Privacy policy
In this document, the following capitalized definitions are used:
Privacy Policy: the policy established and implemented by Enneagram Europe regarding the use and processing of personal data, as set out in this document.
Enneagram Europe: the sole proprietorship registered with the Dutch Chamber of Commerce under number 27270055.
Website: the website of Enneagram Europe, located at www.enneagram-europe.com.
Personal Data: data provided by clients and customers of Enneagram Europe, as defined in the General Data Protection Regulation (GDPR).
User: any user of the Website.
Client: any third party that has entered into an agreement with Enneagram Europe, under which the provision of Personal Data may occur.
Confidential Information: all information obtained by Enneagram Europe during the execution of its activities (training, education, coaching, etc.) which it classifies as confidential and to which the provisions of this Privacy Policy apply.
General
Since 2007, Enneagram Europe has been the leading training and consultancy agency for personal, spiritual, professional, and team development based on the Enneagram. In the course of its activities, Enneagram Europe registers privacy-sensitive data. These data are handled in accordance with the GDPR. Additionally, all Enneagram Europe employees are bound by an internal code of conduct that includes provisions regarding the protection of all privacy-sensitive information.
Article 1 – Purpose and Legal Basis for Data Processing
The purposes for which data are collected and processed include:
performing all activities related to registration and participation in training, education, coaching, personal tests, and/or assessments (e.g., leadership training or in-company projects);
responding to information requests from Clients and Customers;
sending newsletters and other informational messages, training updates, and developments (within the scope of relevant legislation);
conducting analyses to improve services;
performing all other operations related to Enneagram Europe’s business activities;
providing access to online learning programs;
publishing participant information through its own website or learning portal;
calculating, recording, and collecting fees related to requested services (including transferring claims to third parties);
handling disputes;
conducting audits;
meeting accreditation requirements;
complying with legal obligations.
Article 2 – Personal Data Processed by Enneagram Europe
Enneagram Europe may process the following personal data:
name, initials, title, gender, date of birth, Enneagram type and subtype, address, postal code, city, phone number, email address, and bank account number of the client or participant;
an administrative number, provided it contains no other information than the above;
nationality and place of birth;
information necessary for the health or well-being of the participant;
data related to the nature and progress of education or training;
data on academic or training results achieved;
data necessary for organizing educational activities;
data for calculating, recording, and collecting training fees;
information about teachers and coaches relevant to the organization of assignments, coaching, and training;
data required to meet the accreditation standards of the IEA;
any other data that must be processed pursuant to applicable law.
Article 3 – Disclosure of Personal Data
Personal Data are disclosed to:
individuals who:
are responsible for the activities listed under Article 1, or
supervise those activities, or
are necessarily involved in performing those activities;
other parties, if:
the client or participant has given explicit consent, or
the processing is required by law, or
the processing is necessary to protect a vital interest of the participant (e.g., recording a food allergy), or
the data are further processed for historical, statistical, or scientific purposes, in which case Enneagram Europe ensures that they are only used for these specific purposes, or
the data form part of a delivered product or coaching program.
Article 4 – Confidentiality
Personal Data and Confidential Information are always handled by Enneagram Europe in accordance with the GDPR.
Employees are contractually bound to handle all Personal and Confidential Information in compliance with data protection law.
When Enneagram Europe engages third parties for work on behalf of Clients, it enters into agreements ensuring that confidentiality of Personal and Confidential Information is adequately safeguarded.
Article 5 – Use and Storage of Personal and Confidential Information
The processing of Personal and Confidential Information is strictly limited to the purposes for which it was collected and recorded. Such data will not be made available to third parties unless explicitly requested by the Client or necessary for the performance of an assignment.
All data are stored exclusively within the European Union.
Article 6 – Security, Retention, and Deletion
Enneagram Europe has implemented appropriate physical, technical, and organizational security measures to protect privacy-sensitive data against unauthorized access, disclosure, alteration, or deletion, as well as against fire, theft, or comparable risks.
Privacy-sensitive data are retained for 60 months after termination of the agreement for the stated purposes, or as long as required by law. After this period, consent will be requested for continued communication.
Your data will be deleted immediately upon request.
Article 7 – Internal Disclosure within Enneagram Europe
Personal and Confidential Information is disclosed within Enneagram Europe only to employees who, by virtue of their position, need access to such data and only insofar as consistent with the purpose of the registration.
Article 8 – Disclosure to Third Parties
Enneagram Europe will only transfer Personal and Confidential Information to third parties if:
the transfer is to a processor engaged by Enneagram Europe for the purposes described in this Privacy Policy, under a processing agreement that guarantees adequate technical and organizational data protection measures;
your name is provided to the training venue where your course takes place;
your name, address, postal code, and city are provided to the distributor of educational materials;
and/orEnneagram Europe is legally obliged to disclose such data to competent authorities.
The Website contains links to external websites. Enneagram Europe bears no responsibility for the manner in which these third parties handle your data. Please check whether the website you visit has a privacy statement and review it to determine whether you agree with its terms.
Article 9 – Right of Access and Rectification
Clients, Participants, and Users have the right to access, correct, supplement, delete, restrict, and transfer their Personal or Confidential Information, in accordance with the GDPR.
If you wish to exercise any of these rights or have questions about this Privacy Policy, you may contact Enneagram Europe via email at service@enneagram-europe.com.
Article 10 – Cookies
Enneagram Europe uses cookies.
Article 11 – Changes to the Privacy Policy
Enneagram Europe reserves the right to modify this Privacy Policy. Any changes will be published on this page.
Clients, Participants, and Users are encouraged to check this page regularly for updates.
This version is dated April 13, 2020.
Your data are managed carefully by Enneagram Europe.
If you believe this is not the case, or if you have other privacy-related questions, please contact us:
By mail:
Enneagram Europe
Unit M1.43, Binckhorstlaan 36
2516 BE The Hague
The Netherlands
By email: service@enneagram-nederland.nl
By phone: +31 (0)6 415 451 35
In case of escalation, you may contact the Dutch Data Protection Authority (Autoriteit Persoonsgegevens),
PO Box 93374, 2509 AJ, The Hague.
Further information is available at www.autoriteitpersoonsgegevens.nl.
