privacy statement

The data controller for the processing of personal data is: The Present Edge B.V. Based in Amsterdam Registered with the Chamber of Commerce under number 97346012 Website: www.thepresentedge.nl For questions about this Privacy Statement or the processing of personal data, you can contact us at: [email protected]

Depending on the nature of the contact and the Service provided, TPE may process the following personal data: a) General personal data: name; email address; phone number; billing and payment details; company name and position (in business processes). b) Service-related data (Customer data): HRV and other measurement data (in analyzed form, such as reports); completed questionnaires; intake and progress information; transcriptions of conversations; audio recordings; chat messages or other forms of interaction; planning and progress data. c) Technical and functional data: IP address; browser and device data; limited website usage data.

TPE processes personal data exclusively for the following purposes: – executing Agreements and Services; – providing measurements, analyses, coaching, and educational advice; – planning and implementing appointments; – processing payments and administrative obligations; – improving Services and internal processes; – ensuring security and continuity; – complying with legal obligations. Personal data is not processed for medical, paramedical, therapeutic, or diagnostic purposes.

TPE processes personal data based on one or more of the following legal grounds: – execution of an agreement; – consent from the data subject (where required); – legal obligation; – legitimate interest, such as business operations, quality improvement, and security. If processing is based on consent, this consent can be withdrawn at any time.

Some Customer data may contain information that indirectly provides insight into stress regulation or physiological patterns. This data is processed exclusively: – in the context of providing the Service; – with explicit consent from the Customer, where required; – within a strictly secured environment; – by authorized persons. TPE does not process medical records and does not perform medical diagnoses.

For measurements, TPE uses external technology and sensor suppliers. Measurement data is made available to TPE via secured environments and dashboards of these suppliers, solely for the purpose of providing the Service. Appropriate contractual and technical safeguards are applied. Suppliers may change over time. TPE ensures processing is always GDPR-compliant.

TPE may use automated analyses, algorithms, and AI support in the processing of Customer data and drafting of Advice documents. It is ensured that: – AI is used solely as supportive; – there is no fully automated decision-making with legal consequences; – the ultimate responsibility always lies with TPE; – Customer data is never used to train third-party AI models; – processing through AI technology only takes place within the secure infrastructure of TPE or its contractually bound processors.

TPE does not use advertising cookies, tracking cookies, or external analysis services like Google Analytics. The website solely uses: – functional cookies; – limited, anonymized statistics via the website platform, solely to gain insight into general website usage. No user profiles are built and no data is shared with advertising or tracking networks.

TPE retains personal data no longer than necessary for the purposes for which it was collected, unless a longer retention period is legally required. Specific retention periods per data type are included in article 10.6 of the General Terms and Conditions. Administrative and financial data are retained in accordance with legal retention obligations. After the applicable retention period, personal data is securely deleted. The Customer can request earlier deletion at any time, except for data with a legal retention obligation.

TPE only shares personal data with third parties if necessary for: – the execution of the Agreement; – providing Services; – complying with legal obligations. This may concern: IT and hosting service providers; payment service providers; technology and sensor suppliers; other processors who support TPE. Processor agreements are concluded with these parties, where required. Personal data is not sold to third parties. An up-to-date overview of processors engaged by TPE is available on request via [email protected].

If personal data is processed outside the European Economic Area, TPE implements appropriate safeguards in accordance with the GDPR, such as standard contractual clauses or equivalent protection mechanisms.

TPE takes appropriate technical and organizational measures to protect personal data against loss, misuse, unauthorized access, or unlawful processing. These measures are evaluated periodically and adjusted where necessary.

Data subjects have the right to: – access their personal data; – have personal data corrected or deleted; – restrict processing; – object to processing; – request data portability; – withdraw given consent. Requests can be submitted via [email protected]. TPE responds within legal time frames.

If a data subject believes TPE unlawfully processes personal data, a complaint can be filed with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

TPE reserves the right to change this Privacy Statement. The most current version is always available on the website. In case of material changes, TPE will communicate this appropriately.

This Privacy Statement is governed by Dutch law.

In case of differences or inconsistencies between the Dutch version of this Privacy Statement and any translated version, only the Dutch text is decisive for interpretation and application.