Privacy Policy

Data Controller

whitnehwkl B.V. is the data controller responsible for processing your personal data. Our contact details are:

Data Collection

The data we collect includes personal information such as your name, email address, phone number, fitness goals, health information, and payment details when you use our services. We collect this information when you:

• Register for our virtual personal training services
• Complete fitness assessments or health questionnaires
• Participate in training sessions or consultations
• Contact us through our website, email, or phone
• Subscribe to our newsletters or marketing communications
• Make payments for our services
• Use our website and interact with our online platforms

We may also collect technical data such as IP addresses, browser information, and usage patterns to improve our services and website functionality.

How We Use Your Data

We explain how we use your information to provide and improve our virtual personal training services. The use of your data includes:

• Providing personalised fitness coaching and training programs
• Conducting virtual training sessions and fitness assessments
• Communicating with you about your training progress and appointments
• Processing payments and managing your account
• Sending you relevant health and fitness information
• Improving our services based on your feedback and usage patterns
• Complying with legal obligations and protecting our legitimate interests
• Marketing our services to you (with your consent where required)

Legal Basis for Processing

Under GDPR, we process your personal data based on the following legal grounds:

• Contract Performance: To provide our virtual training services and fulfill our contractual obligations
• Legitimate Interest: To improve our services, conduct business operations, and ensure security
• Consent: For marketing communications and non-essential cookies (where required)
• Legal Obligation: To comply with accounting, tax, and other legal requirements
• Vital Interests: In emergency situations where your health and safety may be at risk

Data Sharing and Third Parties

We may share your personal data with trusted third parties in the following circumstances:

• Payment processors to handle secure transactions
• Video conferencing platforms for virtual training sessions
• Cloud storage providers for secure data backup
• Professional advisors including lawyers, accountants, and consultants
• Regulatory authorities when required by law
• Emergency services if there are immediate health and safety concerns

We ensure all third parties maintain appropriate data protection standards and use your data only for the specified purposes.

Data Retention

We retain your personal data for as long as necessary to provide our services and comply with legal obligations:

• Active client data: For the duration of your service agreement plus 3 years
• Health and fitness data: Up to 7 years for professional liability purposes
• Financial records: 7 years as required by Dutch law
• Marketing data: Until you withdraw consent or 3 years of inactivity
• Website analytics: 26 months maximum

After the retention period expires, we securely delete or anonymise your personal data unless we are required to retain it longer by law.

Your Rights

Under GDPR, you have the following rights regarding your personal data:

• Right of Access: Request copies of your personal data
• Right to Rectification: Request correction of inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data in certain circumstances
• Right to Restrict Processing: Request limitation of how we use your data
• Right to Data Portability: Request transfer of your data to another service provider
• Right to Object: Object to processing based on legitimate interests or for marketing purposes
• Right to Withdraw Consent: Withdraw consent for processing where consent is the legal basis

To exercise any of these rights, please contact us at privacy@whitnehwkl.top. We will respond within one month of receiving your request.

International Data Transfers

We primarily process your data within the European Economic Area (EEA). When we transfer data outside the EEA, we ensure appropriate safeguards are in place:

• Standard Contractual Clauses approved by the European Commission
• Adequacy decisions recognising equivalent data protection standards
• Certification schemes and codes of conduct
• Explicit consent for specific transfers where appropriate

Data Security

We implement appropriate technical and organisational measures to protect your personal data:

• Encryption of data in transit and at rest
• Regular security assessments and penetration testing
• Access controls and staff training on data protection
• Secure video conferencing platforms for training sessions
• Regular backups and disaster recovery procedures
• Incident response plans for data breaches

While we strive to protect your data, no internet transmission is completely secure. We encourage you to take precautions when sharing personal information online.

Cookies and Tracking

Our website uses cookies and similar technologies to enhance your experience and analyse usage. For detailed information about our cookie practices, please see our Cookie Policy.

You can manage your cookie preferences through your browser settings or our cookie consent banner when you first visit our website.

Children's Privacy

Our services are designed for adults aged 18 and over. We do not knowingly collect personal data from children under 16 without parental consent. If you believe we have collected data from a child without appropriate consent, please contact us immediately at privacy@whitnehwkl.top.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of significant changes by email or through our website. The "Last updated" date at the top of this policy indicates when the most recent changes were made.

Contact Us

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us:

You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) if you believe we have not handled your personal data appropriately.