Welcome to our website at www.lifesaveracademy.nl and thank you for your interest in our courses, tuitions, and resources. We take the protection of your Personal Data very seriously and process your data in accordance with Curaçao’s National ordinance on data protection (“NODP”), the Dutch GDPR Implementation Act (Uitvoeringswet Algemene Verordening gegevensbescherming) (“UAVG”) and the EU’s General Data Protection Regulation (“GDPR”).

With the help of this Privacy Policy, we inform you comprehensively about the processing of your Personal Data by us and the rights to which you are entitled.

Personal data is information that makes it possible to identify a natural person. This includes in particular, your name, date of birth, address, telephone number, e-mail address, but also your IP address. Anonymous data as such only exists if no personal reference to the user can be made.

The Data Controller

In accordance with the NODP, the UAVG and the GDPR, the person responsible for processing of Personal Data when using the website is Lifesaver Academy, P.O.Box 2045 Willemstad, Curacao.

Categories of data subjects and types of data processed

During the course of using our website and services, we process the following types of data from visitors and users:

• inventory data (e.g., names, addresses),
• contact data (e.g., e-mail),
• content data (e.g., text entries, messages),
• usage data (e.g., web pages visited, interest in content, access times), and
• meta/communication data (e.g., device information, IP addresses,).

Purpose of the processing

The Purpose of processing Personal Data are:

• provision of the courses, our website and online offer, their functions and contents,
• responding to contact requests and communicating with users,
• security measures, and
• reach measurement/marketing.

Relevant legal basis

In accordance with NODP, the UAVG and the GDPR, the following legal basis, unless specifically described below apply to the processing of your Personal Data:

• you have given your consent,
• the data is necessary for the fulfillment of a contract / pre-contractual measures,
• the data is necessary for the fulfillment of a legal obligation, or
• the data is necessary to protect our legitimate interests, provided that your interests are not overridden.

Security of your Personal Data

We take appropriate technical and organizational measures, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to, input, disclosure, ensuring availability and segregation of the data. We also have procedures in place to ensure the exercise of data subjects’ rights, deletion of data and response to data compromise. Furthermore, we already take the protection of Personal Data into account during the development and selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and through data protection-friendly default settings.

Cooperation with processors and third parties

If, in the course of our processing, we disclose data to other persons and companies, transmit it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as to payment service providers, is necessary for the performance of the contract, you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.). If we commission third parties to process data on the basis of a so-called “processing agreement”. Currently, our processors are, WhatsApp for communication purposes, Hibox for Course Bookings, WordPress (Automattic Inc) to provide our website, Fonts by Google Fonts by Google LLC and Font Awesome by Fonticons Inc,Invoicing  and expense managemen: Invoice-Way.

Further we may also process certain Personal Data, when you contact us via Social media (LinkedIn, Facebook)we and the respective social media platform are jointly responsible for the processing of your data and enter into a so-called joint-controller agreement.

Transfers to third countries

If we process data in a third country (i.e. outside Curacao or the European Economic Area (EEA)) or if this is done in the context of using third-party services or disclosing or transferring data to third parties, this is only done if it is done in order to fulfill our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests.

Your rights

These rights are standardized in NODP, the UAVG and the GDPR. This includes:

• the right to information,
• the right to rectification,
• the right to erasure,
• the right to restriction of data processing,
• the right to data portability,
• the right to object to data processing,
• the right to revoke any consent you have given, and
• the right to lodge a complaint with the competent supervisory authority.

Please contact us at any time with questions and suggestions regarding data protection and to enforce your rights as a data subject.

Cookies

Cookies” are small files that are stored on your device. Different information can be stored within the cookies. We may use temporary and permanent cookies and will explain this in our Cookie Policy. The legal basis for the use of cookies is either your consent or our legitimate interest.

Deletion of data

Unless expressly stated in this Privacy Policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. I.e., the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law.

Contractual services

We process the data of our customers within the scope of our contractual services. In doing so, we process:

• inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., e-mail, telephone numbers),
• content data (e.g., text entries, testimonials, and messages),
• contract data (e.g., subject matter of contract, term),
• payment data (e.g., payment confirmations and payment history),
• usage data and metadata (e.g., in the context of evaluating and measuring the success of marketing measures).

As a matter of principle,

• we do not process special categories of Personal Data, unless these are components of commissioned processing.
• we only process data that is necessary for the justification and fulfillment of contractual services and point out the necessity of their disclosure. Disclosure to external parties only takes place if it is necessary in the context of the service.
• we do not collect or store any payment transaction information such as credit card numbers or bank details during the payment process. You only provide this information directly to the respective payment service provider.

When processing the data provided to us within the scope of providing our courses, tuitions, and classes, we act in accordance with the instructions of the client and do not process the data for any other purposes than those specified in the course, tuition and/or class.

We delete the data after the expiry of statutory warranty and comparable obligations. The necessity of storing the data is reviewed every three years; in the case of statutory archiving obligations, the deletion takes place after their expiry (6 years).

In the case of data disclosed to us by the user within the scope of a course, tuition and/or class, we delete the data in accordance with the specifications of the course, tuition and/or class, in principle after the end of the course, tuition and/or class.

Administration, financial accounting, office organization, contact management

We process data within the scope of administrative tasks as well as organization of our business, financial accounting, and compliance with legal obligations, such as archiving.

In doing so, we process the same data that we process in the context of providing our contractual services. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e., tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services.

The deletion of data with regard to contractual services and contractual communication corresponds to the information mentioned in these processing activities.

In this context, we disclose or transmit data to the tax authorities, consultants such as tax advisors or auditors as well as other fee offices and payment service providers.

Furthermore, we store information on suppliers, organizers, and other business partners on the basis of our business interests, e.g., for the purpose of contacting them at a later date. This data, most of which is company-related, is stored permanently.

Contact

When contacting us, the user’s details are processed for the purpose of handling the request and its processing. The user’s details may be stored in a customer relationship management system or comparable enquiry organization. We delete the enquiries if they are no longer necessary. We review the necessity every two years; furthermore, the legal archiving obligations apply.

Hosting

The hosting services used by us for the purpose of operating this website is MochaHost.com. In doing so MochaHost.com, process inventory data, contact data, content data, contract data, usage data, meta data and communication data of customers, interested parties and visitors of our website on the basis of our legitimate interests in an efficient and secure provision of the website in conjunction with the provision of contractual services and the conclusion of the contract for our services, including but not limited to our courses, tuitions, and classes).

Collection of access data and log files

We, or rather MochaHost.com, collect data on every access to our website on the basis of our legitimate interest. The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Data Breaches/Notification

Databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised, and the notice will be accompanied by a description of action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible after which the breach was discovered.

Children’s Privacy

Our services are restricted to users who are 13 years of age or older. We do not knowingly collect Personal Data from anyone under the age of 13 without parental or legal guardian consent. If you suspect that a user is under the age of 13, please contact us.

Changes

Because we’re always looking for new and innovative ways to improve our website and services, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes. This Privacy Policy was last updated on Saturday, 30th of September 2023.

Who should I contact for more information?

If you have any questions or comments about our Privacy Policy or wish to exercise your rights under applicable laws, please contact us using info@ehbocuracao.com, or call us on (+5999) 5211152.