Privacy Policy

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1. Purpose and scope 

1.1. Pursuant to the requirements of GDPR and other legislation regulating data protection, this Privacy Statement contains information on how the Coach process personal data of Clients natural persons. 

1.2. The provisions of the Privacy Statement shall apply to natural persons who contact the Coach via this website. 

2. Terminology 

2.1. Terminology and abbreviations used in this Privacy Statement have the following meanings: 

2.1.1 Personal Data shall mean any information related to a natural person who can be identied directly or indirectly (e.g., name, surname, contact details, etc.). 

2.1.2 Client shall mean a natural person (data subject) the data of whom is being processed. 

2.1.3 GDPR shall mean the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation). 

2.1.4 Data Processing shall mean any operation which is performed on personal data of the Person (e.g., collection, recording, storage, giving access, transferring, etc.). 

2.2. Other terminology used in the Privacy Statement shall be understood as it is described in the legislation regulating the protection of personal data (GDPR, Laws of the Republic of Latvia and others). 

3. Objectives and legal grounds of personal data processing 

3.1. The Coach shall process the Personal Data only for particular purposes and on the grounds laid down in the legislation when: 

3.1.1. it is necessary to process the data in order to conclude and/or carry out the agreement concluded with a Client; 

3.1.2. the Client has given consent to process his or her data for one or several specific purposes; 

3.1.3. the Coach must process Personal Data while following legislation requirements; 

3.1.4. Personal Data must be processed pursuant to legitimate interests of the Coach. 

3.3. In all of the cases provided above, the Coach shall process Personal Data only as far as it is necessary to obtain respective, clearly defined and legitimate purpose with regard to the requirements of the protection of personal data. 

3.4. Coach's legitimate interests are:

3.4.1. ensure the fulfilment of the contractual obligations;

3.4.2. avoid undue financial risks to its operations;

3.4.3. to retain Client applications and requests for registration for training or seminars, other applications and requests, and notes thereon, including those made on websites and in the self-service environment;

3.4.4. analyse, develop and implement improvements to the Coach website, internet resources;

3.4.5. take actions to retain Clients;

3.4.6. segment the Clients database for more efficient service delivery;

3.4.7. design and develop services;

3.4.8. advertise its services by sending information notices;

3.4.9. to send other communications about the progress of the contract and events relevant to the performance of the contract, and to conduct surveys of Clients about the services and their experience of using them;

3.4.10. ensure effective business management processes;

3.4.11. ensure and improve the quality of the services;

3.4.12. administer payments;

3.4.13. administer not performed payments;

3.4.14. to apply to public administration and law enforcement authorities and to the courts for the protection of their legal interests;

3.4.15. inform the public of its activities.

4. Storage period 

4.1. Coach shall store and process the Client's personal data for as long as at least one of the following criteria applies:

4.1.1. only for as long as the agreement with the Client is valid;

4.1.2. for as long as Coach or the Client can exercise its legitimate interests (e.g. to object or to bring or pursue legal action) in accordance with external laws and regulations;

4.1.3. for as long as either party is legally obliged to retain the data;

4.1.4. as long as the Client's consent to the processing of the personal data is valid, there is no other lawful basis for the processing. 

4.2. The Client's personal data shall be deleted once the above circumstances cease to apply.

5. Obtaining and usage of personal data 

5.1 Coach may collect personal data from the Client directly when the Client provides information to Coach to register for training or seminars, to receive information or training materials, to leave a comment, ask a question, contact Coach or for other purposes.

5.2 Data that Coach may collect directly from Client: 

5.2.1. name; 

5.2.2. postal address; email address;

5.2.3. telephone number; payment history

5.3. Coach processes personal data for the following purposes: 

5.3.1. to communicate;

5.3.2. to identify the recipient of the Coach service; 

5.3.3. for the registration of the course participant;

5.3.4. for the preparation and conclusion of the contract;

5.3.5. for the execution/provision of the services; 

5.3.6. improvement of services, development of new services; 

5.3.7. to promote the use of the service; 

5.3.8. review and processing of objections;

5.3.9. customer retention, loyalty, satisfaction measures; billing administration;

5.3.10. debt collection and recovery;

5.3.11. maintenance and improvement of the website.

