PRIVACY STATEMENT BETTER MINDS
At Better Minds, we value your privacy and take our clients’ expectations seriously. That is why we make every effort to explain in this privacy statement, in clear and straightforward language, which personal data we collect, what we use it for, and what your rights are in this regard.
1. ABOUT BETTER MINDS
Better Minds (“Better Minds” or “we” or “us”) is the controller responsible for processing your personal data.
Belgium: Better Minds at Work BV, registered office at Schoebroekstraat 8, 3583 Beringen, with a branch at Stokerijstraat 17, box 5, 2110 Wijnegem (Belgium), registered in the CBE under number BE 0548.982.089.
Netherlands: Better Minds B.V., registered office in Amsterdam (Netherlands), business address Helicopterstraat 25 D, 1059 CE Amsterdam, registered with the Dutch Chamber of Commerce under number 34302497.
You can contact us at info@betterminds.com or by post at the addresses above if you have questions about the processing of your personal data.
2. SCOPE OF THIS PRIVACY STATEMENT
This document describes how Better Minds collects and uses personal data in the context of its services, which include (among other things) booking and/or attending coaching sessions and programs related to personal development and functioning at work.
We also explain how we store your personal data, for how long, how we protect it against misuse, and which rights you have regarding the personal data you provide to us.
We may update this privacy statement from time to time. Please make sure you consult the most recent version whenever you visit our website.
We aim to process your personal data in accordance with 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 (the “General Data Protection Regulation” or “GDPR”).
3. WHAT PERSONAL DATA DO WE PROCESS?
We may collect personal data provided by you or by third parties insofar as this is necessary for Better Minds to deliver its services. Which data this concerns may vary depending on the service you use.
If we process sensitive personal data (for example, health data), we will only do so with your explicit consent or where required by law.
You are not strictly required to provide us with your personal data, but certain services may not be (fully) available without specific data.
In general
Better Minds processes the following types of personal data when you share them directly with us; when you send a question by e-mail or contact us; when you register yourself, your employees or your child for one of our coaching sessions or workshops and possibly attend them; and/or when you purchase one or more products offered in our webshop:
- Identification, contact, delivery and payment details, and personal characteristics: e.g., your name, address, e-mail address, phone number, date of birth and, where applicable, gender, invoicing and payment details. If certain information is mandatory and you do not provide it, we may be unable to complete the registration process or deliver services under optimal conditions.
- Health data: for some services such as coaching sessions, we may process health data relating to our clients, our clients’ employees or other persons registered by the client, insofar as necessary to deliver our services (e.g., food allergies or illnesses).
- Communication preferences: e.g., your preferred channels (e-mail, push notifications, post, phone), as provided during registration/account settings or indirectly by unsubscribing.
- Other data you provide: e.g., information shared by phone or via social media, as well as responses you voluntarily provide in surveys/research.
Direct marketing
We only use your personal data for marketing purposes in two situations:
- if you have given prior explicit consent (“opt-in”); and/or
- if you have purchased one or more of our services, we will inform you about similar or complementary services that may be of interest to you.
Your e-mail address can be removed from our direct mailing list at any time, free of charge and without the need to give reasons, by clicking the unsubscribe link at the bottom of each promotional e-mail.
3.1. SPECIFICALLY FOR THE WEBSITE
We process personal data you provide directly (e.g., via contact or sign-up forms), data resulting from your use of our websites (strictly in aggregated, cookieless form), and data necessary for our services (e.g., payments via Stripe on betterminds.com).
Below is an overview of categories, purposes, legal bases and retention periods that apply specifically to our websites:
4. WHY DO WE PROCESS YOUR PERSONAL DATA?
We collect and process your personal data to ensure that your experience with Better Minds is as smooth and valuable as possible. The information we collect is mainly processed to improve the quality, safety and content of our services and, where you have consented, for direct marketing.
We ensure that every processing activity has an appropriate legal basis. We process personal data where necessary:
- to prepare, perform or terminate an agreement with you (e.g., providing information, delivering products and services, invoicing);
- to comply with legal or regulatory obligations (e.g., tax law, disclosures to authorities in the context of judicial investigations); and/or
- to pursue our legitimate interests, while carefully balancing these against your privacy.
If processing is not necessary for one or more of the above reasons, we will ask for your consent.
