a third party or on the basis of your consent.
You may withdraw your consent at any time by following the specific instructions in relation to the processing for which you provided your consent. For example, by clicking the unsubscribe link in the email. You may also contact us to withdraw your consent (please see ‘Your Rights’ below).
If you refuse to provide personal data that we require for the performance of the contract or compliance with a legal obligation, we may not be able to provide all or parts of the services you have requested from us. For example, we may have to cancel your membership or we may not be able to provide you with the ancillary services requested by you (such as special extension to your free touchstone period).
5. Security and retention
We take the protection of personal data very seriously.
We will take appropriate technical and organizational measures to protect your personal data against loss or unlawful use.
6. Your rights
You may contact our Support Team (please see below) to exercise any of the rights you are granted under applicable data protection laws, which includes:
- the right to access your data,
- to rectify them,
- to erase them,
- to restrict the processing of your data,
- the right to data portability and
- the right to object to processing.
1. Right to access
You may ask us whether or not we process any of your personal data and, if so, receive access to that data in the form of a copy. When complying with an access request, we will also provide you with additional information, such as the purposes of the processing, the categories of personal data concerned as well as any other information necessary for you to exercise the essence of this right.
2. Right to rectification
You have the right to have your data rectified in case of inaccuracy or incompleteness. Upon request, we will correct inaccurate personal data about you and, taking into account the purposes of the processing, complete incomplete personal data, which may include the provision of a supplementary statement.
3. Right to erasure
You also have the right to have your personal data erased, which means the deletion of your data by us and, where possible, any other controller to whom your data has previously been made public by us. Erasure of your personal data only finds place in certain cases, prescribed by law and listed under article 17 of the General Data Protection Regulation (GDPR). This includes situations where your personal data are no longer necessary in relation to the initial purposes for which they were processed as well as situations where they were processed unlawfully. Due to the way we maintain certain services, it may take some time before backup copies are erased.
4. Right to restriction of processing
You have the right to obtain the restriction of the processing of your personal data, which means that we suspend the processing of your data for a certain period of time. Circumstances which may give rise to this right include situations where the accuracy of your personal data was contested but some time is needed for us to verify their (in)accuracy. This right does not prevent us from continuing to store your personal data. We will inform you before the restriction is lifted.
5. Right to data portability
Your right to data portability entails that you may request us to provide you with your personal data in a structured, commonly used and machine-readable format and to have such data transmitted directly to another controller, where technically feasible. Upon request and where this is technically feasible we will transmit your personal data directly to the other controller.
6. Right to object.
You also have the right to object to the processing of your personal data, which means you may request us to no longer process your personal data. This only applies in case the ‘legitimate interests’ ground (including profiling) constitutes the legal basis for processing (see ‘Legal basis’ above).
At any time and free of charge you can object to direct marketing purposes in case your personal data are processed for such purposes, which includes profiling purposes to the extent that it is related to such direct marketing. In case you exercise this right, we will no longer process your personal data for such purposes.
6.2 You may withdraw your consent at any time
You may withdraw your consent at any time by following the specific instructions in relation to the processing for which you provided your consent. For example, you may withdraw consent, by clicking the unsubscribe link in the email.
6.4 How to exercise your rights
When you would like to exercise your rights, all you have to do is send your request to the Support Desk of Straightness Training:
7. How we look after this policy