5.3.12. for planning and accounting; performance measurement

5.3.13. Data quality assurance; reporting;

5.3.14. Client surveys;

5.3.15. Data quality assurance; reporting;

5.3.16. Other specific purposes of which the Client is informed when he provides relevant data.

6. Providing personal data 

6.1. Following the requirements of the legislation, the Coach may transfer the processed Personal Data to the recipients of the data under the following categories: 

6.1.1. Service Providers. The Coach may transfer the processed Personal Data to third parties operating on behalf of the Coach and/or under its instructions that provide the Coach software licencing, maintenance, employment relationship administration, correspondence and other services in order to ensure proper provision of the Coach’s services. In such cases, the Coach shall take the measures necessary to ensure that the engaged service providers (data controllers) manage the submitted Personal Data only for their intended purpose of submission, ensure proper technical and organisational security measures, in accordance with the Coach’s instructions and the requirements of the legislation in force; 

6.1.2. State, law enforcement and monitoring authorities. The Coach may submit the processed Personal Data to government or law enforcement authorities (e.g., the police, State Revenue Service etc.) when it is obligatory in accordance with the legislation in force or in order to ensure legitimate interests of the Coach or third parties; 

6.1.3. Other third parties. The Coach may submit Personal Data to other recipients of the data on legal grounds according to the legislation. 

7. Cookies

7.1. The Coach website is equipped with cookies created by Google Analytics, a programme developed by GoogleInc. The purpose of using Google Analytics cookies is to improve the quality of the content on the Coach website and to adapt the content to the needs of users. For more information on the Google Analytics terms of service, please visit the GoogleInc website at https://www.google.com/analytics/terms/us.html. If you do not want the Coach website to collect information about your activities, you must deactivate Google Analytics in the manner specified by GoogleInc. 

8. Personal rights 

8.1. After contacting the Coach and confirming his or her identity, the Client has the right to: 

8.1.1. access Personal Data concerning him or her processed by the Coach;

8.1.2. rectify incorrect, incomplete, inaccurate Personal Data concerning him or her; 

8.1.3. erase or stop collecting Personal Data concerning him or her, where it is allowed by external requirements; 

8.1.4. receive Personal Data concerning him or her which he or she has provided to a controller in a structured, commonly used, machine-readable and interoperable format; 

8.1.5. restrict the processing of Personal Data concerning him or her in accordance with the applicable legislation, e.g., for the period during which the Coach will evaluate if the Client has the right to erase Personal Data concerning him or her; 

8.1.6. object to processing of the Personal Data concerning him or her and/or, in case the Personal Data are processed on the basis of consent – withdraw his or her consent to process the Personal Data concerning him or her at any time, without affecting the legitimacy of processing based on consent before its withdrawal; 

8.2. You may contact us with issues regarding this Privacy Statement or Personal Data processing carried out by the Coach in writing by email tatjana@kucerenko.coach . 

8.3. Should the issues related to processing of your Personal Data carried out by the Coach and/or your rights are not resolved, you also have the right to submit a claim to the monitoring authority – the Data State Inspectorate, pasts@dvi.gov.lv . 

9. Validity of and amendments to this Privacy statement 

9.1. This Privacy Statement contains key provisions of Personal Data processing. Additional information about how the Coach processes Personal Data is available in the agreements, other documents of the Coach, or can be provided through remote channels (e.g., by email, etc.). 

9.2. Should legislation requirements and/or processes, etc., of the Coach change, the Coach has the right to amend and/or supplement this Privacy Statement for Clients unilaterally. The Coach will inform about the changes in the Privacy Statement by disclosing it on this website. In certain cases, the Coach may also inform the Clients about the changes via mail, email or otherwise (e.g., by disclosing it to the press).