More specifically, we use your personal data for the following purposes:
- Performance of our agreement, including:
- managing your registrations, receiving your payment and providing customer support and communications (e.g., confirmations for coaching sessions);
- executing sales on our webshops;
- delivering our services during coaching sessions, workshops, camps and other programs.
- Publication of photos and audiovisual material featuring your image.
- During our (online) sessions, workshops and camps, photos and audiovisual material may be recorded where you may be the central figure. At the start of these activities, we ask for your consent to use these materials in brochures, posters, general marketing materials and on the Better Minds website or other (social) media channels to promote and convey the atmosphere of the activities.
- “Atmospheric” images not centered on you as a focal person may be shared with partners or sponsors.
- Direct marketing by e-mail: to communicate news and future promotions that may interest you or to offer new products/services by Better Minds, including personalised content aligned with your interests (you can unsubscribe at any time via the link in each e-mail).
- Market research and analysis to improve and tailor our products and services, based on your feedback, our interactions with you and (where consented) cookies; you may also be invited to voluntarily participate in surveys.
- Where applicable, and only if you have consented:
- to process your health data in order to respond to requests relating to accessibility requirements or allergies;
- to provide other companies within the Golazo group with the opportunity to send you information about (sports) events organised by them;
- to share your data with partners for their further use (including photographs and other audiovisual material in which you are portrayed as a central figure).
4.1. ADDITIONAL – WEBSITE-SPECIFIC PURPOSES
- handling contact requests and sign-ups;
- sending newsletters (after subscription/opt-in);
- security, abuse and error prevention;
- statistical/analytical insights based on cookieless web statistics;
- providing typography, media and forms;
- payment processing for purchases (betterminds.com only).
4.2. COOKIES AND SIMILAR TECHNOLOGIES
Our websites use a limited set of technologies. Marketing cookies and tracking pixels are not used unless explicitly stated.
We use:
- Plausible Analytics – cookieless analytics, aggregated statistics only;
- Fillout – embedded forms using functional cookies/session storage for proper operation and anti-abuse;
- Adobe Fonts (Typekit) – consistent typography; typically no cookies, limited technical data transfer;
- Mailchimp (newsletter) – we use sign-up only, without tracking. No marketing cookies are set;
- Stripe (payments, betterminds.com only) – processes personal data at checkout; does not place cookies on our site.
- Cloudflare (security) – protects our websites against DDoS and malicious traffic; may place a temporary security cookie to distinguish trusted visitors.
5. HOW LONG DO WE PROCESS YOUR PERSONAL DATA?
We never retain your data longer than needed to deliver the products and/or services you requested, for the purposes described in this statement, and for legal purposes that require us to keep information. If we no longer need your data and there is no legal/regulatory reason to retain it, we delete it or anonymise it so you can no longer be identified.
- Mailing list data: up to 5 years after the workshop, coaching session or camp that gave rise to it, or immediately upon your opt-out.
- Reservation/purchase/contract data: up to 10 years after termination of the agreement.
- Invoicing data: 7 years after 1 January following the invoice date.
- Videos: two months after recording, unless needed to evidence a crime, damage or nuisance, or to identify an offender, witness or victim.
- Images: up to 15 months after a session/workshop, then deleted or blurred.
5.1. ADDITIONAL – WEBSITE-SPECIFIC RETENTION
- Contact requests: stored until the request is handled and for a maximum of 5 years thereafter.
- Newsletter data: stored as long as someone is subscribed and for a maximum of 5 years thereafter, or immediately upon opt-out/unsubscribe.
- Analytics: aggregated only, completely cookieless, with no storage of personal data.
- Local storage: used only temporarily for proper functioning or convenience; contains no personal data and is limited to the session.
- Payment data: stored in accordance with statutory accounting obligations, namely 7 years from 1 January following the invoice date.
6. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?
We do not share your personal data with third parties for commercial purposes. In certain cases, your data may be shared with other companies of the Golazo group, who will only use it in line with this statement. Where required, we will ask for your consent before sharing personal data.
We share data with:
- Suppliers, subcontractors and freelancers: e.g., marketing, communications, infrastructure and IT providers who help us optimise services, process card transactions and prevent fraud, deliver services, perform collections, analyse data and handle user feedback. They may access personal data only as necessary to perform their services or comply with the law and must implement appropriate data protection measures.
- Public authorities and legal obligations: we may be required to disclose personal data due to a legal obligation or court order, to comply with the law or requests from authorities, to detect/prevent fraud or technical/security issues, or to protect the rights of the Golazo group.
- Business transfers: in case of reorganisation, merger, sale or transfer of assets, provided the receiving party agrees to process your data in line with this statement.
We will not sell, rent, distribute or otherwise commercially make your personal data available to third parties, except as described here or with your prior explicit consent.
Only a specific part of our trusted team has access to your data. We have taken legal and technical measures to prevent unauthorised access and use, and we impose similar contractual obligations on our providers.
6.1. ADDITIONAL – WEBSITE PROCESSORS
We use processors that handle personal data on our behalf:
- Mailchimp (newsletters)
- Plausible (analytics)
- Fillout (forms)
- Adobe Fonts (typography)
- Stripe (payments; betterminds.com only)
- Hosting/security partners.
Data processing agreements are in place with these parties.
7. SECURITY
We are committed to securing your personal data. We implement appropriate measures to limit misuse and unauthorised access, ensuring access is granted only to those who need it. Our security measures are reviewed and updated regularly.
8. INTERNATIONAL TRANSFERS OUTSIDE THE EEA
Where personal data is stored or processed outside the European Economic Area by third parties that do not provide an adequacy guarantee, we ensure appropriate safeguards (contractual or otherwise) so the protection is equivalent to that within the EU.
8.1. WEBSITE AND INTERNATIONAL TRANSFERS
For processors that may process data outside the EEA (such as Mailchimp and Stripe), we rely on appropriate safeguards, including the EU Standard Contractual Clauses (SCCs).
9. WHAT ARE YOUR RIGHTS?
Under the GDPR you have several rights regarding the personal data we process about you. Exercising these rights may be subject to additional legal conditions.
Right to information and access
You can obtain information about our processing and, where applicable, access your personal data and related processing details.
Right to rectification
If your personal data is inaccurate or incomplete, you may have it corrected without undue delay. Please notify us via the contact details below.
Right to erasure (“right to be forgotten”)
You may request deletion of your data, for example when:
- the data are no longer necessary for the purposes for which they were collected;
- you withdraw consent and there is no other legal basis;
- you object on grounds relating to your particular situation and there are no overriding legitimate grounds;
- your data have been processed unlawfully;
- erasure is required to comply with a legal obligation.
Right to restriction of processing
You may request that we restrict processing in certain cases, e.g., while we verify the accuracy of contested data.
Right to object
You may object to processing on grounds relating to your particular situation. For direct marketing, you may object at any time without giving reasons.
Right to data portability
Where processing is automated and based on consent or contract, you may receive the data you provided to us in a structured, commonly used, machine-readable format and transmit it to another controller.
Right to withdraw consent
If processing is based on consent, you may withdraw it at any time. This does not affect the lawfulness of processing before withdrawal.
Rights regarding automated decision-making and profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
10. EXERCISING YOUR RIGHTS
If you wish to exercise your rights under this privacy statement or have questions, contact us using the details below. We may ask you to verify your identity (e.g., a copy of the front of your ID card).
- E-mail: info@betterminds.com
- By post:
- Belgium: Better Minds – Stokerijstraat 17, box 5, 2110 Wijnegem
- Netherlands: Better Minds – Helicopterstraat 25 D, 1059 CE Amsterdam
You have the right to lodge a complaint with the competent authority:
- Belgium:
Data Protection Authority (GBA/APD)
Drukpersstraat 35 / Rue de la Presse 35
1000 Brussels, Belgium
Tel. +32 2 274 48 00 – Fax +32 2 274 48 35
E-mail: contact@apd-gba.be
- Netherlands:
Dutch Data Protection Authority
PO BOX 93374
2509 AJ The Hague, the Netherlands
Tel: 088 180 52 50
Email: info@autoriteitpersoonsgegevens.nl
This does not affect your right to bring proceedings before the civil courts. If you have suffered damage as a result of the processing of your personal data, you may seek compensation.
11. GOVERNING LAW AND JURISDICTION
This privacy statement is governed by and construed in accordance with Belgian or Dutch law, depending on the Better Minds entity acting as controller. In case of disputes, only the courts of the judicial district of the relevant Better Minds entity shall have jurisdiction.